L-14-257, Davis-Bes, Perry, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Davis-Bes, Perry, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML14240A285
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	08/28/2014
From:	Belcher S FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-14-257, TAC MF0841, TAC MF0842, TAC MF0961, TAC MF0962
Download: ML14240A285 (28)

Text

FENOC Firct Enelgt Nucrea.

o*'on ffiqQ 76 South Main Street Akron. Ohio 44308 Samuel L. Belcher Senior Vice President and Chief Operating Officer August 28,2A14 L-14-257 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, Ltcense No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 FirstEnergy Nuclear Operatinq Companv's (FENOC's) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifyinq Licenses with Reqard to Requirements for Mitisation Strategies for Bevond-Design-Basis External Events (Order Number EA-12-049)

(TAC Nos. MF0841, MF0842, MF0961, and MF0962)

On March 1 2, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference 1) to FENOC. Reference 1 was immediately effective and directs FENOC 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 Attachm ent 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section lV, Condition C. Reference2 endorses industry guidance document Nuclear Energy Institute (NEl) 12-06, Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the FENOC initial status report regarding mitigation strategies. Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Davis-Besse Nuclear Pourer Station (DBNPS), and Perry Nuclear Power Plant (PNPP).

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 third

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-14-257 Page 2 six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The attached reports for BVPS, DBNPS, and PNPP (Attachments 1, 2, and 3, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compliance

method, schedule, or need for relief/relaxation and the basis, if any.

This letter contains no new regulatory commitments.

lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager-Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on Aug ust '/fi,2014.

Respectfully,,n]

'r'

/:i' 4

h'..--l

/tut--'

(

SamuelL. Belcher Attachments:

1.

Beaver Valley Power Station Third Six-Month Status Reporl for the lmplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Davis-Besse Nuclear Power Station Third Six-Month Status Report for the f mplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Perry Nuclear Power Plant Third Six-Month Status Report for the lmplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

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 NRC lnterim Staff Guidance JLD-lSG-201 2-01, Compliance with Order EA-12-049, Order l\\lodifying Lieenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29,2412 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) lmplementation

Guide, Revision 0, dated August 2012

4.

FirstEnergy Nuclear Operating Company's (FENOC's) lnitial Status Report in

Response

to March 12,2012 Commission Order Modifying Licenses with Regard 2.

3.

2.

3.

5.

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-14-257 Page 3 to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-A49), dated October 26, 2012 cc:

FirstEnergy Nuclear Operating Company's (FENOC's)

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-1 2-049),

dated February 27,2013

Director, Office of Nuclear Reactor Regulation (NRR)

NRC Region I Administrator NRC Region lll Administrator NRC Resident lnspector (BVPS)

NRC Resident lnspector (DBNPS)

NRC Resident Inspector (PNPP)

NRC Project Manager (BVPS)

NRC Project Manager (DBNPS)

NRC Project Manager (PNPP)

Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments)

Site BRP/DEP Representative (without Attachments)

Utility Radiological Safety Board (without Attachments)

Attachment 1

L-14-257 Beaver Valley Power Station Third Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 7 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Beaver Valley Power Station, Unit Nos. 1 and 2 (Reference 1 in Section B), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. 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 lrelaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31,2014 and are current as of July 31,2014.

o Update 2 was submitted o Completed the Unit 2 plant modifications targeted for 2R1 7 (spring 2014 refueling outage)

Completed the fence and gate modification design and the new fence and gate construction Completed the security barrier pipe penetrations design 3

Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt 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 detaifs are developed.

The revised milestone target completion dates reflect the relief/relaxation of the Reference 2 requirement for completion of full implementation for Beaver Valley Power Station, Unit No. 1, until the completion of the fall of 2016 refueling outage for reactor coolant pump shutdown seal installation that was granted on May 20,2014 (Reference 4).

The following milestones are deleted based upon the relief/relaxation granted by Referen ce 4'.

o lssue Beaver Valley FSG lmplement Training L-14-257 Page 2 of 7 The fof lowing milestones are added based upon the relieflrelaxation granted Reference 4:

o Update 6 Update 7 Complete 1R24 outage modifications o lssue Beaver Valley Unit 2 FSG lssue Beaver Valley Unit 1 FSG lmplement Unit 2 Training lmplement Unit 1 Training M ilestone Target Completion Date Activity Status (as of 7131114)

Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02128113 Complete 6 Month NRC Status Updates 0812811s Started 08128116 Update 1 08t28113 Complete Update 2 02t28t14 Complete Update 3 08t28t14 Started Update 4 02t27 t15 Not Started Update 5 08t28t15 Not Started Update 6*

02t28t16 Not Started Update 7*

08t28t16 Not Started Gomplete FLEX Strateqy Review March-2013 Complete Validation Februarv-2015 Not Started Walk-throughs or Demonstrations February-2015 Not Started Complete Staffing Analysis Novem b er-2014 Started Submit NEI 12-01 Phase 1 Staffinq Studv April-2013 Complete Submit NEI 12-01 Phase 2 Staffins Studv Novem b er-2014 Started Gomplete Plant Modifications Novem b er-2015 Started November-2016 Target plant modifications April-2013 Complete Unit 1 Modifications complete Mav-2015 Started Novemb er-2016 Complete 1 R22 outaqe modifications November-2413 Complete Complete on-line modifications Februarv-2015 Started Seotember-2016 Complete 1 R23 outaqe modificafrons May-2015 Started Complete 1 R24 outaqe modificafions*

