RS-14-012, Second 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)
| ML14059A219 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/28/2014 |
| From: | David Helker Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, RS-14-012 | |
| Download: ML14059A219 (17) | |
Text
Order No. EA-12-049 RS-14-012 February 28,2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
Second 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, " Issuance of Order to Modify 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
Revision 0, dated August 2012
- 4. Exelon Generation Company, LLC's 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. Exelon Generation Company, LLC 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 (RS-13-022)
- 6. Exelon Generation Company, LLC 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 049), dated August 28,2013 (RS-13-123)
- 7. NRC letter to Exelon Generation Company, LLC, Limerick Generating Station, Units 1 and 2 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0847 and MF0848), dated January 10, 2014
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2014 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC 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.
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 the EGC initial status report regarding mitigation strategies. Reference 5 provided the Limerick Generating Station, Units 1 and 2 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. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Limerick Generating Station. The purpose of this letter is to provide the second 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 enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 7.
As described in Reference 5, full implementation of NRC Order EA-12-049 required mitigation strategies is dependent upon implementation of reliable hardened containment venting capability established in accordance with NRC Order EA-12-050. NRC Order EA-13-1 09 issued by the NRC on June 6, 2013, rescinded the requirements of Order EA-12-050 and established revised schedule timelines and implementation dates for reliable hardened containment vents capable of operation under severe accident conditions. The revised schedule and implementation timeline contained in Order EA-13-1 09 delays the ability to achieve full implementation of the mitigation strategy requirements of Order EA-12-049. This need for relaxation from the implementation requirements of Order EA-12-049 is described in Section 5 of the enclosed update report. The request for relaxation of the full implementation schedule requirements of Order EA-12-049 is being submitted separately.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2014.
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28,2014 Page 3 Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Enclosure:
- 1. Limerick Generating Station, Units 1 and 2 Second 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 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Limerick Generating Station, Units 1 and 2 NRC Project Manager, NRR - Limerick Generating Station, Units 1 and 2 Ms. Jessica A Kratchman, NRR/JLD/PMB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L Dennig, NRR/DSS/SCVB, NRC Mr. Peter Bamford, NRR/DPR/MSD/MSPB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection
Enclosure Limerick Generating Station, Units 1 and 2 Second 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 (13 pages)
Limerick Generating Station. Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Enclosure Limerick Generating Station, Units 1 and 2 Second Six Month Status Report for the Implementation of Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Limerick Generating Station, Units I and 2 developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis. if any.
2 Milestone Accomplishments The following milestone(s) have been completed since the August 28. 2013 status report (Reference 4) and are current as of January 24. 2014.
- Engineering contracts have been awarded for FLEX Modifications on both units and detailed Engineering has commenced.
- Development of Site Specific procedures for implementation of the FLEX Strategies has commenced.
3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference I). 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.
The need for relief relaxation on site implementation of Order EA-12-049 is provided in Section 5 of this enclosure.
Milestone Schedule Site: Limerick Generating Station Target Revised Target Activity Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Contract with RRC October 2012 Complete Submit 6 Montb Updates:
Update I August 2013 Complete Page I of 13
Limerick Generating Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Target Revised Target Activity Completion Activity Status Completion Date Date Complete with Update 2 February 2014 this submittal I Update 3 August 2014 Not Started Update 4 February 2015 Not Started Update 5 August 2015 Not Started Update 6 February 2016 Not Started Not required Update 7 August 2016 Not Started based on April 2016 second unit live date Submit Completion Report April 2016 Not Started Modification Development &
Implementation:
Unit I Modification Development (All February 2015 Started FLEX Phases)
Unit I Modification Implementation (All April 2016 Not Started FLEX Phases)
November 2014 Unit 2 Modification Development (All (Mod March 2014 Started FLEX Phases) implementation not affected)
Unit 2 Modification Implementation (All April 2015 Not Started FLEX Phases)
Procedures:
Create Site-Specific Procedures April 2015 Started Validate Procedures (NEI 12-06, Sect.
