Text

August 2014 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 EA-12-049)
	ML14241A379
Person / Time
Site:	Calvert Cliffs
Issue date:	08/26/2014
From:	Korsnick M; Constellation Energy Nuclear Group, Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, FLL-14-027
	Download: ML14241A379 (36)
	v • d • e

AMaria Korsnlck ASenior A Exelon Generation, Vice President, Northeast Operations Chief Nuclear Officer, CENG 100 Constellation Way Suite 500P Constellation Energy Nuclear Group, LLC Baltimore, MD 21202 410-470-5133 Office 443-213-6739 Fax www.exeloncorp.com maria.korsnick@exeloncorp.com NRC Order No. EA-12-049 FLL-14-027 August 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318

Subject:

August 2014 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 (ML12054A735)

(2) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Response to NRC Letter on Technical Issues for Resolution Regarding Communications Submittals Associated with Near Term Task Force Recommendation 9.3, dated February 22, 2013 (ML13066A710)

(3) Letter from B. K. Vaidya (NRC) to G. H. Gellrich (CENG), Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC Nos. ME9947 and ME9948),

dated April 24, 2013 (ML13100A240)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 12-049 (Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for Calvert Cliffs Nuclear Power Plant, LLC (CCNPP), Units 1 and 2. Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Attachment (1) provides the six-month Status Report for CCNPP. The report updates the milestone accomplishments since the submittal of the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

In Reference (2), CCNPP committed to include the status of the implementing actions identified in Section 4.12 of the Communications Assessment as part of the six-month status reports

U. S. Nuclear Regulatory Commission August 26, 2014 Page 2 required by Section IV.C.2 of NRC Order EA-12-049. Attachment (1) includes an update of the status of these implementing actions. This will be the last status update for those actions.

Future six-month status reports submitted in accordance with Section IV.C.2 of NRC Order EA-12-049 will not include a status of the implementing actions identified in Section 4.12 of the Communications Assessment, as these updates have negligible safety significance. Thus, this letter deletes the regulatory commitment made in Reference (2). As documented in Reference (3), the regulatory commitments to implement the CCNPP Units 1 and 2 improvements related to mitigating strategies (FLEX) derived from the results of the communications assessment will be completed: a) prior to the startup of CCNPP Unit 1 following the Spring 2016 refueling outage and b) prior to the startup of CCNPP Unit 2 following the Spring 2015 refueling outage.

There are no regulatory commitments contained in this letter.

If there are any questions regarding this letter, please contact Bruce Montgomery, Acting Manager - Licensing, at 443-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 6 th day of August, 2014.

Rpsectfully,,

MarGI~sn ick MGK/STD Attachment (1) Six-Month Status Report (August 2014) for Mitigation Strategies for Beyond-Design-Basis External Events cc: Regional Administrator, Region I, USNRC NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant Director, Office of Nuclear Reactor Regulation J. A. Kratchman, NRC

ATTACHMENT (1)

I SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CALVERT CLIFFS NUCLEAR POWER PLANT, LLC August 26, 2014

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX) in response to NRC Order Number EA-12-049 (Reference 2). Subsequently, a supplement to the CCNPP Oil for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and associated basis (if applicable).

CCNPP developed an Interim Action Implementation Schedule as part of an Assessment of Communications during an Extended Loss of AC Power (ELAP) (Reference 4). A commitment was made in Reference 4 to include the status of the implementing actions identified in Section 4.12 of CCNPP's communications assessment as part of the six-month status reports prepared pursuant to Section IV.C.2 of NRC Order EA-12-049. The updated status of the communications assessment interim actions is provided in Section 8. It should be noted that this is the last status report in which an update of communications assessment interim actions will be provided. This change in regulatory commitment is addressed in the cover letter submitting this status report.

Since the submittal of the last two status reports in August 2013 (Reference 6) and February 2014 (Reference 8), CCNPP FLEX has progressed with engineering analysis, calculations and design of modifications that support the mitigating strategies while making some refinements to modification concepts. However, no significant changes to the mitigation strategies or planned modifications in support of the mitigation strategies have occurred. Work to formalize agreements to utilize local spaces as staging areas has progressed with some owners while remaining a challenge with others.

By letter dated December 17, 2013, the NRC issued to CENG the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1142 and MF 1143) (Reference 7). The Interim Staff Evaluation (ISE) contains open and confirmatory items for which Exelon, the CCNPP licensee, has begun to provide clarifying or additional information in the February 2014 and this six-month status reports in order for the NRC to determine that the issues are on a path to satisfactory resolution. This information and the item status are given in Table 3.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP (References 1 and 3),

and are current as of July 15, 2014:

" Performed exploratory fluid system walk downs in support of pending modifications for FLEX strategies during spring 2013 Refueling Outage (RFO). (8/2013)

Performed exploratory electrical system walk downs in support of pending modifications for FLEX strategies during spring 2013 RFO. (8/2013)

Performed preliminary site walk downs in support of FLEX equipment deployment and storage strategies. (8/2013)

Submitted the first six-month FLEX status report in August 2013. (8/2013).

Page 1 of 33

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

Submitted the second six-month FLEX status report in February 2014. (2/2014)

Submitted the third six-month FLEX status report in August 2014. (8/2014)

Developed Strategies/Contract with the Regional Response Center (RRC), (8/2014) 3 Milestone Schedule Status Table 1 provides an update to Attachment 2-1 of the CCNPP OIP (Attachment 4 - References 1 and 3). 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. Any changes to the indicated target completion dates will be reflected in subsequent 6-month status reports.

The revised milestone target completion dates do not impact the Order implementation date.

Walk-throughs or demonstrations encompassing all FLEX equipment points of connection/tie-ins for Phase 2 and Phase 3 strategies will be performed as presented in Table 1. A detailed schedule for walk-throughs or demonstrations, including individual target dates, has not been developed.

Table 1 Status of CCNPP FLEX O1P Milestones Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete U-2: October 2013 Commence Engineering and November 2013 Started Design U-1: October 2014 Commence Procurement of June 2015 Started U-2: January 2015 Equipment U-i: January 2016 Commence Installation of Eqimen t March 2016 Not Started Equipment October 2014 Submit 6-Month Status Report August 2013 Complete U-2: September Develop Modifications October 2013 Started 2014 U-i: July 2015 Develop Strategies/Contract with the Regional Response November 2013 Complete Center (RRC)

Perform Staffing Analysis January 2014 Not Started August 2014 Page 2 of 33

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of CCNPP FLEX OIP Milestones Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 6-Month Status Report February 2014 Complete Complete Engineering and March 2014 Started U-2: October 2014 Design U-I: June 2015 Create Maintenance and dJune 2014 Started December 2014 Testing Procedures Submit 6-Month Status Report August 2014 Complete Procedure Changes Training September 2014 Started December 2014 Material Complete Develop Training Plan November 2014 Started April 2014 Submit 6-Month Status Report February 2015 Not Started Issue FLEX Support March 2015 Started U-2: January 2015 Guidelines (FSG) U-1: January 2016 Unit 2 Modification Implementation Outage April 2015 Not Started March 2015 Unit 2: March Walk-throughs or 2015 Started Demonstrations Unit 1: March 2016 Implement Training June 2015 Started U-2: April 2014 U-i: April 2015 Submit 6-Month Status Report August 2015 Not Started Complete Procurement of U-2: September Equipment 2014 August 2015 Started U-i: September 2015 Submit 6-Month Status Report February 2016 Not Started Unit 1 Modification Implementation Outage April 2016 Not Started March 2016 Page 3 of 33

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of CCNPP FLEX OIP Milestones Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 6-Month Status Report August 2016 Not Started Full compliance with EA November 2016 Not Started 049 is achieved Submit Completion Report December 2016 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1) and Nuclear Energy Institute (NED 12-06 (Reference 5).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation CCNPP 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 Draft Safety Evaluation Table 2 provides a summary of the open items documented in the OIP and those added in a subsequent six month status report and the status of each item.

