Text

August 2014 Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)
	ML14241A380
Person / Time
Site:	Nine Mile Point
Issue date:	08/26/2014
From:	Korsnick M; Constellation Energy Nuclear Group, Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, FLL-14-028
	Download: ML14241A380 (49)
	v • d • e

AMaria Korsnlck ASenior Vice President, Northeast Operations A

Exeton GenerationQ Chief Nuclear Officer, CENG 100 Constellation Way Suite 500P Constellation Energy Nuclear Group, LLC Baltimore, MD 21202 410-470-5133 Office 443-213-6739 Fax www.exeloncorp.com maria.korsnick@exeloncorp.com NRC Order No. EA-12-049 FLL-14-028 August 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-410

Subject:

August 2014 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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 (ML12054A735)

(2) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Response to NRC Letter on Technical Issues for Resolution Regarding Communications Submittals Associated with Near Term Task Force Recommendation 9.3, dated February 22, 2013 (ML13066A710)

(3) Letter from B. K. Vaidya (NRC) to C. Costanzo (CENG), Nile Mile Point Nuclear Station, Unit Nos. 1 and 2 - Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC Nos. ME9970 and ME9971),

dated April 24, 2013 (ML13100A236)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 12-049 (Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for Nile Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2 (NMP1 and NMP2). Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan.

Attachments (1) and (2) provide the six-month Status Reports for NMP1 and NMP2, respectively. The report updates the milestone accomplishments since the submittal of the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

In Reference (2), NMPNS committed to include the status of the implementing actions identified in Section 4.12 of the Communications Assessment as part of the six-month status reports

U. S. Nuclear Regulatory Commission August 26, 2014 Page 2 required by Section IV.C.2 of NRC Order EA-12-049. Attachment (1) includes an update of the status of these implementing actions. This will be the last status update for those actions.

Future six-month status reports submitted in accordance with Section IV.C.2 of NRC Order EA-12-049 will not include a status of the implementing actions identified in Section 4.12 of the Communications Assessment, as these updates have negligible safety significance. Thus, this letter deletes the regulatory commitment made in Reference (2).

As documented in Reference (3), the regulatory commitments to implement the NMP1 and NMP2 improvements related to mitigating strategies (FLEX) derived from the results of the communications assessment will be completed: a) prior to the startup of NMP1 following the Spring 2015 refueling outage; and b) prior to the startup of NMP2 following the Spring 2016 refueling outage.

There are no regulatory commitments contained in this letter.

If there are any questions regarding this letter, please contact Bruce Montgomery, Acting Manager - Licensing, at 443-532-6533.

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

2 6 th day of August, 2014.

Executed on the Respectfully, MGK/STD Attachments (1)

NMP1 Six-Month Status Report Design-Basis External Events (2)

NMP2 Six-Month Status Report Design-Basis External Events (August 2014) for Mitigation Strategies for Beyond-(August 2014) for Mitigation Strategies for Beyond-cc:

Regional Administrator, Region I, USNRC NRC Project Manager, NRR - Nile Mile Point Nuclear Station NRC Senior Resident Inspector - Nile Mile Point Nuclear Station Director, Office of Nuclear Reactor Regulation J. A. Kratchman, NRC S. Gray, DNR

ATTACHMENT (1)

NMP1 SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NINE MILE POINT NUCLEAR STATION, LLC August 26, 2014

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 lIntroduction The Nine Mile Point Unit 1 (NMP1) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2).

Subsequently, a supplement to the NMP1 0IP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis (if applicable).

NMP1 developed an Interim Action Implementation Schedule, as part of an Assessment of Communications during an Extended Loss of AC Power (ELAP) (Reference 4). A commitment was made in Reference 4 to include the status of the implementing actions identified in Section 4.12 of the NMP1 communications assessment as part of the Six Month Status Reports prepared pursuant to Section IV.C.2 of NRC Order EA-12-049.

The updated status of the communications assessment interim actions is provided in Section 8. However, the six month communications assessment interim actions updates are not required by any related NRC Order or endorsed guidance for Beyond-Design-Basis External Events.

Nine Mile Point continues to work on implementation plans associated with meeting the guidance in NEI 12-06 (Reference 5) and recognizes the close coordination and relationship to the guidance in NEI 12-01 Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. Communications plan interim action status updates will no longer be included in the FLEX Six Month Updates following this edition. This reduction in commitment will align the Exelon Northeast sites (former CENG sites) with the rest of the fleet.

