Text

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)
	ML14069A318
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	02/27/2014
From:	Korsnick M; Constellation Energy Nuclear Group, EDF Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049
	Download: ML14069A318 (84)
	v • d • e

ilhary G. Korsnick Office 410-470-5133 Acting Chief Executive Officer Fa~t 443-213-6739 Chief Nuclear Officer E-mail: iVMaria.(,orsnick@cengllc.com CENG a joint venture of Constellatio Enry 4-#'eDF February 27, 2014 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

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 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-4 10 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)

REFERENCE:

(a) 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)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference a) to Constellation Energy Nuclear Group, LLC (CENG) for Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) , R.E. Ginna Nuclear Power Plant, LLC (Ginna), and Nine Mile Point Nuclear Station, LLC, (NMPNS) Units 1 (NMP1) and 2 (NMP2). Reference (a) requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Attachments (1) through (4) provide the 6-Month Status Reports for CCNPP, Ginna, NMPI, and NMP2, respectively. These reports update 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.

This letter contains no new regulatory commitments.

Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 200C, Baltimore, MD 21202

Document Control Desk February 27, 2014 Page 2 If there are any questions regarding this submittal, please contact Bruce Montgomery, Manager-Nuclear Safety and Security, at 443-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 27, 2014.

Sincerely, Mary G. Korsnick MGK/STD/EMT/bjd Attachments: (1) CCNPP 6-Month Status Report (February 2014) for Mitigation Strategies for Beyond-Design-Basis External Events (2) Ginna 6-Month Status Report (February 2014) for Mitigation Strategies for Beyond-Design-Basis External Events (3) NMP1 6-Month Status Report (February 2014) for Mitigation Strategies for Beyond-Design-Basis External Events (4) NMP2 6-Month Status Report (February 2014) for Mitigation Strategies for Beyond-Design-Basis External Events cc: NRC Project Manager, Calvert Cliffs Resident Inspector, Calvert Cliffs NRC Project Manager, Ginna Resident Inspector, Ginna NRC Project Manager, Nine Mile Point Resident Inspector, Nine Mile Point W. M. Dean, NRC S. Gray, DNR J. A. Kratchman, NRC

ATTACHMENT (1)

CCNPP 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Constellation Energy Nuclear Group, LLC February 27, 2014

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 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 OIP 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.

Since the submittal of the last status report in August 2013 (Reference 6), CCNPP FLEX has progressed with engineering analysis and calculations 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. Procurement of debris removal and FLEX Phase 2 equipment is progressing. Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued with an onsite review of the CCNPP local staging area, primary and alternate delivery routes, delivery methods to the proposed onsite laydown areas, and initiation of the SAFER Response Plan (Playbook) preparation.

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 CENG will provide clarifying or additional information in six-month status reports in order for the NRC to determine that the issues are on a path to satisfactory resolution.

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

and are current as of January 17, 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. (8/2013).

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 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 OIP Milestones Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Started U-2: October 2013 Commence Engineering and November 2013 Design U-I: October 2014 Commence Procurement of EupetJune 2015 Started U-2: January 2015 Equipment U-i: January 2016 Commence Installation of EquipmentEupetMarch 2016 Not Started 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 May 2014 Submit 6-Month Status Report February 2014 Complete Page 2 of 21

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 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 Complete Engineering and March 2014 Started U-2: August 2014 Design U-I: June 2015 Create Maintenance and June 2014 Not Started December 2014 Testing Procedures Submit 6-Month Status Report August 2014 Not Started Procedure Changes Training September2014 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 Not Started U-2: January 2015 Guidelines (FSG) U-i: January 2016 Unit 2 Modification Implementation Outage

April 2015 Not Started March 2015 Unit 2: March Walk-throughs or 2015 Not Started Demonstrations Unit 1: March 2016 U-2: April 2014 June 2015 Not Started Implement Training U-I: April 2015 Submit 6-Month Status Report August 2015 Not Started Complete Procurement of U-2: September Equipment 2014 August 2015 Not Started U-I: September 2015 Submit 6-Month Status Report February 2016 Not Started Unit 1 Modification Unt MdiictonApil206Not Started March 2016 Implementation Outage* April 2016 Submit 6-Month Status Report August 2016 Not Started Page 3 of 21

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 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 Full compliance with EA November 2016 Not Started 049 is achieved Submit Completion Report December 2016 Not Started

(Full compliance after second listed refueling outage) 4 Changes to Compliance Method Changes were made to the information provided in the O1P that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5).

The following is a list of the open items from the OIP or the NRC's ISE that have been added, deleted or completed, and of coping strategies that have been changed from the last six month status report with an explanation of the changes:

A. OIP Open Items

1. General Integrated Plan Elements Pressurized Water Reactor (PWR)

Open Item 10: Determine the location of the CCNPP local staging area, primary and alternate delivery routes, and delivery methods to the proposed onsite laydown areas.

This open item is complete. On December 3 and 4, 2013, a team from the SAFER visited CCNPP as part of their rehearsal of concept support to utilities. The SAFER team visited the location of the CCNPP local staging area, primary and alternate delivery routes, and delivery methods to the proposed onsite laydown areas. No issues were found with the proposed location, delivery routes, and delivery methods.

2. General Integrated Plan Elements Pressurized Water Reactor (PWR)

Open Item 12: Define criteria for the local staging area by June 2013.

This open item is complete. SAFER defined the criteria for local staging area in RRC-01, SAFER Response Plan, Rev. 01 Chapters 5 and 8.

3. General Integrated Plan Elements Pressurized Water Reactor (PWR)

Open Item 13: Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site.

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CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS This open item is complete. The following staging areas for portable FLEX equipment to be delivered from the [Regional Response Center] RRC to CCNPP were selected:

a. West Road at CCNPP

b. Owner Controlled Area parking lot

c. Walmart Parking Lot in Dunkirk, Maryland

d. Baltimore-Washington International (BWI) Airport

4. Maintaining Core Cooling, PWR Installed Equipment Phase 1 Open Item 18: Perform engineering analyses to confirm that CCNPP maintains an adequate level of Shutdown Margin (SDM) for a [Reactor Coolant System[ RCS cooldown to 350'F, to cover a period of at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This open item is complete. The analyses show that the cycle-independent established time for which a cooldown to 325°F could be performed without boration while maintaining reactivity more negative than -1000 pcm (per cent mille) is 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months following reactor trip. Beyond 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months , boration is required in order to provide confidence that the reactor remains shut down by more than 1000 pcm.

5. Maintaining Core Cooling, PWR Installed Equipment Phase 1 Open Item 22: Implement a design change to install reliable local level indicators on all of the water storage tanks located in the 11, 12 and 21 [Condensate storage tank] CSTs, 11

[Demineralized water storage tank] DWST, and 11 and 12 [Pretreated water storage tank]

PWSTs.

This open item was deleted. A design change will no longer be implemented. A hand-held thermographic measurement instrument will be used to measure the water levels in the tanks.

6. Maintaining Core Cooling, PWR Installed Equipment Phase 2 Open Item 29: Perform an analysis to determine that there is sufficient decay heat generated for [Turbine Driven Auxiliary Feedwater] TDAFW operation 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after shutdown.

This open item is complete. The analysis concluded that there is sufficient decay heat to support 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of operation.

7. Maintaining Core Cooling, PWR Installed Equipment Phase 2 Open Item 32: Install a design change to add makeup and pump suction hose connections for FLEX pump connection to 12 CST.

This open item was deleted. Instead of the previously proposed design change, a tool consisting of a specifically designed hose bonnet with "T" isolation valves and hose connections will be installed in place of the 12 CST demineralized water makeup line check valve bonnet when needed. The check valve is located adjacent to the tank inside the concrete enclosure. The tool will be stored in the enclosure.

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CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

8. Maintaining Core Cooling, PWR Installed Equipment Phase 2 Open Item 35: Install design change to add 4" hose connections to the Reactor Coolant Waste Receiver Tanks (RCWRTs) and Reactor Coolant Waste Monitor Tanks (RCWMTs).

This open item was deleted. There are several sources of cooling water available at CCNPP that can be used during an ELAP. It is therefore not cost-beneficial to modify the Reactor Coolant Waste Receiver Tanks (RCWRTs) and RCWMTs by adding hose connections in order to increase an already large number of cooling water sources.

9. Maintaining Core Cooling, PWR Portable Equipment Phase 3 Open Item 48: Provide modified 4160 VAC breakers for direct RRC [Diesel generator] DG connection for use in place of the normal 4160 VAC breakers in service for [Low Pressure Safety Injection] LPSI Pump and ISaltwater] SW Pump power supplies.

This open item was deleted. No physical modification to 4160 VAC breakers will be required.

The connections will utilize existing Class IE 4160 VAC equipment.

10. Maintaining Containment, PWR Installed Equipment Phase 3 Open Item 54: Install hose connections on the Service Water (SRW) supply and return lines to the IContainment Air Cooler] CAC for connection to a RRC portable heat exchanger.

This open item was deleted. The Containment Pressure and Temperature Response Evaluation concluded that containment cooling will not be needed in Phase 3. Additionally, a Phase 3 modification to the SW Cooling Systems on Units 1 and 2 will be implemented for a modified 36" diameter pipe header flange with RRC large flow, low pressure hose connection to be available in Phase 3 for restoration of one header of SW cooling system per unit such that service water (SRW) cooling can be restored for cooling to the CAC System.

11. Safety Functions Support, PWR Installed Equipment Phase 1 Open Item 69: Investigate changing Appendix R lighting batteries to a longer life battery or new battery technology to lengthen the duration of lighting available in vital areas of the plant.

This open item was deleted. On-shift individuals and members of the Emergency Response Organization will be issued hardhat mounted lights ("miners" lights). Therefore, there is no longer a need to investigate changing Appendix R lighting batteries.

12. Safety Functions Support, PWR Installed Equipment Phase 1 Open Item 72: Procure six (6) portable diesel generator powered exterior lighting units with 30 [foot] ft. masts and a minimum 400,000 lumens.

This open item is complete. The portable diesel generator-powered exterior lighting units have been purchased and are at CCNPP.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

13. Safety Functions Support, PWR Installed Equipment Phase I Open Item 73: Change Appendix R lighting from incandescent to LED to lengthen the duration of lighting available in vital areas of the plant.

This open item was deleted. On-shift individuals and members of the Emergency Response Organization will be provided with hardhat mounted lights ("miners" lights). Therefore, there is no longer a need to change Appendix R lighting from incandescent to LED.

14. Safety Functions Support, PWR Installed Equipment Phase 1 Open Item 77: Purchase one wheeled and one tracked vehicle with bucket/blade and grapple of sufficient size and load handling capacity to remove debris.

This open item is complete. Two frontloaders (Bobcats), one wheeled and one tracked vehicle with bucket/blade and grapple of sufficient size and load handling capacity to remove debris were purchased.

15. Safety Functions Support, PWR Installed Equipment Phase 3 Open Item 93: Install connection points on Class IE 4KV Buses for the RRC 4KV portable DG.

This open item was deleted. A procedure will be developed for connecting the 4160 VAC RRC DG to Class IE 4160VAC buses.

B. ISE Open Items and Confirmatory Items

1. ISE Confirmatory Item 3.2.1.2.A - The [Reactor Coolant Pump] 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 [Pressurized-Water Reactor Owner's Group] PWROG white paper addressing the RCP seal leakage for [Combustion Engineering] CE plants. If the RCP seal leakage rate 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.

This item is complete. The modeling of a 15 gpm per RCP leakage rate represents an upper bound expectation for the ELAP event. Each controlled bleed-off (CBO) line from the RCPs has a flow limiting check valve set to actuate at a flow rate of 10 to 15 gpm. Therefore, by assuming 15 gpm through each check valve, the maximum RCP seal leakage flow is assumed.

Additionally, this combined flow of 60 gpm must pass through the common CBO line. It is conservatively assumed that there has been no isolation of the CBO in the PWROG analysis, which is in line with the fact that CCNPP does not have the capability to isolate CBO.

2. ISE Confirmatory Item 3.2.1.9.D - The licensee provided an open item, to perform engineering analysis to determine that there is sufficient decay heat generated for TDAFW operation 36-hours after shutdown and that the TDAFW pumps can operate reliably provided there is greater than 65 [pounds per square inch - absolute] psia steam pressure in one of the [Steam Generators (S/Gs)].

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS This item is complete. The analysis concluded that there is sufficient decay heat to support 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of operation.

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. Explanations for added, deleted and completed items are provided in Section 4.

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.

Table 2 Status of CCNPP FLEX OIP Open Items CCNPP OIP Open Items Status

1. Add margin to design FLEX components and hard connection points to address future requirements as re-evaluation warrants. Portable FLEX components will be procured Started (2/2014) commercially

2. Implement a design change to install permanent protected FLEX equipment connection Started (2/2014) points

3. Evaluate deployment strategies and deployment routes to ensure they are assessed for and Started (2/2014) address applicable hazards impact.

4. Develop a process for implementation of exceptions for the site security plan or other (license/site specific - 10CFR50.54X) requirements of a nature requiring NRC approval will Not Started be communicated in a future 6 month update following identification.)

5. Define implementation routes upon finalizing a location or locations for FLEX equipment Started (8/2013) storage location(s).

6. Evaluate requirements, options, and develop strategies to provide reasonably protected Started (8/2013) storage on site for the FLEX portable equipment.

7. Design and build a protected storage location or locations for the FLEX equipment. Ensure Started (8/2013) the design meets the requirements of NEI 12-06.

8. Identify analysis needed to develop or support mitigating strategies. Started (8/2013)

9. Provide an administrative program governing the FLEX deployment strategy, marking of setup locations, including primary and alternate pathways, maintaining the pathways clear, Not Started and clearing the pathways.

10. Determine the location of the CCNPP local staging area, primary and alternate delivery Complete (2/2014) routes, and delivery methods to the proposed onsite laydown areas.

11. Determine schedule for when RRCs will be fully operational. Complete (8/2013)

12. Define criteria for the local staging area by June 2013. Complete (2/2014)

13. Establish a suitable local staging area for portable FLEX equipment to be delivered from the Complete (2/2014)

RRC to the site. I Page 8 of 21

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CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

14. Develop site specific SAFER Response Plan (playbook) for delivery of portable FLEX Started (2/2014) equipment from the RRC to the site.

15. Implement a design change to replace the 1 ft. diameter wheel with a 3 ft. wheel on each Started (2/2014)

Atmospheric Dump Valve (ADV) chain operator.

16. Evaluate the feasibility of the WCAP-17601 -P recommendation to install a remotely operated Deleted (8/2013)

RCP CBO return line isolation valve.

17. Develop a procedure or FSG to perform an early cooldown and depressurization as Started (8/2013) recommended by WCAP- 17601 -P.

18. Perform engineering analyses to confirm that CCNPP maintains an adequate level of Shutdown Margin (SDM) for an RCS cooldown to 350'F, to cover a period of at least 72 Complete (2/2014) hours.

19. Implement a design change to re-power the [Safety Injection Tank] SIT level and pressure Started (2/2014) indicators from a vital 120 VAC instrument bus.

20. Implement a design change to install new leak-tight SIT vent Solenoid Valves (SV) that will Deleted (8/2013) allow the vent line pipe caps to remain off.

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 headers. Started (2/2014)

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.

22. Implement a design change to install reliable local level indicators on all of the water storage Deleted (2/2014) tanks located in the 11, 12 and 21 CSTs, 11 DWST, and 11 and 12 PWSTs.

23. Perform an analysis to determine the necessary scope of the DC load shedding strategy. Started (2/2014)

24. Implement a design change to clearly identify the set of DC load breakers that will either be left energized or load shed by identifying the selected breakers by their unique numbers and Started (2/2014) load title.

25. Implement a procedure or FSG to perform the DC load shedding. Started (8/2013)

26. Complete a time-motion study to validate that DC load shedding can be accomplished on Not Started each unit in one (1) hour.

27. Implement a design change to install an 8-hour Uninterruptible Power Supply (UPS) on the Started (2/2014)

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 RCS conditions, following an ELAP. The Started (2/2014) analysis should determine the FLEX pump capacity needed to provide adequate flow in all RCS conditions.

29. Perform an analysis to determine that there is sufficient decay heat generated for TDAFW Complete (2/2014) operation 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after shutdown.