Table 3 provides a summary of the open items and confirmatory items documented in the NRC's CCNPP ISE (Reference 7) and the status of each item.

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of CCNPP FLEX OIP Open Items CCNPP OIP Open Items Status

1. Add margin to design FLEX components and hard Started.

connection points to address future requirements as re-evaluation warrants. Portable FLEX components will be procured commercially (Notification provided in Reference 8)

2. Implement a design change to install permanent Started.

protected FLEX equipment connection points (Notification provided in Reference 8)

3. Evaluate deployment strategies and deployment Started.

routes to ensure they are assessed for and address applicable hazards impact. (Notification provided in Reference 8)

4. Develop a process for implementation of exceptions for the site security plan or other Stad (license/site specific - 10CFR50.54X) requirements of a nature requiring NRC approval (Notification provided in Reference 8) will be communicated in a future 6 month update following identification.)

5. Define implementation routes upon finalizing a Started.

location or locations for FLEX equipment storage location(s). (Notification provided in Reference 6)

6. Evaluate requirements, options, and develop Started.

strategies to provide reasonably protected storage on site for the FLEX portable equipment. (Notification provided in Reference 6)

7. Design and build a protected storage location or Started.

locations for the FLEX equipment. Ensure the design meets the requirements of NEI 12-06. (Notification provided in Reference 6)

8. Identify analysis needed to develop or support Started.

mitigating strategies.

(Notification provided in Reference 6)

9. Providean administrative program governing the FLEX deployment strategy, marking of setup Started.

locations, including primary and alternate pathways, maintaining the pathways clear, and (Notification provided in Reference 8) clearing the pathways.

10. Determine the location of the CCNPP local staging area, primary and alternate delivery routes, C and delivery methods to the proposed onsite (Addressed in Reference 8) laydown areas.

11. Determine schedule for when RRCs will be fully Complete.

operational.

(Addressed in Reference 6)

12. Define criteria for the local staging area by June Complete.

2013.

(Addressed in Reference 8)

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

13. Establish a suitable local staging area for portable Started.

FLEX equipment to be delivered from the RRC to the site. (Notification provided in this status report)

14. Develop site specific SAFER Response Plan Started.

(playbook) for delivery of portable FLEX equipment from the RRC to the site. (Notification provided in Reference 8)

15. Original open item text:

Implement a design change to replace the 1 ft.

diameter wheel with a 3 ft. wheel on each Atmospheric Dump Valve (ADV) chain operator. Started.

Modified open item text: (Notification provided in Reference 8)

Implement a design change to improve mechanical advantage on each Atmospheric Dump Valve (ADV) chain operator.

16. Evaluate the feasibility of the WCAP-17601-P Deleted.

recommendation to install a remotely operated RCP CBO return line isolation valve. (Addressed in Reference 6)

17. Develop a procedure or FSG to perform an early Started.

cooldown and depressurization as recommended by WCAP-17601-P. (Notification provided in Reference 6)

18. Perform engineering analyses to confirm that CCNPP maintains an adequate level of Shutdown Complete.

Margin (SDM) for an RCS cooldown to 350'F, to (Addressed in Reference 8) cover a period of at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

19. Implement a design change to re-power the Started.

[Safety Injection Tank] SIT level and pressure indicators from a vital 120 VAC instrument bus. (Notification provided in Reference 8)

20. Implement a design change to install new leak- Deleted.

tight SIT vent Solenoid Valves (SV) that will allow the vent line pipe caps to remain off. (Addressed in Reference 6)

21. Original open item text:

Implement design changes to install "plug and play" protected hose connections for the portable alternate [Auxiliary Feedwater] AFW pump to AFW on the exterior of the Auxiliary Building west wall with piping run to the 27 ft. East penetration Rooms to connect to the AFW to S/G Started.

headers.

(Notification provided in Reference 8)

Modified open item text:

Utilize flexible hose to connect a FLEX pump to a newly installed, dedicated hose connections (one per unit) located on the motor driven AFW pump cross-connect lines on the 5 ft. elevation of the Auxiliary Building.

Page 6 of 33

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

22. Implement a design change to install reliable local Deleted.

level indicators on all of the water storage tanks located in the 11, 12 and 21 CSTs, 11 DWST, and (Addressed in Reference 8) 11 and 12 PWSTs. (AddressedinReference_8)

23. Perform an analysis to determine the necessary Started.

scope of the DC load shedding strategy.

(Notification provided in Reference 8)

24. Implement a design change to clearly identify the Sted.

set of DC load breakers that will either be left energized or load shed by identifying the selected (Notification provided in Reference 8) breakers by their unique numbers and load title.

25. Implement a procedure or FSG to perform the DC Started.

load shedding.

(Notification provided in Reference 6)

26. Complete a time-motion study to validate that DC Started.

load shedding can be accomplished on each unit in one (1) hour. (Notification provided in Reference 8)

27. Original open item text:

Implement a design change to install an 8-hour Uninterruptible Power Supply (UPS) on the Mansell RCS Level Monitoring System. Started.

Modified open item text: (Notification provided in Reference 8)

Implement a design change to connect a portable diesel generator to the Mansell RCS Level Monitoring System.

28. Perform engineering analyses and develop strategies for providing RCS make-up and core cooling while in Modes 5 and 6, for all possible Started.

RCS conditions, following an ELAP. The analysis should determine the FLEX pump (Notification provided in Reference 8) capacity needed to provide adequate flow in all RCS conditions.

29. Perform an analysis to determine that there is Complete.

sufficient decay heat generated for TDAFW operation 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after shutdown. (Addressed in Reference 8)

30. Implement a design change to provide dedicated Started.

hose connections and piping to the Safety Injection System. (Notification provided in Reference 8)

31. Develop a procedure or FSG to mimic the AFW Started.

makeup strategy described in ERPIP-611, Attachment 1. (Notification provided in Reference 6)

32. Install a design change to add makeup and pump Deleted.

suction hose connections for FLEX pump connection to 12 CST. (Addressed in Reference 8)

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

33. Install a design change to replace the 2-1/2 inch hose connections with 4 inch hose connections at 11 and 21 CSTs, 11 DWST, and 11 and 12 (Addressed in Reference 6)

PWSTs.

34. Install a design change to add hose connections at Started.

11 and 21 Refueling Water Storage Tanks (RWT) for makeup and suction for the FLEX pumps. (Notification provided in Reference 8)

35. Install design change to add 4" hose connections Deleted.

to the Reactor Coolant Waste Receiver Tanks (RCWRTs) and Reactor Coolant Waste Monitor (Addressed in Reference 8)

Tanks (RCWMTs).

36. Perform an analysis to determine the survivability of the wells as a long-term source of make-up Started.

water. Analysis should include any modifications needed to improve the survivability of the associated Well Water System piping and to provide 480 VAC power to the well pumps.

37. Perform an analysis to determine the long-term Started.

effect on the S/Gs from use of water from the

[Ultimate Heat Sink] UHS as a cooling medium.

38.Perform an analysis to determine station battery coping time with DC load shedding. Analysis Started.

should consider battery age, battery performance without battery room ventilation, and load and (Notification provided in Reference 8) load duration prior to completion of DC load shedding.

39. Track the completion of ECP-1 1-000293 and - Started.

000294, the Reserve Battery distribution system modification that is currently in progress. (Notification provided in Reference 6)

40. Develop and implement procedures to supply Started.

power to critical instrumentation using primary and alternate methods. (Notification provided in Reference 6)

41. Perform an analysis to determine that the assumed Complete.

load capacity of the FLEX 480 VAC DG is sufficient to provide power to the selected loads. ECP-14-000052 includes an analysis to determine that the assumed load capacity of the FLEX 480 VAC DG is sufficient to provide power to the selected loads.