Since the submittal of the last status report in February 2014 (Reference 8), NMP1 FLEX has progressed with engineering analysis and calculations that support the mitigating strategies and the modification concepts have been refined. Some changes to the mitigation strategies and planned modifications in support of the mitigation strategies have occurred and are explained within this document.

Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued, with review of proposed supporting equipment specifications to allow regional center equipment purchases to commence, and initial development of the site specific SAFER Response Plan has begun.

By letter dated December 19, 2013, the NRC issued to CENG the Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7).

The Interim Staff Evaluation (ISE) contains open and confirmatory items for which CENG will provide clarifying or additional information in Six Month Status Reports in order for the NRC to determine that the issues are on a path to satisfactory resolution.

Page 1 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference

3) and are current as of July 15, 2014.

" Refueling Outage (RFO), including walk downs in support of pending modifications for installation for FLEX strategies (see status provided in 8/2013 OIP Update)

Six Month Integrated Plan Progress Report submitted (Reference 6)

Six Month Integrated Plan Progress Report submitted (Reference 8) 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMP1 0IP (Attachment 2 - References 1 and 3). It provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Any changes to the following target completion dates will be reflected in subsequent Six Month Status Reports.

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

Table 1 Status of NMP1 FLEX OIP Milestones Revised Target Target Completion Activity Completion Milestone Date Status Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Implementation February Plan 2013 Complete Refueling Outage Spring 2013 Complete Six Month Integrated Plan Progress Report August 2013 Complete Engineering and Design Completion -

November Equipment Storage Facility January 2014 Started 20141 February Six Month Integrated Plan Progress Report 2014 Complete Engineering and Design Completion -

February Portable Equipment Connections 2014 Started August 2014 Six Month Integrated Plan Progress Report August 2014 Complete Page 2 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of NMP1 FLEX OIP Milestones (cont'd)

Revised Target Target Completion Activity Completion Milestone Date Status Date February Six Month Integrated Plan Progress Report 2015 Not Started Non-Outage Installation - Portable Equipment Connection March 2015 Not Started Validation Walkdowns Complete March 2015 Not Started Portable Equipment Procedures Changes March 2015 Started FLEX Training April 2015 Not Started Outage Installation - Portable Equipment Connections May 2015 Not Started Equipment Storage Facility Installation May 2015 Not Started Final Implementation Notification to USNRC July 2015 Not Started Note 1:

Revised from previous NMP1 Six Month Status Report which identified July 2014.

Building design supporting the start of construction in August has been completed. Design supporting building services and security access will be completed in November 2014. Overall completion to the Milestone for 'Equipment Storage Facility Installation' remains unaffected.

4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last Six Month Status Report. NMP1 will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures (References 9 and 10).

The following coping strategy changes have occurred since the previous Six Month Status Update provided on February 28, 2014 (Reference 8)

Calculations have been completed that provide evaluation of the environmental conditions in the Reactor Building, including the refueling floor, after an event.

The calculation demonstrates that opening various Reactor Building air lock doors and Turbine Building doors/side wall vents during an ELAP event will minimize the temperature/pressure rise in the Reactor Building and the long term environmental conditions are acceptable.

Page 3 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS No modifications will be installed to support mitigating strategies for Phase 3. The connection of the majority of Phase 3 equipment will be made to connection points established for Phase 2 equipment and strategies. Resources will be available, and sufficient, at the times required for Phase 3 implementation. The remaining Phase 3 non-redundant equipment will be deployed utilizing field established connections, without the reliance on plug and play type modifications.

" The original concept for a suction source for all portable pumps was to install a dry hydrant in the intake structure. This has been modified to provide access ports through the north wall of the Screenhouse Building, through which flexible suction hoses will be fed, and dropped into the intake/discharge bays inside the Screenhouse Building. This change results in minor wording changes to Open Items 6, 7 and 50.

The last NMP1 FLEX Six Month Update (Reference 8) identified the following strategy change for Spent Fuel Pool (SFP) makeup capability:

"The NMP1 0IP (Reference 3) description of the primary connection modification for SFP makeup and preliminary drawings associated with the makeup water capability for the SFP identified that there would be a hard pipe tied into the SFP cooling system return line. This has changed in that the primary injection point for makeup to the SFP will instead be routed to the refueling floor such that it will discharge directly into the SFP. Hard pipe will be routed to the refueling floor and a connection point added. A hose will be connected at that point and be routed to the SFP and secured so that it discharges into the SFP. This change eliminates the need to modify the existing safety related SFP cooling system and utilizes existing floor penetrations in order to run the piping to the SFP and achieve the same result. For this reason, Open Item 53 in Table 2 has been revised to remove the wording that identified that makeup to the SFP would be connected to the SFP cooling system return line."