30. Implement a design change to provide dedicated hose connections and piping to the Safety Injection System. Started (2/2014)

31. Develop a procedure or FSG to mimic the AFW makeup strategy described in ERPIP-61 1, Started (8/2013)

Attachment 1.

32. connection Install a design to 12change CST. to add makeup and pump suction hose connections for FLEX pump Deleted (2/2014)

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CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

33. Install a design change to replace the 2-V2 inch hose connections with 4 inch hose Deleted (8/2013) connections at 11 and 21 CSTs, 11 DWST, and 11 and 12 PWSTs.

34. Install a design change to add hose connections at 11 and 21 Refueling Water Storage Tanks Started (2/2014)

(RWT) for makeup and suction for the FLEX pumps.

35. Install design change to add 4" hose connections to the Reactor Coolant Waste Receiver Deleted (2/2014)

Tanks (RCWRTs) and Reactor Coolant Waste Monitor Tanks (RCWMTs).

36. Perform an analysis to determine the survivability of the wells as a long-term source of make-up water. Analysis should include any modifications needed to improve the Started (2/2014) 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 effect on the S/Gs from use of water from the Started (2/2014)

[Ultimate Heat Sink] UHS as a cooling medium.

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

Analysis should consider battery age, battery performance without battery room ventilation, Started (2/2014) and load and load duration prior to completion of DC load shedding.

39. Track the completion of ECP-I 1-000293 and -000294, the Reserve Battery distribution Started (8/2013) system modification that is currently in progress.

40. Develop and implement procedures to supply power to critical instrumentation using primary Started (8/2013) and alternate methods.

41. Perform an analysis to determine that the assumed load capacity of the FLEX 480 VAC DG Started (2/2014) 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 train 480 VAC load centers on each unit to provide power to the battery chargers and Started (2/2014) other critical AC equipment.

43. Implement a design change to provide direct connection of a portable 100 kW diesel generator to reactor [Motor Control Centers] MCCs 104 or 114 and 204 or 214 to provide power to the inverter backup bus (which can power the 120VAC vital bus), the SIT Outlet Started (2/2014)

[Motor Operated Valves] MOVs, and the AFW Pump Room Vent Fans.

44. Implement a design change to install connection points, conduit, cabling, and transfer switches locally at battery chargers to provide for direct connection from the FLEX 480 VAC Deleted (8/2013)

DGs.

45. Perform an analysis to determine the feasibility of the S/G "batch" feeding strategy. Not Started

46. Implement a procedure to connect a 4160 VAC RRC DG to either of the A or B Train 1E Started (2/2014) 4160 VAC Buses on each unit to provide power for Phase 3.

47. Develop procedures or FSGs for repower vital 4160 VAC Class IE buses from RRC FLEX Not Started 4KV DGs.

48. Provide modified 4160 VAC breakers for direct RRC DG connection for use in place of the Deleted (2/2014) normal 4160 VAC breakers in service for LPSI Pump and SW Pump power supplies.

49. Implement a design change to power containment dome and reactor cavity temperatures Started (2/2014) instrumentation from a vital 120 VAC instrument bus.

50. Perform an analysis to determine containment temperature and pressure response over a period 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 Complete (8/2013) restoration of containment air cooling.

51. Implement a design change to install a hose connection on the A-Train and B-Train Deleted (8/2013)

[Containment Spray] CS headers in the Auxiliary Building. Deleted_(8/2013)

52. Purchase additional special check valve bonnets and store them inside each [Emergency Core Not Started Cooling System] ECCS Pump Room.

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CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

53. Perform an analysis to determine the feasibility of providing Containment cooling with CAC Deleted (8/2013)

Units using an alternate cooling water strategy.

54. Install hose connections on the Service Water (SRW) supply and return lines to the CAC for Deleted (2/2014 connection to a RRC portable heat exchanger. De )

55. Implement a design change to install reliable wide range spent fuel pool (SFP) level Started (8/2013) instrumentation in accordance with NRC Order EA- 12-051.

56. Implement a design change to provide a 6" hose connection to each RWT. Started (2/2014)

57. Implement a design change to provide dedicated hose connections to the SFP Cooling Started (2/2014) system.

58. Develop and implement procedures or FSGs that include the SFP Cooling FLEX makeup Started (8/2013) flow path.

59. Develop procedures or FSGs that mimic the ERPIP-612 sections for SFP makeup and SFP Started (8/2013) spray.

60. Implement a design change to install reliable wide range SFP fuel pool level instrumentation (Duplicate item) in accordance with NRC Order EA- 12-051 See Item # 55

61. Perform an analysis to determine the Control Room temperature response over a period of 72 Started (2/2014) hours.

62. Perform an analysis to confirm that TDAFW Pump room air temperature remains below Complete (8/2013) 130'F over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of pump operation.

63. Develop primary and alternate strategies for ventilating the TDAFW Pump Room. Complete (8/2013)

64. Perform an analysis to confirm the [Probable Maximum Precipitation] PMP event maximum Complete (8/2013) flood height will not impact the operation of TDAFW or preclude access to the room.

65. Perform an analysis to determine the possible effects of Beyond Design Basis External Events (BDBEEs) on the Turbine Building structure and the potential effect on access to the Started (2/2014)

TDAFW Pump Room.

66. Develop an alternate access strategy for access into the TDAFW Pump Room. Started (8/2013)

67. Perform an analysis to determine the temperature profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area around Started (2/2014)

ADV enclosures.

68. Perform an analysis to determine the Cable Spreading Room temperature response over a Started (2/2014) period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

69. Investigate changing Appendix R lighting batteries to a longer life battery or new battery Deleted (2/2014) technology to lengthen the duration of lighting available in vital areas of the plant.

70. Procure battery operated hardhat mounted lights ("miners" lights) for on-shift and Not Started Emergency Response Organization (ERO) personnel.

71. Procure a sufficient quantity of hand-held battery operated lanterns for on-shift and ERO Not Started personnel.

72. Procure six (6) portable diesel generator powered exterior lighting units with 30 ft. masts and Complete (2/2014) a minimum 400,000 lumens.

73. Change Appendix R lighting from incandescent to LED to lengthen the duration of lighting Deleted (2/2014) available in vital areas of the plant.

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 operation, for the Plant Public Address system. This includes backup power for the Started (2/2014) individual building speaker network amplifiers.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

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 of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months operation for the system and Started (2/2014) 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 and antennas protected from seismic, wind, Started (2/2014) and wind-driven missiles, including back-up power 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 with bucket/blade and grapple of sufficient Complete (2/2014) size and load handling capacity to remove debris.

78. Purchase the portable equipment needed to outfit CCNPP Fire Engine 171 for debris Deleted (8/2013) removal.

79. Implement a design change to install a protected alternate means 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 / strained and how the resulting debris will effect core cooling.

80. Develop strategies for use of the Control Room and Cable Spreading Room Appendix R Started (2/2014)

Ventilation System during an ELAP.

81. Perform an analysis to evaluate hydrogen buildup in the battery rooms during charging and Not Started the long term room temperature profiles. NotStarted

82. Perform an analysis to determine the Switchgear Room temperature response under the above scenario and assuming various 480 VAC load center and 4160 VAC bus loadings over Started (2/2014) a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

83. Perform an analysis to verify the above strategy will provide sufficient air flow to vent steam Started (2/2014) from the SFP Area.

84. Evaluate the cost of draining 21 Fuel Oil Storage Tank (FOST) and IA DG FOST and Started (2/2014) refilling with ultra low sulfur (<15 ppm) diesel fuel oil.

85. Implement a design change to install dedicated FLEX hose connections on 21 FOST, IA DG Not Started FOST, and the IB, 2A, and 2B DG fuel oil Y-strainers.

86. Provide a permanent, fully protected diesel FOST for refueling the FLEX diesel-driven Not Started equipment.

87. Perform an analysis of the fuel consumption rate 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 to determine a conservative refueling Started (2/2014) interval.

88. Develop strategies to reduce the transport time for fuel oil loading and delivery. Started (8/2013)

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 Not Started independent of offsite support.

90. Provide a procedure governing the maintenance and distribution of the consumables that will Not Started 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 independent of offsite support.

91. Develop a strategy to protect onsite consumables for use after a BDBEE. Not Started

92. Develop equipment operating procedures or FSGs, considering vendor technical manual operating procedures, for each of the pieces of portable FLEX equipment that will be Not Started procured.

93. Install connection points on Class IE 4KV Buses for the RRC 4KV portable DG. Deleted (2/2014)

94. Develop procedures or FSG for each of the RRC based strategies and for operation of the Not Started equipment provided by the RRC.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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 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 Not Started submitted, and the licensee should confirm 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 plan for analysis for core and containment cooling is still under development and CENG will identify additional analysis to support the mitigating strategies. The subjects of the analyses are: maintaining core cooling (e.g., confirm shutdown margin during cooldown, DC load shedding, and adequate steam pressure for TDAFW pump operation), containment temperature and Started (2/14) pressure response for containment cooling, and various safety functions regarding ventilation and cooling systems (e.g., for the main control room, TDAFW pump room, cable spreading room, battery rooms, switchgear rooms and the SFP area). Review of these analyses is needed to confirm acceptability of the mitigating strategies.

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 approach regarding boric acid mixing discussed in Section 3.2.1.8 of this report; Started (2/2014) however, the 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 8 of the Integrated Plan, the licensee specified that Phase 2 FLEX components will be stored at the site in a location or locations such that they are reasonably protected and that no one external event can reasonably fail the site FLEX capability. Provision will be made for multiple sets of Started (2/2014) portable on-site equipment stored in diverse locations or through storage in structures designed to reasonably protect from applicable external events. FLEX equipment storage location(s) have not been selected.

2. ISE Confirmatory Item 3.1.1.1.B - The licensee will provide the specific protection Started (2/2014) requirements described in NEI 12-06 for the 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 all hazards. The licensee will develop a playbook which will provide the detail Started (2/2014) 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.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

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 impact. The second was to provide an administrative program governing the FLEX 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 remain Not Started viable for the flooded condition, and that the effects of the maximum storm surge or probable maximum hurricane should be considered in evaluating the adequacy of the baseline deployment strategies.

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 identified an open item to implement a design change to install a protected alternate Started (2/2014) means 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 resulting debris will affect core cooling.

7. ISE Confirmatory Item 3.1.3.2.A - The licensee specified that CCNPP currently has a varied array of wheeled vehicles, e.g., forklifts, small tractors, and a backhoe, that Started (2/2014) could be used for debris removal. However, the licensee did not specify if this equipment would be protected from high wind and other hazards.

8. ISE Confirmatory Item 3.1.4.2.A - The licensee did not address procurement requirements to ensure that the FLEX equipment can be operated in extreme hot or Started (2/2014) cold temperature environments or how hot or cold temperatures will affect manual actions.

9. ISE Confirmatory Item 3.1.4.2.B - Deployment of FLEX equipment has not been addressed for conditions of snow, ice and extreme cold. The current screening omits a Started (2/2014) discussion of deployment of FLEX equipment for hazards due to ice blockage or formation of frazil ice on the UHS.

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 leakagerate for the ELAP event discussed in the PWROG white paper addressing the RCP seal Complete (2/2014) leakage for CE plants. If the RCP seal leakage rate 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 licensee has not provided sufficient analyses to confirm instruments are reliable and accurate in the containment harsh conditions Started (2/2014) with high moisture levels, temperature and pressure during the ELAP event.

12. ISE Confirmatory Item 3.2.1.6.A - The following references used as basis for several sequence of events (SOE) Action Time constraints were not available for Started (2/2014) review: CCN0012-17-STUDY-001, and CCNPP FLEX Strategy Table Top.

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 Started (2/2014) any SOE changes that may result from ongoing evaluations for; RCP seal leakage, plant specific CENTS analysis, and any revised battery load shed analysis.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

14. ISE Confirmatory Item 3.2.1.7.A -The Generic Concern related to the shutdown and refueling modes, required clarification of CCNPP's approach to demonstrate that the Started strategies can be implemented in all modes. During the audit, the licensee informed (2/2014) the NRC of their plans to abide by this generic resolution. The implementation of these plans is identified as Confirmatory Item 3.2.1.7.A.

15. ISE Confirmatory Item 3.2.1.9.C - During the audit process, the licensee stated that it will provide revised analyses as detailed engineering evaluations are performed for Not Started each Phase 3 FLEX component and modification strategy.

16. ISE Confirmatory Item 3.2.1.9.D - The licensee provided an open item, to perform engineering analysis to determine that there is sufficient decay heat generated for Complete (2/2014)

TDAFW operation 36-hours after shutdown and that 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 licensee did not discuss the impacts of salt/brackish water on the structures and components of the SFP system, and the fuel.

During the audit process the licensee specified that they will perform an analysis to Started (2/2014) determine the effects of salt/brackish water on the structures and components (including instrumentation) of the SFP system and the stored fuel.

18. ISE Confirmatory Item 3.2.2.B - The licensee will perform an analysis to verify that the proposed strategy for SFP ventilation will provide sufficient air flow to vent steam Started (2/2014) from the SFP area, in order to determine whether natural air circulation is sufficient, or forced ventilation provided by FLEX equipment will be required.

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, the licensee provided a document Started (2/2014) entitled "CCNPP Containment Analysis" that was 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 - Charging Pump Room ventilation is provided by the non-safety related Auxiliary Building Supply and Exhaust Ventilation System. An Started (2/2014) evaluation will be performed to determine if the Charging Pumps can meet their mission time without room ventilation.

21. ISE Confirmatory Item 3.2.4.2.A - The licensee identified an open item to perform an analysis to determine the Control Room temperature response over a period of 72 Started (2/2014) hours.

22. ISE Confirmatory Item 3.2.4.2.B - The licensee identified an open item to develop strategies for use of the Control Room and Cable Spreading Room Appendix R Started (2/2014)

Ventilation System during an ELAP.

23. ISE Confirmatory Item 3.2.4.2.C - The licensee identified an open item to perform Not Started an analysis to evaluate hydrogen buildup in the battery rooms during charging and room temperature profiles.

24. ISE Confirmatory Item 3.2.4.2.D - The licensee identified an open item to perform an analysis to determine the Switchgear Room temperature response following the reenergizing of buses and assuming various 480 VAC load center and 4160 VAC bus loadings over a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

25. ISE Confirmatory Item 3.2.4.2.E - The West Electrical Penetration Rooms will begin to heat up after the Reactor motor control centers (MCC) are re-energized from Started (2/2014) the FLEX 480 VAC DGs, therefore, they will need to be evaluated for limiting temperatures for equipment survivability.

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 changing Appendix R lighting batteries to a longer life battery or new battery technology to lengthen the duration of lighting available in vital areas of the plant, 2) procure battery operated hardhat mounted lights

("miners" lights) for on-shift and emergency response organization (ERO) personnel, Started (2/2014)

3) to procure a sufficient quantity of hand-held battery operated hardhat lanterns for on-shift and ERO personnel, 4) to procure six (6) portable diesel generator powered exterior lighting units with 30 ft. masts and a minimum 400,000 lumens, and 5) to change Appendix 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 communications is reasonable, and the analyzed existing systems, proposed Started (2/2014) enhancements, and interim measures will help to ensure that communications are maintained. Confirmation that upgrades to the 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 Not Started the primary and alternate access points NotStarted

29. ISE Confirmatory Item 3.2.4.6.A - The licensee has identified an open item to perform an analysis to determine the temperature profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area Started (2/2014) around the Atmospheric Dump Valve enclosures.

30. ISE Confirmatory Item 3.2.4.6.B - The licensee identified an open item to perform an analysis to determine the Cable Spreading Room temperature response over a Started (2/2014) period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

31. ISE Confirmatory Item 3.2.4.6.C - The licensee identified two open items to perform an analysis to determine the possible effects of BDBEE on the Turbine Building structure and the potential effect on access to the TDAFW Pump Room, and to develop an alternate access strategy for access into the TDAFW Pump Room.

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 Started (2/2014) protective devices as specified in AREVA document 51-9199717-000. An evaluation will be performed to verify the internal protection is adequate to protect the lE buses.

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 480 VAC Load Center on that unit.

The 480VAC/125KVA diesel generators are intended as an alternate strategy to Started (2/2014) connect to one of two vital reactor MCCs on each unit. The supplied reactor MCC can be cross-connected to the redundant train reactor MCC on that unit. An evaluation to validate the intended use of these diesel generators is pending.