42. Implement a design change to connect a FLEX 480 VAC Diesel generator to either of the A or B Started.

train 480 VAC load centers on each unit to provide power to the battery chargers and other (Notification provided in Reference 8) critical AC equipment.

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

43. Implement a design change to provide direct connection of a portable 100 kW diesel generator to reactor [Motor Control Centers] MCCs 104 or Staed.

114 and 204 or 214 to provide power to the inverter backup bus (which can power the (Notification provided in Reference 8) 120VAC vital bus), the SIT Outlet [Motor Operated Valves] MOVs, and the AFW Pump Room Vent Fans.

44. Implement a design change to install connection Deleted.

points, conduit, cabling, and transfer switches locally at battery chargers to provide for direct (Addressed in Reference 6) connection from the FLEX 480 VAC DGs.

45. Perform an analysis to determine the feasibility of Not Started.

the S/G "batch" feeding strategy.

46. Implement a procedure to connect a 4160 VAC Staed.

RRC DG to either of the A or B Train 1E 4160 VAC Buses on each unit to provide power for (Notification provided in Reference 8)

Phase 3.

47. Develop procedures or FSGs for repower vital Started.

4160 VAC Class lE buses from RRC FLEX 4KV DGs. (Notification provided in Reference 8)

48. Provide modified 4160 VAC breakers for direct RRC DG connection for use in place of the normal D 4160 VAC breakers in service for LPSI Pump and (Addressed in Reference 8)

SW Pump power supplies.

49. Implement a design change to power containment Started.

dome and reactor cavity temperatures instrumentation from a vital 120 VAC instrument (Notification provided in Reference 8) bus. (NotificationprovidedinReference_8)

50. Perform an analysis to determine containment temperature and pressure response over a period Complete.

of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Perform analysis with and without RCS cooldown and with and without restoration (Addressed in Reference 6) of containment air cooling.

51. Implement a design change to install a hose Deleted.

connection on the A-Train and B-Train

[Containment Spray] CS headers in the Auxiliary (Addressed in Reference 6)

Building.

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

52. Purchase additional special check valve bonnets Deleted.

and store them inside each [Emergency Core Cooling System] ECCS Pump Room. The scope of this action was to build additional hose bonnet tools for each ECCS pump room rather than one tool that would have to be moved from room to room if being used to support the FLEX mitigation strategy. The CCNPP FLEX strategy for containment cooling will no longer use this connection path. FLEX will not use the same means to cool containment as B.5.b uses for containment flooding through the spray header. Therefore additional tools, as were originally planned, are not needed for this scope of FLEX modification.

53. Perform an analysis to determine the feasibility of Started.

providing Containment cooling with CAC Units using an alternate cooling water strategy.

54. Install hose connections on the Service Water Deleted.

(SRW) supply and return lines to the CAC for connection to a RRC portable heat exchanger. (Addressed in Reference 8)

55. Implement a design change to install reliable wide Started.

range spent fuel pool (SFP) level instrumentation in accordance with NRC Order EA-12-051. (Notification provided in Reference 6)

56. Implement a design change to provide a 6" hose Started.

connection to each RWT.

(Notification provided in Reference 8)

57. Implement a design change to provide dedicated Started.

hose connections to the SFP Cooling system.

(Notification provided in Reference 8)

58. Develop and implement procedures or FSGs that Started.

include the SFP Cooling FLEX makeup flow path.

(Notification provided in Reference 6)

59. Develop procedures or FSGs that mimic the Started.

ERPIP-612 sections for SFP makeup and SFP spray. (Notification provided in Reference 6)

60. Implement a design change to install reliable wide Duplicate Open Item.

range SFP fuel pool level instrumentation in accordance with NRC Order EA-12-051 See Open Item #55

61. Perform an analysis to determine the Control Complete.

Room temperature response over a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottest part of the day.

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CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

62. Perform an analysis to confirm that TDAFW Complete.

Pump room air temperature remains acceptable over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of pump operation. Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottest part of the day.

63. Develop primary and alternate strategies for Complete.

ventilating the TDAFW Pump Room.

(Addressed in Reference 6)

64. Perform an analysis to confirm the [Probable Maximum Precipitation] PMP event maximum Complete.

flood height will not impact the operation of (Addressed in Reference 6)

TDAFW or preclude access to the room.

65. Perform an analysis to determine the possible Complete.

effects of Beyond Design Basis External Events (BDBEEs) on the Turbine Building structure and The turbine building was originally designed to the the potential effect on access to the TDAFW requirements for a Seismic Class II structure, including wind Pump Room. load and seismic load. The building is an integrated steel structure with metal siding, supported on reinforced concrete foundations. In addition, all of the structural steel columns, beams, and roof trusses of the building have been designed as independent members and in accordance with American Institute of Steel Construction, Inc. specifications. It was determined that facilities which were built to the requirement of basic construction codes have the ability to survive seismically-induced loadings and stresses well in excess of the original allowances. Although a quantitative evaluation of the seismic capability of the turbine building has not been performed, it is unlikely that catastrophic failure of the turbine building would occur.

Class II structures are designed in accordance with design methods of accepted codes and standards insofar as they are applicable. Wind design (25 psf zone) is in accordance with the UBC, with a one third increase in the allowable stresses.

Seismic design is in accordance with the UBC. Seismic forces were based on Seismic Probability Zone 3 multiplied by a ratio of 0.08/0.30. A one third increase in allowable stresses was not allowed. All of the structural steel columns, beams, and roof trusses of the building have been designed as independent members and in accordance with AISC Specifications. The Turbine Building is constructed below grade from the turbine deck down to its base mat.

In addition, taking the position stated in the NRC-endorsed Generic Imolementation Procedure (GIP), it is a fact that Page I1 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status large, commercial industrial structures, such the steel-constructed Turbine Building, have behaved very well during strong motion earthquakes with seismic ground motion in excess of 0.9gs. They have retained their structural and system integrity with the exception of localized damage due to insufficiently anchored equipment. Facilities which were built to the requirements of basic code construction have been found to have the ability to survive seismic-induced loadings and stresses well in excess of the original allowables.

A review of the Turbine Building structural design revealed that it is a ductile structure with inherent damping and energy absorbing capacity. The building is built to withstand 90 mph winds, thereby resisting lateral loads in excess of UBC seismic requirements. As a result, the review of the Turbine Building at CCNPP and NRC-endorsed GIP statements, the turbine building has the ability to survive an SSE without the potential for damage to its piping systems and there is a high likelihood the structure will remain standing following a Beyond Design Basis External Event (BDBEE).

66. Develop an alternate access strategy for access Complete.

into the TDAFW Pump Room.

Based on the determination that the Turbine Building can withstand a BDBEE, it can be concluded that the normal access path to the TDAFW pump room will not be blocked.

Consequently, there is no need to consider an alternate route to reach the TDAFW pump room. Consideration to have an alternate access path to the TDAFW pump room was given prior to concluding that the Turbine Building would not suffer any damage during a BDBEE.

67. Perform an analysis to determine the temperature Complete.

profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area around ADV enclosures. Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the area environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottest part of the day.

68. Perform an analysis to determine the Cable Complete.

Spreading Room temperature response over a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

69. Investigate changing Appendix R lighting Deleted.

batteries to a longer life battery or new battery technology to lengthen the duration of lighting (Addressed in Reference 8) available in vital areas of the plant.

70. Procure battery operated hardhat mounted lights

("miners" lights) for on-shift and Emergency Not Started.

Response Organization (ERO) personnel.

71. Procure a sufficient quantity of hand-held battery ot Started.

operated lanterns for on-shift and ERO personnel.