This strategy has been refined further in that hard piping will now be installed from the floor below to the refueling floor and directed to discharge into the SFP. Hose will be connected at that point (below the Refueling Floor) which is routed from the Reactor Building track bay on the ground floor and connected to the FLEX pump water supply. This change to the strategy was made in order to comply with the specific guidance in NEI 12-06 Table C-3 to "...provide a means to supply SFP makeup without accessing the refueling floor."

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

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation NMP1 expects to comply with the order implementation date and no relief/relaxation is required at this time.

Page 4 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Table 2 provides a summary of the open items documented in the OIP and those added in any subsequent Six Month Status Reports and the status of each item.

The following is a list of the open items from the OIP that have been added, deleted or completed since the last Six Month Status Report with an explanation of the changes:

1. Maintain Core Cooling - BWR Portable Equipment Phase 2 Open Item #7:

Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the dry hydrants will consider Phase 3 requirements.

This item is deleted. Open Item # 6 specifically addresses the necessary analysis for Phase 2. Phase 2 strategies will provide sufficient capabilities to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Placing additional equipment in service to support restart of plant equipment (such as Shutdown Cooling) is not necessary to support indefinite coping, is considered to be part of plant recovery, and is therefore not within the scope of the mitigating strategies.

2. Safety Function Support - BWR Portable Equipment Phase 2 Open Item 11: Verify plans for the FLEX storage facilities in accordance with NEI 12-06 requirements, also accommodate the storage and availability of fuel for the small gas generators.

This item is complete.

An Exelon fleet design specification has been developed, including all applicable Nine Mile Point site specific design requirements.

Robust structure design work is complete, including those drawings, specifications and calculations that allow for construction to begin and space for the storage of the small gas generators and the fuel for them within the building. All FLEX equipment, including combustible material cabinets and fuel cans for refueling portable generators will be stored in the FLEX storage structure.

Open Item #40:

Perform an analysis of Refuel Floor/SFP area for long term environmental conditions.

This item is complete. Calculation SO-GOTHIC-ELAP001 "Reactor Building Response Following an Extended Loss of AC Power" has been completed.

The calculation demonstrates that opening various Reactor Building air lock doors and Turbine Building doors/side wall vents during an ELAP event will minimize the temperature/pressure rise in the Reactor Building and the long term environmental conditions are acceptable.

Page 5 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Open Item # 47: Perform an analysis of the need for dewatering based on leak rates and flood response capabilities and implement dewatering portable equipment and strategies based on this analysis.

This item is deleted. The following is provided in the original 0IP; "Note that this is not a required strategy for core, containment or spent fuel pool cooling but for the long term consideration of normalization of plant systems." Based on this, there is no need for dewatering actions to be planned within the scope of the mitigating strategies.

3. Maintain Core Cooling - BWR Portable Equipment Phase 3 Open Item # 30 and # 31: # 30 -Perform an analysis to determine the flow/capacity needed for the portable pump from the RRC to adequately supply the Emergency Service Water (ESW) system, and# 31 - Evaluate the connection point for the RRC portable pump to ESW and implement a design change to ensure that the pump can be connected.

These items are deleted. Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Placing ESW in service to support the restart of Reactor Building Closed Loop Cooling is considered to be part of plant recovery and is therefore not within the scope of the mitigating strategies.

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

This item is deleted. Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Placing Reactor Building Closed Loop Cooling in service is considered to be part of plant recovery and is therefore not within the scope of the mitigating strategies.

Open Item # 52: Evaluate and implement a design change to install permanent generator connection points for 4160 VAC.

This item is deleted.

Phase 1 and 2 strategies provide sufficient capabilities to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Connecting a RRC 4160 VAC generator to a safety related bus will only be performed as needed to support recovery and is therefore not within the scope mitigating strategies.

4. Maintain Containment - BWR Portable Equipment Phase 3 Open Item # 36: Perform an analysis to determine when ambient heat losses will be enough to cool the containment with Shutdown Cooling (SDC) in Phase 3.

This item is deleted.

Containment analysis provides that Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Placing SDC in service is considered to be part of plant recovery and is therefore not within the scope of the mitigating strategies.

