NL-16-1050, 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)

ML16221A397
Person / Time
Site:	Hatch
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-16-1050
Download: ML16221A397 (7)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Off1ce Box 1295 Birmingham , AL 35201 SOUTHERN . \

Tel 205.992.7872 Fax 205 992.7601 NUCLEAR A SOUTHERN COMPANY AUG 0 8 2016 Docket Nos.: 50-321 NL-16-1050 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch 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. Edwin I. Hatch 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. Edwin I. Hatch 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- Hatch Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

6. Edwin I. Hatch Nuclear Plant - Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated May 3, 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 Edwin I. Hatch Nuclear Plant (HNP) - 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.

U.S. Nuclear Regulatory Commission NL-16-1050 Page2 Reference 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, Condition C.1.a of Reference 1. Reference 2 endorses industry guidance document NEI 12-06 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the initial HNP overall integrated plan (OIP). A revised OIP was submitted with the fall2014 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 HNP Unit 1 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.

R*C~tl~"(t C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Sworn to and subscribrrJ before me this _t.;;;;__"ti__day of ~,u k

, a , 2016.

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Notary Public

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My commission expires: / 0 zo 11

Enclosure:

Edwin I. Hatch 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-16-1050 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02.004 U.S. Nuclear Regulatorv Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Edwin I. Hatch 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 Edwin I. Hatch 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-16-1050 Seventh Six-Month Status Report of FLEX Implementation Edwin I. Hatch 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 Edwin I. Hatch Nuclear Plant- Units 1 and 2 developed an Overall Integrated Plan (OIP)

(Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX) , in response to Reference 2. Reference 5 of this enclosure provided a revised OIP in fall 2014.

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

• Unit 1 Implementation Outage Complete

• Unit 1 Walk-through or Demonstrations Complete

• Implement Training 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 5).

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

Target Revised Target Activity Milestone Completion Completion Status Date Date Subm it 60 Day Status Report Oct 2012 Complete N/A Subm it OveralllntegJated Plan Feb 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Submit 6 Month Status ReR_ort Feb 2014 Complete N/A Initiate Phase 2 Equipment Procurement Jun 2014 Complete N/A Submit 6 Month Status Rep_ort Aug 2014 Complete N/A Perform Staffing Analysis (Phase 2) Oct 2014 Complete N/A Submit 6 Month Status Rep_ort Feb 2015 Complete N/A Unit 2 Implementation Outage ** Mar 2015 Complete N/A Submit 6 Month Status Report Aug 2015 Complete N/A Develop Modifications- Unit 1 Oct 2015 Complete N/A Develop Modifications- Unit 2 Nov 2015 Complete N/A Develop Operational Procedure Changes Nov 2015 Com_Qiete N/A Create Maintenance Procedures Nov 2015 Complete N/A Develop Training Material Nov 2015 Complete N/A Develop Strategies (Hatch Response Dec 2015 Complete N/A Plan)

Submit 6 Month Status Report Feb 2016 Complete N/A Phase 2 Equipment Procurement Mar 2016 Complete N/A Unit 1 Implementation Outage

• Mar 2016 Complete N/A Implement Training Mar 2016 CorTIQiete N/A Unit 1 Walk-throuahs or Demonstrations Mar 2016 Complete N/A E-1

Enclosure to NL-16-1 050 Seventh Six-Month Status Report of FLEX Implementation Target Revised Target Activity Milestone Completion Completion Status Date Date Issue FSGs*** Mar 2016 In Progress Dec 2016 Submit 6 Month Status Rep_ort Aug 2016 Complete N/A Unit 2 Walk-throughs or Demonstrations Dec 2016 In Progress Unit 2 lm!Jiement Non-Outa_g_e Mods .... Dec 2016 In Pro_gress Submit Completion Report Feb 2017 Not Started

• Full compliance after second listed refueling outage

• • Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016

• • • unit 1 and common FSGs have been issued, Unit 2 FSGs will be issued by December 31, 2016.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 5).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant - Unit 1 has completed the implementation of this Order and the compliance letter has been submitted to the NRC dated May 3, 2016 (Reference 6). Edwin I.

Hatch Nuclear Plant - Unit 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation Edwin I. Hatch Nuclear Plant Unit 2 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 January 13, 2016 (Reference 7) 7 Potential Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for HNP (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 Edwin I. Hatch Nuclear Plant, Units 1 and 2."

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Enclosure to NL-16-1 050 Seventh Six-Month Status Report of FLEX Implementation 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Edwin I. Hatch 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.

3. Edwin I Hatch Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Related to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) {TAC NOS. MF0712 and MF0713).

4. Edwin I. Hatch Nuclear Plant- Units 1 and 2 Response to Request for Information Pursuant to Title 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the NTIF Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012, providing the Hatch Phase 2 On-Shift Staffing Analysis report sent October 9, 2014.

5. Edwin I. Hatch 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 - Hatch Units 1 & 2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

6. Edwin I. Hatch Nuclear Plant - Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation, dated May 3, 2016.

7. NRC letter, Edwin I. Hatch 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. MF0712, MF0713, MF0721, and MF0722), dated January 13,2016.

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