72. Procure six (6) portable diesel generator powered Complete.

exterior lighting units with 30 ft. masts and a minimum 400,000 lumens. (Addressed in Reference 8)

73. Change Appendix R lighting from incandescent to Deleted.

LED to lengthen the duration of lighting available in vital areas of the plant. (Addressed in Reference 8)

74. Implement a design change to install a protected, backup power supply capable of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of Started.

operation, for the Plant Public Address system.

This includes backup power for the individual (Notification provided in Reference 8) building speaker network amplifiers.

75. Implement a design change to modify the 800 MHz Radio System to provide protection from external hazards, transmitter and antennas protected from seismic, wind, and wind-driven missiles, including back-up power supply capable (Notification provided in Reference 8) of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months operation for the system and repeaters, or install an alternative communication system in lieu of the 800 MHz Radio system.

76. Implement a design change to modify the Fixed Dedicated Satellite Phone System to provide protection from external hazards, and transmitter Started.

and antennas protected from seismic, wind, and wind-driven missiles, including back-up power (Notification provided in Reference 8) supply capable of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months operation for the system.

77. Purchase one wheeled and one tracked vehicle Complete.

with bucket/blade and grapple of sufficient size and load handling capacity to remove debris. (Addressed in Reference 8)

78. Purchase the portable equipment needed to outfit Deleted.

CCNPP Fire Engine 171 for debris removal.

(Addressed in Reference 6)

79. Implement a design change to install a protected alternate means of accessing the UHS for all BDBEEs, including installing necessary Started.

modifications to meet required deployment times.

The strategy must also address how debris in the (Notification provided in Reference 8)

UHS will be filtered / strained and how the resulting debris will effect core cooling.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

80. Develop strategies for use of the Control Room Deleted.

and Cable Spreading Room Appendix R Ventilation System during an ELAP. The use of the Control Room and Cable Spreading Room Appendix R Ventilation System for ELAP is no longer being pursued. The opening of doors and the activation of a 2,000 cfm portable fan units are planned for the Control Room. The opening of doors is planned for the Cable Spreading Rooms (Refer to Calculation CA08253). It was concluded that temporary power required to reactivate the Control Room and Cable Spreading Room Appendix R Ventilation System during an ELAP would be not be provided given that this equipment is in a non-protected location and likely would not survive a BDBEE.

81. Perform an analysis to evaluate hydrogen buildup Complete.

in the battery rooms during charging and the long term room temperature profiles. Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the battery room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with possible limited stay times and that hydrogen concentration will remain well below flammable limits.

82. Perform an analysis to determine the Switchgear Complete.

Room temperature response under the above scenario and assuming various 480 VAC load Calculation CA08253, "Room Heatup for FLEX Evaluation center and 4160 VAC bus loadings over a period (Loss of HVAC)" has been completed. The conclusion is that of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.

83. Perform an analysis to verify the above strategy Complete.

will provide sufficient air flow to vent steam from the SFP Area. Calculation CA08253, "Room Heatup for FLEX Evaluation (Loss of HVAC)" has been completed. The conclusion is that the planned compensatory measures (e.g., opening doors), will provide sufficient air flow to vent steam and maintain the spent fuel pool area environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.

84. Evaluate the cost of draining 21 Fuel Oil Storage Started.

Tank (FOST) and IA DG FOST and refilling with ultra-low sulfur (<15 ppm) diesel fuel oil. (Notification provided in Reference 8)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS CCNPP OIP Open Items Status

85. Original open item text:

Implement a design change to install dedicated FLEX hose connections on 21 FOST, IA DG FOST, and the IB, 2A, and 2B DG fuel oil Y- Started.

strainers.

(Notification provided in this status report)

Modified open item text:

Implement a design change to install dedicated FLEX hose connections on the 21 FOST.

86. Provide a permanent, fully protected diesel FOST Deleted.

for refueling the FLEX diesel-driven equipment.

The existing 21 Fuel Oil Storage Tank (FOST) will be modified to accommodate connections to take fuel for FLEX equipment through an air-driven pump that will be mounted inside the enclosure. Air will be supplied via a FLEX portable air compressor. As a result, there will no longer be a need to provide a permanent, protected Diesel FOST for refueling the FLEX Diesel-driven equipment. (See the modified text of OIP Open Item 85.)

87. Perform an analysis of the fuel consumption rate Sted.

for all of the FLEX equipment that could be in operation during an ELAP for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Notification provided in Reference 8) to determine a conservative refueling interval.

88. Develop strategies to reduce the transport time for Started.

fuel oil loading and delivery.

(Notification provided in Reference 6)

89. Purchase the consumables that should be stocked to support at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of site operation Started.

independent of offsite support.

90. Provide a procedure governing the maintenance and distribution of the consumables that will be Started.

stocked to support at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of site operation independent of offsite support.

91. Develop a strategy to protect onsite consumables Staed.

for use after a BDBEE.

92. Develop equipment operating procedures or FSGs, Started.

considering vendor technical manual operating procedures, for each of the pieces of portable (Notification provided in Reference 8)

FLEX equipment that will be procured.

93. Install connection points on Class 1E 4KV Buses Deleted.

for the RRC 4KV portable DG.

(Addressed in Reference 8)

94. Develop procedures or FSG for each of the RRC Started.

based strategies and for operation of the equipment provided by the RRC. (Notification provided in Reference 8)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of CCNPP Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status

1. ISE Open Item 3.2.1.1.A - The licensee will need to perform a plant specific analysis of RCS cooling and inventory control. If the CENTS code is used, the value of flow quality at the upper region of [Steam Generator] SG tubes for the condition when the RCS makeup pump is required to inject water into the RCS will also need to be Started.

submitted, and the licensee should confirm (Notification provided in this status report) that CENTS is not used outside of any ranges of applicability discussed in the white paper addressing the use of CENTS (e.g., prior to the reflux boiling initiation). If other codes are used for the ELAP analysis, the licensee will need to justify the acceptance of the codes for this use.

2. ISE Open Item 3.2.1.1.B - The licensee's Complete.

plan for analysis for core and containment cooling is still under development and CENG Calculation CA08023, "Minimum Allowable RCS will identify additional analysis to support Temperature to Support FLEX Implementation" has been the mitigating strategies. The subjects of the completed. The conclusion is that the cycle-independent analyses are: maintaining core cooling (e.g., established time for which a cooldown to 325°F could be confirm shutdown margin during cooldown, performed without boration while maintaining reactivity DC load shedding, and adequate steam more negative than -1000 pcm is 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months following reactor pressure for TDAFW pump operation), trip. Beyond 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months , boration is required in order to containment temperature and pressure provide confidence that the reactor remains shut down by response for containment cooling, and more than 1000 pcm.

various safety functions regarding ventilation and cooling systems (e.g., for the main DC load shedding: To confirm the safety-related station control room, TDAFW pump room, cable batteries will support the vital instrumentation required for spreading room, battery rooms, switchgear the Phase 1 FLEX mitigation strategy at Calvert Cliffs until rooms and the SFP area). Review of these the Phase 2 diesel generators are deployed, the following analyses is needed to confirm acceptability of calculations are prepared corresponding to the four safety-the mitigating strategies. related station batteries: CA08256 - Battery 11 Load Shed Coping Time for ELAP Event; CA08257 - Battery 12 load Shed Coping Time for ELAP Event; CA08258 - Battery 21 Load Shed Coping Time for ELAP Event; CA08259 -

Battery 22 Load Shed coping Time for ELAP Event.

An analysis was performed to determine that there is sufficient decay heat generated for TDAFW operation 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after shutdown. The results of the analysis show that there is sufficient decay heat to support adequate steam pressure for TDAFW pump operations for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Open Items Status Containment temperature and pressure response:

Calculation CA07961 evaluates the containment temperature and pressure response to an ELAP.

