RS-14-212, Third 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)

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Third 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)
ML14241A252
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/28/2014
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-14-212
Download: ML14241A252 (20)
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Text

ti Order No. EA-12-049 RS-14-212 August28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

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

References:

1. NRC Order Number EA-12-049," Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012
3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012
5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-024)
6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013 (RS-13-127)
7. Exelon Generation Company, LLC 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 049), dated February 28, 2014 (RS-14-014)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page2

8. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0845 and MF0846), dated November 22, 2013 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Ref ere nee 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Peach Bottom Atomic Power Station, Units 2 and 3 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. References 6 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition C.2, ot Reference 1 tor Peach Bottom Atomic Power Station. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 8.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2014.

a Respectfully subdittA.----

~I~

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Peach Bottom Atomic Power Station, Units 2 and 3 Third 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector- Peach Bottom Atomic Power Station, Units 2 and 3 NRC Project Manager, NRR - Peach Bottom Atomic Power Station, Units 2 and 3 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Jason C. Paige, NRR/DPR/MSD/MSPB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Third 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 (16 pages)

Peach Bollom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implcrncntation of FLEX August 28, 2014 Enclosure Peach Bottom Atomic Power Station Units 2 and 3 Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirement" for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Peach Bottom Atomic Power Station, Units 2 and 3 developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments None 3 Milestone Schedule Status The following provides an update to Attachment 2 ofthe Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

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 Contract with National SAFER Response Complete Center Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Page 1 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Tmplcrnentalion of FLEX August 28, 2014 Target Revised Target Milestone Completion Activity Status Completion Date Date

~------~-

Complete with Update 3 Aug 2014 this submittal Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Submit Completion Report Dec 2016 Not Started Perform Staffing Analysis May 2015 Not started Modifications:

Unit 2 Design Engineering May 2015 Started September 2015 Unit 2 Implementation Outage Nov 2016 Not Started Unit 3 Design Engineering June 2014 Started December 2014 Unit 3 Implementation Outage Oct 2015 Not Started Storage:

Storage Design Engineering Oct 2015 Started Storage Implementation Oct 2015 Not started FLEX Equipment:

Procure On-Site Equipment Sept 2015 Started Develop Strategies with National SAFER Dec 2014 Started Response Center Procedures:

Create Site-Specific Procedures Sept 2015 Started Page 2 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Target Revised Target Milestone Completion Activity Status Completion Date Date Validate Procedures (NEl-12.06, section Sept 2015 Not started 11.4.3)

Create Maintenance Procedures Sept 2015 Not started Training:

Develop Training Plan March 2015 Not started Training Complete Oct 2015 Not started Unit 2 FLEX Implementation Oct 2016 Not started Unit 3 FLEX Implementation Oct 2015 Not started Full Site FLEX Implementation Oct 2016 Not started 4 Changes to Compliance Method No changes from the previous Second Six month Update submittal.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation No changes from the previous Second Six Month Update submittal.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE} and the status of each item.

Section Reference Overall Integrated Plan Open Item Status Multiple Sections Item 1) Transportation routes will be Started developed from the equipment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all Page 3 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the lrnplementation of FLEX August 28, 2014 strategies can be deployed during all modes of operation. The location of the storage areas, identification of the travel paths and creation of the administrative program are open items.

Programmatic Controls (p. 7) Item 2) An administrative program for FLEX Started to establish responsibilities, testing and maintenance requirements will be implemented.

Describe Training Plan (p. 8) Item 3) Training materials for FLEX will be Not started developed for all station staff involved in implementing FLEX strategies.

Maintain Spent Fuel Pool Item 4) Complete an evaluation of the spent Started Cooling (p. 30) fuel pool area for steam and condensation to determine vent path strategy requirements.

Safety Function Support {p. Item 5) RCIC room temperature analysis is Started

38) still in progress.

Safety Function Support Item 6) Evaluate the habitability of the Main Started (p.38) Control Room and develop a strategy to maintain habitability.

Safety Function Support (p. Item 7) Develop a procedure to prop open Started

38) battery room doors and utilize portable fans or utilize installed room supply and exhaust fans upon energizing the battery chargers to prevent a buildup of hydrogen in the battery rooms.

Sequence of Events (p. 4) Item 8) Timeline walk through will be Not started completed for the FLEX generator installations when the detailed design and site strategy is finalized. The final timeline will be validated once the detailed designs are developed. The results will be provided Page 4 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 in a future 6 month update.

