ML15244B202

Surry, Unit 2 - Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML15244B202
Person / Time
Site:	Surry
Issue date:	08/24/2015
From:	Sartain M D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-395C, EA-12-049
Download: ML15244B202 (9)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261August 24, 201510 CFR 2.202EA-1 2-049Attention:

Document Control Desk Serial No.: 14-3950U.S. Nuclear Regulatory Commission NL&OS/DEA:

RIWashington, D.C. 20555-0001 Docket No.: 50-281License No.: DPR-37VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNIT 2FIFTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12. 2012COMMISSION ORDER MODIFYING LICENSES WITH REGARD TOREQUIREMENTS 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 toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"

dated March 12, 20122. 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. 12-163B)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 March 2, 2015 (Serial No. 14-395A)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 July 22,2015 (Serial No. 14-395B)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.Aisi Serial No. 14-395CDocket Nos.50-281Six-Month Status Report -Order EA-1 2-049Page 2 of 3Reference I 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 fifth six-month status report and an update ofmilestone accomplishments since the submittal of the previous 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 Surry Unit 2 only. Surry Unit I hascompleted the Order requirements and has reported compliance to the Commission.

(Reference 4).If you have any questions, please contact Ms. Diane E. Aitken at (804) 273-2694.

Sincerely, Mark D. SartainVice 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 andCommonwealth 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 inthe document are true to the best of his knowledge and elief.Acknowledged before me of I"//, U," , 2015.My Commission Expires:

44 SCommonwe~alth of VirginiaNoayPbi (SEAL) e,#

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Serial No. 14-395CDocket No.50-281Six-Month Status Report -Order EA-1 2-049Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Ms. K. R. Cotton GrossNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 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 NRC Senior Resident Inspector Surry Power Station Serial No. 14-395CDocket No. 50-281Order EA-1 2-049Attachment Six-Month Status Report for the Implementation of Order EA-1 2-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsAugust 2015Surry Power Station Unit 2Virginia Electric and Power Company (Dominion)

Serial No. 14-395CDocket No. 50-281Order EA-12-049 Attachment Page 1 of 5Six-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 Surry Power Station (Surry) 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 Surry Unit 2 only. Surry Unit 1 has completed therequirements 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 arecurrent as of July 31, 2015.* Submit OIP* Develop Strategies

• Develop Modifications

• Implement Unit 1 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

• Unit I Outage Implementation 3 Milestone Schedule StatusThe following table provides an update to Attachment 2A of the OIP. It provides the activitystatus of each item, and whether the expected completion date has changed.

The dates areplanning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates for 'Implement Unit 2 Modifications' and 'Unit 2Outage Implementation' do not impact the Order implementation for Surry Unit 2, but simplyreflect a revision to the Surry Unit 2 Fall 2015 Refueling Outage scheduled completion date.

Serial No. 14-395CDocket No. 50-281Order EA-1 2-049Attachment Page 2 of 5Target Aciiy Revised TargetMilestone Completion Activtys Completion Date DateSubmit Overall Integrated Plan February 2013 CompleteDevelop Strategies October 2013 CompleteDevelop Modifications December 2014 CompleteImplement Unit 1 Modifications May 2015 CompleteImplement Unit 2 Modifications November 2015 Started December 2015Develop Training Plan April 2014 CompleteImplement Training August 2014 Complete

________Issue FSGs and Associated Proedue RvisonsDecember 2014 CompleteDevelop Strategies/Contract with August 2014 CompleteNSRCPurchase Equipment February 2014 CompleteReceive Equipment November 2014 Complete

_______Validation Walk-throughs orDemonstrations of FLEX December 2014 CompleteStrategies and Procedures Create Maintenance Procedures August 2014 CompleteUnit 1 Outage Implementation April 2015 Complete

________Unit 2 Outage Implementation November 2015 Not Started December 20154 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion providedBasis (BDB) events at Surry Units 1 and 2 (Reference 1)049, dated March 12, 2012 (Reference 2). The first,an OIP to address Beyond-Design-as required by Order Number EA-12-second, third, and fourth Six-Month Status Report of the OIP for Surry were provided by letters dated August 23, 2013 (Reference 5), February 27, 2014 (Reference 6), August 28, 2014 (Reference 7), and March 2, 2015(Reference 3), respectively.

There have been no changes to the compliance method information provided in the Surry OIPand subsequent updates previously reported.

Serial No. 14-3950Docket No. 50-281Order EA-12-049 Attachment Page 3 of 55 Need for RelieflRelaxation and Basis for the RelieflRelaxation Dominion expects to comply with the Order implementation date and no requiredrelief/relaxation has been identified at this time.6 Open Items6.1 Open Items from Overall Integrated PlanLicensee Identified Open Items have been completed as described in either the Surry FinalAudit Report (Reference

9) or the Surry Unit 1 Compliance letter for Order EA-12-049 (Reference 4).6.2 Open Items from the Interim Staff Evaluation (ISE)The Interim Staff Evaluation (ISE) Open Items for Surry (Reference

8) have been completed for both Surry Unit 1 and Unit 2 as described in the Surry Unit 1 Compliance letter for OrderEA-12-049 (Reference 4).6.3 Confirmatory Items from the Interim Staff Evaluation (ISE)The Interim Staff Evaluation (ISE) Confirmatory Items have been completed for both Surry Unit1 and Unit 2 as described in the Surry Unit 1 Compliance letter for Order EA-12-049 (Reference 4).6.4 Audit Questions Reviewed During the SPS NRC Onsite AuditAudit Questions have been resolved as described in either the Surry Final Audit Report(Reference

9) or the Surry Unit I Compliance letter for Order EA-1 2-049 (Reference 4).6.5 Additional Items Reviewed During the SPS NRC Onsite AuditSafety Evaluation (SE) Review items identified during the January 2015 NRC Onsite Audithave been completed as described in the Surry Final Audit Report (Reference 9).7 Potential Safety Evaluation ImpactsSection 6.5 addresses the additional Safety Evaluation (SE) Review items identified andevaluated during the NAPS NRC Onsite Audit.Dominion is participating in the ongoing industry effort to develop guidance for the FinalIntegrated Plan that will support NRC preparation of the Safety Evaluation documenting Surry'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 (Reference 10).

Serial No. 14-395CDocket No. 50-281Order EA-12-049 Attachment Page 4 of 58 References The following references support the updates to the alP described in this attachment and areavailable in ADAMS or have previously been provided to the staff for their review.1. Virginia Electric and Power Company 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. 12-163B).

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events,"dated March 12, 2012.3. 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 March 2, 2015 (Serial No. 14-395A).

4. Virginia Electric and Power Company's letter titled "Surry Power Station Unit 1,Compliance Letter in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated July 22, 2015 (SN:14-395B).

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. 12-163D).

6. 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 27, 2014 (Serial No. 12-163E).

7. 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.14-395).8. NRC letter from Jeremy S. Bowen, Chief, Mitigating Strategies Branch Office of NRR, toDavid A. Heacock, President and Chief Nuclear Officer, Virginia Electric and PowerCompany, "Surry Power Station, Units 1 and 2 -Interim Staff Evaluation Related toOverall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies),"

datedFebruary 19, 2014 (ML14002A145).

Serial No. 14-395CDocket No. 50-281Order EA-1 2-049Attachment Page 5 of 59. NRC letter from John Boska, Senior Project Manager, JLD, Office of NRR, to David A.Heacock, President and Chief Nuclear Officer, Virginia Electric and Power Company,"Surry Power Station, 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,"

dated April 14, 2015 (ML15096A391).

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 SafetyEvaluations 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 July1, 2014 (ML14161A643).