Room ventilation and cooling: Calculation CA08253 evaluates the temperature response of auxiliary and turbine building area in response to the loss of forced ventilation (HVAC) during an Extended Loss of A/C Power (ELAP) event. The purpose of this analysis is to establish the necessary mitigating actions and required timing of those actions to support the FLEX Overall Integrated Plan (OIP) of ensuring survivability of coping equipment and the operator's ability to perform the required mitigating actions in a safe and timely manner. The mitigating actions will be detailed in Emergency Response Plan Implementing Procedure ERPIP-0652, "Alignment for Area Cooling" and include establishing ventilation pathways, e.g. opening personnel and equipment doors, and staging portable ventilation equipment, e.g. portable fan units powered by small portable diesel generators. No permanent plant modifications are planned in order to implement these mitigating actions. The plant areas addressed include:

Charging Pump Rooms; Battery Rooms, Cable Spreading Rooms, Spent Fuel Pool Heat Exchanger and Pump Room; East Piping Penetration Rooms, Main Steam Piping Penetration Rooms, Main Steam Piping Penetration Rooms, West Piping Penetration Rooms, Switchgear Rooms, Main Control room, Truck Bay Loading Area, Spent Fuel Pool Level Instrumentation Area, Atmospheric Dump Valve Area, East Electrical Penetration Rooms, Spent Fuel Pool Area, Main Plant Exhaust Equipment Room, and Turbine Driven Auxiliary Feedwater (TDAFW) Pump Rooms.

3. ISE Open Item 3.2.1.8.A - During the audit process, the licensee informed the NRC staff of its intent to abide by the Pressurized-Water Reactor Owners Group (PWROG) generic Started.

approach regarding boric acid mixing discussed in Section 3.2.1.8 of this report; however, the (Notification provided in Reference 8)

NRC staff concluded that the August 15, 2013, position paper was not adequately justified and that further information is required.

ISE Confirmatory Items Status

1. ISE Confirmatory Item 3.1.1.1.A - On page Complete.

8 of the Integrated Plan, the licensee specified that Phase 2 FLEX components will be stored FLEX equipment storage locations have been selected. One at the site in a location or locations such that robust storage building and one commercial building will be Page 17 of 33

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status they are reasonably protected and that no one constructed at CCNPP. The robust building, the Flex external event can reasonably fail the site Storage Robust Building (FSRB), will be of reinforced FLEX capability. Provision will be made for concrete approximately 60' wide x 140' long x 21' high and multiple sets of portable on-site equipment located outside of the Protected Area to the west. The stored in diverse locations or through storage commercial building, the Flex Storage Commercial Building in structures designed to reasonably protect (FSCB), will be a pre-engineered building approximately from applicable external events. FLEX 60' wide x 60' long x 18' high and located outside of the equipment storage location(s) have not been Protected Area to the south. The distance between the two selected. buildings is approximately 2,685 feet.

2. ISE Confirmatory Item 3.1.1.1.B - The licensee will provide the specific protection requirements described in NEI 12-06 for the (Notification provided in Reference 8) applicable hazard.

3. ISE Confirmatory Item 3.1.1.4.A - The licensee has not yet identified the local staging area or described the methods to be used to deliver the equipment to the site for Started.

all hazards. The licensee will develop a playbook which will provide the detail (Notification provided in Reference 8) necessary to ensure the successful delivery of the portable FLEX equipment from the RRC to the local staging area and from the local staging area to the site.

4. ISE Confirmatory Item 3.1.2.2.A - The licensee identified two open items; one regarding evaluating deployment strategies and deployment routes to ensure they are assessed for and address applicable hazards Started.

impact. The second was to provide an administrative program governing the FLEX (Notification provided in Reference 8) deployment strategy, marking of setup locations, including primary and alternate pathways, maintaining the pathways clear, and clearing the pathways.

5. ISE Confirmatory Item 3.1.2.2.B -

Regarding the open items noted in 3.1.2.2.A, evaluations are needed to assure that connection points for portable equipment Started.

remain viable for the flooded condition, and that the effects of the maximum storm surge (Notification provided in Reference 8) or probable maximum hurricane should be considered in evaluating the adequacy of the baseline deployment strategies.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

6. ISE Confirmatory Item 3.1.2.2.C - The licensee specified that primary access to the UHS is via the openings in the [Circulating Water] CW Discharge Structure (plant outfall). An alternate UHS location has not been established; however the licensee has Started.

identified an open item to implement a design change to install a protected alternate means (Notification provided in Reference 8) of accessing the UHS for all BDBEEs, including installing necessary modifications to meet required deployment times. The strategy must also address how debris in the UHS will be filtered and/or strained and how the resultin2 debris will affect core cooling.

7. ISE Confirmatory Item 3.1.3.2.A - The Complete.

licensee specified that CCNPP currently has a varied array of wheeled vehicles, e.g., Equipment that has been procured and evaluated in support forklifts, small tractors, and a backhoe, that of the FLEX effort and that will be dedicated for use during could be used for debris removal. However, an ELAP event will be stored in the FLEX storage buildings the licensee did not specify if this equipment (see Item 3.1.1.1 .A). The decision to store which equipment would be protected from high wind and other in what building is based on the guidance given in NEI 12-hazards. 06.

8. ISE Confirmatory Item 3.1.4.2.A - The Started.

licensee did not address procurement requirements to ensure that the FLEX FLEX equipment is being procured to the extreme hot and equipment can be operated in extreme hot or cold temperature environments specified in Calvert Cliffs' cold temperature environments or how hot or Design Criteria Document "Implementation of Diverse and cold temperatures will affect manual actions. Flexible Coping Strategies (FLEX)".

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

+

9. ISE Confirmatory Item 3.1.4.2.B - Complete.

Deployment of FLEX equipment has not been addressed for conditions of snow, ice and Calvert Cliffs Units 1 and 2 use its circulating water (CW) extreme cold. The current screening omits a and saltwater (SW) systems suction and discharge structures discussion of deployment of FLEX equipment for the ELAP Ultimate Heat Sink (UHS) water source for all for hazards due to ice blockage or formation BDBEEs. The primary access to the UHS water source is of frazil ice on the UHS. via openings in the CW/SW discharge structure (plant outfall). The alternate access to the UHS water source is via the intake structure downstream of the circulating water screens through existing access hatches associated with the CW screen wash pumps. The alternate UHS water source can be readily accessed to meet required deployment strategies and is protected from debris and ice by the CW screens. There are 12 CW pumps (6 per Unit) rated at 200,000 gpm each and 6 SW pumps (3 per Unit) rated at 15,500 gpm each, resulting in a normal flow through the intake and discharge structures of approximately 2,500,000 gpm. Under ELAP conditions, the maximum expected flow through the intake structure will be less than 20,000 gpm (1% of the normal flow), and more like reverse flow through the CW screens, which significantly reduces the intake velocity into the intake area and screens as well as providing significant margin for screen clogging due to debris or ice as described in the Exelon Position Paper, "FLEX Water Source Debris Clogging at Suction Point." Similarly, while Calvert Cliffs has been found not to be susceptible to frazil ice (Ref. Station Response to INPO SOER 2007-02, "Intake Cooling Water Blockage"), this reduced intake velocity also provides significant margin for screen blockage due to frazil ice, if it were to occur concurrent with a BDBEE.

10. ISE Confirmatory Item 3.2.1.2.A - The RCP seal initial maximum leakage rate should be greater than or equal to the upper bound expectation for the seal leakage rate for the ELAP event discussed in the PWROG Complete.

white paper addressing the RCP seal leakage for CE plants. If the RCP seal leakage rate (Addressed in Reference 8) used in the plant-specific ELAP analysis is less than upper bound expectation for the seal leakage rate discussed in the white paper, justification should be provided.