Sequence of Events (p.4) Item 9) Timeline walk through will be Not started completed for the FLEX pump installations when the detailed design and site strategy is finalized. The final timeline will be validated once the detailed designs are developed.

The results will be provided in a future 6 month update.

Sequence of Events (p. 5) Item 10) Additional analysis will be Started performed during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

Sequence of Events (p. 5} Item 11} Analysis of deviations between Completed Exelon's engineering analyses and the analyses contained in BWROG Document NEDC-33771P, "GEH Evaluation of FLEX Implementation Guidelines and documentation of results on Att. lB, "NSSS Significant Reference Analysis Deviation Table." Planned to be completed and submitted with August 2013 Six Month Update.

Safety Function Support (p. Item 12) Evaluate the effect of additional Started

38) load shed on the battery coping time.

Draft Safety Evaluation Open Item Status See Attachments 1 and 2 See Attachments 1 and 2 Page 5 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. Peach Bottom Atomic Power Station Units 2 and 3, 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. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013.
4. NRC Order Number EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012
5. First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)." Dated August 28, 2013
6. Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies)" dated November 22, 2013
7. Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)." Dated February 28, 2014
8. Relaxation of Certain Schedule Requirements for Order EA-12-049 "Issuance of Order to Modify Licenses with regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events." Dated April 15, 2014 9 Attachments
1. Attachment 1 Interim Safety Evaluation 4.1 Open Items
2. Attachment 2 Interim Safety Evaluation 4.2 Confirmatory Items
3. Attachment 3 Confirmatory Item 3.1.1.1.A Response Page 6 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the lrnplementat.ion of FLEX August 28, 2014 Attachment 1 4.1 Open Items . ..

Open Item Status 3.2.3.A Revision 3 to the BWROG EPG/SAG is a Generic Concern because the BWROG has not addressed the potential for the revised venting strategy to increase the likelihood of detrimental effects on Started containment response for events in which the venting strategy is invoked.

3.2.4.3.A Freeze protection has not been discussed in the Integrated Plan or during the audit process. Not started 3.2.4.4.A Portable and emergency lighting during an ELAP has not been Started discussed in the inteqrated plan or durinq the Audit process.

3.2.4.5.A Access to protected and internal locked plant areas during an Started. The existing ELAP has not been discussed in the Integrated Plan or during the audit Peach Bottom procedure process. SE-11 "Loss of Offsite Power" issues Master Security Keys to Operations personnel for actions requiring access inside the Protected Area.

Page 7 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachn1ent 2 4.2 Confirmatory Items .

Confirmatory Item Status 3.1.1.1.A The method selected for protection of equipment during a Started BDBEE was not discussed in the Integrated Plan or during the audit process. There was no discussion of the specifications stated in NEI 12- The design of the 06, Sections 5.3.1, 6.2.3.1, 7.3.1, 8.3. i, and 9.3.1. Also, there was no structure is in full discussion of securing large portable equipment for protection during a compliance with seismic hazard. requirements set forth in NEI 12-06. The equipment will be tethered to hold points in the base slab of the building to secure it while in storage. The building will have ventilation to provide protection against high temperatures, and heat to protect against freezing.

See Attachment 3 3.1.1.2.A Deployment routes have not yet been finalized or reviewed for Started possible impacts due to debris and potential soil liquefaction The haul path has now been defined as the location of the robust building protecting the FLEX portable equipment is now known. This path has been sampled and the geotechnical report confirmed that no liquefaction issues exist for the deployment haul path. Debris will be moved using the plow attachment of the F-750 truck.

3.1.1.2.C Protection of vehicles used to deploy and re-fuel Completed. The FLEX portable/FLEX equipment during a BDBEE was not discussed in the portable equipment Integrated Plan or during the audit process. including the F-750 which will be used to transport fuel for refilling the portable pumps and generators will be housed in the new robust building which is engineered to meet the requirements of N El 12-06 Sections 11, 5.3.1, 8.3.1 and 9.3.1.

Page 8 of 16

Peach Bottom Atomic Power Station. Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28. 2014 Attachment 2 The building design meets the SSE requirements and has heating and ventilation appropriate with the desiqn requirements.

3. 1. 1.3.A Seismic procedural intertace consideration NEI 12-06, Section 5.3.3, consideration 1, which considers the possible failure of seismically qualified electrical equipment by beyond-design basis Started seismic events, was not discussed in the Integrated Plan or during the audit process.

