NL-16-1049, Seventh Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Seventh Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

ML16221A398
Person / Time
Site:	Farley
Issue date:	08/08/2016
From:	Pierce C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-16-1049
Download: ML16221A398 (7)

Text

Charles R. Pierce Regulatory Affairs Director AUG 0 8 2016 Docket Nos.: 50-348 50-364 Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN /&\\

NUCLEAR A SOUTHERN COMPANY NL-16-1049 Joseph M. Farley Nuclear Plant - Units 1 and 2 Seventh Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012.

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

4. Joseph M. Farley Nuclear Plant-Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013.

5. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2 - Farley Units 1 &2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

6. Joseph M. Farley Nuclear Plant-Unit 2 Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events, dated June 22, 2016.

Ladies and Gentlemen:

On March 12,2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Joseph M. Farley Nuclear Plant (FNP) - Units 1 and 2 to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Refere~e 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2} and an overall integrated plan pursuant to Section IV,

U.S. Nuclear Regulatory Commission NL-16-1 049 Page2 Condition C.1.a of Reference 1. Reference 2 endorses industry guidance document NEI 12-06, Revision 0, (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the initial FNP Units 1 and 2 overall integrated plan (OIP). A revised OIP was submitted with the fall 2014 six-month update (Reference 5).

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the seventh six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. Reference 6 documents compliance with NRC Order EA-12-049 on FNP Unit 2 in spring 2016. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

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

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Re2tlf/b~

C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Sworn to and subscri ed before me this ~~~ day of h~

,2016.

My commission expires: /0- ~~ Zot1

Enclosure:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Seventh Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

U.S. Nuclear Regulatory Commission NL-16-1049 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President-Farley Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. B. J. Adams, Vice President-Engineering Mr. D. R. Madison, Vice President-Fleet Operations Ms. B.L. Taylor, Regulatory Affairs Manager-Farley RType: CFA04.054 U. S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Senior Project Manager-Farley Mr. S. R. Monarque, NRR Senior Project Manager-Farley Mr. P. K. Niebaum, Senior Resident Inspector-Farley Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer

Joseph M. Farley Nuclear Plant

• Units 1 and 2 Seventh Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure Joseph M. Farley Nuclear Plant

• Units 1 and 2 Seventh Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-16-1 049 Seventh Six-Month Status Report of FLEX Implementation Joseph M. Farley Nuclear Plant - Units 1 and 2 Seventh Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) 1 Introduction Joseph M. Farley Nuclear Plant - Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the previous 6-month update, and are current as of June 30, 2016:

Phase 2 Equipment procurement Complete Issue FSGs Implement Training Unit 2 Walk-through or Demonstrations Unit 2 Implementation Outage 3

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

It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The Target and Revised Target Completion Dates are based on the approval of one additional refueling cycle for full implementation of the Order for Joseph M. Farley Nuclear Plant-Units 1 and 2 (References 4 & 5).

Target Activity Revised Target Milestone Completion Status Completion Date Date Submit 60 Day Status Re_Q_ort Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Unit 2 1st RFO M~2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Eguipment Procurement SeQ_ 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aug 2014 Complete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Submit 6 Month Status Report Aug 2015 Complete N/A Develop Strategies (Farley Response Plan)

Dec 2015 Complete N/A with National SAFER Response Center Develop Operational Procedure Changes Dec 2015 Complete N/A Develop Modifications Dec 2015 Complete N/A Develop FSGs Dec 2015 Complete N/A Develop Training Material Dec 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Phase 2 Equipment Procurement Complete Mar 2016 Compete N/A Implement Training Mar 2016 Complete N/A E-1

Enclosure to N L 1 049 Seventh Six-Month Status Report of FLEX Implementation Target Activity Revised Target Milestone Completion Status Completion Date Date Unit 2 Walk-throughs or Demonstrations Mar 2016 Complete N/A Issue FSGs May 2016 Complete N/A Unit 2 Implementation Outage

• May 2016 Complete N/A Submit 6 Month Status Report Aug 2016 Complete N/A Unit 1 Walk-throughs or Demonstrations Sep 2016 Not Started Unit 1 Implementation Outage

• Oct 2016 Not Started Submit Completion Report Dec 2016 Not Started

• Full compliance consistent w1th NRC-approved extens1on (Reference 5) 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Joseph M. Farley Nuclear Plant -Unit 2 has completed the implementation of this Order and the compliance letter has been submitted to the NRC dated June 22, 2016 (Reference 8). Joseph M. Farley Nuclear Plant-Unit 1 requested and received a schedule relaxation of one additional refueling cycle for full implementation of the Order requirements and expects to comply with the relaxed date (References 4 & 5). No additional relief/relaxation is required or anticipated at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation Joseph M. Farley Nuclear Plant Unit 1 has no open items documented in the Overall Integrated Plan or the Interim Staff Evaluation (ISE). All open or pending items were closed during the onsite NRC audit and documented in the NRC's report for the Audit dated February 8, 2016 (Reference 7) 7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for FNP (Reference 3) with no Open Items.

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

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

1. Joseph M. Farley Nuclear Plant - Units 1 and 2, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 27, 2013.

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

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Enclosure to NL-16-1049 Seventh Six-Month Status Report of FLEX Implementation

3. NRC Letter, Joseph M. Farley Nuclear Plant-Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0716 and MF0717), dated January 17, 2014.

4. Joseph M. Farley Nuclear Plant-Units 1 and 2, Request for Relaxation of Commission Order Modifying Licenses with Regards to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2014.

5. NRC Letter, Joseph M. Farley Nuclear Plant-Units 1 and 2-Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies Beyond Design Basis External Events dated April 14, 2014.

6. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2-Farley Units 1 &2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

7. NRC letter, Joseph M. Farley Nuclear Plant, Units 1 and 2-Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF0716 and MF0717), dated February 8, 2016.

8. Joseph M. Farley Nuclear Plant -Unit 2 Completion of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events, dated June 22, 2016.

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