CP-201301046, First 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)

First 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)

ML13252A077
Person / Time
Site:	Comanche Peak
Issue date:	08/28/2013
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201301046, EA-12-049, TAC MF0860, TAC MF0861, TXX-13129
Download: ML13252A077 (17)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael.flores@luminant.com Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201301046 REF 10 CFR 2.202 Log # TXX-13129 August 28, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, First 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) (TAC NOS. MF0860 and MF0861)

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. Luminant Generation Company LLC's Letter TXX-12158, Initial 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 October 25, 2012

5. Luminant Generation Company LLC's Letter TXX-13030, 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 28, 2013

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued an order (Reference

1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant 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.

A member of the STARS Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

U. S. Nuclear Regulatory Commission TXX-13129 Page 2 of 2 08/28/2013 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. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided Luminant Power's initial status report regarding mitigation strategies. Reference 5 provided Luminant Power's overall integrated plan.

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 first 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. The attached report provides an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Carl B. Corbin at 254-897-0121 or carl.corbin@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Executed on August 28, 2013.

Sincerely, Luminant Generation Company LLC Rafael Flores

/, eW . Madden Director, Oversight & Regulatory Affairs

Attachment:

Comanche Peak's First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design- Basis External Events c- Eric J. Leeds, Director, Office of Nuclear Reactor Regulation Steven A. Reynolds, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Resident Inspectors, Comanche Peak

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 1 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Comanche Peak Nuclear Power Plant's (CPNPP) First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Comanche Peak developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/ relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of August 14, 2013.

" FLEX Strategy Evaluation - Complete

" Modifications Evaluations - Complete

• Procedures - PWROG issues NSSS-specific guidelines - Complete 3 Milestone Schedule Status The following table provides an update to Attachment 2 of the Overall Integrated Plan. 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. As of this status report, the target completion dates for all activities are unchanged relative to the Overall Integrated Plan documented in Reference 1. Note, italicized items in the following table were not provided as milestone items in Attachment 2 of the Overall Integrated Plan. However, these items are added here for consistency with the 6 month status update template and will be carried forward in future 6 month status updates.

Attachment to TXX- 13129 CPNPP First Six Month Status Report for Requirements for Page 2 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update I Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Aug 2013 Complete Walk-througlis or Demonstrations Apr 2015 Not Started Perform Phase 2 Staffing Analysis Jun 2014 Not Started Modifications:

Modifications Evaluation Aug 2013 Complete Develop Unit 1 Modifications Mar 2014 Started Unit 1 Implementation Outage (1RF17) Oct 2014 Not Started Develop Unit 2 Modifications Mar 2015 Started Unit 2 Implementation Outage (2RF15) Oct 2015 Not Started Storage:

Storage Design Engineering Mar 2014 Started Storage Implementation Oct 2014 Not Started FLEX Equipment.

Procure On-Site Equipment Ju12014 Started Develop "Playbook" with RRC Nov 2013 Started Install Off-Site Deliverj Station (if Aug 2014 Not Started Necessanj)

Regional Response Center Operational Aug 2014 Started Procedures:

PWROG issues NSSS-specific guidelines May 2013 Complete Issue FSGs Aug 2014 Started Create Maintenance Procedures Jul 2014 Not Started Training:

Develop Training Plan May 2014 Not Started Implement Training Aug 2014 Not Started Full Site FLEX Implementation Oct 2015 Started Submit Completion Report Feb 2016 Not Started

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 3 of 15 Mitigation Strategies for Beyond-Design-Basis External Events 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1). However, the following table documents necessary corrections or clarifications to the OIP resulting from reconciliation of the submitted Overall Integrated Plan with the modifications evaluation.

Pages Location Action 10 First paragraph second sentence Change A3-30 through A3-35 to A3-31 throughi A3-34 15 First paragraph second sentence Change A3-32 to A3-33 15 Second paragraph third sentence Change A3-31 to A3-32 15 Last paragraph fourth sentence Change and secondary connections to connection Change Figures A3-16 through A3-17 to Figure A3-18 16 End of first bullet Add (total offour new connections) 18 Third paragraph second sentence Change A3-31 and A3-33 to A3-32 and A3-34 19 Second column first bullet end of first Add (total offour new connections) sentence 23 Second paragraph first sentence Change Phase 2 to Phase 3 30 First column second paragraph first Change through A3-9 to and A3-8 sentence 30 First column last paragraph Delete last two sentences and replace with:

A single portablegeneratorwill be staged in staging area 2 for powering the high pressure, low flow pinup on both units.

31 First column first paragraph first sentence Change through A3-9 to and A3-8 31 First column first paragraph last sentence Change A3-33 to A3-34 42 Fourth bullet Change A3-11 through A3-15 to A3-13 and A3-14 44 First column third paragraph third Change at the 820'-6" to near the 810'-6" sentence 44 Last column first paragraph first sentence Change auxiliary tofitel 49 Third paragraph first and second sentences Change 10-hp to 15-hp 49 Fourth paragraph Change A3-22 to A3-23 49-50, Delete XB10-1-2 52 56 Last paragraph first sentence Change Phase 2 to Phase 3 58 Second column last item Delete Unit 1

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 4 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Pages Location Action 59 Second column first item Change condensate line to piping connected to CST 59 Second column Unit 2 description Delete Unit 2 and its description 59 Second colunm item 3 Change Two to Four Change 1 to 2 59 Second colunm items 4 and 5 Change 2 to Four 63 SSI and SCR sections third column Delete last sentence and replace with:

The connection will be via a hose and submerged eductor arrangement.