November-2016 Started Unit 2 Modifications complete Novem b er-2015 Started Complete 2R1 7 outage modifications Mav-2014 Complete Com plete on-l i ne mod ifications Auqust-2015 Started Complete 2R1 B outaqe modifications November-2015 Started FLEX Storage Complete March-2015 Started October-2015 Complete Buildinq Desiqn June-2014 Started Decemb er-2014 Commence Construction June-2014 Not Started January-2015 Complete Construction March-2015 Not Started October-2015 River (UHS) Access Complete October-2014 Started Fence & Gate Modification Design February-2014 Complete New Fence & Gate Construction Auqust-2014 Complete

Attachment 1

L-14-257 Page 3 of 7

" New milestones added as a result of relief/relaxation for Unit 1 (Reference 4)

"" Submittal of completion report occurs after end of refueling outage.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Relief/relaxation of the Reference 2 requirement for completion of full implementation for Beaver Valfey Power Station Unit No. 1 until the completion of the fall of 2016 refueling outage for reactor coolant pump shutdown seal installation was granted on May 2A,2A14 (Reference 4). No relieflrelaxation is required at this time for Beaver Valley Power Station Unit No. 2.

6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (lSE) (Reference 3) and the status of each item.

Milestone Target Completion Date Activity Status (as of 71311141 Revised Target Gompletion Date Security Barrier Pipe Penetrations Desron March-2014 Complete Security Barrier Pipe Penetration Construction October-2014 Not Started On-site FLEX Equipment Decemb er-2014 Started October-2015 Confirm FLEX Eq uipment Req uirements Novemb er-2013 Complete FLEX Equipment Ordered June-2014 Started April-2015 FLEX Eq uipment Delivered Decemb er-2014 Not Started October-2015 Off-site FLEX Equipment April-2015 Started October-2015 Develop Strateqies with RRC June-2014 Started June-2015 Phase 3 Sffe Access Strateqies in Place October-2014 Started June-2015 Complete Near Sffe Sfaging Location (as needed)

April-2015 Not Started October-2015 Procedures Complete December-2014 Started October-24rc PWROG rssues NSSS-sp ecific suidelines June-2013 Complete

/ssue Beaver Vallev Unit 2 FSG*

October-2015 Started

/ssue Beaver Vallev Unit 1 FSG*

October-2016 Started

/ssue Maintenance Procedures Decemb er-2014 Started Training Complete April-2015 Started Septemb er-2016 Develop Traininq Plan Seotem b er-2414 Started Decemb er-2014 Implement Unit 2 Traininq*

September-2015 Started lmplement Unit 1 Traininq" September-2016 Started Submit Completion Report November-2015 Not Started Januarv-2017**

Attachment 1

L-14-257 Page 4 of 7 Overall Integrated Plan Open ltem Status Ol 1. Finalize the location of the FLEX storage building. The deployment routes, distances, and times provided in this report are bounded for the currently proposed locations but will be updated as necessary.

Complete. (Described in February -2014 status report)

Ol 2. Perform containment evaluation based on the boundary 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.

Started.

Ol 3. Modify the RWST [refueling water storage tankl at each unit to protect it from tornado missiles or identify a borated source that is protected from tornados and can be utilized to provide core cooling when steam generators are not available.

Complete. (Described in February-z}14 status report)

Interim Staff Evaluation Open ltem Status 3.2.1.6.A Verify that the TDAFW [turbine driven auxiliary feedwaterl pump exhaust stacks are adequately protected from tornado missile hazards.

Started.

3.2.1.8.4 Verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS [reactor coolant systeml under natural circulation conditions potentially involving two-phase flow.

Complete. (Described in February-2A14 status report)

ISE Confirmatory ltem Status 3.1.1.4.4 Confirm that primary and secondary staging areas for the RRC [regional response center] equipment have been selected and will meet the requirements of the applicable site response plan.

Started.

3.1.2.4.4 Confirm that the primary and secondary staging areas have been identified and that the plan for the use of offsite resources will comply with NEI 12-06, Section 6.2.3.4 regarding the need to evaluate for flooding hazard. This confirmation should include a description of the methods to be used to deliver the equipment to the site.

Started.

3.1.3.1.A Confirm that the location of the storage and protection building for FLEX equipment has been identified. Confirm that the FLEX storaqe Started.

L-14-257 Page 5 of 7 ISE Confirmatory ltem Status building is designed to withstand tornado missiles at a level equal to, or greater than, the plant's tornado missile desiqn basis.

3.1.3.4.A Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06, Section 7.3.4 reqardinq hiqh wind hazards.

Not started.

3.1.4.4.A Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06 Section 8.3.4 regarding snow, ice and extreme cold hazards.

Not started.

3.2.1.1.A Confirm that the licensee has verified that reliance on the NOTRUMP code for the ELAP

[extended loss of AC power] analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. This includes specifying an acceptable definition for reflux condensation coolinq.

Not started.

3.2.1.1

.B Confirm that the application of the WCAP-176A1 analysis simulating the ELAP transient is properly established.

Not started.

3.2.1.2.A Confirm that, if the licensee continues to credit SHIELD shutdown seals, as planned, (e.9.,

1 gallon per minute leakage/seal) in the ELAP analyses for the RCS response, then the impacts of the Westinghouse 10 CFR Parl21 report, "Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21 :'dated July 26,2013 (ADAMS Accession No. ML132114168) on the use of the low seal leakage rate in the ELAP analysis are addressed.

Started.

3.2.1.2.8 Confirm that if the seals are changed, the acceptability of the seals used is addressed, and the RCP seal leakage rates for use in the ELAP analysis are iustified.

Not started.

3.2.2.4 Since the RWSTs are not currently fully protected against tornado missiles, confirm that the licensee has completed their review to determine whether or not the RWST will need to be further protected against missile hazards.