33. 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 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 Not Started refueling interval, and to develop strategies to reduce the transport time for fuel oil loading and delivery.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

34. 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 load shed by identifying the selected I Started (2/2014) breakers by their unique numbers and load title; to implement a procedure or FSG to perform the [DC} load shedding; and to complete a time-motion study to validate that DC load shedding can be accomplished on each unit in one hour.

35. ISE Confirmatory Item 3.2.4.10.B - Maintenance of vital 125 VDC power will include aligning the Reserve Battery to one of the four vital 125 VDC buses via bus work and disconnects that are currently being installed under an existing plant modification. This action will extend the coping time for one vital 125 VDC bus to Started (2/2014) greater than 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . The licensee needs to provide a copy of the analysis/calculations which shows aligning the Reserve Battery to one of the four 125VDC buses can extend the coping time for one vital 125 VDC bus to greater than 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months .

36. 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 12.2, with regard to the capability to obtain equipment and commodities to sustain and backup the site's Not Started 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.

Page 17 of 21

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

1. Determine the status of existing fixed satellite phone system and antennas in terms of suitability of being "reasonably protected."

2. Install additional antennas as necessary to support the use of fixed satellite 8/31/2014 Not Started phones at all locations.

North Service Building and Switchyard House

1. Determine whether or not the North Service Building (NSB) and Switchyard 12/31/2013 Complete (2/2014)

House are "reasonably protected."

Portable Satellite Phones

1. Stage satellite phones Complete (8/2013)

2. Stage batteries and chargers in the 10/31/2013 Complete (2/2014) applicable ERO Facilities.

3. Update work instructions for portable 10/31/2013 Complete (2/2014) satellite phone inventory.

4. Develop/update preventive maintenance and testing procedures for portable 12/31/2013 Complete (2/2014) satellite phones, batteries and chargers.

5. Include information on portable satellite phone locations and usage in procedures.

6. Procure and install a high power UPS or 12/31/2014 Started similar modification providing backup power for the battery chargers for portable satellite phones.

Fixed Satellite Phones

1. Procure and install fixed satellite phones, additional antennas and uninterruptable power supplies for the Technical Support Center 12/31/2014 Not Started (TSC)/Operations Support Center (OSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC).

2. Update work instructions for fixed Complete (8/2013) satellite phone inventory

3. Develop/update preventive maintenance Complete (8/2013) and testing procedures for fixed satellite phones.

Page 18 of 21

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

4. Include information on fixed satellite Complete (8/2013) phone locations and usage in procedures.

5. Determine the acceptability of the backup UPS in its present location. 8/31/2014 Not Started Relocate higher, if necessary.

6. Provide instructions for use at every Complete (8/2013) fixed satellite phone location. Complete_(8/2013)

Communication with ORO Facilities

1. Provide each Offsite Response Organization (ORO) identified in Section 4.0 of the Communications 10/31/2013 Complete (2/2014)

Assessment with instructions for proper storage and rotation of satellite phone batteries.

Portable Generators

1. Develop portable generator fueling plan to ensure ability to provide power for a 8/31/2015 Complete (2/2014) minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Develop procedures to maintain and test Complete (2/2014) the portable generators. 12/31/2013

3. Update work instructions to inventory Complete (2/2014) portable generators and ensure adequate 12/31/2013 volume of fuel.

4. Develop preventive maintenance Complete (2/2014) procedure for portable generators fuel 12/31/2013 supply.

5. Procure additional generators as Started required to support FLEX and 6/30/2014 communications strategies.

6. Determine a process for relocating Not Started portable generators to the appropriate Startup 2015 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 Not Started attain battery backed operation in the event of a loss of all AC power at the site.

Page 19 of 21

ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 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 Actions Completion Status Completion Date Date

2. Revise ERPIP 3.0, Immediate Actions, to provide guidance to the Shift Manager on how to implement back-up site 12/31/2013 Complete (2/2014) announcements if the Site Paging system is not functional.

3. Revise ERPIP 750, Security, to provide specific guidance on how to execute the 12/31/2013 Complete (2/2014) public address announcements if the plant paging system is not functional.

4. Revise ERPIP-B. 1, Equipment Checklist, to add necessary bull horns to 12/31/2013 Complete (2/2014) support back-up method for site announcements.

Training

1. Evaluate training needs specific to the use of, portable and fixed satellite phones, radios and implementation of 11/30/2014 Not Started back-up methods for site announcements during an extended loss of AC power event.

2. Develop and implement training on the Startup 2015 Not Started 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 battery life and purchase additional batteries as necessary based on an 10/31/2013 Started (8/2013) December 2014 estimate of minimum talk time to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation.

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.

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.

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ATTACHMENT (1)

CCNPP SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

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.

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ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Constellation Energy Nuclear Group, LLC February 27, 2014

ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The R.E. Ginna Nuclear Power Plant, LLC (Ginna) 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 Ginna OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment 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 associated basis (if applicable).

Ginna 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 Ginna'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.

Since submittal of the last status report in August 2013 (Reference 5), Ginna FLEX strategy implementation has progressed with some engineering analysis and calculations that support the mitigation strategies and the modification concepts have been refined. As a result of the 10 CFR Part 21 report regarding the Westinghouse low leakage Reactor Coolant Pump (RCP) seals, Ginna no longer intends to utilize low leakage RCP seals for its beyond-design-basis external event mitigation strategies.

Ginna is currently working on its revised strategy that will account for the need for additional RCS borated makeup for RCS inventory control and to maintain subcriticality. The revised strategy will provide the basis for the assumed RCP seal leakage for the Model 93 RCPs which are installed at Ginna.

Ginna expects to have the related strategies determined for the August 2014 submittal.

Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued with review of proposed supporting equipment specifications and participation on committees that have been assembled to identify and provide specific needs.

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

and are current as of January 17, 2014.

0 Six month integrated plan progress report submitted 3Q2013 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the Ginna O1P (Attachment 1 - 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 following 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.

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 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 I Status of Ginna FLEX OIP Milestones Target Activity Revised Target Milestone Completion Status Completion Date Date Commence Engineering and Design July 2013 Started December 2014*

Commence Procurement of Equipment July 2013 Started September 2015*

Commence Installation of Equipment July 2013 Started November 2015*

Submit 6-Month Status Report August 2013 Complete Develop Strategies/Contract with the November 2013 Started March 2015 Regional Response Center (RRC)

Submit 6-Month Status Report February. 2014 Complete Complete Engineering and Design March 2014 Started December 2014

Create Maintenance and Testing Procedures June 2014 Started December 2014

Submit 6-Month Status Report August. 2014 Not Started Procedure Changes Training Material September. 2014 Not Started March 2015 Complete Develop Training Plan November 2014 Not Started Submit 6-Month Status Report February 2015 Not Started Issue FLEX Support Guidelines April. 2015 Not Started November 2015

Perform Walk-throughs or Demonstrations May 2015 Not Started Provide onsite and augmented staffing assessment considering functions related to May 2015 Not Started Near-Term Task Force (NTTF)

Recommendation 4.2.

Implement Training June 2015 Not Started Submit 6-Month Status Report August. 2015 Not Started Complete Procurement of Equipment September 2015 Not Started Full compliance with EA- 12-049 is achieved Fall 2015 Not Started Page 2 of 25

ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of Ginna FLEX OIP Milestones Milestone Target Completion Activity Revised Target Dato Status Completion Date Date Submit Completion Report December 2015 Not Started

Change since submittal of last six month status report.

4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 6).

The following is a list of the open items from the OIP that have been added, deleted or completed, and of coping strategies that have been changed from the last six month status report with an explanation of the changes. Additional details on how Ginna's OIP complies with the guidance in NEI 12-06 are also provided:

1. An assessment to ensure consideration of NEI-12-06, Section 5.3.2, consideration 4, has been performed for all current strategies. There is currently no planned movement or deployment of equipment that specifically requires electrical power, such that consideration for a power supply strategy is required. Any such movement of gates, doors, fences, etc. will and can be performed by manual action.

2. Large internal flooding sources that are not seismically robust were evaluated for SEP topic IX-3 (Reference 7), and were reevaluated during IPEEE reviews as part of the Seismic Walkdowns (Reference 8). Failure of non-seismically qualified tanks in the Auxiliary Building could cause flooding in the Auxiliary Building subbasement where the Residual Heat Removal pumps are located. If a seismic event occurs while in lower modes, then Residual Heat Removal will be implemented in Phase 2. In this scenario, the water would be pumped from the subbasement to gain access to the Residual Heat Removal connections. Adequate resources (personnel and equipment) and time are allotted for this activity. The Intermediate Building, Standby Auxiliary Feedwater Building, Standby Auxiliary Feedwater Building Annex, Containment and Control Building do not have non-seismically qualified water sources that could cause internal flooding following a seismic event.

3. Ginna is not impacted by failure of a not seismically robust downstream dam. Ginna is located on the South shore of Lake Ontario. Lake Ontario water levels are regulated by the Moses-Saunders power dam in Massena, NY. Levels currently range from 245.0 ft to 246.7 ft (IGLD85)

(Reference 9). Prior to dam construction, the water level ranged from 242.6 ft to 249.3 ft (IGLD85). Failure of the Robert-Saunders Moses power dam would not have an adverse effect on the Ginna FLEX strategy.

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ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

4. FLEX equipment was purchased commercial grade that would be transportable and inherently rugged. Power Prime Pumps (Flex Pumps) are currently in use at FRAC sites and oil fields worldwide and subject to extreme conditions. The maximum temperature observed for the site region has been 100'F. From the John Deere Operators manual section, "Operating in Warm temperature Climates - John Deere engines are designed to operate using glycol base engine coolants." From the Cummins Operators Manual (100 KW D/G) - if operation in high temperature environments is anticipated, increase the frequency of coolant level checks. Neither of these sections place any limits on operation with high temperatures. The "N" designated "Flex Pump" will be stored in an environmentally controlled building. Designated N+I equipment will be stored in a structure that will protect the equipment from weather hazards. The buildings will ensure reliable starting of equipment under extreme weather conditions.

5. The decay heat model for existing thermal hydraulic analyses that are used to support mitigation strategies at Ginna will depend on the engineering / current licensing basis requirements in effect at the time of the analysis. Generally, conservatisms are applied for assumed decay heat values, but in all cases, the decay heat model assumptions are provided.

For new thermal hydraulic analyses performed specifically for FLEX, the decay heat model in Updated Final Safety Analysis Report (UFSAR) Chapter 6 will be used: The ANS Standard 5.1 has been used for the determination of decay heat energy in the Loss of Coolant Accident (LOCA) Mass and Energy (M&E) release model for the Ginna Extended Power Uprate (EPU)

Program. This standard was balloted by the Nuclear Power Plant Standards Committee (NUPPSCO) in October 1978 and subsequently approved. The official standard was issued in August 1979. UFSAR Table 6.2-4 lists the decay heat curve used in the Ginna EPU Program M&E release analysis. Significant assumptions in the generation of the decay heat curve for use in the LOCA M&E release analysis include the following:

" The decay heat sources considered are fission product decay and heavy element decay of U-239 and Np-239

" The decay heat power from fissioning isotopes other than U-235 is assumed to be identical to that of U-235

" The fission rate is constant over the operating history of maximum power level

" The factor accounting for neutron capture in fission products has been taken from ANSI/ANS-5.1 1979

" The fuel has been assumed to be at full power for 108 seconds

" The total recoverable energy associated with one fission has been assumed to be 200 MeV/fission

" Two sigma uncertainty (two times the standard deviation) has been applied to the fission product decay Based upon NRC staff review, Safety Evaluation Report of the March 1979 evaluation model, use of the ANS Standard 5.1 decay heat model was approved for the calculation of mass and energy releases to the containment following a LOCA.

In the NRC Safety Evaluation (SE) Related to Extended Power Uprate at R.E. Ginna Nuclear Power Plant (ML061380249), the NRC noted that Ginna has also used American Nuclear Society (ANS) Standard 5.1 with a 2y uncertainty band and other assumptions that maximize the decay heat added to the coolant, and as noted in Section 2.6.3 of this SE, the licensee uses the ANS 5.1 decay heat model with a 2y uncertainty band included. This is conservative and acceptable.

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

6. The direct current (dc) load profile (in table format) with the required loads for the mitigation strategies to maintain core cooling, containment, and spent fuel pool cooling is documented in Design Analysis DA-EE-2001-028, Vital Battery 8 Hour Capacity (Reference 10), which is referenced in the March 8, 2013 OIP submittal and is available on the ePortal (eDocs) site.

7. The loads that the operators will shed from the dc busses are specified in ECA-0.0, Loss of All AC Power (Reference 11), and ATT-8.0, Attachment DC Loads (Reference 12). The timeline for shedding the DC loads was documented in the March 8, 2013 OIP and should be completed within 30 minutes. DA-EE-2001-028 documents that the DC load reductions in procedures ECA-0.0 (describes loads in the Control Room) and ATT-8.0 (with locations and load descriptions) were applied to the Battery A load calculations, and therefore are necessary and sufficient to ensure adequate capacity of Battery A for an 8-hour station blackout event. DA-EE-2001-028, Attachment 3, lists the loads removed from Battery A. Battery B is shown to have adequate capacity for an 8-hour station blackout event even without procedural load reductions. The analysis is conservative because it applies 50% of the calculated load reduction to Battery A, and only during period 3. 50% of the calculated load reduction is conservatively small such that the load reduction may take place any time in the first half of period 3, which is 467 minutes long.

ECA-0.0, ATT-8.0, and DA-EE-2001-028 were referenced in the March 8, 2013 OIP submittal and are available on the ePortal (eDocs) site. The functions that are lost as a result of load shedding are listed in the procedures ECA-0.0 and ATT-8.0. The current load shedding does not impact defense-in-depth or redundancy as these loads do not impact mitigation strategy equipment or instrumentation available after an ELAP event

8. The minimum dc bus voltage required to ensure proper operation of all required electrical equipment is 108.6 V. This ensures that devices supplied by the batteries have adequate voltage levels after accounting for line losses between the battery terminals and the devices (Technical Specification Basis B.3.8.6, Battery Cell Parameters; Reference 13). Design Analysis DA-EE-99-047, 125 VDC System Loads and Voltages (Reference 14), provides a detailed analysis supporting this minimum voltage number.

9. Through analysis, Ginna has identified that a modification to qualify containment pressure instrumentation for a Tornado Missile event is no longer necessary. Ginna will proceduralize using hand-held instruments to take local readings of containment pressure. These measurements will be taken utilizing containment pressure transmitters located in the Auxiliary Building intermediate level. The structure is SC-I, flood protected and the intermediate level is protected from the effects of tornado winds and missiles.

10. For non-safety-related installed equipment that will be used in the mitigation strategies, Ginna will be installing a 1 MW Standby Diesel Generator (D/G) along with a 160,000 Gallon Condensate Storage Tank (CST). Although installed in a Seismic / Tornado and Flood proof structure, the 1 MW D/G will be classified as non-safety. The tank will also be classified as non-safety (connection points and piping penetrations will be protected by design or orientation). It will be seismically mounted and provide a suction source to the two safety related Standby AFW Pumps. During an ELAP, the 1 MW D/G will be started and use manual transfer switches to provide power to the two safety related SBAFW Pumps, which will then provide feed water to the steam generators. Ginna will also be installing a non-safety high pressure positive displacement charging pump with power being supplied by the 1 MW D/G through a breaker on its associated load center. The charging pump will be installed in the existing STBY Auxiliary Feedwater Building, which is safety related. The suction source is still under development at this time and when determined, updated in a future 6-month update.

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ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS New Open Item 74: Any additional non-safety equipment will be identified and evaluated for suitability in the mitigation strategies.

11. The new CST, TCD05, is a 160,000 gallon, flat bottom, stainless steel de-ionized water tank and meets the definition of robust in accordance with the guidance in NEI 12-06 as follows:

Seismic: The tank is anchored to a caisson foundation which has been seismically evaluated using a time history analysis scaled to Ginna's safe-shutdown earthquake (SSE). The extracted floor response spectra was then utilized to seismically qualify the tank in accordance with API-650. The tank is therefore qualified to the SSE and is seismically robust.

" External Flooding: When filled, the tank is not buoyant. Tank discharge will be routed to flood protected areas. There are no flood induced failure mechanisms. The tank is robust with regards to external flooding.

