CP-201400244, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14071A008
Person / Time
Site:	Comanche Peak
Issue date:	02/27/2014
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201400244, EA-12-049, TAC MF0860, TAC MF0861, TXX-14025
Download: ML14071A008 (12)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael.flores@luminant.com Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201400244 REF 10 CFR 2.202 Log # TXX-14025 February 27, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC NOS. MF0860 and MF0861)

REFERENCES:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Luminant Generation Company LLC's Letter TXX-12158, Initial Status Report in Response to March 12, 2012 Conmmission Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External events (Order Number EA-12-049), dated October 25, 2012

5. Luminant Generation Company LLC's Letter TXX-13030, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External events (Order Number EA-12-049), dated February 28, 2013

Dear Sir or Madam:

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

1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

A member of the STARS Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek Av5'

U. S. Nuclear Regulatory Commission TXX-14025 Page 2 of 2 02/27/2014 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference

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

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

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

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

Executed on February 27, 2014.

Sincerely, Luminant Generation Company LLC Rafael Flores

/Fred W. Madden Director, External Affairs

Attachment:

Comanche Peak Nuclear Power Plant (CPNPP) Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design- Basis External Events c- Eric J. Leeds, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Nuclear Power Plant

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 1 of 10 Mitigation Strategies for Beyond-Design-Basis External Events Comanche Peak Nuclear Power Plant (CPNPP) Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Comanche Peak Nuclear Power Plant (CPNPP) developed an Overall Integrated Plan (Reference 1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan and first Six Month Status Report (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of February 20, 2014.

• FLEX Strategy Evaluation - Complete

• Modifications Evaluations - Complete

• Procedures - PWROG issues NSSS-specific guidelines - Complete

3. Milestone Schedule Status The following table provides an update to Attachment 2 of the Overall Integrated Plan (OIP). 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.

Note, italicized items in the following table were not provided as milestone items in Attachment 2 of the OIP. However, these items are added here for consistency with the 6 month status update template and will be carried forward in future 6 month status updates.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 2 of 10 Mitigation Strategies for Beyond-Design-Basis External Events Target Revised Target Milestone Completion Activity Status Completion Date* Date*

Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Aug 2013 Complete Walk-throughs or Demonstrations Apr 2015 Not Started Perform Phase 2 Staffing Analysis Jun 2014 Started Modifications:

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

Storage Design Engineering Mar 2014 Started Storage Implementation Oct 2014 Started FLEX Equipment:

Procure On-Site Equipment Ju12014 Started Develop "Playbook" with RRC Nov 2013 Started Apr 2014 Install Off-Site Delivery Station (if Not Required Not Required Not Required Necessary)

Regional Response Center Operational Aug 2014 Started Procedures:

PVVAROG issues NSSS-specific guidelines May 2013 Complete Issue FSGs Aug 2014 Started Create Maintenance Procedures Ju12014 Started Training:

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

• Dates are potentially impacted by schedule relief request (Reference 5) discussed in Section 5.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 3 of 10 Mitigation Strategies for Beyond-Design-Basis Externat Events

4. Changes to Compliance Method The following are either changes to the compliance method or clarifications of the staff's understanding of the OIP, as documented in the Interim Staff Evaluation (Reference 4) and are in addition to those identified in the First Six Month Status Report (Reference 3).

Auxiliary Building Connections for Spent Fuel Pool Cooling Further evaluation has concluded that the two connections located inside the Fuel Building are sufficient to successfully perform the primanj strategy for spent fuel pool cooling. Modifications to credit the additional connections from the Auxiliary Building through associated penetrations will not be performed. The Auxiliary Building connections are discussed on pages 9 and 16 of Reference 4. The secondary strategy continues to credit the two external connections and penetrations through the east wall of the Fuel Building such that building access is not required for successful performance of the secondanj strategy.

Residual Heat Removal (RHR) System Restoration in Phase 3 Further review has concluded that the preferred method for maintaining core cooling in Phase 3 is continued steaming of the steam generators as fed by the turbine driven AFW pump, the Phase 2 steam generator FLEX pump, or the Phase 3 backup pump. Full restoration of RHR in Phase 3 will not be performed. Rather, RHR system alignment will be pursued but an RHR pump will not be placed into service until the transition from Phase 3 to recovery occurs. The previous strategy is discussed on pages 10, 45 and 53 of Reference 4.