Page 6 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Open Item # 60: Perform an evaluation in order to identify and implement the capability to provide motive power to restore the SDC system (new Open Item added subsequent to original OIP submittal and described in the August 2013 Six Month Update).

This item is deleted: Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Placing SDC in service is considered to be part of plant recovery and is therefore not within the scope of the mitigating strategies.

Open item # 61: In Phase 3, a modification to remove water from the torus using RRC supplied equipment will be evaluated and implemented as required (new Open Item based on strategy changes described in the August 2013 Six Month Update).

This item is deleted: Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Containment response analysis identifies that Torus water level is satisfactory and therefore dewatering the Torus is considered to be part of plant recovery and is therefore not within the scope of the mitigating strategies.

5. Maintain Containment - BWR Installed Equipment Phase 1 Open Item # 34: Perform a site specific analysis to confirm that the containment parameters (temperature, pressure and level) stay below their design limits during Phase 1 following an ELAP.

This item is complete.

Calculation SO-GOTHIC-ELAP002 "Primary Containment Response Following an Extended Loss of AC Power" has been completed.

The calculation demonstrates that the primary containment parameters (temperature, pressure, level) remain essentially at or below their design limits during Phases 1 and 2 following an ELAP for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

6. Maintain Spent Fuel Pool Cooling - BWR Installed Equipment Phase 1 Open Item #37:

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

This item is complete. Calculation SO-GOTHIC-ELAP001 "Reactor Building Response Following an Extended Loss of AC Power" has been completed.

The calculation demonstrates that by opening various Reactor Building air lock doors and Turbine Building doors/side wall vents during an ELAP event will minimize the temperature/pressure rise in the Reactor Building and the long term environmental conditions are acceptable.

Open Item # 42:

Evaluate the ELAP/FLEX strategy to cope with the potential pressurization of the refueling floor and to prevent buildup of steam and condensation if required.

This item is complete. Calculation SO-GOTHIC-ELAP001 "Reactor Building Response Following an Extended Loss of AC Power" has been completed.

The calculation demonstrates that by opening various Reactor Building air lock doors and Turbine Page 7 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Building doors/side wall vents during an ELAP event will minimize the temperature/pressure rise in the Reactor Building and the long term environmental conditions are acceptable.

Table 2 Status of NMP1 FLEX OIP Open Items NMP1 OIP Open Items Status Complete (see the

1.

Define criteria for the local (25 mile) staging area 2/2014 OIP Update)

2.

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

3.

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

4.

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

10 CFR 50.54x) requirements of a nature requiring NRC approval Started (8/2013) will be communicated in a future Six Month Update following identification

5.

Determine schedule for when Regional Response Centers (RRC)

Complete (see the will be fully operational 8/2013 0IP Update)

6.

Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the intake/discharge bays will consider Phase 2 requirements

7.

Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow Deleted (this OIP requirements from the intake/discharge bays will consider Phase 3 Update 8/2014) requirements

8.

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

9.

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

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

11.

Verify plans for the FLEX storage facilities in accordance with NEI Complete (this QIP 12-06 requirements; also accommodate the storage and availability Update 8/2014) of fuel for the small gas generators I

I Page 8 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP10OIP Open Items Status

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

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

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

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

Staging Area "C"

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

17. Provide the necessary storage facilities in order to provide fuel to Started (8/2014) the transfer pumps during an ELAP event

18. Develop site specific SAFER Response Plan (playbook) for Satd(/03 delivery of portable FLEX equipment from the RRC to the site

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

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM)

Started (8/2013) recommendation and Electric Power Research Institute (EPRI) guidelines for FLEX equipment

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

22. Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport Started (8/2014)

FLEX portable equipment during all modes of operation

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

Operating Procedures (EOPs)

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

25. Evaluate requirements and options and develop strategies related to the storage and transport of the on-site FLEX portable Started (2/2014) equipment Page 9 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

26. Evaluate NMP1 containment integrity for Phases 1 through 3 and Added (see the provide analysis in a future required Six Month Status Report (new 8/2013 OIP Open Item added since original OIP as a result of further Update) considerations of necessary analysis to support FLEX strategies)

Started

27. Implement a design change to install a permanent connection point Added (see the for a portable pump to provide makeup to the Emergency 8/2013 OIP Condensers (ECs) (new Open Item added as a result of strategy Update) changes described in the August 2013 Six Month Update)