" High Wind: In accordance with calculation 175180-000-SP-CL-00001 (Reference 15),

the tank has been evaluated for external wind load of 132 miles per hour (mph). This wind speed meets the current design basis tornado wind speed for Ginna. The tank is robust with regards to high winds.

" Tornado Missile: In accordance with calculation 12574-1 (Reference 16), the tank is qualified to withstand the current design basis missile suite. Nozzles will be provided localized protection from tornado missiles from barriers and surrounding buildings. The tank is robust with regards to tornado missiles.

" Extreme Cold: The tank is provided with insulation and a tank heater located in the new enclosure building. The tank temperature will be continuously maintained. The tank heater will also be capable of being fed from the new 1 MW D/G during a loss of power.

The tank is robust with regards to cold temperatures.

" Snow: In accordance with calculation 175180-000-SP-CL-00001 (Reference 15), the tank has been evaluated for a snow load of 84 pounds per square foot (psf) (Corresponds to ground snow load of 100 psf). This exceeds the design basis ground snow load of 40 psf. The tank is robust with regards to postulated snowfall.

12. The normal water source for the Turbine Driven Auxiliary Feedwater (TDAFW) pump is the Condensate Storage System. However, the Condensate Storage System and the TDAFW pump are not considered "robust" as defined in NEI 12-06 for protection from seismic and tornado events. Therefore, Ginna plans to install a new robust CST and 1 MW D/G to power the Standby Auxiliary Feedwater (SAFW) pumps to provide cooling water to the Steam Generators (S/Gs) in the event that the TDAFW pump and CST are lost. The bounding strategy assumes that no switchover occurs, but rather that the Auxiliary Feedwater flow is stopped as a result of the event.

The FLEX strategy credits the Control Room instrumentation showing Steam Generator Level and Pressure instrumentation as available, since they are powered by the Safety Related Batteries.

The new D/G is manually started from the Standby Auxiliary Feedwater (SBAFW) Building Annex (currently under construction). The currently installed SBAFW Pumps are manually realigned to take suction from the new CST and manually realigned to be fed power from the new D/G. The SBAFW pump flow is manually controlled using a local throttle valve to maintain S/G level as directed by the local operator from the Control Room. The new CST has local level indication and the SBAFW pumps have local pressure indication.

In the event Beyond Design Basis External Event (BDBEE) conditions completely destroy the TDAFW/CST:

i. Instrumentation to switch injection from TDAFW/CST system to new CST/SAFW system, will remain operational as follows:

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

1. Instrumentation for the new D/G and CST is local and is powered from the new D/G.

2. Control Room instrumentation is safety-related (SR), redundant and powered by SR DC batteries.

3. Communications equipment will be stored in a robust protected location.

ii. Switchover function will be accomplished in a timely manner:

1. Modes 1 through 4, and Mode 5 Loops Filled timeline (Draft), shows restart of flow to the Steam Generators within approximately 37 minutes. Steam Generator dryout is conservatively estimated to occur at 35 minutes and existing procedures and analysis support refill of dry Steam Generators.

2. The switchover function will be carried out manually at the new SBAFW Building Annex, having communications with the Control Room.

iii. Injection to S/Gs will be sufficient to prevent fuel damage:

1. These SBAFW pumps are the same pumps, with the same capacity, as are currently used in the Ginna accident analysis to ensure that sufficient flow will be provided to the Steam Generators to prevent fuel damage.

2. Steam generator level and pressure information will be provided to personnel in the Annex to make adjustments to the injection flow rate, if needed.

iv. The new SBAFW Building Annex is being designed to be a robust structure per NEI 12-06 and will be accessible following BDBEE phenomena.

v. The switchover function is fail-safe:

1. The mechanical alignment for switchover is manual valves, the electrical alignment to the new D/G is a manual disconnect, and

2. The function logic, software, hardware, related piping, valves, systems, structures and components (SSCs), and system water level instrumentation to support the switchover function, either manually or automatically, are safety related and are qualified for all potential ELAP events including seismic, tornado/high winds, flooding and missiles.

3. S/G Pressure and Level indications are SR. The existing SBAFW pumps, motor and piping are SR. The new D/G, Electrical, pipe and CST are not SR but are being designed to meet all the requirements of NEI 12-06. They will be able to operate following an SSE, Probable Maximum Flood (PMF), or a Design Basis Tornado Missile.

13. Qualification of the RWST and how it meets the definition of robust in accordance with NEI 12-06 is described as follows:

The refueling water storage tank (RWST), TSIO0 is a flat bottom, stainless steel tank located in the Auxiliary Building, a Safety-Related, Seismic Category (SC) I structure.

" Seismic: The tank is located in a SC-I structure. The tank is evaluated within DA-CE-95-125 (Reference 17) and is shown to withstand design basis SSE loadings.

" External Flooding: The tank is located within the Auxiliary Building. The Auxiliary Building is flood protected to withstand external flood events. The tank is not susceptible to external flooding events.

High Winds: The tank is located within the Auxiliary Building. The Auxiliary Building structure is evaluated to withstand the effects of external wind loads developed by design basis tornado wind. The structure utilizes backdraft dampers (Tornado dampers) in order to eliminate the effects of differential pressure associated with design-basis tornado (UFSAR Section 3.3.5.7, Reference 18). The RWST was subsequently evaluated for wind pressure effects due to a tornado (UFSAR Section 3.3.3.3.1).

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ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Tornado Missile: In accordance calculation 428-4824-034-1C (Reference 19), the tank is

-qualified- to-withstand the current design basis missile suite. There are no exposed nozzles that could cause the tank to drain if struck by a tornado missile.

Extreme Cold: The tank is located within the Auxiliary Building, which has minimum allowable temperature of 50'F per UFSAR Table 3.11-1 (Reference 18). Ginna is currently completing a GOTHIC calculation for extreme minimum temperature of the Auxiliary Building. This calculation will be completed by June 2014.

Snow: The tank is located within the Auxiliary Building which has been evaluated for 40 psf design basis ground snow loadings. The tank is not susceptible to snow loads.

14. Rather than using the RWST as an indefinite source of water for Phase 3 boron control/RCS injection, the bounding strategy for supplying an indefinite source of water of Phase 3 Boron control/RCS injection is the new CST. To refill the CST any existing source of demineralized water on site will be preferentially used until the RRC water treatment system arrives. The bounding FLEX scenario will deploy a FLEX diesel driven portable pump with hard suction hose to pull suction from the Discharge Canal and discharge hose connected to refill the CST within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if required. Bags of boron are available to mix with this clean water for borated reactivity control. If required, the RRC delivered pump capability will provide a backup to the on-site FLEX pumps.

15. The bounding strategy for supplying an indefinite source of water of Phase 3 containment cooling will be to deploy a diesel driven portable pump provided by the RRC with a hard suction hose to pull suction from the Discharge Canal and with the discharge hose connected to the Containment Recirculation Fan Cooler (CRFC) supply side, outside of Containment, via a fire hose type connection. Existing safety-related discharge piping will return CRFC discharge water back to the Lake.

16. Ginna intends to comply with the NRC endorsement of the following applicable generic concerns:

" Battery Life (ML13241A188)

" Shutdown / Refueling Modes (ML13267A382)

" Maintenance and Testing (ML I 3276A224)

" Boron Mixing (MLI3276A 183)

Note: The MAAP and CENTS computer codes are not applicable to Ginna.

17. General Integrated Plan Elements Open Item 3: Exceptions for the site security plan or other (license/site specific - 10 CFR 50.54x) requirements of a nature requiring NRC approval will be communicated in a future 6-month update following identification.

This item is complete. This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the unit emergency operating procedures in accordance with established EOP change processes, and their impact to the design basis capabilities of the unit evaluated under 10 CFR 50.59. The Page 8 of 25

ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS plant Technical Specifications contain the limiting conditions for normal unit operations to ensure

--.---. that -design -safety -features are available to respond to a design basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p).

Reference:

Task Interface Agreement (TIA) 2004-04, "Acceptability of Proceduralized Departures from Technical Specifications (TSs) Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273).

18. General Integrated Plan Elements Open Item 8: Define criteria for the local RRC staging area by June 2013.

This item is complete. Criteria are identified in the "SAFER Response Plan Document,"

(Reference 20) in Sections 5 and 8.

19. Maintain Core Cooling & Heat Removal (S/Gs Available; Modes 1-4 and Mode 5 with Loops Filled)

Open Item 13: Perform an analysis to determine the time to restore feed to a S/G if only one S/G was able to be supplied with feedwater after a trip and then feed is lost to that one S/G. This is to account for the reduction in water available for heat removal.

This item has been deleted. The strategy is to feed both S/Gs. This analysis is not needed.

20. Maintain Core Cooling & Heat Removal (S/Gs Available; Modes 1-4 and Mode 5 with Loops Filled)

Open Item 22: Develop and implement procedures to refill the new CST from an alternate water source prior depleting the usable volume (approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event).

This item is revised to state "Develop and implement procedures to refill the new CST from an alternate water source prior depleting the usable volume (approximately 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months after the event)." The CST will not have a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months usable capacity for all BDBEEs.

21. Maintain Core Cooling & Heat Removal (S/Gs Available; Modes 1-4 and Mode 5 with Loops Filled)

Open Item 26: Implement a design change to provide a sustainable source of nitrogen and/or air to the Power Operated Relief Valves (PORVs) to protect RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops filled.

This item is revised to state "Implement a strategy to provide a sustainable source of nitrogen and/or air to the Power Operated Relief Valves (PORVs) to protect RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops filled."

A design change is not necessary to provide a sustainable source of nitrogen and/or air to the PORVs.

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

22. Maintain Core Cooling & Heat Removal Open Item 28: Ensure RRC can supply D/Gs capable of powering vital bus loads.

This item is complete. AREVA Document: 51-9199717-001, "Regional Response Center

- Generic and Site-Specific Equipment," (Reference 21) documents that the RRC can supply a Medium Voltage Generator (4160 V) and a Low Voltage Three-Phase Generator (480 V).

23. Maintain RCS Inventory Control / Long Term Subcriticality (Modes 1-4 and Mode 5 with Loops Filled)

Open Item 31: Implement a design change to install low leakage Reactor Coolant Pump (RCP) seals. The new seals need to be able to withstand Thor for an extended period of time.

This item is deleted. As a result of the 10 CFR Part 21 report regarding the Westinghouse low leakage RCP seals, Ginna no longer intends to utilize low leakage RCP seals for its BDBEE mitigation strategies. Ginna is currently working on its revised strategy that will account for the need for additional RCS borated makeup for RCS inventory control and to maintain subcriticality.

The revised strategy will provide the basis for the assumed RCP seal leakage for the Model 93RCPs which are installed at Ginna. Ginna expects to have the related strategies determined for the August 2014 submittal.

24. Maintain RCS Inventory Control / Long Term Subcriticality (Modes 1-4 and Mode 5 with Loops Filled)

Open Item 32: Perform an analysis to validate that a FLEX Boric Acid Storage Tank (FBAST) with a boron concentration of at least 2750 parts per million (ppm) and no more than 3050 ppm, and containing a minimum usable volume of 7000 gallons, is sufficient to maintain the reactor subcritical at Beginning of Life (BOL) or End of Life (EOL) conditions with Tave at or near no-load Tave, and at EOL conditions with a cooldown to 3501F.

(Analysis must be bounding for current and future cycles.)

This item is deleted. As a result of the 10 CFR Part 21 report regarding the Westinghouse low leakage RCP seals, Ginna no longer intends to utilize low leakage RCP seals for its BDBEE mitigation strategies. Ginna is currently working on its revised strategy that will account for the need for additional RCS borated makeup for RCS inventory control and to maintain subcriticality.

The revised strategy will provide the basis for the assumed RCP seal leakage for the Model 93RCPs which are installed at Ginna. Ginna expects to have the related strategies determined for the August 2014 submittal.

25. Maintain RCS Inventory Control / Long Term Subcriticality Open Item 34: Design and implement the capability to inject blended borated water into the RCS using an inline blender, at the required flow rate with margin, once an analysis determines the RCS makeup requirement for Mode 5, loops not filled and pressurizer manway not removed.

This item is revised to state "Implement a strategy to batch mix boron in the FBAST." To implement this strategy the new CST will be hard piped to the FBAST to provide gravity feed refill capability. A ladder / stairway access will allow manual addition of dry chemical with Page 10 of 25

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS mixing occurring by either an electric mixer or a pump sparger recirculation system within the tank. The boric acid source will be dry chemical in the new structure. -

26. Maintain Core Cooling & Heat Removal (S/Gs Not Available; Modes 5 & 6)

Open Item 44: Perform a boron mixing analysis for the effects on RCS boron concentration by providing unborated water to the refueling cavity via the transfer canal from the Auxiliary Building to Containment.

This item is deleted. This method will not be used to provide makeup to the refueling cavity.

27. Maintain Core Cooling & Heat Removal (S/Gs Not Available; Modes 5 & 6)

Open Item 47: Implement a design change to install permanent connection point for Instrument Air to Containment.

This item is revised to state "Implement a strategy to provide a connection point for Instrument Air to Containment."

A design change is not necessary to provide instrument air to containment.

28. Maintain Containment Open Item 49: Perform an analysis to determine the containment pressure profile during an ELAP / Loss of Ultimate Heat Sink (LUHS) event, after the low leakage RCP seal technology is chosen, and determine the mitigating strategies necessary to ensure the instrumentation and controls in containment which are relied upon by the Operators are sufficient to perform their intended function.

This item is revised to state "Perform an analysis to determine the containment pressure profile during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and determine the mitigating strategies necessary to ensure the instrumentation and controls in containment which are relied upon by the Operators are sufficient to perform their intended function."

As a result of the 10 CFR Part 21 report regarding the Westinghouse low leakage RCP seals, Ginna no longer intends to utilize low leakage RCP seals for its BDBEE mitigation strategies.

Ginna is currently working on its strategy that will account for the higher RCP seal leakage into containment. Ginna expects to have the related strategies determined for the August 2014 submittal.

29. Maintain Spent Fuel Pool Cooling Open Item 54: Implement a design change to install a protected makeup connection to the Spent Fuel Pool (SFP) cooling piping to provide makeup to the SFP that exceeds SFP boil-off and provide a means to supply SFP makeup without accessing the SFP walkway.

This item is revised to state "Implement a strategy to provide for a protected makeup connection to the Spent Fuel Pool (SFP) cooling piping to provide makeup to the SFP that exceeds SFP boil-off and provide a means to supply SFP makeup without accessing the SFP walkway."

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

..... A design change is not necessary to implement-this strategy. ...

30. Maintain Spent Fuel Pool Cooling Open Item 58: SFP Water Level instrument numbers will be provided upon detailed design completion.

This item is complete. The SFP Water Level instrument numbers are:

" LI-3 10, SFP Wide Range Level Indicator (Northeast Channel)

" LI-3 11, SFP Wide Range Level Indicator (Southeast Channel)

31. Safety Functions Support Open Item 64: Implement a design change to install a protected primary and secondary means of accessing the Ultimate Heat Sink (UHS) for all BDBEEs, and install necessary modifications to meet required deployment times. This must also address how debris in the UHS or other raw water sources will be filtered / strained and how the resulting debris will effect core cooling.

This item is revised to state "Implement a strategy for accessing the UHS for all BDBEEs and to meet required deployment times. This must also address how debris in the UHS or other raw water sources will be filtered / strained and how the resulting debris will effect core cooling."

A design change will not be necessary for accessing the UHS.

32. Safety Functions Support Open Item 65: Implement a design change to provide for transferring diesel fuel from the D/G A and D/G B Fuel Oil Storage Tanks (FOSTs) to a fuel transfer vehicle.

This item is revised to state "Implement a strategy to provide for transferring diesel fuel from the D/G A and D/G B Fuel Oil Storage Tanks (FOSTs) to a fuel transfer vehicle."

A design change will not be necessary for transferring diesel fuel from the D/G A or D/G B FOSTs to a fuel transfer vehicle.

33. Safety Functions Support Open Item 71: Table 3 lists Phase 3 Response Equipment / Commodities that are being considered for pre-staging at an offsite location. These include:

Radiation Protection Equipment

Commodities - Food, Potable Water

Diesel Fuel

Heavy Equipment - Transportation, Debris Removal

Boric Acid

Portable Lighting

Portable Toilets Page 12 of 25

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS This item is deleted. There are no plans to pre-stage commodities at an offsite location. Diesel fuel will be provided by the RRC for initial start and test of RRC provided- equipment. Portable lighting will be provided by the RRC as generic equipment to the site and also to staging area C.

