ML15069A233

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

ML15069A233
Person / Time
Site:	North Anna
Issue date:	03/02/2015
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-394B, EA-12-049
Download: ML15069A233 (10)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 2, 2015 10 CFR 2.202 EA-12-049 Attention: Document Control Desk Serial No.: 14-394B U.S. Nuclear Regulatory Commission NL&OS/MAE: R2 Washington, D.C. 20555-0001 Docket No.: 50-338 License No.: NPF-4 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT I SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.

2. Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-162B.)

3. Virginia Electric and Power Company's Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 (Serial No.14-394).

4. Virginia Electric and Power Company's Status of Required Action for EA-12-049 Issuance of Order To Modify Licenses With Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events, dated December 8, 2014 (Serial No. 14-394A).

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 was immediately effective and directed Dominion to develop, implement, and maintain guidance and strategies to maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Page 2 of 3 Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2) pursuant to Section IV, Condition C. Reference 1 also required submission of a status report at six-month intervals following submittal of the OIP.

The attachment to this letter provides the fourth six-month status report and an update of milestone accomplishments since the submittal of the prior six-month status report (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis. This update is applicable to North Anna Unit 1 only. North Anna Unit 2 has completed the Order requirements and has reported compliance to the Commission. (Reference 4).

If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering Attachment (1)

Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this . day of da4-k 2015.

My Commission Expires: eez.sty- 31, 1:o1&/.

CRAIG D SLY N fi Pbli Notary Public Notary Public (SEAL) Commonwealth Reg.# 7518653 of Virginia My Commission Expires December 31, 20

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13 H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. K. R. Cotton NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.

Glen Allen, Virginia 23060

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Six-Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events February 2015 North Anna Power Station Unit I Virginia Electric and Power Company (Dominion)

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 1 of 6 Six-Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverse and flexible strategies (FLEX) for North Anna Power Station (NAPS) in response to NRC Order Number EA-12-049 (Reference 2). This attachment provides an update of milestone accomplishments and open items since submittal of the last status report (Reference 3),

including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. This update is applicable to North Anna Unit 1 only. North Anna Unit 2 has completed the requirements of Order EA 12-049 and has reported compliance to the Commission (Reference 4).

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP, and are current as of January 31, 2015.

• Submit Integrated Plan

• Develop Strategies

" Develop Modifications

• Develop Training Plan

" Implement Training

" Issue FSGs and Associated Procedure Revisions

• Develop Strategies/Contract with NSRC

" Purchase Equipment

• Receive Equipment

• Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures

• Create Maintenance Procedures 3 Milestone Schedule Status The following table provides an update to Attachment 2A of the OIP. The table provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 2 of 6 Target Activity Revised Target Milestone Completion Status Completion Date Date Submit Integrated Plan February 2013 Complete Develop Strategies October 2013 Complete Develop Modifications July 2014 Complete Implement Unit 1 Modifications April 2015 Started March 2015*

Develop Training Plan April 2014 Complete Implement Training September 2014 Complete Issue FSGs and Associated September 2014 Complete Procedure Revisions Develop Strategies/Contract with August 2014 Complete NSRC**

Purchase Equipment February 2014 Complete***

Receive Equipment August 2014 Complete***

Validation Walk-throughs or Demonstrations of FLEX Strategies September 2014 Complete and Procedures Create Maintenance Procedures August 2014 Complete Unit 1 Outage Implementation April 2015 Started March 2015*

• Refer to Section 8, Supplemental Information, for an explanation of Milestone changes

• • NSRC is the National SAFER Response Center The 'Purchase Equipment' and 'Receive Equipment' Milestones were completed in February 2014 and August 2014, respectively, for the equipment identified in Table 1 provided with the NAPS OIP (and subsequent Six-Month Status Reports). As discussed in Section 4a, a decision has been made to purchase an additional boric acid mixing tank (BAMT). This additional BAMT was not required for implementation of Unit 2 and will be available to meet the N+1 requirement prior to site implementation following the Unit 1 spring outage.

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 3 of 6 4 Changes to Compliance Method By letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at NAPS Units 1 and 2, as required by Order Number EA-12-049, dated March 12, 2012. The first, second, and third Six-Month Status Report of the OIP for NAPS were provided by letters dated August 23, 2013 (Reference 5), February 28, 2014 (Reference 6), and August 28, 2014 (Reference 3), respectively. Listed below are changes to the compliance method information provided in the North Anna OIP, which continue to meet NEI 12-06 (Reference 7):

a) Boric Acid Mixing Tanks: Dominion has reevaluated the proposed number of Boric Acid Mixing Tanks (BAMTs) to support the RCS injection strategy in the unlikely event that both Refueling Water Storage Tanks are unavailable following a tornado event. Two BAMTs provide the ability to batch one tank while the other is being injected into the RCS. Since two tanks allow for nearly continuous operation of a single RCS Injection pump, a third tank is being procured to comply with the N+1 philosophy outlined in NEI 12-06. Table 1 from the Overall Integrated Plan (and subsequent Six-Month Status Reports) which list the required BDB Equipment is not provided with this update. However, the BDB Equipment table in the Final Implementation Plan (FIP) will identify that three BAMTs are required for North Anna and they will be stored in the BDB Storage Building.

b) As a clarification, only one additional Flowserve seal will be installed during the upcoming spring 2015 Unit 1 Refueling Outage. Following installation, the Unit 1 RCP seal configuration will be the same seal configuration as NAPS Unit 2 (2 Flowserve seals/ 1 Westinghouse seal). This seal configuration limits the RCP seal leakage to quantities bounded by the extended loss of alternating current (ac) power (ELAP) analyses which demonstrate the effectiveness of the North Anna FLEX strategies required in Attachment 2 of the Order.