Phase 3 4160V Generator Sizing Because the restoration of RHR is no longer credited for indefinite coping, the required capacity of the Phase 3 4160V generators is reduced. Conceptual design concludes two 1 MW 4160V generators per unit are sufficient for performance of Phase 3 strategies. Luminant is awaiting confirmation from the equipment vendor regarding acceptability of the proposed load sequencing. The previous strategy is discussed on pages 10 and 55 of Reference 4.

Source Range Instrumentation As discussed on pages 11 and 37 of Reference 4, readings for the core exit thermocouples (CETs) and reactor vessel level instrumentation system (RVLIS) cannot be taken locally. This limitation also applies to the source range instrumentation.

Stored Debris Removal Equipment Equipment intended to facilitate debris removal stored within the protected storage building has changed. Rather than two Pettibones, as described on pages 21 and 50 of Reference 4, the stored debris removal equipment will consist of one four-wheel drive capable Pettibone and one track-loader (Bobcat).

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 4 of 10 Mitigation Strategies for Beyond-Design-Basis External Events Reactor Coolant System Cooldown Installation of low-leakage reactor coolant pump seals (SHIELD) supports acceptability of delaying initiation of the reactor coolant system (RCS) cooldown for approximately twelve hours post-Extended Loss of AC Power (ELAP). However, CPNPP has modified this approach (delayed cooldown) and now intends to complete RCS cooldown within four hours post-ELAP.

This change maintains consistency with the current Station Blackout response, and ensures all important instrumentation powered by the station batteries remain available during the RCS cooldown. Additionally, this change ensures the steam generator atmospheric relief valves can be controlled remotely from the control room for the duration of the RCS cooldown. The previous strategy is discussed on pages 29, 32, 34, and 40 of Reference 4.

Declaration of ELAP Review of the latest revision of the Emergency Response Guidelines Footnote Basis Document indicates declaration of ELAP should be performed within the licensed station blackout coping time, four hours for CPNPP. Further review of the expected plant conditions following an ELAP with licensed Senior Reactor Operator personnel confirms four hours is appropriate for ELAP declaration. CPNPP will declare ELAP within four hours of initiation rather than the one hour documented on page 38 of Reference 4.

Loss of Ventilation to Inverter Rooms Further evaluation of expected inverter room temperatures during an ELAP indicates that timely deployment of forced ventilation is required to maintain equipment functionality. At five and a half hours after ELAP initiation, the doors to the inverter rooms will be blocked open, and at eighteen hours after ELAP initiation, forced ventilation using portable generators and fans will be deployed. The previous strategy is discussed on pages 39 and 47 of Reference 4.

Pump Staging for Makeup from the Safe Shutdown Impoundment (SSI)

The FLEX pump designated for tank makeup from the SSI will be deployed to and staged near the Service Water Intake Structure. This change will facilitate access to the SSI and ensures the pump/eductor arrangement will draw suction from deep water. The previous strategy to deploy the pump to the SSI dam is discussed on pages 41, 42 and 53 of Reference 4.

Battery Packs As previously discussed, the restoration of RHR in Phase 3 is no longer the strategy for maintaining core cooling. However, the alignment of RHR, including opening and closing valves, can be accomplished using power available in Phase 3; therefore, battery packs will not be purchased or used during the alignment of RHR. The previous strategy for use of battery packs is discussed on pages 45 and 53 of Reference 4.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 5 of 10 Mitigation Strategies for Beyond-Design-Basis External Events Station Battery Life Contrary to pages 48, 57 and 58 of Reference 4, no single train of station battery is expected to last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The reduction in battery coping is primarily the result of implementation of the guidance and restrictions posed in the NEI position paper entitled "Battery Life Issue" (ADAMS Accession ML13241A186) as endorsed by the NRC in ML13241A188. Battery coping calculation revisions are being prepared with preliminary results indicating 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> coping for all station batteries. The battery coping calculations will be provided via the virtual audit response process following completion.

480V Generator Sizing Conceptual design indicates that a single 500kW 480VAC generator is sufficient to power three battery chargers per unit, two battery room exhaust fans per unit, and one high-pressure RCS injection pump per unit. The associated connected loading and fraction of generator maximum loading discussed on page 55 of Reference 4 will necessarily increase, however, the generator sizing of 500kW remains sufficient. The associated generator sizing calculation has not been completed. The sizing calculation will be provided via the virtual audit response process following completion.

Because the station batteries are expected to deplete at approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (pending calculation completion), the 480VAC generator will be deployed and connected within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of ELAP initiation. This earlier deployment is considered achievable.