11. ISE Confirmatory Item 3.2.1.5.A - The Complete.

licensee has not provided sufficient analyses to confirm instruments are reliable and Confirmation that instruments are reliable and accurate in accurate in the containment harsh conditions the containment harsh conditions is provided in Engineering with high moisture levels, temperature and Change Package ECP-14-000024, Instrument Re-Power pressure during the ELAP event. Modification.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

.1-

12. ISE Confirmatory Item 3.2.1.6.A - The Complete.

following references used as basis for several sequence of events (SOE) Action Time CCN0012-17-STUDY-001, Rev. 0, Analysis of Calvert constraints were not available for review: Cliffs DC Systems in Support of INPO Event Report 11-4, CCNOO12-17-STUDY-001, and CCNPP is a 596-page document. It will be posted to the CCNPP FLEX Strategy Table Top. ePortal and be available for review. It should be noted that the DC Systems study has been superseded by detailed DC system analyses. (Refer to ISE Open Item 3.2.1.l.B).

On the other hand, "CCNPP FLEX Strategy Table Top "is not a document. It was a compilation of notes the meeting organizer took while conducting the table tops. These notes were discarded sometime after the table tops were conducted and their results were reviewed.

13. ISE Confirmatory Item 3.2.1.6.B - The licensee has not completed final analysis regarding validation of the action times reported in the Sequence of Events, including S any SOE changes that may result from (Notification provided in Reference 8) ongoing evaluations for; RCP seal leakage, plant specific CENTS analysis, and any revised battery load shed analysis.

14. ISE Confirmatory Item 3.2.1.7.A -The Complete.

Generic Concern related to the shutdown and refueling modes, required clarification of CCNPP will implement PWROG Shutdown mode guidance CCNPP's approach to demonstrate that the PA-PSC-1 126, Core Team Interim Guidance for Early strategies can be implemented in all modes. Implementers as provided in letter OG-14-101, dated March During the audit, the licensee informed the 14, 2014. This includes implementing Shutdown Mode NRC of their plans to abide by this generic FSG-14, Shutdown RCS Makeup and FSG-15, Shutdown resolution. The implementation of these plans Water Management.

is identified as Confirmatory Item 3.2.1.7.A. WaterManagement.

15. ISE Confirmatory Item 3.2.1.9.C - During Complete.

the audit process, the licensee stated that it will provide revised analyses as detailed Detailed engineering evaluations of each Phase 3 FLEX engineeiing evaluations are performed for component and modification strategy are provided in the each Phase 3 FLEX component and following Engineering Change Packages:

modification strategy.

ECP-14-000153, Phase 3 4160 VAC RRC DG Connection Mod (Note: 10% package only)

ECP-14-000105: Phase 3 0 Long Term Coping for Reactor Core Cooling via Shutdown Cooling

Provide boric acid batching capability for RWT /

RCS makeup

Maintain Spent Fuel Pool (SFP)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

16. ISE Confirmatory Item 3.2.1.9.D - The licensee provided an open item, to perform engineering analysis to determine that there is Complete.

sufficient decay heat generated for TDAFW operation 36-hours after shutdown and that (Addressed in Reference 8) the TDAFW pumps can operate reliably provided there is greater than 65 psia steam pressure in one of the SGs.

17. ISE Confirmatory Item 3.2.2.A - The Complete.

licensee did not discuss the impacts of salt/brackish water on the structures and The source of spent fuel pool makeup water will be selected components of the SFP system, and the fuel. based on availability, priority of use, and water quality.

During the audit process the licensee Condensate-grade water from any available condensate specified that they will perform an analysis to storage or demineralized water tank is the preferred source, determine the effects of salt/brackish water on followed by pre-treated (fire) water, well water, and finally, the structures and components (including as a last resort, Chesapeake Bay (brackish) water via B.5.b instrumentation) of the SFP system and the (10 CFR 50.54 (hh) (1)) methods in response to potential stored fuel. aircraft threats. As brackish water is already approved for use in response to 10 CFR 50.54 (hh) (1), analysis of the effects of brackish water on SFP structures and components, including instrumentation and fuel, is not planned. It should be noted that the newly installed spent fuel pool level instrumentation would not be affected by brackish water because the cone, its closest part to the water, hangs 2.5 ft.

above the pool water surface.

18. ISE Confirmatory Item 3.2.2.B - The Complete.

licensee will perform an analysis to verify that the proposed strategy for SFP ventilation Calculation CA08253, "Room Heatup for FLEX Evaluation will provide sufficient air flow to vent steam (Loss of HVAC)" has been completed. The conclusion is from the SFP area, in order to determine that the planned compensatory measures (e.g., opening whether natural air circulation is sufficient, or doors), will provide sufficient air flow to vent steam and forced ventilation provided by FLEX maintain the spent fuel pool area environment acceptable for equipment will be required. occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.

19. ISE Confirmatory Item 3.2.3.A - The licensee specified that an analysis of the Containment response during the ELAP event indicated that the Containment would not require additional cooling. During the audit, Started.

the licensee provided a document entitled "CCNPP Containment Analysis" that was (Notification provided in Reference 8) based on the GOTHIC code, however, the tabulated results did not match those transmitted in the August 2013 6-month update.

20. ISE Confirmatory Item 3.2.4.1.A - Complete.

Charging Pump Room ventilation is provided by the non-safety related Auxiliary Building Calculation CA08253, "Room Heatup for FLEX Evaluation Page 22 of 33

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status Supply and Exhaust Ventilation System. An (Loss of HVAC)" has been completed. The conclusion is evaluation will be performed to determine if that the planned compensatory measures (e.g., opening the Charging Pumps can meet their mission doors, using temporary fans and air coolers) will maintain time without room ventilation, the charging pump room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

21. ISE Confirmatory Item 3.2.4.2.A - The Complete.

licensee identified an open item to perform an analysis to determine the Control Room Calculation CA08253, "Room Heatup for FLEX Evaluation temperature response over a period of 72 (Loss of HVAC)" has been completed. The conclusion is hours. that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hrs with limited stay times possible during the hottest part of the day.

22. ISE Confirmatory Item 3.2.4.2.B - The Deleted.

licensee identified an open item to develop strategies for use of the Control Room and The use of the Control Room and Cable Spreading Room Cable Spreading Room Appendix R Appendix R Ventilation System for ELAP is no longer Ventilation System during an ELAP. being pursued. The opening of doors and the activation of a 2,000 cfm portable fan units are planned for the Control Room. The opening of doors is planned for the Cable Spreading Rooms (Refer to Calculation CA08253). It was concluded that temporary power required to reactivate the Control Room and Cable Spreading Room Appendix R Ventilation System during an ELAP would be not be provided given that this equipment is in a non-protected location and would likely not survive a BDBEE.

23. ISE Confirmatory Item 3.2.4.2.C - The Complete.

licensee identified an open item to perform an analysis' to evaluate hydrogen buildup in the Calculation CA08253, "Room Heatup for FLEX Evaluation battery rooms during charging and room (Loss of HVAC)" has been completed. The conclusion is temperature profiles. that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the battery room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with possible limited stay times and that hydrogen concentration will remain well below flammable limits.