February 20 15 Not Started 11.4.3)
Create Maintenance Procedures April 2015 Not Started Perform Staffing Analysis November 2014 Not Started Storage Plan and Construction April 2015 Started FLEX Equipment Acquisition April 2015 Started Training Completion April 2015 Not Started Page 2 of 13
Limerick Generating Station. Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 I
Target II Revised Target Activity Completion Activity Status Completion Date Date Regional Response Center Operational December 2014 Statted Stat1ed For Hardened April 2016 vent related Unit I FLEX Implementation compliance See Section 5 of this enclosure.
Stmted For Hardened Unit 2 FLEX Implementation April 2015 vent related compliance See Section 5 of this enclosure.
Stat1ed For Hardened April 2016 Full Site FLEX Implementation vent related compliance See Section 5 of this enclosure.
4 Changes to Compliance Method Following submittal of the Overall Integrated Plan and the August 28.2013 status report (Reference 4).
Limerick has determined that modifications are not required to the plant 480 VAC switchgear. In place of modifications. the temporary generator connection will be made by insetting spare Motor Control Center (MCC) buckets into the MCCs at the time of the event. These actions can be completed in the required time frames. This change will still comply with NEI 12-06 (Reference 6) and will reduce the number of plant modifications required.
Following submittal of the Overall Integrated Plan and the August 28.2013 status report Limerick has determined that repowering of portions Division III 480 V AC electrical system is also not required. This bus was originally to be repowered to support recovery of installed Main Control Room (MCR) ventilation systems. The site has determined that installing temporary fans for MCR ventilation is adequate. Computations will document the requirements and procedures will be developed to install the required ventilation equipment.
There are no other changes to the FLEX strategies identified at this time.
5 Need for ReliefIRelaxation and Basis for the RelieflRelaxation This section provides a summary of needed relief/relaxation only. The specific details are being submitted in a separate document.
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Limerick Generating Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 of Mitigation to include procedures,
'H~l"'"' or installing equipment needed for the The Overall
- 1) provided the Limerick Generating Station response to NRC Order EA 049. The cover letter that in implementing the Hardened Containment Vent System as required NRC Order EA-J 109 will also implementation of the Mitigation Strategies Order EA-l actions.
The Overall Integrated Plan I) enclosure describes the Limerick Generating Station Mitigation that are based on the containment using the Hardened Containment Vent System. It also that a modification to install a Hardened Containment Vent System (HCVS) is required.
Thus, the Limerick Generating Station NRC Order EA-12-049 response provided in Reference 1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.
Upon issuance of NRC Order EA-J 109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of NRC Order EA-12-050.
As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference I for Limerick Generating Station Units I and 2 will not be achieved until compliance to NRC Order EA-I 109 is achieved. Relief/relaxation from the NRC Order EA-12-049 IV.A.2 requirements is required.
Limerick Generating Station will be in compliance with the aspects of the Reference I. Unit I and Unit 2 Mitigation that do not rely upon a Hardened Containment Vent System unless otherwise described.
6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.
Section Reference Overall Integrated Plan Open Item Status Sequence of Events (p. 8) The times to complete actions in the Events Not Stal1ed Timeline are based on operating judgment, conceptual designs, and cunent supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures developed.
Sequence of Events (p. 7) Initial evaluations were used to determine the Started Installed Phase 1 fuel pool timelines. Formal calculations will Equipment (p.37) be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.
Sequence of Events (p. 7) Analysis of deviations between Exelon's Completed (Reference 4)
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Limerick Generating Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 engineeling analyses and the analyses contained in BWROG Document NEDC-33771 p, "GEH Evaluation of FLEX Implementation Guidelines" and !
documentation of results was not completed and submitted with the Overall Integrated Plan (Reference I).
Identify how strategies Transpol1ation routes will be developed from Started will be deployed in all the equipment storage area to the FLEX modes staging areas. An administrative program will (p. 11) be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation.
Identification of storage areas and creation of the administrative program are open items.