Complete. (Described in February-2014 status report) 3.2.2.8 Confirm that opening doors provides adequate ventilation for SFP lspent fuel pooll area.

Not started.

3.2.3.A Confirm that containment evaluations for all phases are performed based on the boundary Started.

ISE Confirmatorv ltem Status conditions described in Section 2 of NEI 12-06.

Based on the results of this evaluation, confirm that required actions to ensure maintenance of containment integrity and required instrument function have been developed.

3.2.4.2.A Confirm that the licensee has clarified why the Integrated Plan stated the maximum temperature of the Unit 1/Unit 2 AFW [auxiliary feedwaterl pump rooms would reach 115.91112.3 degrees Fahrenheit ('F), respectively, while Calculation 8700-DMC-2312, described during the audit process, indicated that the maximum temperature would reach 142.9"F.

Not started.

3.2.4.2.8 Confirm that the licensee has provided an analysis or calculation to demonstrate that the dissipation of heat generated by the batteries via natural circulation will be adequate to maintain the temperatures in the battery rooms within acceptable levels.

Started.

3.2.4.2.C Confirm that the licensee has addressed how hydrogen concentration in the battery rooms will be limited to acceptable levels.

Started.

3.2.4.6.4 Confirm that the licensee has completed a review of Unit 1 AFW room and developed any plans required to maintain a suitable environment.

Not started.

3.4.4 Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 1 2-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.

Not started.

Attachment 1

L-14-257 Page 6 of 7 7

Potential Interim Staff Evaluation lmpacts There are no potential impacts to the ISE identified at this time.

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

1. FirstEnergy Nuclear Operating Company's (FENOC's) 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-1 2-A49), dated February 27, 2013.

L-14-257 Page 7 of 7

2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12.2012.

Beaver Valley Power Station, Units 1 and 2 - lnterim Staff Evaluation Related To Overall Integrated Plan In Response To Order EA-1 2-049 (Mitigation Strategies),

dated January 29,2014.

NRC Letter, Beaver Valley Power Station, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 "lssuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" (TAC No. MF0841), dated May 2A, 2014.

3.

4.

L-14-257 Davis-Besse Nuclear Power Station Third Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 7 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2.

This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for rellef/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31,2014 and are current as of July 31, 2014.

o Update 2 was submitted 3

Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

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

Attachment 2

L-14-257 Page 2 of 7 Milestone Target Completion Date Activity Status (as of 7131114)

Revised Target Completion Date Submit FLEX Inteqrated lmplementation Plan 02128113 Complete 6 Month NRC Status Updates 02128116 Started Update I 08128113 Complete Update 2 02t28t14 Complete Update 3 j\\tzgt14 Started Update 4 02127115 Not Started Update 5 08128115 Not Started Update 6 02128116 Not Started Validation April-2016 Not Started Wal k-th ro uq h s or De m on strati o n s April-2016 Not Started Complete Staffing Analysis October-2015 Not Started Submit NEI 12-01 Phase 2 Staffinq Studv October-2015 Not Started Complete Plant Modifications Aoril-2016 Started Target plant modifications May-2013 Complete Mod ifications com plete April-2016 Started Complete 1 Rl B outaqe modifications June-2014 Complete*

Com plete on-l ine modifications Februarv-2016 Started Januarv-2016 Complete 1 R1 9 outaqe modifications April-2016 Started Com plete Commu nications Modifications April-2016 Started Complete SFP Level lndication Modifications April-2016 Started FLEX Storaqe Gomplete April-2016 Started Complete Buildinq Desiqn March-2015 Started Commence Construction June-2015 Not Started Complete Construction Aprt-2016 Not Started On-site FLEX Equipment Aprt-2016 Started February-2016 Confirm FLEX Equipment Requirements Julv-2014 Started October-2014 FLEX Equipment Ordered Januarv-2015 Started October-2015 FLEX Equipment Delivered April-2016 Not Started Februarv-2016 Off-site FLEX Equipment April-2016 Started Februarv-2016 Develop Strateqies with RRC Auqust-2015 Started October-2015 Phase 3 Sife Access Strategies in Place April-201 6

Not Started October-2015 Complete Near Sife Sfaging Location (as needed)

April-2016 Not Started Februarv-2016 Procedures Complete April-2016 Started PWROG issues NSSS-sp ecific quidel ines Auqust-2013 Complete

/ssue Davis-Besse FLFX Strateqv Guidelines June-2015 Not Started

/ssue Maintenance Procedures April-2016 Not Started Training Complete April-2016 Not Started Develop Training Plan September-2015 Not Started lmplement Training April-2016 Not Started Submit Completion Report April-2016 Not Started June-2016*"

• Modifications are targeted for 1 R19 and on-line; none targeted for 1 R1B.

• • Submittal of completion report occurs after end of refueling outage.

L-14-257 Page 3 of 7 4

Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe Interim Staff Evaluation (lSE) and the status of each item.

Overall lnteqrated Plan Open ltem Status Ol 1. Finalize locations for FLEX storage buildings.

Deployment routes, distances and times contained in the submittal are bounded for the currently proposed locations but will be updated as necessary.

Started.

Ol 2. Finalize the strategy for providing a protected source of borated water to support FLEX strategies.

Complete. FENOC plans to utilize both the borated water storage tank (BWST) and clean waste receiver tank (CWRT) in the strateqy.

Ol 3. Determine if a mobile boration unit and/or water purification unit is required to support the FLEX strategies.

Complete. No mobile boration unit or water purification unit is required. Site sources of water are adequate.