24. ISE Confirmatory Item 3.2.4.2.D - The Complete.

licensee identified an open item to perform an analysis to determine the Switchgear Room Calculation CA08253, "Room Heatup for FLEX Evaluation temperature response following the (Loss of HVAC)" has been completed. The conclusion is reenergizing of buses and assuming various that the planned compensatory measures (e.g., opening 480 VAC load center and 4160 VAC bus doors, using temporary fans and air coolers) will maintain loadings over a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

25. ISE Confirmatory Item 3.2.4.2.E - The Complete.

West Electrical Penetration Rooms will begin to heat up after the Reactor motor control Calculation CA08253, "Room Heatup for FLEX Evaluation centers (MCC) are re-energized from the (Loss of HVAC)" has been completed. The conclusion is FLEX 480 VAC DGs, therefore, they will that the planned compensatory measures (e.g., opening need to be evaluated for limiting temperatures doors, using temporary fans and air coolers) will maintain for equipment survivability, the West Electrical Penetration Rooms environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

26. ISE Confirmatory Item 3.2.4.4.A - On page 56 of the Integrated Plan, the licensee identified five open items to; 1) investigate Complete.

changing Appendix R lighting batteries to a longer life battery or new battery technology The status of these five open items is as follows:

to lengthen the duration of lighting available in vital areas of the plant, 2) procure battery 1. On-shift individuals and members of the Emergency operated hardhat mounted lights ("miners" Response Organization will be provided with hardhat lights) for on-shift and emergency response mounted lights ("miners" lights). Therefore, there is no organization (ERO) personnel, 3) to procure a longer a need to change Appendix R lighting from sufficient quantity of hand-held battery incandescent to LED.

operated hardhat lanterns for on-shift and 2. See Item 1 ERO personnel, 4) to procure six (6) portable 3. See Item 1 diesel generator powered exterior lighting 4. The six portable diesel generator-powered exterior units with 30 ft. masts and a miinimum lighting units have been purchased and are at CCNPP.

400,000 lumens, and 5) to change Appendix 5. See Item 1 R lighting from incandescent to LED to lengthen the duration of lighting available in vital areas of the plant.

27. ISE Confirmatory Item 3.2.4.4.B - The NRC staff reviewed the licensee communications assessment and has determined that the assessment for Complete.

communications is reasonable, and the analyzed existing systems, proposed The assessment for satellite communications has started.

enhancements, and interim measures will help The assessment for radios is on-going with the final phase to ensure that communications are scheduled by the summer of 2014. At that time the scope of maintained. Confirmation that upgrades to the modification for 800MHz radio system will be determined.

site's communications systems have been completed will be accomplished at a later date.

28. ISE Confirmatory Item 3.2.4.5.A - The licensee has not completed its evaluation of Started.

the primary and alternate access points Page 24 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

29. ISE Confirmatory Item 3.2.4.6.A - The Complete.

licensee has identified an open item to perform an analysis to determine the Calculation CA08253, "Room Heatup for FLEX Evaluation temperature profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area (Loss of HVAC)" has been completed. The conclusion is around the Atmospheric Dump Valve that the planned compensatory measures (e.g., opening enclosures. doors, using temporary fans and air coolers) will maintain the area environment acceptable for occupancy as well as equipment for 72 hrs with limited stay times possible during the hottest part of the day.

30. ISE Confirmatory Item 3.2.4.6.B - The Complete.

licensee' identified an open item to perform an analysis' to determine the Cable Spreading Calculation CA08253, "Room Heatup for FLEX Evaluation Room temperature response over a period of (Loss of HVAC)" has been completed. The conclusion is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . that the planned compensatory measures (e.g., opening doors, using temporary fans and air coolers) will maintain the room environment acceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.

31. ISE Confirmatory Item 3.2.4.6.C - The Complete.

licenseeý identified two open items to perform an analysis to determine the possible effects The Turbine Building was originally designed to the of BDBEE on the Turbine Building structure requirements for a Seismic Class H1 structure, including wind and the potential effect on access to the load and seismic load. The building is an integrated steel TDAFW Pump Room, and to develop an structure with metal siding, supported on reinforced concrete alternate access strategy for access into the foundations. In addition, all of the structural steel columns, TDAFW Pump Room. beams, and roof trusses of the building have been designed as independent members and in accordance with American Institute of Steel Construction, Inc. specifications. It was determined that facilities which were built to the requirement of basic construction codes have the ability to survive seismically-induced loadings and stresses well in excess of the original allowances. Although a quantitative evaluation of the seismic capability of the turbine building has not been performed, it is unlikely that catastrophic failure of the turbine building would occur.

Class II structures are designed in accordance with design methods of accepted codes and standards insofar as they are applicable. Wind design (25 psf zone) is in accordance with the UBC., with a one third increase in the allowable stresses.

Seismic design is in accordance with the UBC. Seismic forces were based on Seismic Probability Zone 3 multiplied by a ratio of 0.08/0.30. A one third increase in allowable stresses was not allowed. All of the structural steel columns, beams, and roof trusses of the building have been designed as independent members and in accordance with AISC Specifications. The Turbine Building is constructed below grade from the turbine deck down to its base mat.

Page 25 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status In addition, taking the position stated in the NRC-endorsed Generic Implementation Procedure (GIP), it is a fact that large, commercial industrial structures, such the steel-constructed Turbine Building, have behaved very well during strong motion earthquakes with seismic ground motion in excess of 0.9gs. They have retained their structural and system integrity with the exception of localized damage due to insufficiently anchored equipment.

Facilities which were built to the requirements of basic code construction have been found to have the ability to survive seismic-induced loadings and stresses well in excess of the original allowables.

A review of the Turbine Building structural design revealed that it is a ductile structure with inherent damping and energy absorbing capacity. The building is built to withstand 90 mph winds, thereby resisting lateral loads in excess of UBC seismic requirements. As a result, the review of the Turbine Building at CCNPP and NRC-endorsed GIP statements, the turbine building has the ability to survive an SSE without the potential for damage to its piping systems and there is a high likelihood the structure will remain standing following a Beyond Design Basis External Event (BDBEE).

Based on the determination that the Turbine Building can withstand a BDBEE, it can be concluded that the normal access path to the TDAFW pump room will not be blocked.

Consequently, there is no need to consider an alternate route to reach the TDAFW pump room. Consideration to have an alternate access path to the TDAFW pump room was given prior to concluding that the Turbine Building would not suffer any damage during a BDBEE.

32. ISE Confirmatory Item 3.2.4.8.A - The medium voltage 4160VAC generators and the low voltage 480VAC 800kW generators that will arrive from the RRC will have protective Started.

devices as specified in AREVA document 51-9199717-000. An evaluation will be performed to verify the internal protection is adequate to protect the IE buses.

Page 26 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

33. ISE Confirmatory Item 3.2.4.8.B - One 480VAC/675KVA diesel generator set will be deployed for each unit to connect to one vital Started 480 VAC Load Center on that unit. The 480VAC/125KVA diesel generators are Engineering Change Package ECP-14-000052, 480 VAC intended as an alternate strategy to connect to FLEX Diesel Generator Connection Modification evaluates one of two vital reactor MCCs on each unit. the 480VAC/500KW and 480VAC/100KW diesel The supplied reactor MCC can be cross- generators for their intended use.

connected to the redundant train reactor MCC on that unit. An evaluation to validate the intended use of these diesel generators is pending'.

34. ISE Confirmatory Item 3.2.4.9.A - The licensee identified Open items to perform an analysis of the fuel consumption rate for all of the FLEX equipment that could be in Started.

operation during an ELAP for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to determine a conservative refueling (Notification provided in this status report) interval, and to develop strategies to reduce the trans'port time for fuel oil loading and delivery.

35. ISE Confirmatory Item 3.2.4.10.A - On page 19 of the Integrated Plan, the licensee identified Open Items: to implement a design change to clearly identify the set of [DC] load breakers-that will either be left energized or Started.

load shed by identifying the selected breakers S by their unique numbers and load title; to (Notification provided in Reference 8) implement a procedure or FSG to perform the

[DC I load shedding; and to complete a time-motion study to validate that DC load shedding can be accomplished on each unit in one hour.

