ML15069A233

North Anna, Unit 1 - 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:	Sartain M D 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 COMPANYRICHMOND, VIRGINIA 23261March 2, 201510 CFR 2.202EA-12-049 Attention:

Document Control Desk Serial No.: 14-394BU.S. Nuclear Regulatory Commission NL&OS/MAE:

R2Washington, D.C. 20555-0001 Docket No.: 50-338License No.: NPF-4VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNIT ISIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION 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 toRequirements 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 toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements 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 toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements 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 ForMitigation Strategies For Beyond-Design-Basis External Events, dated December8, 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 wasimmediately effective and directed Dominion to develop, implement, and maintainguidance and strategies to maintain core cooling, containment, and spent fuel poolcooling capabilities in the event of a beyond-design-basis external event.

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Page 2 of 3Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a statusreport at six-month intervals following submittal of the OIP.The attachment to this letter provides the fourth six-month status report and an updateof milestone accomplishments since the submittal of the prior six-month status report(Reference 3), including any changes to the compliance method, schedule, or need forrelief and the basis. This update is applicable to North Anna Unit 1 only. North AnnaUnit 2 has completed the Order requirements and has reported compliance to theCommission.

(Reference 4).If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. SartainVice President

-Nuclear Engineering Attachment (1)Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIACOUNTY 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 andPower 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 hisknowledge and belief.Acknowledged before me this .day of da4-k 2015.My Commission Expires:

eez.sty-31, 1:o1&/.CRAIG D SLY N fi PbliNotary Public Notary Public(SEAL) Commonwealth of VirginiaReg.# 7518653My Commission Expires December 31, 20 Serial No. 14-394BDocket No. 50-338Order EA-12-049 Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13 H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257 Dr. V. Sreenivas NRC Project Manager North AnnaU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. K. R. CottonNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power StationMr. J. E. Reasor, Jr.Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 3004201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 14-394BDocket No. 50-338Order 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 forBeyond-Design-Basis External EventsFebruary 2015North Anna Power Station Unit IVirginia Electric and Power Company (Dominion)

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 1 of 6Six-Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference

1) documenting the diverseand flexible strategies (FLEX) for North Anna Power Station (NAPS) in response to NRC OrderNumber 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 andthe basis, if any. This update is applicable to North Anna Unit 1 only. North Anna Unit 2 hascompleted the requirements of Order EA 12-049 and has reported compliance to theCommission (Reference 4).2 Milestone Accomplishments The following milestones have been completed since the development of the OIP, and arecurrent 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 StatusThe following table provides an update to Attachment 2A of the OIP. The table provides theactivity status of each item, and whether the expected completion date has changed.

Thedates are planning dates subject to change as design and implementation details aredeveloped.

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 2 of 6Target Activity Revised TargetMilestone Completion Status Completion DateDateSubmit Integrated Plan February 2013 CompleteDevelop Strategies October 2013 CompleteDevelop Modifications July 2014 CompleteImplement Unit 1 Modifications April 2015 Started March 2015*Develop Training Plan April 2014 CompleteImplement Training September 2014 CompleteIssue FSGs and Associated September 2014 CompleteProcedure Revisions Develop Strategies/Contract with August 2014 CompleteNSRC**Purchase Equipment February 2014 Complete***

Receive Equipment August 2014 Complete***

Validation Walk-throughs orDemonstrations of FLEX Strategies September 2014 Completeand Procedures Create Maintenance Procedures August 2014 CompleteUnit 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 CenterThe 'Purchase Equipment' and 'Receive Equipment' Milestones were completed in February 2014and 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 beenmade to purchase an additional boric acid mixing tank (BAMT). This additional BAMT was notrequired for implementation of Unit 2 and will be available to meet the N+1 requirement prior to siteimplementation following the Unit 1 spring outage.