3.1.1.3.B Seismic procedural intertace considerations NEI 12-06, section 5.3.3, 2 and 3, which considers flooding from large internal sources and also mitigation of ground water was not discussed in the Not started Integrated Plan or during the audit process.

3.1.1.4.A Utilization of offsite resources - the local staging area was not Started discussed in the Integrated Plan or during the audit process.

3.1.2.A Characterization of the external flooding hazard in terms of Started. The Flood warning time and persistence was not discussed in the Integrated Plan Hazard reanalysis is in or during the audit process. progress.

3.1.2.1 A Protection of portable/FLEX equipment during a flooding Started BDBEE was not discussed in the Integrated Plan or during the audit At the time of the initial process. RAI the final locations for the FLEX robust storage location was not determined. Through the update process as stated in Attachment 3, the FLEX pumps, generators and other equipment will be stored below the PMF elevation; however, procedures governing the actual or predicted high river level or flows will include guidance for relocating equipment to an elevation above the PMF and prior to a river level that would prevent transport. Rapid rise of the water level is not anticipated to be a realistic scenario for the site; however, the floodina analvsis is still Page 9 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 2 underway as of 8/28/14.

3.1.2.2.A Movement of equipment and restocking of supplies in the Started context of a flood with long persistence during a BDBEE was not Plans for equipment discussed in the Integrated Plan or during the audit process. relocation have been addressed in Attachment 3, section 6.2.3.1 Protection of FLEX Equipment (Flooding) item 2. Events causing a river level exceeding 1i6' elevation that would prevent transport of FLEX equipment would potentially have several days warning; however, the flood hazard reanalysis is in progress and will provide information on the persistence of a flood event.

3.1.3.2.A Availability of debris clearing equipment during a BDBEE was Started. The vehicle and not discussed in the Integrated Plan or during the audit process. equipment used to clear debris will be stored in the FLEX building.

3.1.4.2.A Snow or ice removal during a BDBEE was not discussed in Started. The vehicle and the Integrated Plan or during the audit process. Additionally, there was equipment used for snow no discussion of ice blocking the FLEX pump suctions. and ice removal will be stored in the FLEX building.

3.2.1.1 .A MAAP benchmarks should be identified and discussed which demonstrate that MAAP4 is an appropriate code for the simulation of an Started ELAP event.

3.2.1.1.B MAAP Analysis - collapsed level should remain above Top of Active Fuel (TAF) and the cool down rate should be within Started technical specification limits.

3.2.1.1 .C MAAP4 should be used in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper. Started 3.2.1.1.0 MAAP modeling parameters. In using MAAP4, the licensee should identify and justify the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Started Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1020236).

3.2.1.1.E The specific MAAP4 analysis case that was used to validate Started Page 10 of 16

Peach Bottom Atomic Power Station, lJnits 2 and 1 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 2 the timing of mitigating strategies in the Integrated Plan should be identified and available for review.

3.2.1.2.A There was no discussion of the assumed recirculation system leakage rates including the recirculation pump seal leakage rates that were used in the ELAP analysis. Questions still remain unanswered regarding pressure dependence of the assumed leakage rates, Not started assumed leakage phase, i.e. single phase liquid, two phase, or steam, and other questions presented in the audit.

3.2.1.4.A Required flow rates and portable/FLEX pump characteristics were not discussed in the Integrated Plan or during the audit process.

Likewise, there was no discussion of the required flow for mitigation Started strategies and no discussion of the calculations that verify adequate flow.

3.2.1.4.B There was no discussion of the assumptions used in the calculations for battery coping time and to evaluate the effectiveness of de load reduction including the basis for the assumed minimum battery Started voltage.

3.2.1.4.C The operability of the RCIC pump at elevated suction temperature was not discussed in the Integrated Plan or during the audit Started process.

3.2.1.4.D Water quality issues and guidance on priority of water source Started usage were not fully addressed in the Integrated Plan or during the audit Water quality is process and requires further analysis by licensee. prioritized using clean sources to dirty sources as they are exhausted and then transfer back to clean as they become available in accordance with the BWROG's recommendation of maintaining level high if dirty water is used.

3.2.2.A Evaluation of the refueling floor SFP area for steam and condensation was not yet completed. Mitigating strategies for a Started vent pathway were not discussed in the Integrated Plan or during the audit process.

3.2.4.2.A The impact of high temperature on the operability of RCIC Started Room electrical and mechanical equipment, including the RCIC turbine A GOTHIC analysis of the speed controller, was not discussed in the Integrated Plan or during the room was performed.

audit process.