Interim Staff Evaluation Open ltem Status 3.2.1.2.A Verify the following with respect to reactor coolant pump (RCP) seals:

(1) the DBNPS [Davis-Besse Nuclear Power Stationl plant condition during an ELAP

[extended loss of all alternating current power] is bounded by the seal leakage test conditions with respect to relevant parameters.

(2) the pop-open failure mechanism resulting from hydraulic instability that is discussed in WCAP-16175-P and WCAP-1 7601-P would not occur or would be bounded by the assumed leakage rate.

(3) a basis for the assumed leakage rate of 2 gpm lqallons per minutel is iustified in liqht of Started.

Attachment 2

L-14-257 Page 4 of 7 Interim Staff Evaluation Open ltem Status recommendations for a larger value of leakage for similarly designed RCPs and seals discussed in WCAP-16175-P and WCAP-1 7601-P.

(a) the modeling of the pressure-dependence of the seal leakage rate is justified.

(5) the seal design performance under stresses induced by the cooldown of the RCS [reactor coolant systeml is iustified.

3.2.1.4.4 Verify that any industry-identified gaps and recommendations applicable to the generically developed mitigating strategies proposed for DBNPS are addressed (e.g., those documented in WCAP-17792-P (transmittal letter located at ADAMS Accession No. ML14037A237) and the appropriate revision of the PWROG's [Pressurized Water Reactors Owners Group] Core Cooling Management Interim Position Paper).

Started.

3.2.1.6.8 Verify that a revised sequence of events that is consistent with the final ELAP analyses is developed.

Started.

3.2.1.8.4 Verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.

Started.

ISE Confirmatorv ltem Status 3.1.1.1.A Confirm that the diesel-driven service water pumps have deployment and storage plans developed in accordance with the provisions of NEI

[Nuclear Enerqy Institute] 12-06.

Started.

3.1.1.2.A Confirm that the routes that plant operators will have to access to deploy and control the strategy will only require access through seismically robust structures.

Sta rted.

3.1.1.2.8 Confirm that, if power is required to operate the storage building doors, either power supplies will be available to operate the doors or the doors will be equipped with manual overrides to permit manual door openinq.

Not Started.

3.1.1.3.A Confirm that guidance is provided for critical actions to pedorm until alternate indications can be connected and on how to control critical equipment without associated control power.

Not Started.

Attachment 2

L-14-257 Page 5 of 7 ISE Confirmatory ltem Status 3.1.1.4.4 Confirm the RRC [regional response center] local staging area, evaluation of access routes, and method of transportation to the site.

Not Started.

3.1.2.4 Confirm that the licensee has identified the warning time and persistence of the external flooding hazard.

Not Started.

3.1.2.2.4 Confirm that the licensee plans to conform to deployment consideration 1 and 2 of NEI 12-06, Section 6.2.3.2.

Not Started.

3.1.3.1.A Confirm that the chosen storage locations are sufficiently separated in distance and axially from the typical tornado path as compared to the local tornado data for tornado width.

Complete. FENOC intends to utilize one robust building constructed for design basis loads and one not protected for wind, which is consistent with NEI 12-06 Frequently Asked Question (FAQ) 2A13-07 3.2.1.1.A Confirm that reliance on the RELAP5/MOD2-B&W code in the ELAP analysis for Babcock and Wilcox plants is limited to the flow conditions prior to boiler-condenser cooling initiation.

Started.

3.2.1.1.B Confirm that the licensee has:

(1) ldentified the specific analysis case(s) from WCAP-17792-P that are being referenced as the basis for demonstrating the acceptability of the mitigating strategies for DBNPS, and (2) Provided justification that the analyses from WCAP-17792-P that are being credited for DBNPS are adequately representative of the actual plant design, FLEX equipment, and planned mitiqatinq strateqies.

Started.

3.2.1.1.C Confirm the continuity of natural circulation by demonstrating the adequacy of the modeling of operator actions associated with primary-to-secondary heat transfer.

Started.

3.2.1.2.8 Confirm that either:

(1) closure of valve MU38 will not be credited in the ELAP analysis for DBNPS, or (2) procedures to close valve MU3B prior will be implemented to provide assurance that its closure can be credited in the ELAP analvsis.

Not Started.

3.2.1.3.4 Confirm the basis for the decay heat modeling assumptions present in the analysis credited for DBNPS in WCAP-17792-P, which was not availabte to the staff durinq the audit.

Started.

Attachment 2

L-14-257 Page 6 of 7 7

Potential Interim Staff Evaluation lmpacts There are no potential impacts to the ISE identified at this time.

ISE Confirmatorv ltem Status 3.2.1.3.8 Confirm that the cooldown directed by the DBNPS mitigating strategy is consistent with the capability of the atmospheric vent valves.

Not Started.

3.2.1.6.A Confirm licensee's hydraulic analysis supports that injecting borated water into the RCS within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the event is initiated will maintain subcriticality.

Started.

3.2.1.8.8 Confirm adequate shutdown margin for ELAP scenarios:

(1) with the highest applicable reactor coolant system leakage, and (2) with no reactor coolant system leakage. ln addition, confirm that core reload calculation procedures would ensure that these shutdown margin calculations remain bounding for future fuel cvcles.

Started.

3.2.1.8.C Confirm that adequate RCS venting capability exists to support the ELAP mitigating strategy for DBNPS.

Started.

3.2.3.A Confirm that the containment pressure and temperature after an event initiated in Modes 1 through 4 will stay at acceptable levels during Phases 1, 2, and 3 and that no additional installed equipment or operator actions are required to maintain containment inteqrity.

Not Started.