Equipment transportation will be provided from RRC to staging area C and from staging area C to staging area B.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ginna expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim 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. Explanations for added, deleted and completed items are provided in Section 4.

Table 3 will provide a summary of the open items documented in the Ginna Interim Staff Evaluation (ISE) and the status of each item following the issuance of the ISE.

Table 2 Status of FLEX OIP Open Items Ginna OIP Open Items Status

1. Implement a design change to install permanent protected FLEX equipment Started (8/2013) connection points. (also see 01 23)

2. Provide for onsite storage of Phase 2 FLEX components that is protected Started (2/2014) against external events by design or location.

Implement a design change to provide a protected storage location for transportation (equipment and fuel) and debris removal equipment.

Evaluate deployment strategies and deployment routes for hazards impact.

Evaluate requirements and options and develop strategies related to the storage onsite of the FLEX portable equipment.

Establish deployment routes from FLEX equipment storage locations to connection points.

Develop a strategy and purchase equipment to respond to events that may require debris removal such as following a flood, tornado, or snow storm.

Develop a strategy to move FLEX equipment, including providing reasonable protection from a BDBEE.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of FLEX OIP Open Items Ginna OIP Open Items Status "3. Exi~eiitiorisfr tiesit e security plan or other (license/site specific - 10 CFR Complete (2/2014) 50.54x) requirements of a nature requiring NRC approval will be comnmunicated in a future 6-month update following identification.

4. Develop and implement procedures to commence feeding the steam Not Started generators (S/Gs) from Standby Auxiliary Feedwater (SAFW) powered by the new SAFW Diesel Generator (D/G) and taking suction from the new Condensate Storage Tank (CST) prior to reaching 5 ft in the existing CST.

5. Develop and implement a FLEX method / procedure to refill the new SAFW Not Started CST prior to losing suction.

6. Develop and implement a program and/or procedure to keep FLEX Not Started equipment deployment pathways clear or with identified actions to clear the pathways.

7. Determine schedule for when RRCs will be fully operational. Complete (8/2013)

8. Define criteria for the local RRC staging area by June 2013. Complete (2/2014)

9. Establish a suitable local staging area for portable FLEX equipment to be Started (2/2014) delivered from the RRC to the site.

10. Develop site specific playbook for delivery of portable FLEX equipment Started (8/2013) from the RRC to the site.

11. Perform an analysis to determine the diesel driven portable high pressure Not Started pump upper and lower head requirements to provide for a minimum of 215 gpm to a S/G without causing Reactor Coolant System (RCS) pressure to decrease to the point where nitrogen will be injected from the SI Accumulators, assuming suction is directly from the Ultimate Heat Sink (UHS).

12. Develop and implement procedures to close Safety Injection (SI) Not Started Accumulator injection valves or vent the SI Accumulators prior to nitrogen injection into the RCS.

13. Perform an analysis to determine the time to restore feed to a S/G if only Deleted (2/2014) one S/G was able to be supplied with feedwater after a trip and then feed is lost to that one S/G. This is to account for the reduction in water available for heat removal.

14. Implement the design change to install the 1 MW SAFW D/G, 160,000 Started (8/2013) gallon Condensate Storage Tank (CST), and enclosure meeting the reasonable protection requirements of NEI 12-06.

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

15. Dievelop'a'nd implement procedures to feed S/Gs using a SAFW Pump Not Started powered by the new SAFW D/G and taking suction on the new 160,000 CST. Revise procedures to direct Operators to manually establish makeup to the S/Gs via this flow path if the Turbine Auxiliary Feedwater (TDAFW)

Pump fails to deliver water to the S/Gs.

16. Implement a design change to protect a S/G Atmospheric Relief Valve Not Started (ARV) from Tornado Missiles to address reactor core cooling and heat removal using a high capacity portable diesel driven pump.

17. Perform an analysis to demonstrate adequate manpower, communications Started (8/2013) capability, and habitability for local operation of the S/G ARVs. If this cannot be demonstrated, implement a design change to provide for ARV control from the Control Room for seismic and tornado missile events.

18. Develop and implement procedures/administrative controls to ensure that Not Started the new CST maintains a minimum usable volume at all times.

19. Perform an analysis or implement a design change to qualify S/G Pressure Started (2/2014) instrumentation for a Tornado Missile event.

20. Identify instrumentation and develop procedures to take field readings of Started (8/2013) necessary parameters, including (Pressure Indicator) PI-430 and (Level Indicator) LI-427.

21. Implement a strategy to connect a portable air compressor at a location/ Not Started configuration to support ARV operation.

22. Develop and implement procedures to refill the new CST from an alternate Revised (2/2014) water source prior depleting the usable volume (approximately 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months Not Started after the event).

23. Implement a design change as part of the installation of the new CST to Started (8/2013) install a mechanical connection that will allow the tank to be refilled from a portable diesel driven pump.

24. Perform an analysis to establish plant conditions in Phase I that will allow Started (2/2014) diesel driven high capacity portable pump to be utilized as soon as plant resources are available to provide defense in depth for maintaining an adequate heat sink should SAFW fail.

25. Implement a design change to install a new isolation valve upstream of the Not Started FLEX connection to S/G B in case a tornado missile impacts a section of unprotected piping between the SAFW Building and the connection point.

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

26. Implement a strategy to provide a sustainable source of nitrogen and/or air Revised (2/2014) to the Power Operated Relief Valves (PORVs) to protect RCS Integrity Started (2/2014) during a BDBEE while in Mode 4 or Mode 5, loops filled.

27. Develop and implement procedures to provide guidance for water solid S/G Not Started cooldown using FLEX equipment.

28. Ensure RRC can supply D/Gs capable of powering vital bus loads. Complete (2/2014)

29. Implement a design change to provide connections to 480 Volt vital busses Not Started to be able to connect to RRC supplied D/Gs.

30. Ensure RRC can supply a water processing unit. Started (8/2013)

31. Implement a design change to install low leakage Reactor Coolant Pump Deleted (2/2014)

(RCP) seals. The new seals need to be able to withstand Th., for an extended period of time.

32. Perform an analysis to validate that a FLEX Boric Acid Storage Tank Deleted (2/2014)

(FBAST) with a boron concentration of at least 2750 parts per million (ppm) and no more than 3050 ppm, and containing a minimum usable volume of 7000 gallons, is sufficient to maintain the reactor subcritical at Beginning of Life (BOL) or End of Life (EOL) conditions with Tave at or near no-load Tave, and at EOL conditions with a cooldown to 350'F. (Analysis must be bounding for current and future cycles.)

33. Implement a design change to convert the existing SAFW Test Tank to the Not Started FBAST with a permanent connection to the new pre-staged high pressure pump and connection(s) for a portable diesel driven pump.

34. Implement a strategy to batch mix boron in the FBAST. (also see 01 39) Revised (2/2014)

Not Started

35. Implement a design change to install a pump capable of pumping 22 gallons Started (8/2013) per minute (gpm) of borated water into the RCS at 2235pounds per square inch gage (psig), or 70 gpm at 1500 psig, from the new FBAST with discharge piping connected to the Charging header.

36. Develop and implement procedures to initiate RCS boration prior to Not Started commencing RCS cooldown to provide margin to prevent re-criticality.

37. Implement a design change to connect a portable diesel engine driven high Not Started pressure pump to the FBAST and the Charging line, which is capable of pumping 20 gpm of borated water from the FBAST to the RCS at 2235 psig.

38. Ensure the RRC will supply boric acid for use with the inline blender. Started (2/2014)

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

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

39. Perform an analysis to determine minimum RCS makeup flow sufficient for Started (2/2014) simultaneous core heat removal and boron flushing for Mode 5, loops not filled and pressurizer manway not removed. (also see 01 34)

40. Perform an analysis to determine the transition point from gravity fill of the Not Started refueling cavity to when forced makeup is required.

41. For Mode 5, Loops Not Filled, and Pressurizer Manway Not Removed, RCS Started (2/2014)

Heat Removal will be by RCS Bleed and Feed. Items under consideration are:

Establish RCS feed path using low pressure pump capable of [To Be Determined] gpm at > 50 psig and a maximum discharge pressure of 410 psig to the RCS.

Establish sufficient RCS bleed path (PORVs, Reactor Head Vents)

Implement a strategy to provide a connection point for Instrument Air to Containment (0147)

" Establish feed to available S/Gs Partial strategy for consideration - Fill available S/Gs to provide limited heat sink function and additional time before boiling of the coolant occurs. Existing procedural guidance for Water Solid S/G Cooldown provides guidance that can be modified for use with a high flow portable diesel driven pump to maintain the limited heat sink function.

" If Water Solid S/G Cooldown is effective to maintain core cooling and heat removal, secure RCS Bleed and Feed and maintain Pressurizer Level.

42. Perform an analysis to determine RCS vent path requirements for Mode 5 Started (2/2014) with PORV vent path.

43. Develop and implement procedures to makeup to the refueling cavity from Not Started the new CST, UHS, or FBAST to maintain refueling cavity level and boron concentration.

44. Perform a boron mixing analysis for the effects on RCS boron concentration Deleted (2/2014) by providing unborated water to the refueling cavity via the transfer canal from the Auxiliary Building to Containment.

45. Evaluate the viability of feed and bleed for available S/Gs to provide a Started (2/2014) limited heat sink function and additional time before boiling of the coolant occurs as a parallel mitigating strategy during Modes 5 & 6. This analysis must address reflux condensation and its potential effects on reactor shutdown margin.

46. Implement a design change to establish provisions for refilling the FBAST Not Started with borated water.

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ATTACHMENT (2)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2

- Status of FLEXOIP Open Items Ginna OIP Open Items Status

47. Implement a strategy to provide a connection point fo"r lInsrument Air to Revised (2/2014)

Containment. Started (2/2014)

48. Perform an evaluation to determine a method for recirculation cooling of the Started (2/2014)

RCS if the Auxiliary Building Sub-basement is flooded by Tornado Missiles damaging non-protected tanks on the Auxiliary Building Operating Floor.

49. Perform an analysis to determine the containment pressure profile during an Revised (2/2014)

ELAP / Loss of Ultimate Heat Sink (LUHS) event and determine the Started (2/2014) mitigating strategies necessary to ensure the instrumentation and controls in containment which are relied upon by the Operators are sufficient to perform their intended function.

50. Perform an analysis of the containment function to determine the mitigating Not Started strategy acceptance criteria for an ELAP / LUHS event.

51. Implement a strategy to determine containment pressure after a Tomado Revised (8/2013)

Missile event. Started (2/2014)

52. Develop the Phase 3 strategy after the containment pressure analysis is Not Started completed as described in Maintain Containment, PWR Portable Equipment Phase 2.

53. Ensure the RRC will provide additional portable pumps and equipment to Started (2/2014) spray water into containment or supply water to the Containment Recirculation Fans / Coolers.

54. Implement a strategy to provide for a protected makeup connection to the Revised (2/2014)

Spent Fuel Pool (SFP) cooling piping to provide makeup to the SFP that Started (2/2014) exceeds SFP boil-off and provide a means to supply SFP makeup without accessing the SFP walkway.

55. Provide the necessary connecting hoses and/or equipment to work with Started (2/2014) existing pumps and water sources for filling the SFP.

56. Revise ER-SFP.2 to provide multiple strategies for establishing a diverse Not Started means of SFP makeup for at least 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months without offsite supplies.

57. Perform an analysis to determine if a vent pathway from the SFP is needed Started (2/2014) for steam and condensate to minimize the potential for steam to cause access and equipment problems in the Auxiliary Building. (also see 01 62)

58. SFP Water Level instrument numbers will be provided upon detailed design Complete (2/2014) completion.

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

59. Ensure the RRCwill provide additional portable pumps arid equipment to: Started (8/2013)

provide water from the UHS to the Standby SFP Heat Exchanger to remove heat from the SFP cooling system with the Standby SFP Recirculation Pump; or

provide water to SFP Heat Exchanger A to remove heat from the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A, or

" provide a heat exchanger and equipment to provide cooling for the SFP.

60. Implement a design change to install connection points needed to supply the Started (2/2014) battery chargers from the 1 MW D/G.

61. Implement a design change to install connection points needed to supply the Started (2/2014) battery chargers from a 100 kW D/G.

62. Perform GOTHIC calculations consistent with NUMARC 87-00, Guidelines Started (8/2013) and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, to determine the effects of a loss of HVAC during an ELAP for the following areas:

Intermediate Building, TDAFW Pump and ARV/ (Safety Valve (SV) areas

Auxiliary Building, Refueling Water Storage Tank (RWST) area

Battery Rooms, Relay Room, and Control Room

Standby Auxiliary Feedwater Building

63. Perform an analysis to evaluate the Battery Room low temperature for an Started (2/2014)

ELAP event, assuming -16°F air temperature to determine if, and when, Battery Room heating is required.

64. Implement a strategy for accessing the UHS for all BDBEEs and to meet Revised (2/2014) required deployment times. This must also address how debris in the UHS Started (2/2014) or other raw water sources will be filtered / strained and how the resulting debris will effect core cooling.

65. Implement a strategy to provide for transferring diesel fuel from the D/G A Revised (2/2014) and D/G B Fuel Oil Storage Tanks (FOSTs) to a fuel transfer vehicle. Started (2/2014)

66. Perform an analysis to provide a basis that the Offsite D/G FOSTs are Not Started reasonably protected from BDBEEs.

67. Develop the strategy to transfer fuel from protected fuel storage locations to Not Started FLEX equipment.

68. Develop strategies to provide for emergency lighting to support Operator Started (2/2014) actions after a BDBEE.

69. Develop a strategy to protect onsite consumables for use after a BDBEE. Started (2/2014)

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

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

70. Develop and implement procedures to establish batteiy room ventilation Not Started within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the event to prevent exceeding the unacceptable hydrogen concentration limit of 2%, once the GOTHIC analysis has been completed as discussed in Phase 2.

71. Table 3 lists Phase 3 Response Equipment / Commodities that are being Deleted (2/2014) considered for pre-staging at an offsite location. These include:

" Radiation Protection Equipment

" Commodities - Food, Potable Water

Diesel Fuel

" Heavy Equipment - Transportation, Debris Removal

Boric Acid

Portable Lighting

" Portable Toilets

72. Install wide range SFP level instrumentation in accordance with NRC Order Started (8/2013)

EA-12-051.

73. Implement a strategy to provide cooling water to the RHR Heat Exchangers Started (2/2014) using a portable diesel driven pump.

74. Any additional non-safety equipment will be identified and evaluated for Started(2/2014) suitability in the mitigation strategies Started(2/2014)

Table 3 Status of Interim Safety Evaluation (ISE) Open and Confirmatory Items ISE and Confirmatory Open Items Status None 7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation as 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.

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

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

Fixed Satellite Phone System and Antennas

1. Determine the status of existing fixed 12/31/2013 Complete (8/2013) satellite phone system and antennas in terms of suitability of being "Reasonably protected"

2. Install additional antennas as necessary 8/31/2014 Not Started to support the use of additional fixed satellite phones at all onsite locations (Control Room, Technical Support Center (TSC), and Operational Support Center (OSC)).

NAB, TSC and Service Buildings

1. Determine whether or not the Nuclear 12/31/2013 Complete (2/2014)

Assurance Building (NAB), TSC and Service Building are "reasonably protected."

Portable Satellite Phones

1. Stage portable satellite phones Complete Complete (2/2013)

2. Stage portable satellite phone batteries 10/31/2013 Complete (2/2014) and chargers in the applicable Emergency Response Organization (ERO) Facilities.

3. Update work instructions for portable 10/31/2013 Complete (2/2014) satellite phone inventory.

4. Develop/update preventive maintenance 12/31/2013 Complete (2/2014) and testing procedures for portable satellite phones, batteries and chargers.

5. Include information on portable satellite 12/31/2013 Complete (2/2014) phone locations and usage in procedures.

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

6. Stage off-site portable off-site satellite 12/31/2013 Complete (2/2014) phones.

7. Procure and install a high power UPS or 12/31/2014 Not Started similar modification providing backup power for the battery chargers for portable satellite phones.