Identify how the An administrative program for FLEX to Not Started programmatic controls establish responsibilities, and testing &
will be met (p. 12) maintenance requirements will be implemented.
Sequence of Events (p. 9) Additional work will be performed during Not Started detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.
Portable Equip Phase 2 Complete an evaluation of the spent fuel pool Not Started (p.50) area for steam and condensation.
Installed Equip Phase I Evaluate the habitability conditions for the Started (p.47) Main Control Room and develop a strategy to maintain habitability.
Portable Equip Phase 2 (p.49)
Installed Equip Phase I Develop a procedure to prop open battery Stm1ed (p.47) room doors upon energizing the battery chargers to prevent a buildup of hydrogen in Portable Equip Phase 2 the battery rooms.
(p.50)
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Limerick Generating Station, Units 1 and 2 Month Status Report for the Implementation of FLEX February 2014 Item Number Interim Staff Evaluation Status Open Items I Confirmatory Actions Open Item 3.1.1.2.A NEI 12-06 states that if power is required to Future 6-month update move or deploy the equipment to open the door from a storage location), then power supplies should be provided as part of the deployment. The Integrated Plan did not address whether or not power would be required to move or deploy equipment. and thus this evaluation must be completed sati sfactod Iy.
Open Item 3.1.1.3.A The licensee did not address actions to be Future 6-month update taken if key instruments were lost due to a seismic event. as specified in NEl 12-06.
section 5.3.3. Verify that this activity is completed satisfactorily.
Open Item 3.1.2.2.A Further review is required regarding how the Complete with this licensee will address NEI 12-06 Section submittal The design basis 6.2.3.2 deployment considerations 2. 4, 5. and flood event at Limerick 8 with respect to transient floods. This review Generating Station is a shall include an applicable procedure review. transient flood due to a local intense precipitation.
This flood has been analyzed by the site using defined flood plains, as shown on drawing ESK-SK-C-0378. Sheet 3. Based on CUITent site analysis, flood levels during the local intense precipitation are at grade elevation in the southeast flood plains on site. Locations for the portable generators on site will be on the south side of the plant outside of the flood plains. Fuel for the generators will be from the diesel generator day tanks, located in the diesel enclosures, or the diesel generator main tanks.
located south of the reactor enclosure outside of the flood plains. All connection points for the generators will be in the Page 6 of I3
Limerick Generating Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28. 2014 emergency diesel generator rooms or in the reactor enclosure (entrances on south side of the plant).
Based on a review of the tlood design at Limerick Generating Station, all requirements from NEI 12-
- 06. Section 6.2.3.2 will be met for a transient tlood.
All material and supplies will be stored outside the required tlood plains for a local intense precipitation.
Electrical Connections are inside the diesel generator enclosure or the reactor enclosure. with entrances outside of the defined tlood plains. No temporary flood barriers are used at Limerick Generating Station for flooding. and therefore do not require protection.
Flexible pumps will be stored near the spray pond pump house with connections located in the spray pond pump house.
This area is one of the highest elevations of the site and therefore. is not a concern for the transient flood.
Open Item 3.2.3.A With regard to maintaining containment, the Future 6-month update implementation of Boiling Water Reactor Owners Group (BWROG) Emergency Procedure Guideline (EPG)/Severe Accident Guideline (SAG), Revision 3. including any associated plant-specific evaluations, must be completed in accordance with the provisions of NRC letter dated January 9, 2014.
Open Item 3.2.4.2.C With regard to elevated temperatures in Future 6-month update general, the licensee should provide an evaluation of the impact of elevated temperatures, as a result of loss of ventilation and/or cooling, on electrical equipment being Page 7 of 13
Limerick Generating Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 credited as part of the ELAP strategies (e.g.,
electrical equipment in the RCTC pump rooms).
Open Item 3.4.A The licensee should provide details that Future 6-month update demonstrate the minimum capabilities for offsite resources will be met. per NEI 12-06 Section 12.2.