3.2.4.2.B Evaluation of high and low battery temperatures is to be provided during a future six-month-update. Not started 3.2.4.4.B Plant communications during an ELAP were not discussed in Started. Three satellite the Integrated Plan or the audit process. Follow-up of commitments phones are available for Page 11 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of HBX August 28, 2014 Attachment 2 made in the communications assessment (ADAMS Accession No. ML offsite communications.

12306A 199) is necessary. The plant radio Talk Around" is adequate for line of sight communications and extra batteries and chargers are available.

Evaluation of existing communications systems is in progress.

3.2.4.6.A Initial analysis for accessibility and habitability of critical plant locations as the RCIC Room showed relatively high temperatures.

There was no discussion of the effectiveness of ventilation with portable Not started fans. There was no discussion of long term habitability in critical plant locations during an ELAP.

3.2.4.7.A Emergency Cooling Tower water volume and replenishment Started was not discussed in the lntemated Plan or durinq the audit process.

3.2.4.8.A The licensee did not provide sufficient information regarding Started loading/sizing calculations of portable diesel generator(s) and strategy Estimated Load for Unit 2 for electrical isolation for FLEX electrical generators from installed plant is 231.9 kw, 281.3 kva.

equipment. Estimated Load for Unit 3 is 130.0 kw, 164.0 kva.

FLEX Generators are 480 vac/ 500 kva. Isolation from installed plant equipment will be by racked out circuit breakers or locked open disconnect switches.

3.2.4.9.A Details of portable equipment fuel storage transfer were provided during the audit process. However, the method to ensure fuel Started quality was not discussed in the Integrated Plan or during the audit process.

3.4.A The program or process to request National SAFER Response Center equipment was not discussed in the Integrated Plan or during Started the audit process.

3.4.B Sizing calculations of National SAFER Response Center FLEX Started equipment and the compatibility of National SAFER Response Center All of the generic equipment to plant connection points were not discussed in the equipment has been Integrated Plan or during the audit process. ordered or received and site specific equipment has been identified.

Page 12 of 16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 3 5.3.1 Protection of FLEX Equipment (Seismic)

1. FLEX equipment should be stored in one or more of following three configurations:
a. In a structure that meets the plant's design basis for the Safe FLEX pumps, generators Shutdown Earthquake (SSE)(e.g., existing safety-related and other equipment will structure). be stored in a robust structure designed to survive a SSE.
b. In a structure designed to or evaluated equivalent to ASCE 7-NA 10, Minimum Design Loads for Buildings and Other Structures.
c. Outside a structure and evaluated for seismic interactions to ensure equipment is not damaged by non-seismically robust NA components or structures.
2. Large portable FLEX equipment such as pumps and power supplies FLEX pumps, generators should be secured as appropriate to protect them during a seismic and other large event (i.e., Safe Shutdown Earthquake (SSE) level). equipment will be secured to prevent damage during a SSE.
3. Stored equipment and structures should be evaluated and The robust FLEX storage protected from seismic interactions to ensure that unsecured structure will be designed and/or non-seismic components do not damage the equipment. to protect the FLEX equipment from unsecured or non-seismic components during a SSE.

6~2.3.1 Protection.of FLEX Equipment (Flooding)

These considerations apply to the protection of FLEX equipment from external flood hazards:

1. The equipment should be stored in one or more of the following configurations:
a. Stored above the flood elevation from the most recent site flood analysis. The evaluation to determine the elevation for storage should be informed by flood analysis applicable to the NA site from early site permits, combined license applications, and/or contiguous licensed sites.
b. Stored in a structure designed to protect the equipment from NA the flood.
c. FLEX equipment can be stored below flood level if time is FLEX pumps, generators available and plant procedures/guidance address the needed and other equipment will actions to relocate the equipment. Based on the timing of the be stored below the PMF limiting flood scenario(s), the FLEX equipment can be relocated elevation. Procedures to a position that is protected from the flood, either by barriers governing actual or or by elevation, prior to the arrival of the potentially damaging predicted high river level flood levels. This should also consider the conditions on-site or flows will include Page 13 of 16

Peach Bottoni Alornic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 2014 Attachment 3 during the increasing flood levels and whether movement of guidance for relocating the FLEX equipment will be possible before potential the equipment to an inundation occurs, not just the ultimate flood height. elevation above the PMF level and prior to a river level that would prevent transport.