Fuel Oil Day Tanks Additional walkdowns have concluded that fuel stored in the Fuel Oil Day Tanks cannot be readily accessed without piping modifications. The small volume of fuel stored in the day tanks, relative to the underground storage tanks, does not warrant performance of the piping modification. Therefore, the Fuel Oil Day Tanks will not be credited in the FLEX strategies. The previous intended use of the day tanks is discussed on page 56 of Reference 4.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 6 of 10 Mitigation Strategies for Beyond-Design-Basis External Events From Reference 4, the following were identified as items requiring additional discussion in the Second Six Month Status Report.

FLEX Storage Building Phase 2 equipment, not otherwise stored within protected structures inside the protected area, will be stored within a single FLEX storage building designed to protect against all external events including safe shutdown earthquake and design basis tornado winds and associated missiles. One N+1 pump currently stored in a "non-protected" structure within the protected area is excluded from the above storage plan.

Debris removal equipment and tow equipment required for Phase 2 equipment deployment will be stored within the FLEX storage building, located as depicted in Figure A3-35 of Reference 3.

CPNPP is not susceptible to extreme snowfall, however, the site can be subjected to ice storms for short durations. Existing severe weather procedures provide guidance for mitigation of icy site roads which include maintaining the capability to spread sand over site roadways (including credited deployment pathways) to enhance equipment traction.

For proper storage environment, the storage building will be provided with forced ventilation and heating, as appropriate. The FLEX storage building clarification request is documented on pages 10 and 24 of Reference 4.

Dry Site Clarification The CPNPP probable maximum flood (PMF) level is based on the guidelines of RG 1.102 and is the same as the definition of Design Basis Flood Level (DBFL) in NEI 12-06 Section 6.2.1. At a current licensing basis PMF level of 789.7 feet, CPNPP is considered a dry site. Even under Recommendation 2.1 re-evaluation conditions the most limiting site PMF level given the spectrum of scenarios evaluated is still less than the proposed FLEX equipment storage and staging areas including onsite deployment paths. Thus, the plant site is not susceptible to external flooding events. The dry site clarification request is documented on page 13 of Reference 4.

Load Shedding Scheme As discussed previously, calculations to determine battery coping time are being prepared.

Assumed load shedding includes the loads documented in ECA-0.OA/B as well as additional load shedding to maximize battery life during an ELAP. The requested information from the battery calculations including load shedding scheme will be provided to the staff via the virtual audit response process following completion. The load shedding scheme request is documented on page 59 of Reference 4, as Confirmatory Item 3.2.4.10.A of Reference 4 and as Audit Question 37.

Regional Response Center (RRC) Resources and Agreements The requested information regarding agreements for mobilization and deployment of off-site resources to sustain and backup the site's coping strategies, as documented on page 64 of Reference 4, will be provided following approval of the RRC Strategic Alliance for Flex Emergency Response (SAFER) Response Plan (otherwise referred to as the RRC Playbook). As noted in the Milestone Schedule above, the target completion date for the Playbook is now scheduled for April 2014. Luminant has provided the site specific input to the RRC regarding the Playbook and is awaiting RRC incorporation.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 7 of 10 Mitigation Strategies for Beyond-Design-Basis External Events The following position papers as endorsed by the NRC will be used by Luminant in support of FLEX strategy development. Any exceptions to the NRC endorsed guidance will be communicated to the staff via the virtual audit process.

Battery Coping The guidance provided in the position paper entitled "Battery Life Issue" (ML13241A186) as endorsed by ML13241A188 will be used to support the performance of ELAP battery coping calculations.

Shutdown / Refueling Modes The guidance provided in the position paper entitled "Position Paper: Shutdown / Refueling Modes" (ML13273A514) as endorsed by ML13267A382 will be used to support the development of the shutdown mode FLEX strategies.

MAAP The guidance provided in the position paper entitled "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications" (ML13190A201) as endorsed by ML13275A318 will be used to support the performance of ELAP containment analyses.

Boron Mixing The guidance provided in the position paper entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)" (ML13235A135) as endorsed by ML13276A183 will be used to support the performance of analyses confirming subcriticality during an ELAP event.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation The Lumninant response (Reference 1) stated that CPNPP Units 1 and 2 are crediting use of low-leakage RCP seals in the FLEX Strategies. There is an industry concern with the current performance of the credited seals and the vendor has developed a plan to improve the seal performance. In Reference 5, Luminant formally requested relief from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, so that the option to credit the low-leakage seal may be pursued. The current required implementation date for Unit 1 is the 2014 fall refueling outage. An extension of one additional refueling cycle was requested which moves the Unit 1 implementation date to the spring of 2016, still within the maximum allowed time frame of December 2016. The extension will provide additional time to resolve industry issues and fully design and safely implement modifications that affect Units I and 2. Open Item 014 tracks this concern. Pending NRC approval of the requested schedule relief, the Milestone Schedule in the next six month status letter will be revised, as appropriate.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 8 of 10 Mitigation Strategies for Beyond-Design-Basis External Events

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

Overall Integrated Plan Open Items Status OI1. Finalize location and protection requirements of FLEX Complete. FLEX equipment will be storage buildings. The storage buildings will be stored in a new single structure designed in accordance with the NEI guidance and the designed as described in Section 4 of applicable hazards, this attachment.