3.2.4.4.4 Confirm that upgrades to the site's communications systems have been completed.

Started.

3.2.4.8.4 Clarify the discrepancy between the Integrated Plan stated size of the Phase 2 FLEX 480v [volt] portable DGs [diesel generators]

(500kW

[kilowatt])

and the stated size of the Phase 2 FLEX 480v portable DGs in response to the sizing audit question (600kW).

Started.

3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.

Not Started.

L-14-257 Page 7 of 7 8

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

1. FirstEnergy Nuclear Operating Company's (FENOC's) 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-1 2-049), dated February 27, 2013.

2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12.2012.

L-14-257 Perry Nuclear Power Plant Third Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 11 1

Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since January 31,2014 and are current as of July 31,2A14.

Update 2 was submitted 3

Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt 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.

FENOC is revising the OIP for Perry Nuclear Power Plant (PNPP). Revision 1 of the OIP is incorporating planned strategy changes and is to be submitted under a separate letter. A summary of this planned revision is provided in Section 4 below. The following milestones are deleted based upon the planned Revision 1 of the PNPP OIP:

Regrade road to barge slip area o Fence and Gate Construction modifications Security Barrier Pipe Penetrations Design o Security Barrier Pipe Penetration Construction The following milestone is added based upon the planned Revision 1 of the PNPP OIP:

o Convert ESW [Emergency Service Water] Pumphouse building Unit 2 areas for storage and use The following milestone is revised:

Create Maintenance Procedures is revised to be Define Maintenance Strategy L-14-257 Page 2 of 11 The scheduled start date for the spring 2015 refueling outage has been delayed by approximately one month. Based on this change in schedule, the completion date for the refueling outage is now April 2015, which still complies with the requirements of the order. The revised milestone target completion dates identified above do not impact the updated order implementation date.

Milestone Target Completion Date Activity Status (as of 71311141 Revised Target Gompletion Date Submit FLEX Inteqrated lmplementation Plan 02t28113 Complete 6 Month Status Updates 02127115 Started Update 1 08t01113 Complete Update 2 02128114 Complete Update 3 08t28114 Started Update 4 02t27115 Not Started FLEX Strategy Review Mav-2013 Complete Validation March-2015 Not Started April-2015 Walkihroughs or Demonstrations March-2015 Not Started April-2015 Complete Staffi nq Analvsis October-2014 Started Complete Plant Modifications March-2015 Started April-2015 Target plant modifications May-2013 Complete Complete on-li ne modifications Decemb er-2014 Started Januarv-2015 Complete 1 R1 5 outaqe modificafions March-2015 Started Aoril-2015 FLEX Storage Januarv-2015 Started Complete Unit 2 Aux Building for storage and Use Januarv-2015 Started Convert Diesel Building for storaqe and use January-2015 Started Convert ESW Pumphouse building Unit 2 areas for storage and use January-2015 Not Started Lake (UHS) Access Novem b er-2414 Started April-2015 On-site FLEX Equipment October-2414 Started Januarv-2015 Ordered March-2013 Started October-2A14 Delivered October-2014 Not Started Januarv-2015 Off-site FLEX Equipment March-2015 Not Started Develop Strategies with RRC June-2014 Not Started January-2015 Complete Near Sife Sfaging Location (as needed)

March-2015 Not Started Phase 3 Sife Access Strateqies in Place Novemb er-2014 Not Started Procedures March-2015 Started Aoril-2015 lmplement EPG/SAG Rev 3 Guidance Auqust-2014 Started April-2015 Create Perrv FSG Mav-2014 Started October-2014 lmplement Perrv FSG March-2015 Started April-2015 Define Maintenance Strateqv Julv-2014 Started April-2015 Training March-2015 Started Develop EOP Traininq Plan Januarv-2014 Complete lmplement EOP Traininq March-2015 Started Develop SAMG Traininq Plan June-2014 Not Started Januarv-2015 I mplement SAMG Trainins March-2015 Not Started

Attachment 3

L-14-257 Page3of11

• Submittal of completion report occurs after end of refueling outage.

4 Changes to Gompliance Method The following changes to the compliance method as documented in the OIP (Reference 1) are being made. These changes are being incorporated into Revision 1 of the OlP, which is being submitted under a separate letter. The changes do not impact compliance with Nuclear Energy Institute (NEl) 12-06.

The following discussion details three significant changes to the coping strategies planned for PNPP OlP, Revision 1:

o Change from 480 volts alternating current (Vac) to 4160 Vac FLEX power source o Change from Suppression Pool "Feed and Bleed" to Suppression Pool Closed Loop Cooling Change from portable pumps at the barge slip to portable pumps in the Emergency Service Water Pumphouse (ESWPH)

Chanqe from 480 Vac to 4160 Vac Alternate Power Source PNPP OlP, Revision 0, provided for the use of a 750 kilowatt (kW) 480 Vac diesel generator to provide power to 480 Vac Bus EF-2-8. Bus EF-2-B would then distribute 480 Vac power to critical loads via (1) Unit 1 divisional 480 Vac busses and (2) dedicated power supplies to new or existing 480 Vac manual transfer switches.

The planned PNPP OlP, Revision 1, provides forthe use of two 1.1 Megawatt (MWe) 4160 Vac turbine generators [similar equipment is to be used at the Regional Response Center(s) (RRCs)J to provide power to Unit 2 4160 Vac Bus EH-21. A distribution center (similar equipment is to be used at the RRCs) will be supplied by two 1.1 MWe 4160 Vac turbine generators (operating in parallel) and connect to Bus EH-21 through a permanently installed docking station and isolation breaker on the bus.