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

6 Open Items 6.1 Open Items from Overall Integrated Plan (Licensee Identified)

With the exception of Item #12, Licensee Identified Open Items have been completed as described in either the North Anna Final Audit Report (Reference 8) or the North Anna Unit 2 Compliance letter for Order EA-12-049 (Reference 4).

Licensee Identified Open Item # 12: "Plant modifications will be completed for permanent plant changes required for implementation of FLEX strategies." Per the Milestone Schedule in Section 3 above, the remaining modifications will be completed in the upcoming spring 2015 Unit 1 Refueling Outage, which is the compliance outage for Unit 1.

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 4 of 6 6.2 Open Items from the Interim Staff Evaluation The Interim Staff Evaluation (ISE) Open Items have been completed for both North Anna Unit 1 and Unit 2 as described in the North Anna Unit 2 Compliance letter for Order EA-12-049 (Reference 4).

6.3 Confirmatory Items from Interim Staff Evaluation The Interim Staff Evaluation (ISE) Confirmatory Items have been completed for both North Anna Unit 1 and Unit 2 as described in the North Anna Unit 2 Compliance letter for Order EA-12-049 (Reference 4).

6.4 Audit Question Reviewed During NAPS Onsite Audit Various NAPS Audit Questions (AQs) were evaluated during the NAPS NRC Onsite Audit.

Only AQ #44 was evaluated and remained "Open" per the North Anna Onsite Audit Report (Reference 8). AQ #44 has been completed as described in the North Anna Unit 2 Compliance letter for Order EA-1 2-049 (Reference 4).

6.5 Additional Items Reviewed During NAPS Onsite Audit A list of the additional Safety Evaluation (SE) Review items identified in the North Anna Audit Plan (Reference 9) and several additional SE Review items identified during the NAPS NRC Onsite Audit were added in the North Anna Onsite Audit Report (Reference 8). The Open SE Review items have been completed as described in either the North Anna Final Audit Report or the North Anna Unit 2 Compliance letter for Order EA-12-049 (Reference 4).

7 Potential Safety Evaluation Impacts Section 6.5 addresses the additional Safety Evaluation (SE) Review items identified and evaluated during the NAPS NRC Onsite Audit.

Additionally, Dominion is participating in the ongoing industry effort to develop guidance for the Final Integrated Plan that will support NRC preparation of the Safety Evaluation documenting NAPS's compliance with Order EA-12-049. The format of the Final Integrated Plan is consistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davis memorandum (ML14161A643) (Reference 10).

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 5 of 6 8 Supplemental Information This supplemental information provides details of the changes identified in the status updates above and addresses the following topics: a) the Milestone Task 'Implement Unit 1 Modifications,' and b) a revision to Milestone Task 'Unit 1 Outage Implementation.'

a) North Anna Unit 1, Milestone Task 'Implement Unit 1 Modifications': The updated completion schedules accurately reflect the current outage schedules. The revised Completion Schedule is as follows:

Milestone Task: Implement Unit 1 Modifications Completion Schedule: March 2015 b) North Anna Unit 1, Milestone Task 'Unit 1 Outage Implementation': The Milestone Task date is revised to reflect the current outage schedule which has been moved to March 2015.

9 References The following references support the updates to the OIP described in this attachment and are available in ADAMS or have been provided to the staff for their review.

1. "Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (Serial No. 12-162B).

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

3. "Virginia Electric and Power Company's Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049)," dated August 28, 2014 (Serial No.12-394).

4. "Virginia Electric and Power Company's Status of Required Action for EA-12-049, Issuance of Order To Modify Licenses With Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," dated December 8, 2014 (Serial No. 14-394A).

5. "Virginia Electric and Power Company's Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049)," dated August 23, 2013 (Serial No. 12-162D).

Serial No. 14-394B Docket No. 50-338 Order EA-12-049 Attachment Page 6 of 6

6. "Virginia Electric and Power Company's Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049)," dated February 28, 2014 (Serial No. 12-162E).

7. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012.

8. Letter from Mr. John Boska (NRC) to Mr. Dave Heacock (Dominion) titled "North Anna Power Station, 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," dated September 24, 2014 (ML14259A458).

9. Letter from Mr. James Polickoski (NRC) to Mr. Dave Heacock (Dominion) titled "North Anna Power Station, Units 1 and 2 - Plan 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," dated April 24, 2014 (ML14112A302).

10. Memorandum from Jack R. Davis, JLD, Office of NRR, to Stewart N. Bailey, Sheena A, Whaley, and Jeremy S. Bowen, "Supplemental Staff Guidance for the Safety Evaluations for Order EA-12-049 on Mitigation Strategies for Beyond-Design-Basis External Events and Order EA-12-051 on Spent Fuel Pool Instrumentation," dated July 1, 2014 (ML14161A643).