Fixed Satellite Phones

1. Procure and install fixed satellite phones, 12/31/2014 Not Started additional antennas, and uninterruptable power supplies for the TSC/OSC, Control Room, Emergency Operations Facility (EOF), Joint Information Center (JIC), and Wayne and Monroe Counties Emergency Operations Centers (EOCs) and Warning Points (WPs). Include the capability to power the portable satellite phone battery chargers.

2. Develop/update preventative 8/31/2014 Not Started maintenance and testing procedures for fixed satellite phones.

3. Include information on fixed satellite 12/13/2013 Complete (2/2014) phone locations and usage in procedures.

4. Provide instructions for use of fixed 12/31/2014 Not Started satellite phones at each location.

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GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

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

Communication with ORO Facilities

1. Provide each Offsite Response 8/31/2013 Complete (2/2014)

Organization (ORO) identified in Section 4.3 of the Communications Assessment with instructions for proper storage and rotation of satellite phone batteries.

Portable Generators

1. Develop portable generator fueling plan 12/31/2013 Complete (2/2014) to ensure ability to provide power for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Develop procedures to maintain and test 12/31/2013 Complete (2/2014) the portable generators.

3. Update work instructions to inventory 12/31/2013 Complete (2/2014) portable generators and ensure adequate volume of fuel.

4. Develop preventive maintenance 12/31/2013 Complete (2/2014) procedure for portable generators fuel supply.

5. Determine a process for relocating 12/31/2013 Complete (2/2014) portable generators to the appropriate locations to power the necessary equipment.

Training

1. Evaluate training needs specific to the 10/31/2015 Not Started use of portable and fixed satellite phones, and radios during an ELAP event.

2. Develop and implement training on the 10/31/2015 Not Started use of backup generators.

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ATTACHMENT (2)

GINNA 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of Communications Assessment Interim Actions Target Revised Communications Assessment Completion Status mTarget Implementing Actions tCompletion DateDate *

3. Revise EPIP-1-18 as described in 10/31/2013 Complete (2/2014)

Section 4.11 of Reference 4 Brief appropriate personnel on the contents of this procedure.

APC Back-UPS ES 750

1. Determine whether APC Back-UPS ES 12/31/2013 Deleted (2/2014) 750 is high enough above ground elevation in the On-Site Telephone UPS ES 750 does not Building to be protected from flooding. exist at Ginna, nor does a telephone building. This implementing action was created in error.

Portable Radios

1. Procure and install a high power UPS or 10/31/2015 Not Started similar modification providing backup power for the radio system repeaters.

2. Complete estimates of portable radio 10/31/2013 Complete (2/2014) battery life and procure additional batteries as necessary based on an estimate of minimum talk time to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation.

Note:

There are no changes to target completion dates. However, the column labeled Revised Target Completion Date is reserved for future use.

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.

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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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

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. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Six-Month Status Report 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.

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

7. SEP Topic IX-3 (NUREG 0821, Integrated Plant Safety Assessment SEP Final Report, December 1982)

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), R. E. Ginna Nuclear Power Plant, Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated November 27, 2012 (ML12347AI04); Attachment 1: Seismic Walkdown Report, Section 7 IPEEE Vulnerabilities Resolution Report

9. Circular 1311, Lake-Level Variability and Water Availability in the Great Lakes, U.S. Geological Survey, Wilcox, Douglas A., Thompson, Todd A., Booth, Robert K., and Nicholas, J.R., 2007.

10. DA-EE-2001-028, Vital Battery 8 Hour Capacity, Revision 1

11. ECA-0.0, Loss of All AC Power, Revision 3800

12. ATT-8.0, Attachment DC Loads, Revision 7

13. Technical Specification Basis, Revision 68

14. DA-EE-99-047, 125 VDC System Loads and Voltages, Revision 1

15. 175180-000-SP-CL-00001, Design Calculations for (1) 36' Diameter x 34'-9" High DRT, Revision 0001 (Proprietary)

16. Calculation 12574-1, Analysis of Tornado Generated Missiles Impacting a Water Storage Tank, Revision 2

17. DA-CE-95-125, Seismic Analysis of Refueling Water Storage Tank, Revision 000

18. UFSAR, Updated Final Safety Analysis Report, Revision 24

19. 428-4824-034-IC, Tornado Missile Impact, Revision 000 (Proprietary)

20. SAFER Response Plan Document, Rev. 01

21. AREVA Document: 51-9199717, Regional Response Center Generic and Site-Specific Equipment, Revision 001 Page 25 of 25

ATTACHMENT (3)

NMPI 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Constellation Energy Nuclear Group, LLC February 27, 2014

ATTACHMENT (3)

NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The Nine Mile Point Unit 1 (NMPl) 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 NMPI OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment 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 applicable).

NMPI 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 the NMP 1 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.

Since the submittal of the last status report in August 2013 (Reference 6), NMPI FLEX has progressed with some engineering analysis and calculations that support the mitigating strategies and the modification concepts have been refined. However, no significant changes to the mitigation strategies or planned modifications in support of the mitigation strategies have occurred. Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued with review of proposed supporting equipment specifications and participation on committees that have been assembled to identify and provide specific needs.

By letter dated December 19, 2013, the NRC issued to CENG the Nine Mile Point Nuclear Station, Units I and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7). The Interim Staff Evaluation (ISE) contains open and confirmatory items for which CENG will provide clarifying or additional information in six-month status reports in order for the NRC to determine that the issues are on a path to satisfactory resolution.

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

and are current as of January 17, 2014;

" Refueling Outage (RFO) including walk downs in support of pending modifications for installation for FLEX strategies (8/2013).

Six month integrated plan progress report submitted (8/2013).

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NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMPI OIP (Attachment 2 - 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 following 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 NMP1 FLEX OIP Milestones Target Revised TargetTarget Completion Activity Status Target Milestone Date Date Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Implementation Plan February 2013 Complete Refueling Outage Spring 2013 Complete 6 Month Integrated Plan Progress Report August 2013 Complete Engineering and Design Completion - Equipment January 2014 Started July 2014' Storage Facility 6 Month Integrated Plan Progress Report February 2014 Complete Engineering and Design Completion - Portable February 2014 Started August 2014 Equipment Connections 6 Month Integrated Plan Progress Report August 2014 Not Started 6 Month Integrated Plan Progress Report February 2015 Not Started Non-outage Installation - Portable Equipment March 2015 Not Started Connection Validation walk downs complete March 2015 Not Started Portable Equipment Procedures Changes March 2015 Not Started FLEX Training April 2015 Not Started Outage Installation - Portable Equipment May 2015 Not Started Connections Page 2 of 16

ATTACHMENT (3)

NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Target Revised TargetTarget Completion Activity Status Compet Milestone Completion Date Date Date Equipment Storage Facility Installation May 2015 Not Started Final Implementation Notification to USNRC July 2015 Not Started Note': Change since submittal of last six month integrated plan status report in August 2013.

4 Changes to Compliance Method Changes were made to the information provided in the O1P that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last six month status report.

The following is a list of the open items from the OIP or the NRC's ISE that have been added, deleted or completed, and of coping strategies that have been changed from the last six month status report with an explanation of the changes:

1. General Integrated Plan Elements Boiling Water Reactor (BWR)

Open Item 1: Define criteria for the local (25 mile) staging area.

This open item is complete. SAFER issued the SAFER Response Plan (playbook) Revision 1 on August 15, 2013. The SRP contains detailed criteria for staging areas in Chapter 5, "Staging Area Procedure" and Chapter 8, "Requirements and Basis."

2. Safety Functions Support, BWR Portable Equipment Phase 2 Open Item 46: Perform an analysis for long term environmental conditions in NMP1 Battery Rooms during an ELAP and evaluate any actions to mitigate the impact of hydrogen production as required.

This open item is complete. At NMP1, during normal plant operation, the Battery Room ventilation is provided from the Turbine Building ventilation system. The Battery Room ventilation occurs by air flow being drawn through the battery door louvers and room air volume being discharged through the Turbine Building ventilation exhaust ducts located in the room.

The Turbine Building ventilation is non-safety related and during an ELAP condition this system is not functional. Therefore during an ELAP, the hydrogen gas will accumulate in the ventilation duct work, which is located above the Battery Rooms, while the batteries are being recharged. To prevent unacceptable hydrogen gas concentrations in the Battery Room ductwork, 3 inch diameter holes are located in the top of the Battery Room exhaust ducts. The exhaust holes are normally closed by dampers and open during a loss of power. The exhaust holes will allow the Page 3 of 16

ATTACHMENT (3)

NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS hydrogen gas to escape from the duct into the Turbine Building atmosphere. Due to the immense volume of the Turbine Building, the hydrogen concentration will be extremely low (below 1%).

This condition had been previously analyzed for the loss of forced ventilation due to loss of offsite power in NMP Calculation S10-H2GAS-HV01, Rev. 00 and Disposition 00A.

Remaining design specifications and requirements and strategy revisions will be determined upon completion of the final design.

No significant coping strategy changes have occurred since the previous six month status update provided on August 28, 2013 (Reference 6). For information, the following minor changes to the coping strategies have been put in place:

The NMPI OWP (Reference 3) identified that primary connection points for makeup water would typically exist external to the station buildings. The OIP specifically stated that "...a means to supply spent fuel pool (SFP) makeup without accessing the interior of any building" would be provided (Reference 3; Spent Fuel Pool Cooling Objectives). The plan to provide external connections has been revised and currently involves routing the discharge of the FLEX diesel driven pump into the Reactor Building to a distribution manifold just inside access doors on the ground floor. This manifold will be the central location for directing the primary injection source for the reactor pressure vessel (RPV), SFP and Emergency Condenser (EC) makeup. This change eliminates the need to create new penetrations through the Secondary Containment (Reactor Building) wall.

The NMP1 OIP (Reference 3) description of the primary connection modification for SFP makeup and preliminary drawings associated with the makeup water capability for the SFP identified that there would be a hard pipe tied into the SFP cooling system return line. This has changed in that the primary injection point for makeup to the SFP will instead be routed to the refueling floor such that it will discharge directly into the SFP. Hard pipe will be routed to the refueling floor and a connection point added. A hose will be connected at that point and be routed to the SFP and secured so that it discharges into the SFP. This change eliminates the need to modify the existing safety related SFP cooling system and utilizes existing floor penetrations in order to run the piping to the SFP and achieve the same result. For this reason, Open Item 53 in Table 2 has been revised to remove the wording that identified that makeup to the SFP would be connected to the SFP cooling system return line.

Preliminary drawings associated with the makeup water capability for the RPV previously depicted a hard piped system from the connection for the portable pump (previously external to the Reactor Building) directly into the Control Rod Drive (CRD) system RPV return line.

Current plans include the necessity to install hose between the distribution manifold inside the Reactor Building (see above) and the connection to be located in the same place on the CRD system, eliminating the installation of hard piping between these points. This change eliminates the need to provide hard piping runs in areas that could impede normal access, and does not involve significant ingress to the Reactor Building to accomplish.

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NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation NMPl 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. Explanations for added, deleted and completed items are provided in Section 4.

Table 3 provides a summary of the open items documented in the NRC's NMP1 ISE (Reference 7) and the status of each item.

Table 2 Status of NMPI FLEX OIP Open Items NMP1 OIP Open Items Status

1. Define criteria for the local (25 mile) staging area. Complete (2/2014)

2. Evaluate deployment strategies and deployment routes for hazard impact. Started (2/2014)

3. Evaluate requirements and options and develop strategies related to the storage on site of the FLEX portable equipment (including lighting tools Started (8/2013) such as flashlights and batteries) in accordance with the requirements of NEI 12-06.

4. Exceptions for the site security plan or other (license/site specific - 10 CFR 50.54x) requirements of a nature requiring NRC approval will be Started (8/2013) communicated in a future 6 month update following identification.

5. Determine schedule for when Regional Response Centers (RRC) will be Complete (8/2013) fully operational

6. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from Started (2/2014) the dry hydrants will consider Phase 2 requirements.

7. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from Started (8/2013) the dry hydrants will consider Phase 3 requirements.

8. Perform calculations and validate assumptions of fuel consumption and replenishment rate to ascertain the time before off-site replenishment is Started (8/2013) required.

9. Perform an evaluation of the Uninterruptible Power Supply (UPS) strategy and design and implement as required or formalize the use of the Started (2/2014) small portable gas generators (communication strategies).

10. Perform an evaluation of the redundant power strategy for radio repeaters and design and implement modifications or programmatic changes as Started (2/2014) required.

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

11. Verify plans for the FLEX storage facilities in accordance with NEI 12-06 requirements also accommodate the storage and availability of fuel for the Started (8/2013) small gas generators.

12. Perform an analysis for feasibility of utilizing the sound powered Started (2/2014) communications for onsite communications for FLEX strategies. Started_(2/2014)

13. Evaluate required consumables and options for storage and availability during an ELAP and implement programmatic controls to ensure required Not Started inventory is maintained.

14. Establish deployment routes from FLEX equipment storage location to Started (2/2014) connection points (including hazard impacts).

15. Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site. Started (8/2013)

Safer Staging area "C"

16. Establish a suitable local staging area for Phase 3 portable FLEX equipment to be deployed on site. Started (8/2013)

Safer Staging area "B"

17. Provide the necessary storage facilities in order to provide fuel to the Not Started transfer pumps during an ELAP event.

18. Develop site specific SAFER Response Plan (playbook) for delivery of Started (8/2013) portable FLEX equipment from the RRC to the site.

19. Develop and implement a program and/or procedures to keep FLEX equipment deployment pathways clear or identify actions to clear the Not Started pathways.

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM) recommendation and Started (8/2013)

Electric Power Research Institute (EPRI) guidelines for FLEX equipment.

21. Evaluate and implement procedures that direct immediate deployment of Phase 2 equipment during Refueling conditions.

22. Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport FLEX portable Not Started equipment during all modes of operation.

23. Develop procedures/guidelines to address the criteria in NEI 12-06 to support existing symptom based strategies in the Emergency Operating Started (2/2014)

Procedures (EOPs).

24. Evaluate potential soil liquefaction for Nine Mile Point site considering final storage location of FLEX portable equipment and deployment routes Started (8/2013) established for this equipment.

25. Evaluate requirements and options and develop strategies related to the storage and transport of the on-site FLEX portable equipment.

26. Evaluate NMPI containment integrity for Phases 1 through 3 and provide analysis in a future required six month status report. (New Open Item Added (8/2013) added since original OIP as a result of further considerations of necessary Started analysis to support FLEX strategies)

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

27. Implement a design change to install a permanent connection point for a portable pump to provide makeup to the Emergency Condensers (ECs). Added (8/2013)

(New Open Item added as a result of strategy changes described in the Started August 2013 Six Month Update)

28. Perform an evaluation to ensure that the recirculation pump seal operating Not Started conditions are consistent with the referenced vendor test report.

29. Perform an analysis of the portable generator to determine it will be Started (2/2014) capable of supplying all expected battery loads.

30. Perform an analysis to determine the flow/capacity needed for the portable pump from the RRC to adequately supply the Emergency Service Started (2/2014)

Water (ESW) system.

31. Evaluate the connection point for the RRC portable pump to ESW and Started (2/2014) implement a design change to ensure that the pump can be connected.

32. Evaluate implementation of makeup capability for the Reactor Building Closed Loop Cooling (RBCLC) system expansion tank to support Started restarting the system in Phase 3.

33. Perform an analysis to determine the containment pressure profile during an ELAP / LUHS event and verify the instrumentation and controls in Not Started containment which are relied upon by the operators are sufficient to perform their intended function.

34. Perform a site specific analysis to confirm that the containment parameters (temperature, pressure and level) stay below their design Not Started limits during Phase 1 following an ELAP.

35. Perform analysis to identify the heat load expected during ELAP conditions and the time required to open vents to maintain containment Started (2/2014) parameters.

36. Perform an analysis to determine when ambient heat losses will be enough to cool the containment with Shutdown Cooling (SDC) in Phase Started (2/2014) 3.

37. Evaluate a strategy to provide a pathway for steam and condensate or justify why it is not needed (for the refuel floor).

38. Perform an evaluation to determine the effects and required actions for Spent Fuel Pool temperatures expected above design of 140OF during an Started (2/2014)

ELAP.