Bus TH-21 will be modified to allow Bus EH-21 to provide an alternate power source to the unit cross-tie, and thereby, the alternate preferred source to the Unit 1 Class 1E switch gear (Bus EH-21 will power the Unit 2 off-site source to Unit 1 Class 1E switch gear). Bus EH-21 is the normal power supplyto Bus EF-2-B via Bus EF-?-A (through its su pply tra nsformer).

PNPP OlP, Revision 0, provided for supplying the Unit 1 Class 1E switch gear and Bus EF-2-B (via Bus EF-2-A and its supply transformer) by connection of the 1.1 MWe 4160 Vac turbine generato(s) to the load via free air cables and ground trucks (Phase 3 Milestone Target Completion Date Activity Status (as of 7131114)

Revised Target Completion Date Develop FLEX Traininq Plan Auqust-2014 Started I mplement F LEX Traininq March-2015 Not Started Submit Completion Report March-2015 Not Started June-2015*

L-14-257 Page 4 of 11 strategy). Bus EF-2-B remains the alternate power to the Suppression Pool Clean Up (SPCU) and Alternate Decay Heat Removal (ADHR) pumps through manual bus transfer switches.

This change in strategy provides for:

o Increased electrical capacity o Reduction in actions to restore power to critical loads required for FLEX coping Provides sufficient power to supply motor driven pumps located in the ESWPH o Simplifies operator action required to re-establish cooling water flow Chanqe from Suppression Pool Feed and Bleed to Suppression Pool Closed Loop Coolinq PNPP OlP, Revision 0, provided for containment heat removal by use of Suppression Pool "Feed and Bleed." Suppression Pool "Feed and Bleed" was accomplished by thermal mass transfer between the Suppression Pool and a dedicated storage volume, with cool water make-up provided by FLEX pumps. The identified "Feed" source was lake water from either the ESW A or ESW B supply headers through hosed connections to either High Pressure Core Spray (HPCS) or Low Pressure Core Spray (LPCS) flush connections. ESW would have been supplied by fire trucks at the barge slip taking a suction on the lake and pumping into the ESW headers via installed dry hydrants and dedicated buried pipe. Suppression Pool "Bleed" was accomplished by use of the SPCU or the ADHR pump taking suction on the Unit 1 Suppression Pool and transferring this heated water to the Unit 2 Suppression Pool.

The planned PNPP OlP, Revision 1, provides forthe use of the SPCU orthe ADHR pump taking a suction on the Unit 1 Suppression Pool and transferring the water to the Residual Heat Removal (RHR) System via the Fuel Pool Cooling and Cleanup (FPCC) to RHR suction header. Water flows through the RHR System, bypassing the RHR pump through existing system piping, through the RHR Heat Exchangers back to either the Reactor Pressure Vessel (RPV) or the Suppression Pool.

Pumps in the ESWPH will take a suction on the ESWPH suction bay that is fed by one of two seismically qualified (fully robust) intake/discharge lines that normally provide water to the ESWPH and discharge into the ESW System between the ESW pump discharge check valve and the discharge strainer. The flow in the ESW System is aligned to provide cooling water to the RHR heat exchangers, with ESW System hose connections to provide various other loads as required.

Suppression Pool Closed Loop Cooling replaces the large RHR pump with smaller 480 Vac pumps (ADHR or SPCU pump) and operates the RHR in a modified Suppression Pool to Suppression Pool flow path.

Additionally, these 480 Vac pumps can also serve as a motor-driven high capacity vessel injection source from the Suppression Pool once the RPV pressure is reduced sufficiently.

L-14-257 Page5of11 Chanqe from Portable Pumps at the Barqe Slip to Portable Pumps in the ESWPH PNPP OlP, Revision 0, provided for the use of two fire trucks to be deployed to the barge slip area where they would be connected to installed dry hydrants and pump the discharge into the ESW System between the ESW pump discharge check valve and the discharge strainer via an installed dedicated buried pipe to the ESWPH. The flow in the ESW System was used to supply water to the Reactor Core lsolation Cooling (RCIC) pump suction, LPCS/HPCS for Suppression Pool "Feed," and the Spent Fuel Pool (SFP) Spray System.

The planned PNPP OlP, Revision 1, provides for the use of one of two motor-driven FLEX pumps (for pumping lake water) in the ESWPH, as previously discussed. The flow in the ESW System is used to supply water to the RCIC pump suction, RHR heat exchangers for Suppression Pool Closed Loop Cooling, and the SFP Emergency Makeup System (SFPEMS). The motor-driven FLEX pumps (either the "N" or "N+1")

are supplied by a repurposed supply line originally designed to supply the Unit 2 Division 1 ESW pump via a docking station in the ESWPH. The docking station is normally fed from an isolation breaker on Bus EH-21 and can supply either the N and N+1 lake water pumps.

The FLEX pumps will be stored and used in the ESWPH. During use, a set of suction lines will be attached and lowered into the ESWPH suction bay via the associated Unit 2 ESW pump pedestal (pumps will be stored in the area where the Unit 2 ESW pump discharge piping would have been installed). Three S-inch discharge hoses will be attached between the FLEX pump discharge and the ESW loop. Free air cables will connect the FLEX pump to the docking station (feed from Bus EH-21 ) to provide electrical power.

Core Cooling and Heat Removal High Pressure Injection As in PNPP OlP, Revision 0, RCIC will be used in Phase 1 and Phase 2 in the planned PNPP OlP, Revision 1. Provisions remain to supply the RCIC Pump with an alternate coolant source to address Suppression Pool temperature concerns.