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 3 of 64 Changes to Compliance MethodBy 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, datedMarch 12, 2012. The first, second, and third Six-Month Status Report of the OIP for NAPSwere 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 thecompliance method information provided in the North Anna OIP, which continue to meet NEI12-06 (Reference 7):a) Boric Acid Mixing Tanks: Dominion has reevaluated the proposed number of Boric AcidMixing Tanks (BAMTs) to support the RCS injection strategy in the unlikely event that bothRefueling Water Storage Tanks are unavailable following a tornado event. Two BAMTsprovide the ability to batch one tank while the other is being injected into the RCS. Sincetwo tanks allow for nearly continuous operation of a single RCS Injection pump, a third tankis being procured to comply with the N+1 philosophy outlined in NEI 12-06. Table 1 fromthe Overall Integrated Plan (and subsequent Six-Month Status Reports) which list therequired 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 forNorth 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 upcomingspring 2015 Unit 1 Refueling Outage. Following installation, the Unit 1 RCP sealconfiguration will be the same seal configuration as NAPS Unit 2 (2 Flowserve seals/ 1Westinghouse seal). This seal configuration limits the RCP seal leakage to quantities bounded by the extended loss of alternating current (ac) power (ELAP) analyses whichdemonstrate the effectiveness of the North Anna FLEX strategies required in Attachment 2of 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 isrequired at this time.6 Open Items6.1 Open Items from Overall Integrated Plan (Licensee Identified)

With the exception of Item #12, Licensee Identified Open Items have been completed asdescribed in either the North Anna Final Audit Report (Reference

8) or the North Anna Unit 2Compliance letter for Order EA-12-049 (Reference 4).Licensee Identified Open Item # 12: "Plant modifications will be completed for permanent plantchanges required for implementation of FLEX strategies."

Per the Milestone Schedule inSection 3 above, the remaining modifications will be completed in the upcoming spring 2015Unit 1 Refueling Outage, which is the compliance outage for Unit 1.

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 4 of 66.2 Open Items from the Interim Staff Evaluation The Interim Staff Evaluation (ISE) Open Items have been completed for both North Anna Unit1 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 NorthAnna 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 AuditVarious 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 2Compliance letter for Order EA-1 2-049 (Reference 4).6.5 Additional Items Reviewed During NAPS Onsite AuditA list of the additional Safety Evaluation (SE) Review items identified in the North Anna AuditPlan (Reference

9) and several additional SE Review items identified during the NAPS NRCOnsite Audit were added in the North Anna Onsite Audit Report (Reference 8). The Open SEReview items have been completed as described in either the North Anna Final Audit Reportor the North Anna Unit 2 Compliance letter for Order EA-12-049 (Reference 4).7 Potential Safety Evaluation ImpactsSection 6.5 addresses the additional Safety Evaluation (SE) Review items identified andevaluated during the NAPS NRC Onsite Audit.Additionally, Dominion is participating in the ongoing industry effort to develop guidance for theFinal 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 isconsistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davismemorandum (ML14161A643)

(Reference 10).

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 5 of 68 Supplemental Information This supplemental information provides details of the changes identified in the status updatesabove and addresses the following topics: a) the Milestone Task 'Implement Unit 1Modifications,'

and b) a revision to Milestone Task 'Unit 1 Outage Implementation.'

a) North Anna Unit 1, Milestone Task 'Implement Unit 1 Modifications':

The updatedcompletion schedules accurately reflect the current outage schedules.

The revisedCompletion Schedule is as follows:Milestone Task: Implement Unit 1 Modifications Completion Schedule:

March 2015b) 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 toMarch 2015.9 References The following references support the updates to the OIP described in this attachment and areavailable 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),"

datedFebruary 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 March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," 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 (SerialNo. 14-394A).

5. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 23, 2013 (Serial No. 12-162D).

Serial No. 14-394BDocket No. 50-338Order EA-12-049 Attachment Page 6 of 66. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," 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 AnnaPower Station, Units 1 and 2 -Report for the Onsite Audit Regarding Implementation ofMitigating 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 "NorthAnna Power Station, Units 1 and 2 -Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to OrdersEA-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 Eventsand Order EA-12-051 on Spent Fuel Pool Instrumentation,"

dated July 1, 2014(ML14161A643).