39. Perform analysis to verify SFP temperature and level after an ELAP event Started (2/2014) and adequate level for maintaining radiological access to the refuel floor.

40. Perform an analysis of Refuel Floor/SFP area for long term environmental Started (2/2014) conditions.

41. Perform an analysis of SFP cooling system capability for restoration activities, will be performed considering that the SFP temperatures will be Deleted (8/2013) elevated

42. Evaluate the ELAP/FLEX strategy to cope with the potential pressurization of the refueling floor and to prevent buildup of steam and Started (2/2014) condensation if required.

43. Perform an analysis to evaluate long term temperature profiles in NMP1 Deleted (8/2013)

Main Control Room (MCR) under ELAP conditions. I Page 7 of 16

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

44. Evaluate requirements and options and develop strategies to maintain MCR habitability after the long-term MCR temperature profile is Deleted (8/2013) developed.

45. Perform an analysis to validate the mild environment in NMP1 EC Deleted (8/2013)

Makeup Tank Area during an ELAP (Turbine Building).

46. Perform an analysis for long term environmental conditions in NMP 1 Complete (2/2014)

Battery Rooms during an ELAP and evaluate any actions to mitigate the impact of this hydrogen production as required.

47. Perform an analysis of the need for dewatering based on leak rates and flood response capabilities and implement dewatering portable equipment Not Started and strategies based on this analysis.

48. Implement a design change to install a permanent FLEX 600 VAC diesel generator (DG) connection point to the 600 VAC power board (PB 16B) Deleted (8/2013) and an alternative connection for the opposite 600 VAC power board (PB I7B)

49. Implement a design change to install a permanent connection point for Started (8/2013)

FLEX portable pump injection through feed water.

50. Implement a design change to install permanent dry hydrants in the intake Started (2/2014) structure for FLEX portable pump suction.

51. Design and implement a modification that will provide a makeup connection to enable a portable pump to refill the Condensate Storage Deleted (8/2013)

Tanks (CSTs)

52. Evaluate and implement a design change to install permanent generator Started (2/2014) connection points for 4160 VAC.

53. Design and implement a modification that provides for connection of a Started (2/2014)

FLEX portable pump to makeup to the SFP.

54. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event to include both Not Started primary and alternate strategies.

55. Revise Station Blackout (SBO) procedures and ELAP procedures, when written, to direct that both EC's are immediately manually placed in service and to manually close Main Steam Isolation Valves (MSIVs) (to conserve RPV inventory).

56. Implement necessary administrative controls to ensure that appropriate Meter and Test (M&T) temperature equipment is maintained in the MCR Not Started for use.

57. Perform time validation of the core cooling injection capabilities when detailed design is complete, implementation procedures are drafted and Not Started final storage facility locations are determined for the portable equipment.

58. Implement a modification to provide a connection into the CRD return Added (8/2013) line for a portable diesel pump connection. (New Open Item based on strategy changes described in the August 2013 Six Month Update) Started (2/2014)

59. Implement a modification to connect a portable diesel generator and portable battery charger to battery 11 and battery 12. (New Open Item Added (8/2013) based on strategy changes described in the August 2013 Six Month Started (2/2014)

Update)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP1 OIP Open Items Status

60. Perform an evaluation in order to identify and implement the capability to provide motive power to restore the SDC system. (New Open Item added Added (8/2013) subsequent to original OIP submittal and described in the August 2013 Started (2/2014)

Six Month Update)

61. In Phase 3, a modification to remove water from the torus using RRC supplied equipment will be evaluated and implemented as required. (New Added (8/2013)

Open Item based on strategy changes described in the August 2013 Six Started (2/2014)

Month Update)

Table 3 Status of NMPI Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status

1. ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, section 5.3.3, consideration 1, which considers the possible failure of seismically qualified electrical equipment by beyond-design- Not Started basis seismic events, was not discussed in the Integrated Plan or during the audit process.

2. ISE Open Item 3.2.1.3.A - The coping strategies for maintaining core cooling were updated in the August 27, 2013 six-month update. Not Started However, the licensee has not yet updated the sequence of events timeline and the discussion of time constraints.

ISE Confirmatory Items Status

3. ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event (BDBEE) was not discussed in the Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard.

4. ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris and potential soil liquefaction. Movement of equipment and procedural Started (2/2014) interfaces during a BDBEE were not discussed in the Integrated Plan or during the audit process.

5. ISE Confirmatory Item 3.1.1.4.A - Utilization of offsite resources, the local staging area, and the method to deliver the FLEX equipment to the Started (2/2014) site were not discussed in the context of impacts of BDBEEs in the Integrated Plan or during the audit process.

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

6. ISE Confirmatory Item 3.2.1.1.A - MAAP benchmarks must be identified and discussed which demonstrate that MAAP4 is an Started (2/2014) appropriate code for the simulation of an ELAP event.

7. ISE Confirmatory Item 3.2.1.1.B - MAAP Analysis-collapsed level must remain above Top of Active Fuel (TAF) and the cool down rate Started (2/2014) must be within technical specification limits.

8. ISE Confirmatory Item 3.2.1.1.C - MAAP4 must be used in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4. 5 of the June 2013 Started (2/2014) position paper.

9. ISE Confirmatory Item 3.2.1.1.D - MAAP modeling parameters must Started (2/2014) be identified and justified.

10. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in the Started (2/2014)

Integrated Plan must be identified and should be available for review.

11. ISE Confirmatory Item 3.2.1.2.A- There was no discussion of the applicability of the assumed recirculation system leakage rates and the recirculation pump seal leakage rates to the ELAP event; the pressure Started (2/2014) dependence of the leak rates; whether the leakage was determined to be single-phase, two-phase, or steam at the donor cell; and how mixing of the leakage flow with the drywell atmosphere was modeled.

12. ISE Confirmatory Item 3.2.3.A - The licensee has yet to evaluate contaimnent integrity for Phases 1 through 3 and provide the finalized Started (2/2014) analysis for review.

13. ISE Confirmatory Item 3.2.3.B - A modification to remove water from the torus in Phase 3 using RRC supplied equipment will be evaluated and Started (2/2014) implemented as required.

14. ISE Confirmatory Item 3.2.4.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet completed. Mitigating strategies, including establishing a vent pathway for steam and Started (2/2014) condensate from the area, were not discussed in the Integrated Plan or during the audit process.

15. ISE Confirmatory Item 3.2.4.2.B - A summary of battery performance with elevated or lowered temperatures in the Battery Room due to an Started (2/2014)

ELAP event will be provided in the future update.

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

16. ISE Confirmatory Item 3.2.4.4.A - The restoration of Emergency Lighting in Phase 2, that may be restored when Battery Board 12 is repowered, is currently under evaluation (i.e. battery loading calculation Started (2/2014) for ELAP). NMP1 will provide a summary of the restoration of Emergency Lighting in a future update.

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of commitments as discussed in the staff analysis (ML13100A236) for communications Not Started assessment is required.

18. ISE Confirmatory Item 3.2.4.6.A - Licensee to provide calculation and basis for use of extrapolated SBO evaluation for Main Control Room Not Started habitability.

19. ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is completed, the specific details on the protection schemes to protect Class IE equipment Started (2/2014) from faults from the portable FLEX equipment will be provided in a future update.

20. ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an updated summary of the sizing calculations for the FLEX generators at a Started (2/2014) future update.

21. ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a summary of the refueling strategies for FLEX equipment will be provided when Started (2/2014) finalized at a future date.

22. ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, DC load profile, discussion of loads Started (2/2014) shed, and minimum DC voltage will be provided in a future update.

23. ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan or during the Started (2/2014) audit process.

24. ISE Confirmatory Item 3.4.B - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant connection Started (2/2014) points was not discussed in the Integrated Plan or during the audit process.

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NMP1 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 Communications Assessment Interim Action Implementation 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.

Table 4 Status of NMPI Communications Assessment Interim Actions Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Fixed Satellite Phones

1. Determine the status of existing 12/31/2013 Complete fixed satellite phone system and (2/2014) antennas in terms of suitability of being "Reasonably Protected."

2. Install additional antennas as 8/31/2014 Not Started necessary to support the use of fixed satellite phones at all locations. (Emergency Operations Center (EOF) / Joint Information Center (JIC)).

3. Procure and install fixed satellite 12/31/2014 Not Started phones, additional antennas and uninterruptable power supplies for the Technical Support Center (TSC) / Operational Support Center (OSC), Emergency Operations Facility (EOF), and JIC.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

4. Develop Standing Order for 8/31/2013 Complete (2/2014)

Interim actions.

Standing Order will contain:

" Description of the communications equipment purchased for enhancement.

Interim storage location of the equipment until final permanent storage is determined.

Conditions describing when equipment will be used.

" Instructions for use of the equipment.

5. Determine whether APC UPS 750 12/31/2013 Complete (2/2014) is high enough above ground elevation in the On-Site Telephone Building to be protected from flooding.

6. Relocate two (2) phones from each 8/31/2014 Not Started Control Room to the TSC/OSC and EOF.

7. Develop/update preventative 8/31/2014 Not Started 12/26/2014 maintenance and testing Date changed to be procedures for fixed satellite consistent with phones. plans to move/install the fixed satellite phones in all locations

8. Provide instructions for use of 12/31/2014 Not Started fixed satellite phones at each location.

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NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

9. Include information on fixed 12/31/2013 Started (2/2014) 10/31/2014 satellite phone locations and usage Date changed to be in procedures. consistent with plans to move/install the fixed satellite phones in all locations Portable Satellite Phones

1. Stage batteries and chargers in the 10/31/2013 Complete (2/2014) applicable Emergency Response Organization (ERO) Facilities.

2. Update work instructions for 10/31/2013 Complete (2/2014) portable satellite phone inventory.

3. Develop/update preventive 12/31/2013 Started (2/2014) maintenance and testing 2/28/2014 procedures for portable satellite phones, batteries and chargers.

4. Include information on portable 12/31/2013 Complete (2/2014) satellite phone locations and usage 2/14/2014 in procedures.

5. Procure and install a high power 12/31/2014 Not Started UPS or similar modification providing backup power for the battery chargers for portable satellite phones Communications with Offsite Response Organizations I. Provide Oswego County 10/31/2013 Complete (2/2014)

Emergency Operations Center (EOC) and Oswego County Warning Point (WP) instructions for proper storage and rotation of satellite phone batteries.

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NMPI SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Portable Generators

1. Develop portable generator fueling 12/31/2013 Complete (2/2014) plan to ensure ability to provide power for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Develop procedures to maintain 12/31/2013 Complete (2/2014) 1/31/2014 and test the portable generators.

3. Update work instructions to 12/31/2013 Complete (2/2014) inventory portable generators and 1/31/2014 ensure adequate volume of fuel.

4. Develop preventive maintenance 12/31/2013 Complete (2/2014) procedure for portable generators 1/31/2014 fuel supply.

5. Determine a process for relocating Prior to Startup Not Started portable generators to the (S/U) NMP1 appropriate locations to power the RFO 2015 necessary equipment.

Site Radio System

1. Procure and install a high power Prior to S/U Not Started UPS or similar modification NMPI RFO providing backup power for the 2015 radio system repeaters

2. Complete estimates of portable 10/31/2013 Complete (2/2014) radio battery life and procure additional batteries as necessary based on an estimate of minimum talk time to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation.

Training

1. Evaluate training needs specific to Prior to S/U Not Started the use of portable and fixed NMPI RFO satellite phones, and radios during 2015 an ELAP event.

2. Develop and implement training Prior to S/U Not Started on the use of backup generators. NMP1 RFO 2015 Page 15 of 16

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NMP1 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 9 References The following references support the updates to the OIP described in this enclosure.

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.

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

3. 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), 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.

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units I and 2 -

Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130), dated December 19, 2013.

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NMP2 6-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Constellation Energy Nuclear Group, LLC February 27, 2014

ATTACHMENT (4)

NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The Nine Mile Point Unit 2 (NMP2) 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 NMP2 0IP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment 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 applicable).

NMP2 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 the NMP2 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.

Since the submittal of the last status report in August 2013 (Reference 6), NMP2 FLEX has progressed with some engineering analysis and calculations that support the mitigating strategies and the modification concepts have been refined. However, no significant changes to the mitigation strategies or planned modifications in support of the mitigation strategies have occurred. Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued with review of proposed supporting equipment specifications and participation on committees that have been assembled to identify and provide specific needs.

By letter dated December 19, 2013, the NRC issued to CENG the Nine Mile Point Nuclear Station, Units I and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7). The Interim Staff Evaluation (ISE) contains open and confirmatory items for which CENG will provide clarifying or additional information in six-month status reports in order for the NRC to determine that the issues are on a path to satisfactory resolution.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (References 1 and 3) and are current as of January 17, 2014; 0 Six month integrated plan progress report submitted (8/2013).

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMP20OIP (Attachment 3 - 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 following 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 NMP2 FLEX OIP Milestones Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Implementation February 2013 Complete Plan 6 Month Integrated Plan Progress Report August 2013 Complete Engineering and Design Completion - January 2014 Started July 2014' Equipment Storage Facility 6 Month Integrated Plan Progress Report February 2014 Complete Refueling outage April 2014 Not Started 6 Month Integrated Plan Progress Report August 2014 Not Started Engineering and Design Completion - November 2014 Started Portable Equipment Connections 6 Month Integrated Plan Progress Report February 2015 Not Started Equipment Storage Facility installation June 2015 Not Started May 20151 6 Month Integrated Plan Progress Report August 2015 Not Started Non-outage Installation - Portable January 2016 Not Started Equipment Connection 6 Month Integrated Plan Progress Report February 2016 Not Started Validation walk downs complete February 2016 Not Started Portable Equipment Procedures Changes March 2016 Not Started FLEX Training March 2016 Not Started Page 2 of 16

ATTACHMENT (4)

NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Target Revised Target Milestone Completion Activity Status Completion Date Date Refueling outage April 2016 Not Started Outage Installation - Portable Equipment May 2016 Not Started Connections Final Implementation Notification to July 2016 Not Started USNRC Note': Change since submittal of last six month integrated plan status report in August 2013.

4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last six month status report.

The following is a list of the open items from the OIP or the NRC's ISE that have been added, deleted or completed, and of coping strategies that have been changed from the last six month status report with an explanation of the changes:

1. General Integrated Plan Elements Boiling Water Reactor (BWR)

Open Item 1: Define criteria for the local (25 mile) staging area.

This open item is complete. SAFER issued the SAFER Response Plan (playbook) Revision 1 on August 15, 2013. The SRP contains detailed criteria for staging areas in Chapter 5, "Staging Area Procedure" and Chapter 8, "Requirements and Basis."

NRC Order EA-12-050, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents has been superseded by Order EA-13-109. Full implementation of Order EA-13-109 is not required for NMP2 until the 2018 refueling outage.

Remaining design specifications and requirements and strategy revisions will be determined upon completion of the final design.

No significant coping strategy changes have occurred since the previous six month status update provided on August 28, 2013 (Reference 6).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation NMP2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 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. Explanations for added, deleted and completed items are provided in Section 4.

Table 3 provides a summary of the open and confirmatory items documented in the NRC's NMP2 ISE (Reference 7) and the status of each item.

Table 2 Status of NMP1 FLEX OIP Open Items NMP2 OIP Open Items Status

1. Define criteria for the local (25 mile) staging area. Complete (2/2014)

2. Evaluate deployment strategies and deployment routes for hazard impact. Started (2/2014)

3. Evaluate requirements and options and develop strategies related to the storage on site of the FLEX portable equipment (including lighting tools such Started 8/2013 as flashlights and batteries) in accordance with the requirements of NEI 12-06.

4. Exceptions for the site security plan or other (license/site specific -

10 CFR 50.54x) requirements of a nature requiring NRC approval will be Started (8/2013) communicated in a future 6-month update following identification.

5. Determine schedule for when Regional Response Centers (RRCs) will be Complete (8/2013) fully operational.

6. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the dry Started (2/2014) hydrants will consider Phase 2 requirements.

7. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the dry Started (8/2013) hydrants will consider Phase 3 requirements.

8. Perform calculations and validate assumptions of fuel consumption and replenishment rate to ascertain the time before off-site replenishment is Started (8/2013) required.

9. Perform an evaluation of the Uninterruptible Power Supply (UPS) strategy and design and implement as required or formalize the use of the small Started (2/2014) portable gas generators (communication strategies).