Confirmatory Item With regard to offsite resources, confirm that Future 6-month update 3.1.1.4.A the licensee develops a plan that will address the logistics for equipment transportation, area set up, and other needs for ensuring the equipment and commodities to sustain the site's coping strategies.
Confirmatory Item The licensee stated that the design of the Future 6-month update 3.1.5.2.A storage facilities will include provisions to ensure the equipment storage facilities are not impacted by high temperatures. Confirm that this is evaluated appropriately.
Confirmatory Item Benchmarks must be identified and discussed Future 6-month update 3.2.1.1.A which demonstrate that Modular Accident Analysis Program (MAAP) is an appropriate code for the simulation of an ELAP event at LGS, consistent with the NRC endorsement of the industry position paper on MAAP.
Confirmatory Item Confirm that the collapsed reactor pressure Future 6-month update 3.2.1.l.B vessel level remains above Top of Active Fuel and the reactor coolant system cool down rate is within technical specifications limits.
Confirmatory Item Confirm that MAAP is used in accordance Future 6-month update 3.2. 1. I.C with Sections 4.1,4.2,4.3,4.4, and 4.5 of the June 2013 position paper.
Confirmatory Item Confirm that, in using MAAP, the licensee Future 6-month update 3.2.1.1.0 identifies and justifies the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1020236).
Confirmatory Item The licensee stated that the "times to complete Future 6-month update 3.2.1.3.A actions in the events timeline are based on .. ,
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Limerick Generating Station. Units I and Second Six Month Status Report for the Implementation of FLEX February 2014 current supporting analyse " Confirm that the final timeline is validated once detailed designs are completed and procedures are developed.
Confirmatory Item The licensee stated that the detailed design Future 6-month update
) A.A will determine containment heat-lip rate and the subsequent impacts on RCIC operation and the need for any modifications. Confirm that this evaluation is completed satisfactorily.
Confirmatory Item The licensee identified two RCIC room The "RCIC Equipment 3.2.] A.B switch set points that were above the Room Delta Temperature predicted maximum temperature but pointed High" setpoint of 109 of is out that the "RCIC Equipment Room Delta used for steam leak Temperature High" setpoint was below that detection in the RCIC room.
temperature at 109 oF. It is not clear whether Temperature Sensors for or not any of the setpoints would have an determining steam leak adverse impact on the planned use of the detection in the RCIC room RCIC as a mitigation strategy. Thus, further are located on the inlet and clarification is needed for this issue. outlet of the ventilation duct work in the RCIC room.
Under the ELAP conditions. ventilation is not available in the RCIC room due to loss of power.
The temperatures for steam leak detection will be approximately the same as no fresh air is pulled in through the duct work.
Therefore. the delta temperature in the room will not result in a loss of RCIC.
Limerick Generating Station EOPs already contain procedure guidance to bypass the RCIC steam leak detection isolations if required.
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Limerick Generating Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Confirmatory Item Because the Integrated Plan makes reference Future 6~month update 3.2.1.4.C to use of the Phase 3 equipment as backup, the Integrated Plan should address the guidance of NEI 12-06 regarding site procedures for Phase 3 implementation. The licensee addressed this coneern during the audit response and stated that LGS would ensure connection capabilities of the Phase 3 offsite equipment to site systems and would develop any procedural guidance required for those connections. Confirm that the connections for the Phase 3 equipment have been properly deteJmined. once the details are finalized.
Confirmatory Item The licensee stated that LGS plans to abide by Future 6-month update 3.2.1.7.A the generic resolution for refueling and cold shutdown conditions. The licensee stated that a review is in progress to develop a plan to address potential plant specific issues associated with implementing the generic approach. Confirm that this evaluation is completed satisfactorily.
Confirmatory Item The licensee stated that the final design of the Future 6-month update 3.2.1.8.A FLEX pump suction will determine if additional screens are required. Confirm that the potential for entrained debris as a result of extreme external hazards (e.g., suspended solids especially during flood conditions, or from high wind debris) in the cooling water from the spray pond is addressed.