36. ISE Confirmatory Item 3.2.4.10.B -

Maintenance of vital 125 VDC power will Complete.

include aligning the Reserve Battery to one of the four vital 125 VDC buses via bus work The reserve battery is not being credited in the Station's and disconnects that are currently being FLEX strategy because the battery load shedding strategy installed'under an existing plant modification. per ERPIP-653 (FSG-4) provides sufficient time (> 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months This action will extend the coping time for to restore battery charging to at least one battery per Unit).

one vital 125 VDC bus to greater than 20 However, the reserve battery has similar capacity to two of hours. The licensee needs to provide a copy the station batteries and slightly smaller capacity than the of the analysis/calculations which shows other two station batteries and therefore would significantly aligning the Reserve Battery to one of the four increase the battery copying time should there be a delay in 125VDC buses can extend the coping time for restoring battery charging.

one vital'125 VDC bus to greater than 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months .

Page 27 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

37. ISE Confirmatory Item 3.4.A - The licensee's plans for the use of off-site resources conform to the minimum capabilities specified in NEI 12-06 Section Started.

12.2, with regard to the capability to obtain equipment and commodities to sustain and (Notification provided in this status report) backup the site's coping strategies. The licensee did not address the remaining minimum capabilities of Section 12.2.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 Communications Assessment Interim Actions Status Table 4 provides a listing of the implementing actions documented in the Assessment of Communications during an ELAP (Reference 4). It provides the status of each action, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. It should be noted that this is the last status report in which an update of communications assessment interim actions will be provided. This change in regulatory commitment is addressed in the cover letter submitting this status report.

Page 28 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of CCNPP Communications Assessment Interim Actions Communications Assessment Target Revised Target Completion Status Completion Implementing Actions Date Date Fixed Satellite Phone System and Antennas

1. Determine the status of existing fixed Complete.

satellite phone system and antennas in terms of suitability of being "reasonably (Addressed in protected." Reference 8)

2. Install additional antennas/dishes as Started.

necessary to support the use of fixed Startup 2016 satellite phones at all locations. RFO Unit 1 (Notification provided in this status report)

3. Stage portable satellite dishes as necessary Startup 2016 to support the use of fixed satellite phones RFO Unit 1 Not Started.

at all locations.

North Service Building and Switchyard House

1. Determine whether or not the North Complete.

Service Building (NSB) and Switchyard 12/31/2013 Houstage "reasonably protected." (Addressed in Reference 8)

Portable Satellite Phones

1. Stage~satellite phones Complete.

(Addressed in

_ _ _ Reference 6)

2. Stage, batteries and chargers in the Complete.

applicable ERO Facilities. 10/31/2013 (Addressed in

_ _ _ Reference 8)

3. Update work instructions for portable Complete.

satellite phone inventory. 10/31/2013 (Addressed in Reference 8)

4. Develop/update preventive maintenance Complete.

and testing procedures for portable 12/31/2013 satellite phones, batteries and chargers. (Addressed in Reference 8)

5. Include information on portable satellite Complete.

phone locations and usage in procedures. 12/31/2013 (Addressed in

_ _Reference 8)

Page 29 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of CCNPP Communications Assessment Interim Actions Communications Assessment Target Revised Target Implementing ActionsDaeat Completion Status Completion Date Date

6. Procure and install a high power UPS or 12/31/2014 Complete.

similar modification providing backup power for the battery chargers for (Notification portable satellite phones. provided in this status report)

Fixed Satellite Phones

1. Procure and install fixed satellite phones, fixed satellite dishes and uninterruptable power supplies for the Technical Support Center Startup 2016 1 12/31/2014 Started.

(TSC)/Operations Support Center RFO Unit 1 (OSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC).

2. Update work instructions for fixed Complete.

satellite phone inventory (Addressed in Reference 6)

3. Develop/update preventive maintenance Complete.

and testing procedures for fixed satellite phones. (Addressed in Reference 6)

4. Include information on fixed satellite Complete.

phone locations and usage in procedures. (Addressed in Reference 6)

5. Determine the acceptability of the backup UPS in its present location. 8/31/2014 Started. 12/31/2014 Relocate higher, if necessary.

6. Provide instructions for use at every Complete.

fixed satellite phone location.

(Addressed in Reference 6)

Communication with ORO Facilities

1. Provide each Offsite Response Organization (ORO) identified in Complete.

Section 4.0 of the Communications 10/31/2013 Assessment with instructions for proper (Addressed in storage and rotation of satellite phone Reference 8) batteries.

Page 30 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of CCNPP Communications Assessment Interim Actions Communications Assessment Target Revised Target omemuntinActions AsseCompletion Status Completion Implementing Actions Date Date

2. Provide each Offsite Response Organization (ORO) identified in Startup 2016 Staed.

Section 4.0 of the Communications RFO Unit 1 Assessment with fixed satellite dish.

Portable Generators

1. Develop portable generator fueling plan Complete.

to ensure ability to provide power for a 8/31/2015 minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (Addressed in Reference 8)

2. Develop procedures to maintain and test Complete.

the portable generators. 12/31/2013 (Addressed in Reference 8)

3. Update work instructions to inventory Complete.

portable generators and ensure adequate 12/31/2013 volume of fuel. (Addressed in Reference 8)

4. Develop preventive maintenance Complete.

procedure for portable generators fuel 12/31/2013 supply. (Addressed in Reference 8)

5. Procure additional generators as Complete.

required to support FLEX and communications strategies. 6/30/20 14 (Addressed in Reference 8)

(see note 1)

6. Determine a process for relocating portable generators to the appropriate Startup 2015 Not Started.

locations to power the necessary RFO Unit 2 equipment.

Plant Paging (Announcement) System

1. Provide a battery backed power source for the Tellabs Peripheral Equipment and the Power Block Amplicenters or Startup 2015 otherwise modify the paging system to RFO Unit 2 Started.

attain battery backed operation in the event of a loss of all AC power at the site.

Page 31 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of CCNPP Communications Assessment Interim Actions Communications Assessment Target Revised Target Completion Status Completion Implementing Actions Date Date

2. Revise ERPIP 3.0, Immediate Actions, to Complete.

provide guidance to the Shift Manager on how to implement back-up site 12/31/2013 (Addressed in announcements if the Site Paging system Reference 8) is not functional.

3. Revise ERPIP 750, Security, to provide Complete.

specific guidance on how to execute the 12/31/2013 public address announcements if the (Addressed in plant paging system is not functional. Reference 8)

4. Revise ERPIP-B. 1, Equipment Complete.

Checklist, to add necessary bull horns to 12/31/2013 support back-up method for site (Addressed in announcements. Reference 8)

Training

1. Evaluate training needs specific to the use of, portable and fixed satellite phones, radios and implementation of back-up methods for site announcements during an extended loss of AC power event.

2. Develop and implement training on the Startup 2015 Staed.

use of portable generators. RFO Unit 2 Portable Radios

1. Procure and install a high power UPS or similar modification providing Startup 2015 Not Started.

backup power for the radio system RFO Unit 2 repeaters

2. Complete estimates of portable radio Started.

battery life and purchase additional batteries as necessary based on an 10/31/2013 (Notification December 2014 estimate of minimum talk time to provided in ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation. Reference 6)

Note:

1. Complete with respect to Communication but not to FLEX 9 References The following references support the updates to the OIP described in this attachment.

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013.

Page 32 of 33

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

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

3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 8, 2013.

4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letter on Technical Issues for Resolution Regarding Communication Submittals Associated with Near-Term Task Force Recommendation 9.3, dated February 22, 2013.

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

6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Calvert Cliffs Nuclear Power Plant, Units 1 and 2- 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 27, 2013 (ADAMS Accession No. ML13254A278)

7. Letter from J. S. Bowen (NRC) to J. A. Spina (CENG), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049 (Mitigation Strategies) (TAC Nos. MF 1142 and MF 1143), dated December 17, 2013.

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), February 2014 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 February 27, 2014 (ADAMS Accession No. ML14069A318)

Page 33 of 33

L-14-027, August 2014 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 EA-12-049)

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L-14-027, August 2014 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 EA-12-049)

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