The RCIC alternate suction connection was to be installed in the Condensate Storage Tank (CST) supply line; however, this modification has been moved to the RCIC pump room just prior to the RCIC pump suction. To support this, dry stand pipes are installed in the east and west sides of the Auxiliary Building. The dry stand pipes run from Auxiliary Building elevation (EL) 620'6" to the Auxiliary Building EL574'6" (568'6") with connection points on Auxiliary Building EL 599'6". ESW supply header modifications (hose connections) can also be used via the dry stand pipes.

L-14-257 Page6of11 Low Pressure Injection PNPP OlP, Revision 0, provided for lake water injection via LPCS or HPCS flush connection supplied from the ESW supply header connection point. This provision remains in the planned PNPP OlP, Revision 1. Use of dry stand pipes replaces the dedicated riser from the ESW supply header in PNPP OlP, Revision 0. The water source and flow paths are not altered, except as previously discussed with respect to access to the Ultimate Heat Sink.

The planned PNPP OlP, Revision 1, also provides for low pressure RPV injection via the SPCU or ADHR pumps.

RPV Pressure PNPP OlP, Revision 0, provided for installation of a single connection point to allow a portable compressor to supply both the Division 1 and Division 2 air system to provide for long term system makeup.

The planned PNPP OlP, Revision 1, deletes the installation of the single connection point. Both air systems provide a seven-d ay air source and only one air bank is needed to provide long term RPV pressure control. Both systems can be supplied by use of normal (robust) system connection points that do not require modification for use.

Containment Function The change in strategy from "Feed and Bleed" to Suppression Pool Closed Loop Cooling, as detailed above, provides for continued containment preservation. The ADHR modification detailed in PNPP OlP, Revision 0, provided for a single hose connection to be installed at the outlet of the ADHR pump. The planned PNPP OlP, Revision 1, provides for three hose connections to allow higher flow rates to the RHR System.

The planned PNPP OlP, Revision 1, also provides for three connection points on the FPCC to RHR suction header to allow the ADHR discharge hoses to be connected.

PNPP OIP Revision 0, previously provided only one hose connection on this piping.

Containment Inteqrity Control of hydrogen is not changed in the planned PNPP OlP, Revision 1; however, an alternate power scheme using portable generators is provided in the case that the two 1.1 MWe 4160 Vac turbine generators cannot supply power to the divisional busses.

Spent Fuel Coolino PNPP OlP, Revision 0, provided for a SFP Spray System to be installed and supplied from either ESW A or ESW B.

L-14-257 Page 7 of 11 The planned PNPP OlP, Revision 1, includes a new SFP Emergency Makeup System that provides the three required functions of remote fill, fill using hoses, and SFP spray.

The SFP Emergency Makeup System provides a dump line configuration with system flow controlled external to the SFP area (external to the Fuel Handling Building). Hose connection point(s) for use of hoses to directly fill the pool or supply portable spray nozzles are also provided. The SFP Emergency Makeup System supply remains unchanged.

Safety Support Function The planned PNPP OlP, Revision 1, provides for a modification to install a new manual transfer switch to supply Distribution Panel F1C08. This manual transfer switch will have alternate power from Bus EF-2-B similar to the SPCU and ADHR pump manual transfer switches. Power to Distribution Panel F1C08 provides for the use of various installed equipment to support FLEX activities.

Storage PNPP OlP, Revision 0, provided for storage of fire trucks in the Unit 2 Auxiliary Building and the Diesel Generator Building. Two diesel generators would be stored in a dedicated Unit 2 bay in the Diesel Generator Building. This storage would utilize all three Unit 2 diesel bays. A new FLEX Storage Building would be constructed to hold the N+1 equipment.

The planned PNPP OlP, Revision 1, provides for storage of FLEX equipment in a single Unit 2 bay of the Diesel Generator Building and the Unit 2 Auxiliary Building. These two areas are sufficient to store all of the identified FLEX equipment, except the portable FLEX pumps used for pumping lake water that will be stored in the ESWPH.

Construction of a new FLEX storage building is not required.

Modification to Security Features and Barqe Slip Area PNPP OlP, Revision 0, provided for modification to security features in the travel path of the fire truck down to the barge slip; regrading of the travel path and deployment area was also required.

The planned PNPP OlP, Revision 1, does not provide for the use of the barge slip area and, therefore, modifications to the security features in the travel path and barge slip a rea a re not req u ired.

Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

L-14-257 PageBofll 6

Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe Interim Staff Evaluation (lSE) (Reference 3) and the status of each item.

Overall Inteqrated Plan Open ltem Status N/A N/A Interim Staff Evaluation Open ltem Status 3.2.1.7.4 FENOC has not indicated their intent to follow the provisions of the NRC-endorsed NEI position paper on Shutdown/Refueling Modes that describes how licensees will develop and maintain an appropriate plan for mitigating strategies capability in all plant modes (ADAMS Accession Nos. ML13273A514 and ML13267A382). FENOC should either confirm that PNPP will follow the endorsed guidance, or provide an alternate approach acceptable to the NRC staff.

Complete. (Described in February-2014 status report)

ISE Confirmatory ltem Status 3.1.1.3.A FENOC indicated that the gravity discharge system passively performs the mitigation of groundwater intrusion. lt was not clear how the passive portion of this system will maintain groundwater elevation below the 590 foot elevation with no pumping power when the flood level around the plant may be at the 620 foot elevation. The licensee needs justification for groundwater mitigation durinq floodinq conditions.

Started.

3.1.1.4.4 With regard to offsite resources, the licensee will develop a plan that will address the fogistics for equipment transportation

, area set up, and other needs for ensuring the equipment and commodities to sustain the site's copinq strateqies.