Confirmatory Item Insufficient technical information is presented Future 6-month update 3.2.1.8.B or referenced in the Integrated Plan to confirm the ability of the portable FLEX pumps to deliver the required flow through the system of FLEX hoses. couplings, valves, elevation changes, etc. for the configurations described.
Confirm that these evaluations are completed and documented.
Confirmatory Item The licensee stated that formal calculations Future 6-month update 3.2.2.A will be performed to validate the timing required for supplying cooling water to the spent fuel pool. Confirm that these calculations are performed, with acceptable results.
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Limerick Generating Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 20 14 Confirmatory Item It was not clear from the information Future 6-month update 3.2.4.2.A presented in the Integrated Plan what analysis or technical basis was used to conclude that the battery room temperature rise is inconsequential. Also. no discussion was presented to address possible low temperature effects. Confirm the adequacy of the battery room ventilation to protect the batteries from the effects of elevated or lowered temperatures.
Confirmatory Item The licensee stated that battery room Future 6-month update 3.2.4.2.B venti lation will be addressed through procedure changes and that the proposed methods of ventilation, open doors and fans, will be confirmed during the detailed design process. Confirm that this is completed satisfactorily.
Confirmatory Item Confirm that the proposed communications Future 6-month update 3.2.4.4.A upgrades in the licensee's communications assessment are completed as planned.
Confirmatory Item The licensee stated that keys for access to the Future 6-month update 3.2.4.5.A plant are available to security, the shift manager and to the radiation protection group.
The licensee further stated that plant areas requiring access as part of the FLEX response. will be evaluated to determine if sufficient keys are available or if additional keys will be required. Confirm that this evaluation is completed.
Confirmatory Item According to the licensee. habitability Future 6 month update 3.2.4.6.A conditions will be evaluated and a strategy will be developed for the main control room.
Confirm that the strategy and associated support analyses are completed Confirmatory Item With regard to the fuel building habitability, Future 6-month update 3.2.4.6.B the licensee acknowledged that the evaluation of the spent fuel pool area for steam and condensation has not yet been performed.
Confirm that this evaluation is completed, and its resulting conclusions satisfactorily addressed.
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Limerick Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28. 2014 Confirmatory Item The Integrated Plan did not provide Future 6-month update
- I.2.4.8.A information regarding the technical basis for the seleetion and size of the FLEX generators to be used in support of the coping strategies.
Confirm that this evaluation is satisfactorily completed.
Confirmatory Item The licensee stated minimum limit for the dc The acceptance criteria for
- I.2.4.IO.B bus voltage is lOS volts. More information is the ELA P battery needed to understand if this minimum voltage evaluations is the same as provides for sufficient operating voltages at that used for design basis the device terminals to ensure proper events. Per the existing operation in support of the strategies. station Class I E Battery Load Duty Cycle calculation (LE-00S2), the station Class IE 12S12S0 VDC minimum acceptable battery voltage is IOSl2lOVDC. This voltage value is used to ensure that MCC voltage used for determining component operability (MOVs) will be maintained.
Confirmatory Item Although the licensee addressed the potential Future 6-month update
- I.2.4.10.C adverse impact from load shedding on main generator hydrogen control, the Iieensee needs to address any other potential adverse impacts to mitigation strategies resulting from the load shed plan.
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 SUpp011 the updates to the Overall Integrated Plan described in this enclosure.
I. Limerick Generating Station Units 1 and 2. "Overall Integrated Plan in Response to Mareh 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 (RS-13-022).
- 2. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.
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Limerick Generating Station, Units 1 and 2 Second Six Month Status RepOlt for the Implementation of FLEX February 28, 2014
- 3. NRC Order EA-13-1 09, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013.
- 4. Limerick Generating Station Units I and 2, "First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)." Dated August 28, 2013 (RIS13-123).
- 5. Limerick Generating Station Units I and 2, "Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies)" dated January 10, 2014.