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP2 OIP Open Items Status

10. Perform an evaluation of the redundant power strategy for radio repeaters and Started 2/2014 design and implement modifications or programmatic changes as required.

11. Verify plans for the FLEX storage facilities in accordance with NEI 12-06 requirements also accommodate the storage and availability of fuel for the Started (8/2013) small gas generators.

12. Perform an analysis for feasibility of utilizing the sound powered Started (2/2014) communications for onsite communications for FLEX strategies.

13. Evaluate required consumables and options for storage and availability during an ELAP and implement programmatic controls to ensure required inventory Not Started is maintained.

14. Establish deployment routes from FLEX equipment storage location to Started (2/2014) connection points (including hazards impacts).

15. Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site. Started (8/2013)

SAFER Staging Area "C"

16. Establish a suitable local staging area for Phase 3 portable FLEX equipment to be deployed on site. Started (8/2013)

SAFER Staging Area "B"

17. Provide the necessary storage facilities in order to provide fuel to the transfer Not Started pumps during an ELAP event.

18. Develop site specific SAFER Response Plan (playbook) for delivery of Started (8/2013) portable FLEX equipment fromn the RRC to the site.

19. Develop and implement a program and/or procedures to keep FLEX equipment deployment pathways clear or identify actions to clear the Not Started pathways.

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM) recommendation and Started (8/2013)

Electric Power Research Institute (EPRI) guidelines for FLEX equipment.

21. Evaluate and implement procedures that direct immediate deployment of Started (2/2014)

Phase 2 equipment during Refueling conditions.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP2 OIP Open Items Status

22. Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport FLEX portable Not Started equipment during all modes of operation.

23. Develop procedures/guidelines to address the criteria in NEI 12-06 to support existing symptom based strategies in the Emergency Operating Procedures Started (2/2014)

(EOPs).

24. Evaluate potential soil liquefaction for Nine Mile Point site considering final storage location of FLEX portable equipment and deployment routes Started (8/2013) established for this equipment.

25. Evaluate requirements and options and develop strategies related to the Started (2/2014) storage and transport of the on-site FLEX portable equipment.

26. Implement a design change to Reactor Core Isolation Cooling (RCIC) that will support operation of the system at elevated Suppression Pool temperatures as identified in GEH 000-0155-1545 (BWROG RCIC Pump and Turbine Durability Evaluation - Pinch Point Study)

27. Perform an analysis of long term RCIC Room temperatures (for equipment qualification and habitability) under ELAP conditions considering elevated Started (2/2014)

Suppression Pool and Secondary Containment temperatures.

28. Perform an evaluation of containment structures to identify necessary actions to enable implementation of the strategy with running RCIC with elevated Not Started temperatures.

29. Perform additional plant specific analysis to verify acceptable Suppression Pool levels during a long term operation of RCIC beginning with suction from Not Started the Condensate Storage Tanks (CSTs). Verify containment limitations are not exceeded.

30. Perform an analysis to verify acceptable parameters (e.g., Net Positive Suction Head (NPSH) requirements) for RCIC operation with the higher temperatures Not Started and anticipated changes in Suppression Pool level.

31. Perform an analysis to validate containment vent sizing to maintain Started (2/2014)

Suppression Pool parameters to support RCIC capability.

32. Perform an analysis to identify necessary actions, (e.g., modifications or programmatic changes) to maximize battery coping time to at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

33. Evaluate NMP2 containment integrity for Phases 1 through 3 and update Not Started calculations.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP2 OIP Open Items Status

34. Implement an alternative Containment Cooling strategy, if required, when the Not Started analysis of structural temperatures are complete.

35. Perform an analysis to determine the containment pressure profile during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and verify the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function.

36. Perform an analysis to determine when ambient heat losses will be low enough such that with Residual Heat Removal (RHR) in a Phase 3 mode of Not Started shutdown cooling, venting of the primary containment will no longer be required.

37. Perform an analysis to verify assumptions related to an adequate nitrogen supply during ELAP conditions and revise or provide ELAP procedures that Not Started optimize Safety Relief Valve (SRV) control during an ELAP condition.

38. Perform an analysis to verify the capability of the portable diesel generator Started (2/2014)

(DG) to power all expected loads.

39. Perform an analysis to determine the limiting conditions for an RHR loop to be restarted (e.g., RHR room, seals and fluid temperatures) and adjust the strategy to start in Shutdown Cooling (SDC) based on the results of the analysis.

40. Perform a load distribution analysis for safety related equipment restoration utilizing either two RRC DGs paralleled on one 4160 VAC bus or one RRC Deleted (8/2013)

DG on each safety related bus (i.e., one on Division 1 and one on Division 2).

41. Perform an analysis to determine the service water cooling water flow needed to accommodate all expected cooling loads and resulting RRC pump size Deleted (8/2013) requirement.

42. Evaluate a strategy to provide a vent pathway for steam and condensate from Started (2/2014) the SFP or justify why it is not needed.

43. Perform an evaluation to determine the effects and required actions for Spent Not Started Fuel Pool temperatures expected above design of 150'F during an ELAP.

44. Perform analysis to verify SFP temperature and level after an ELAP event and Started (2/2014) adequate level for maintaining radiological access to the refuel floor.

45. Perform an analysis to evaluate long term temperature profiles in the NMP2 Deleted (8/2013)

Main Control Room (MCR) under ELAP condition (Phase 1).

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP2 OIP Open Items Status

46. Perform an analysis for long term environmental conditions in the NMP2 Battery Rooms during an ELAP and evaluate any actions to mitigate the Started (2/2014) impact of this hydrogen production as required.

47. Evaluate the strategy for repower of select Emergency Lighting loads when Started (2/2014) the FLEX portable DG reenergizes the 600 VAC bus.

48. Perform an analysis of the light coverage during ELAP conditions and determine if the lighting loads should be re-energized from the non-safety Started (2/2014) related buses by the RRC FLEX generator.

49. Perform an analysis of the need for dewatering based on leak rates and flood Not Started response capabilities.

50. Implement a design change to install permanent 4160 VAC buss connection points to be able to connect to the RRC supplied DG, including paralleling Not Started capability, as required to connect more than one DG to an electrical bus.

51. Implement a design change to receive large capacity RRC pumps to supply Not Started the service water distribution header.

52. Design and implement a modification that provides for connection of a FLEX Not Started portable pump to makeup to the SFP.

53. Implement a design change to install connections for FLEX portable pumps to Not Started RHR for both RHR 'A' and 'B'.

54. Implement a design change to install portable generator connections for 600 VAC primary (2EJS*US 1) and alternate (2EJS*US3) busses.

55. Revise procedures to provide reactor pressure control direction during an Not Started ELAP event.

56. Develop and implement procedure direction to ensure that the Main Turbine Not Started Hydrogen is vented prior to battery depletion.

57. Revise current EOPs to implement EOP actions necessary to support the strategy to terminate emergency depressurization to preserve RCIC operation.

58. Develop and implement procedures to provide direction for re-energizing the Solenoid Operated Valves (SOVs) and ensuring long term pneumatic supply Not Started during an ELAP.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP2 OIP Open Items Status

59. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event to include both primary and Not Started alternate strategies.

60. Develop and implement procedures that provide direction for restoration of Deleted (8/2013)

SFP cooling during ELAP conditions (Phase 3).

61. Implement a design change to install permanent dry hydrants in the intake Not Started structure for FLEX portable pump suctions.

Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status

1. ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, section 5.3.3, consideration 1, which considers the possible failure of seismically qualified electrical equipment by beyond-design- Not Started basis seismic events, was not discussed in the Integrated Plan or during the audit process.

2. ISE Open Item 3.2.3.B - The licensee has not performed finalized calculations to demonstrate that the assumed timeline is appropriate and Started (2/2014) that containment functions will be restored and maintained following an ELAP event.

3. ISE Open Item 3.2.3.C - Revision 3 to the [Boiling Water Reactor Owner's Group] BWROG Emergency Procedure Guidance (EPG)

Severe Accident Guidance (SAG) is a Generic Concern because the BWROG has not addressed the potential for the revised venting strategy Not Started to increase the likelihood of detrimental effects on containment response for events in which the venting strategy is invoked. (identified as a

'Significant Concern' in the Notes for this Open Item in the ISE)

ISE Confirmatory Items Status

4. ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event Started (2/2014)

(BDBEE) was not discussed in the Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

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

5. ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris and potential soil liquefaction. Movement of equipment and procedural interfaces during a BDBEE were not discussed in the Integrated Plan or Started (2/2014) during the audit process. Deployment of temporary flood barriers, restocking of supplies in the context of a flood with long persistence, and the potential impact of surface icing were also not addressed.

6. ISE Confirmatory Item 3.1.1.4.A - Concerning utilization of offsite resources during a BDBEE, the local staging area and access routes were Started (2/2014) not discussed in the Integrated Plan or during the audit process.

7. ISE Confirmatory Item 3.2.1.1.A - MAAP benchmarks must be identified and discussed which demonstrate that MAAP4 is an Started (2/2014) appropriate code for the simulation of an ELAP event.

8. ISE Confirmatory Item 3.2.1.1.B - MAAP Analysis-collapsed level must remain above Top of Active Fuel (TAF) and the cool down rate Started (2/2014) must be within technical specification limits.

9. ISE Confirmatory Item 3.2.1.1.C - MAAP4 must be used in accordance with Sections 4.1,4.2, 4.3, 4.4, and 4. 5 of the June 2013 Started (2/2014) position paper.

10. ISE Confirmatory Item 3.2.1.1.D - MAAP modeling parameters. Started (2/2014)

11. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in the Started (2/2014)

Integrated Plan must be identified and should be available for review.

12. ISE Confirmatory Item 3.2.1.2.A - There was no discussion of the applicability of the assumed recirculation system leakage rates and the recirculation pump seal leakage rates to the ELAP event; the pressure Not Started dependence of the leak rates; whether the leakage was determined to be single-phase, two-phase, or steam at the donor cell; and how mixing of the leakage flow with the drywell atmosphere was modeled.

13. ISE Confirmatory Item 3.2.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet completed. Mitigating Started (2/2014) strategies were not discussed in the Integrated Plan or during the audit process.

14. ISE Confirmatory Item 3.2.3.A - Perform an evaluation of containment structures to identify necessary actions to enable implementation of the strategy with running RCIC with elevated temperatures.

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

15. ISE Confirmatory Item 3.2.4.2.A - The completion and determination of acceptable results for all of the calculations associated with the proposed strategies for ventilation and critical equipment cooling (e.g.,

RCIC and battery rooms) are required.

16. ISE Confirmatory Item 3.2.4.4.A - The potential restoration of a portion of the Emergency Lighting System when Division 1 600 Vac Unit Substation 2EJS*US I (or alternatively Division 11 2EJS*US3) is Not Started repowered is currently under evaluation. NMP2 will provide a summary of the restoration of Emergency Lighting expected to be restored in a future update.

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of communication commitments as discussed in the staff analysis (ML13100A236) is Not Started required.

18. ISE Confirmatory Item 3.2.4.6.A - Licensee to provide calculation and basis for use of extrapolated station blackout (SBO) evaluation for Main Started (2/2014)

Control Room habitability.

19. ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is completed, the specific details on the protection schemes to protect Class 1E equipment Not Started from faults from the portable FLEX equipment will be provided in a future update.

20. ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an updated summary of the sizing calculations for the FLEX generators at a Not Started future update.

21. ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a summary of the refueling strategies for FLEX equipment will be provided when Started (2/2014) finalized at a future date.

22. ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, dc load profile, discussion of loads Not Started shed, and minimum dc voltage will be provided in a future update.

23. ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan or during the Not Started audit process.

24. ISE Confirmatory Item 3.4.8 - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant connection points was not discussed in the Integrated Plan or during the audit process.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 Communications Assessment Interim Action Implementation 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.

Table 4 Status of NMP2 Communications Assessment Interim Actions Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Fixed Satellite Phones

1. Determine the status of existing 12/31/2013 Complete (2/2014) fixed satellite phone system and antennas in terms of suitability of being "Reasonably Protected."

2. Install additional antennas as 8/31/2014 Not Started necessary to support the use of fixed satellite phones at all locations. (Emergency Operations Center (EOF) / Joint Information Center (JIC)).

3. Procure and install fixed satellite 12/31/2014 Not Started phones, additional antennas and uninterruptable power supplies for the Technical Support Center (TSC) / Operational Support Center (OSC), Emergency Operations Facility (EOF), and JIC.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

4. Develop Standing Order for 8/31/2013 Complete (2/2014)

Interim actions.

Standing Order will contain:

" Description of the communications equipment purchased for enhancement.

Interim storage location of the equipment until final permanent storage is determined.

Conditions describing when equipment will be used.

Instructions for use of the equipment.

5. Determine whether APC UPS 750 12/31/2013 Complete (2/2014) is high enough above ground elevation in the On-Site Telephone Building to be protected from flooding.

6. Relocate two (2) phones from each 8/31/2014 Not Started Control Room to the TSC/OSC and EOF.

7. Develop/update preventative 8/31/2014 Not Started 12/26/2014 maintenance and testing Date changed to be procedures for fixed satellite consistent with phones. plans to move/install the fixed satellite phones in all locations

8. Provide instructions for use of 12/31/2014 Not Started fixed satellite phones at each location.

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NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

9. Include information on fixed 12/31/2013 Started (2/2014) 10/31/2014 satellite phone locations and usage Date changed to be in procedures. consistent with plans to move/install the fixed satellite phones in all locations Portable Satellite Phones

1. Stage batteries and chargers in the 10/31/2013 Complete (2/2014) applicable Emergency Response Organization (ERO) Facilities.

2. Update work instructions for 10/31/2013 Complete (2/2014) portable satellite phone inventory.

3. Develop/update preventive 12/31/2013 Started (2/2014) maintenance and testing 2/28/2014 procedures for portable satellite phones, batteries and chargers.

4. Include information on portable 12/31/2013 Complete (2/2014) satellite phone locations and usage 2/14/2014 in procedures.

5. Procure and install a high power 12/31/2014 Not Started UPS or similar modification providing backup power for the battery chargers for portable satellite phones Communications with Offsite Response Organizations

1. Provide Oswego County 10/31/2013 Complete (2/2014)

Emergency Operations Center (EOC) and Oswego County Warning Point (WP) instructions for proper storage and rotation of satellite phone batteries.

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ATTACHMENT (4)

NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Portable Generators

1. Develop portable generator fueling 12/31/2013 Complete (2/2014) plan to ensure ability to provide power for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Develop procedures to maintain 12/31/2013 Complete (2/2014) 1/31/2014 and test the portable generators.

3. Update work instructions to 12/31/2013 Complete (2/2014) inventory portable generators and 1/31/2014 ensure adequate volume of fuel.

4. Develop preventive maintenance 12/31/2013 Complete (2/2014) procedure for portable generators 1/31/2014 fuel supply.

5. Determine a process for relocating Prior to Startup Not Started portable generators to the (S/U) NMP1 appropriate locations to power the RFO 2015 necessary equipment.

Site Radio System

1. Procure and install a high power Prior to S/U Not Started UPS or similar modification NMP 1 RFO providing backup power for the 2015 radio system repeaters

2. Complete estimates of portable 10/31/2013 Complete (2/2014) radio battery life and procure additional batteries as necessary based on an estimate of minimum talk time to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation.

Training

1. Evaluate training needs specific to Prior to S/U Not Started the use of portable and fixed NMP 1 RFO satellite phones, and radios during 2015 an ELAP event.

2. Develop and implement training Prior to S/U Not Started on the use of backup generators. NMPI RFO 2015 Page 15 of 16

ATTACHMENT (4)

NMP2 SIX-MONTH STATUS REPORT (FEBRUARY 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 9 References The following references support the updates to the OIP described in this enclosure.

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.

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

3. 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), 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.

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units 1 and 2 -

Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130), dated December 19, 2013.

Page 16 of 16

v t e Letter Sequence Other
TAC:MF1140, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance Supplement Administration Questions 19 June 2013 25 September 2013 Answers 3 July 2013 Results Approval Other: ML12311A017, ML13254A278, ML13338A646, ML14069A318, ML14224A477, ML14302A174, RS-15-099, Report of Full Compliance with 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), RS-16-028, Sixth 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), RS-16-032, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
MONTHYEAR2013-08-27 [Table View]

ML14069A318

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