2. Storage areas that are potentially impacted by a rapid rise of water Events causing a river should be avoided. level exceeding 116' elevation that would prevent transport of FLEX equipment are precipitation events, which would have advanced warning; however, the flood hazard reanalysis is in progress and additional information will be provided in a future 6 month update .
  • . 7,3.1 Pr<.>tection of fLE,C Eq\Jlprnent (Wind) . .**.... *.* .*

These considerations apply to the protection of FLEX equipment from high wind hazards: .*

1. For plants exposed to high wind hazards, FLEX equipment should be stored in one of the following configurations: ... *. .
a. In a structure that meets the plant's design basis for high wind FLEX pumps, generators hazards (e.g., existing safety-related structure). and other equipment will be stored in a robust structure that will survive the design basis wind.
b. In storage locations designed to or evaluated equivalent to ASCE 7-10, Minimum Design Loads for Buildings and Other Structures given the limiting tornado wind speeds from Regulatory Guide 1.76 or design basis hurricane wind speeds for the site. Given the FLEX basis limiting tornado or hurricane wind speeds, building loads would be computed in accordance NA with requirements of ASCE 7-10. Acceptance criteria would be based on building serviceability requirements not strict compliance with stress or capacity limits. This would allow for some minor plastic deformation, yet assure that the building would remain functional.
  • Tornado missiles and hurricane missiles will be accounted for in that the FLEX equipment will be stored in diverse NA locations to provide reasonable assurance that N sets of Page 14 of 16

Peach Bott.om Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the Implementation of FLEX August 28, 20 l4 Attachment 3 FLEX equipment will remain deployable following the high wind event. This will consider locations adjacent to existing robust structures or in lower sections of buildings that minimizes the probability that missiles will damage all mitigation equipment required from a single event by protection from adjacent buildings and limiting pathways for missiles to damage equipment.

  • The axis of separation should consider the predominant path of tornados in the geographical location. In general, tornadoes travel from the West or West Southwesterly direction, diverse locations should be aligned in the North-South arrangement, where possible. Additionally, in NA selecting diverse FLEX storage locations, consideration should be given to the location of the diesel generators and switchyard such that the path of a single tornado would not impact all locations.
  • Stored mitigation equipment exposed to the wind should be adequately tied down. Loose equipment should be in protective boxes that are adequately tied down to foundations or slabs to prevent protected equipment from NA being damaged or becoming airborne. (During a tornado, high winds may blow away metal siding and metal deck roof, subjecting the equipment to high wind forces.)
c. In evaluated storage locations separated by a sufficient distance that minimizes the probability that a single event would damage all FLEX mitigation equipment such that at least NA N sets of FLEX equipment would remain deployable following the high wind event. (This option is not applicable for hurricane conditions).
  • Consistent with configuration b., the axis of separation should consider the predominant path of tornados in the NA geographical location.
  • Consistent with configuration b., stored mitigation NA equipment should be adequately tied down.

8.3.1 Protection of FLEX Equipment {Snow; lee, Cold) .*

  • These considerations apply to the protection of FLEX equipment from snow, ice, and extreme cold hazards: .
1. For sites subject to significant snowfall and ice storms, portable FLEX equipment should be stored in one of two configurations: .. .*** .*. .. *
a. In a structure that meets the plant's design basis for the snow, FLEX pumps, generators ice and cold conditions (e.g., existing safety-related structure). and other equipment will be stored in a robust structure that will survive Page15of16

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six Month Status Report for the hnplcmcntation of FLEX August 28, 2014 Attachment 3 the design basis for snow, ice, and cold.

b. In a structure designed to or evaluated equivalent to ASCE 7-10, Minimum Design Loads for Buildings and Other Structures NA for the snow, ice, and cold conditions from the site's design basis.
c. Provided the N FLEX equipment is located as described in a. or
b. above, the N+l equipment may be stored in an evaluated NA storage location capable of withstanding historical extreme weather conditions and the equipment is deployable.
2. Storage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The FLEX pumps, generators equipment should be maintained at a temperature within a range and their storage location to ensure its likely function when called upon. For example, by will include appropriate storage in a heated enclosure or by direct heating (e.g., jacket heating.

water, battery, engine block heater, etc.).

9.3.1 Protection of FLEX Equipment (High Temperature)

The equipment should be maintained at a temperature within a range to FLEX pumps, generators ensure its likely function when called upon. and their storage location will include appropriate ventilation such that the equipment will be maintained within operating limits.

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