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

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

013. Development of refueling equipment specifications, Development of final specifications determination of fuel consumption rates, assessment of for all FLEX equipment has started.

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

014. Finalize FLEX strategies and required modifications Issue resolution in progress, following resolution of low-leakage RCP seal including low-leakage RCP seal performance issue. design changes and testing. Schedule relief for FLEX implementation on Unit 1 has been requested (Reference 5).

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 9 of 10 Mitigation Strategies for Beyond-Design-Basis External Events Draft Safety Evaluation and Interim Staff Evaluation are considered synonymous. The following table provides a summary of additional open items documented in the Interim Staff Evaluation (Reference 4). These open items will be carried forward in future 6 month status updates. Luminant Power is participating in the voluntary NRC audit process described in Reference 6.

Interim Staff Evaluation Open Items Status 3.2.1.2.A Regarding the RCP seals, the only O-ring of interest As discussed in Section 4 of this letter, with the safe shutdown low-leakage (SHIELD) installed delayed RCS cooldown is no longer is the RCP seal sleeve to shaft O-ring. Qualification of part of the planned ELAP response the RCP seal sleeve to shaft O-ring will be tracked as for CPNPP. However, the SHIELD part of the SHIELD redesign to confirm the delayed white paper will be reviewed, when cooldown, as documented in the Integrated Plan, is available, to confirm the discussed 0-acceptable. CPNPP will align with testing results to be ring remains qualified to perform its documented in the forthcoming SHIELD white paper. function.

3.2.1.2.C If the RCP seals are changed to the newly designed Acceptability of the use of SHIELD Generation 3 SHIELD seals, or non-Westinghouse seals, low-leakage seals will be provided in the acceptability of the use of the newly designed the forthcoming SHIELD white paper.

Generation 3 SHIELD seals, or non-Westinghouse seals should be addressed, and the RCP seal leakages rates for use in the ELAP analysis should be provided with acceptable justification. During the audit process the licensee stated that CPNPP uses the Westinghouse mode193A RCPs crediting SHIELD for FLEX strategies.

Testing and qualification of SHIELD is ongoing and the licensee is closely following the re-design of SHIELD and will modify analyses and FLEX strategies if needed, based on the conclusions of the SHIELD white paper.

3.2.1.8.A The Pressurized Water Reactor Owners Group Per ML13276A183, the NRC has (PWROG) submitted to NRC a position paper, dated endorsed the PWROG position paper August 15, 2013 (ADAMS Accession No. ML 13235A with restrictions. Luminant is 132, non-public, proprietary), which provides test data currently assessing the impact of regarding boric acid mixing under single-phase natural these restrictions on the CPNPP FLEX circulation conditions and outlines applicability strategy for maintaining conditions intended to ensure that boric acid addition subcriticality.

and mixing would occur under conditions similar to those for which boric acid mixing data is available.

However, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and did not endorse this position paper. As such, ensuring adequate mixing of boric acid into the RCS under ELAP conditions is an open item for CPNPP.

Attachment to TXX-14025 CPNPP Second Six Month Status Report for Requirements for Page 10 of 10 Mitigation Strategies for Beyond-Design-Basis Externat Events

7. Potential Draft Safety Evaluation Impacts Any potential impact to the Interim Staff Evaluation has been previously discussed in Section 4 of this attachment.

8. References The following references support the updates to the OIP described in this attachment.

1. Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 28, 2013.

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

3. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 andMF0861), dated August 28, 2013.

4. NRC Interim Staff Evaluation, "Comanche Peak 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. MF0860 and MF0861)," dated December 19, 2013.

5. Comanche Peak Nuclear Power Plant (CPNPP), Docket Nos. 50-445 and 50-446, Request for Schedule Relaxation for the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated February 12, 2014.

6. NRC Letter from Jack R. Davis to All Operating Reactor Licensees and Holders of Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049," August 28, 2013.