Not started.

3.1.2.1.A During the audit, the licensee was requested to provide the elevations of FLEX equipment that will be deployed or staged across the site. In response, the licensee stated that the flooding re-analysis will need to be reviewed to determine the potential impacts. Confirm the location of FLEX equipment that will be deployed or staged is finalized with that consideration.

Started.

3.2.1.1.A Benchmarks must be identified and discussed which demonstrate that Modular Accident Analysis Proqram (MAAP) is an appropriate code Started.

Attachment 3

L-14-257 Page9of11 ISE Confirmatory ltem Status for the simulation of an ELAP [extended loss of AC powerl event at PNPP, Unit 1, consistent with the NRC endorsement of the industry position paper on MAAP (ADAMS Accession No. M113275A318).

3.2.1.1.B Confirm that the collapsed reactor pressure vessel level remains above Top of Active Fuel and the reactor coolant system cool down rate is within technical specifications limits.

Not Started.

3.2.1.1.C Confirm that MAAP is used in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.

Started.

3.2.1.1.D Confirm that, in using MAAP, the licensee identifies and justifies the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1020236).

Not started.

3.2.1.2.4 Calculations prepared in support of the licensee's Integrated Plan determined the required Phase 1 flow rate needed to stabilize boil-off, using suppression pool water, was well within the RCIC

[reactor core isolation cooling] System injection capacity of 700 gallons per minute. The licensee indicated that further information regarding the specific assumptions and calculations for quantification of inventory losses are captured in proprietary analysis used for Integrated Plan preparation. The licensee should demonstrate adequate RCIC capacity.

Not Started.

3.2.1.3.A The licensee stated that Boiling Water Reactor Owners Group Emergency Procedure Guideline/Severe Accident Guideline, Revision 3, would allow the temperature limit of the suppression pool to be exceeded. The licensee should demonstrate why exceeding this temperature limit is acceptable for PNPP.

Not started.

3.2.3.A Confirm that containment response calculation is completed, commensurate with the level of detail contained in GE Hitachi Report NEDC-33771P/NEDO-33771

, Revision 1, "GEH Evaluation of FLEX lmplementation Guidelins,"

ADAMS Accession No. ML130370742.

Not started.

3.2.3.8 The licensee should provide results from the successful completion of the evaluations and possible modifications which demonstrate that the Started.

Attachment 3

L-14-257 Page10of11 ISE Confirmatory ltem Status Suppression Pool Cleanup pump and piping are seismicaIlV "robust".

3.2.4.2.4 lt is not clear that (1) the assumed temperatures of the various critical rooms, e.9.,

RCIC Room and Control Room, are adequately evaluated for the potentially high temperature that may occur in these areas or that (2) time critical actions are not required to be taken to maintain equipment functionality or personnel habitability limits. Confirm that these analyses/evaluations are completed.

Not started.

3.2.4.2.8 The licensee provided insufficient information on monitoring temperatures and hydrogen concentration levels in the battery rooms to ensure temperature and hydrogen concentration level are within acceptable level. Confirm that battery room temperature and hydrogen concentration remain acceptable.

Started.

3.2.4.4.4 Confirm that the proposed communications upgrades in the licensee's communications assessment are completed as planned.

Started.

3.2.4.7.4 The licensee should confirm that the quality of water injected into the reactor pressure vessel supports and maintains acceptable long term core coolinq.

Not started.

3.2.4.8.4 During the audit process, the licensee indicated that the basis for the minimum bus voltage for Division 1 and Division 2 battery systems is the coil voltage required to operate the 4160 volt ac breakers (diesel generator output breakers) on the divisional busses and operation of Automatic Depressurization System SRV [safety relief valveJ solenoids. Confirm that the battery loading analyses considers the appropriate minimum voltaqe.

Not started.

3.2.4.8.8 The applicable electrical drawing(s) provided during the audit process were not legible.

The licensee should provide a legible copy of electrical drawinqs for NRC staff review.

Started.

3.2.4.8.C During the audit, the licensee indicated a

total load of 429 kilowatts for the FLEX diesel generator which does not appear to match the total sum of all the loads provided during the audit. The licensee should explain and/or resolve this Started.

ISE Confirmatory ltem Status d iscrepancy.

3.2.4.9.4 With respect to refueling of deployed equipment, PNPP is currently evaluating the feasibility of either procuring a fuel trailer (trailer mounted tank with on-board pump mechanism),

or mounting a fuel tank within the bed of a heavy-duty truck, with appropriate pumping mechanisms. The licensee shoud provide a description of the final plans for refueling once these evaluations are complete.

Started.

3.2.4.10.A The licensee should provide the battery dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool cooling.

Not started.

3.2.4.10.8 The licensee shoud provide the final load shedding procedure for review when it is completed.

Started.

3.4.A The licensee did not address considerations 2 through 10 of NEI 12-06, Section 12.2, regarding offsite resources. This information should be confirmed and documented.

Not started.

Attachment 3

L-14-257 Page 11 of 11 7

Potential Interim Staff Evaluation lmpacts FENOC is making changes to the compliance method as documented in the OIP (Reference 1). Although the planned changes do not impact compliance with NEI 12-06, there is an impact on the lSE. The planned changes described in Section 4 above are being incorporated into Revision 1 of the OlP, which is being submitted under a separate letter.

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

1. FirstEnergy Nuclear Operating Company's (FENOC's) 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 27,2013.

2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.

3. Perry Nuclear Power Plant, Unit 1 - Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-1 2-49 (Mitigation Strategies),

dated January 22,2A14.