65 Second column item number 2 Delete item number 2 and its description, replace with:

2. A 4"x4"x4" tee will be added along RWST overflow line 4-CT-1/2-073-152R-5.

78 Action Item 12 second and fifth columns Change 2 to 1 83 Figure A3-1 Replace with Figure A3-1 from Appendix A 84 Figure A3-2 Replace with Figure A3-2 from Appendix A 86 Figure A3-4 title Change Secondary to Primand and Secondanj 93 Figure A3-11 Replace with Figure A3-11 from Appendix A 96 Figure A3-14 Replace with Figure A3-14 from Appendix A 98 Figure A3-16 Replace with Figure A3-16 from Appendix A 101 Figure A3-19 Replace with Figure A3-19 from Appendix A 103 Figure A3-22 Delete 110 Figure A3-30 Delete 112 Figure A3-33* Replace with Figure A3-33 from Appendix A

• Note Figure A3-34 has not changed but is located on the same page as Figure A3-33.

Additionally, the following modifications originally proposed in the submitted Overall Integrated Plan will not be performed. The basis for each change is documented below.

RMWST The primary and secondary connections for feeding the steam generators conform to the guidance of NEI 12-06 and are sufficient for implementing the core cooling strategies. The modification proposed on pages 59 and 60 of the OIP for the RMWST provides a redundant suction connection for feeding the steam generators, is not required and will not be implemented. Note, this modification is separate from the cross-tie modification discussed on page 59. The cross-tie modification will be implemented.

PWST The Potable Water Storage Tank is not protected from seismic, high wind or missile hazards and contains a small water volume relative to other potentially available tanks located within the protected area yard.

The modification proposed on pages 61 and 62 of the OIP for the PWST is not required and will not be implemented.

Attachment to TXX- 13129 CPNPP First Six Month Status Report for Requirements for Page 5 of 15 Mitigation Strategies for Beyond-Design-Basis Externat Events Phase 3 Large Diesel Generator Electrical Connection The primary connection for the 4160 VAC FLEX diesel generators will be established using cables manually routed from the 4160/6900 V step-up transformer, through the Safeguards building 810' elevation hallway outer doors to the emergency switchgear buses. The primary connection is protected from all hazards. The external primary connection modification discussed on pages 24 and 55-57 of the GIP will not be implemented.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation The Luminant Power response (Reference 1) stated that Comanche Peak Units 1 & 2 are crediting use of low-leakage RCP seals in the FLEX Strategies. There is an issue with the current performance of the credited seals and the vendor has developed a plan to improve the seal performance. Luminant is evaluating the need for relaxation from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, so that the option to credit the low-leakage seal may be pursued. The current required implementation date for Unit 1 is the 2014 fall refueling outage. An extension of one additional refueling cycle may be requested which moves the Unit 1 implementation date to the spring of 2016, still within the maximum allowed time frame of December 2016. The extension would provide additional time to resolve the seal performance issue and fully design and safely inmplement modifications that affect Units 1

& 2. A new Open Item, 014, has been included in this submittal.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the Overall Integrated Plan and the status of each item.

Overall Integrated Plan Open Item Status OI1. Finalize location and protection requirements of FLEX Complete. FLEX equipment will be storage buildings. The storage buildings will be stored in a new single structure designed in accordance with the NEI guidance and the designed to reasonably protect from applicable hazards. applicable external events and will be located west of Warehouse A outside the Protected Area. The current structure at this location, designated 2K3 in Figure A3-35 of Appendix A, will be removed.

012. Perform containment evaluation based on the boundary The required analysis has not started.

conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed as necessary.

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 6 of 15 Mitigation Strategies for Beyond-Design-Basis External Events The following table provides a summary of additional open items identified during reconciliation of the submitted Overall Integrated Plan with the modifications evaluation. These open items will be carried forward in future 6 month status updates.

Overall Integrated Plan Open Item Status 013. Development of refueling equipment specifications, Development of final specifications determination of fuel consumption rates, assessment of for all FLEX equipment has started.

fuel supplies and determination of time frames for refueling of FLEX equipment in Phases 2 and 3 will be developed following generation of specifications for FLEX equipment.

014. Finalize FLEX strategies and required modifications Issue resolution in progress, following resolution of low-leakage RCP seal including low-leakage RCP seal performance issue. design changes and testing. Potential impact on Fall 2014 implementation date for Unit 1.

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

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

1. Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 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 28, 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.

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 7 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Appendix A Overall Integrated Plan Figures - Revised and New

Attachment 3: Conceptual Sketches Reactor Core CoolinE & Heat Removal (Steam Generators Available) Alipnments/Flowpaths The primary connection alignment is designated by the green path and the secondary connection alignment is designated by the red path.

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Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 14 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Figure A3-33: Yard Tanks Available and Deployment Path Figure A3-34: Modified A1-0413, Sh. 02 FLEX Staging Areas (Reference 8q) 112

Attachment to TXX-13129 CPNPP First Six Month Status Report for Requirements for Page 15 of 15 Mitigation Strategies for Beyond-Design-Basis External Events Figure A3-35: FLEX Storage Building Location