Started

28. Perform an evaluation to ensure that the recirculation pump seal operating conditions are consistent with the referenced vendor test Started (8/2014) report

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

30. Perform an analysis to determine the flow/capacity needed for the Deleted (this QIP portable pump from the RRC to adequately supply the Emergency Update 8/2014)

Service Water (ESW) system

31. Evaluate the connection point for the RRC portable pump to ESW Deleted (this OIP and implement a design change to ensure that the pump can be Update 8/2014) connected

32. Evaluate implementation of makeup capability for the Reactor Deleted (this OIP Building Closed Loop Cooling (RBCLC) system expansion tank to Update 8/2014) support restarting the system in Phase 3

33. Perform an analysis to determine the containment pressure profile during an ELAP / LUHS event and verify the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function

34. Perform a site specific analysis to confirm that the containment Completed (this parameters (temperature, pressure and level) stay below their OIP Update design limits during Phase 1 following an ELAP 8/2014)

35. Perform analysis to identify the heat load expected during ELAP conditions and the time required to open vents to maintain Started (2/2014) containment parameters Page 10 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

36. Perform an analysis to determine when ambient heat losses will be Deleted (this OIP enough to cool the containment with Shutdown Cooling (SDC) in Update 8/2014)

Phase 3 Completed (this

37. Evaluate a strategy to provide a pathway for steam and oIP Update condensate or justify why it is not needed (for the refuel floor) 8/2014)

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

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

40. Perform an analysis of Refuel Floor/SFP area for long term Completed (this environmental conditions 01P Update 8/2014)

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

42. Evaluate the ELAP/FLEX strategy to cope with the potential Completed (this pressurization of the refueling floor and to prevent buildup of steam 0IP Update and condensation if required 8/2014)

Deleted (see the

43. Perform an analysis to evaluate long term temperature profiles in 8/2013 (eP NMP1 Main Control Room (MCR) under ELAP conditions Update)

Update)

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

Deleted (see the

45. Perform an analysis to validate the mild environment in NMP1 EC 8/2013 (eP Makeup Tank Area during an ELAP (Turbine Building)

Update)

46. Perform an analysis for long term environmental conditions in Complete (see the NMP1 Battery Rooms during an ELAP and evaluate any actions to 2/2014 OIP mitigate the impact of this hydrogen production as required.

Update)

Page 11 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

47. Perform an analysis of the need for dewatering based on leak rates Deleted (this OIP and flood response capabilities and implement dewatering portable equipment and strategies based on this analysis Update 8/2014)

48. Implement a design change to install a permanent FLEX 600 VAC Deleted (see the diesel generator (DG) connection point to the 600 VAC power 8/2013 OIP board (PB1 6B) and an alternative connection for the opposite 600 Update)

VAC power board (PB17B)

49. Implement a design change to install a permanent connection point Started (8/2013) for FLEX portable pump injection through feed water

50. Implement a design change to provide suction hose access points Started (2/2014) in the intake/discharge structures for FLEX portable pump suction

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

Update)

52. Evaluate and implement a design change to install permanent Deleted (this 0IP generator connection points for 4160 VAC Update 8/2014)

53. Design and implement a modification that provides for connection Started (2/2014) of a FLEX portable pump to makeup to the SFP

54. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event Started (8/2014) to include both primary and alternate strategies

55. Revise Station Blackout (SBO) procedures and ELAP procedures, when written, to direct that both EC's are immediately manually Started (8/2014) placed in service and to manually close Main Steam Isolation Valves (MSIVs) (to conserve RPV inventory)

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

57. Perform time validation of the core cooling injection capabilities when detailed design is complete, implementation procedures are Not Started drafted and final storage facility locations are determined for the portable equipment Page 12 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

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

Month Update)

Started (2/2014)

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

Started (2/2014)

60. Perform an evaluation in order to identify and implement the capability to provide motive power to restore the SDC system (new Deleted (this OIP Open Item added subsequent to original OIP submittal and Update 8/2014) described in the August 2013 Six Month Update)

61.

In Phase 3, a modification to remove water from the torus using RRC supplied equipment will be evaluated and implemented as Deleted (this OIP required (new Open Item based on strategy changes described in Update 8/2014) the August 2013 Six Month Update)

Table 3 provides a summary of the open and confirmatory items documented in the NRC's NMP1 ISE (Reference 7) and the status of each item. The following is a list of NMP1 ISE Open or Confirmatory Items Submitted for Closure.

ISE Confirmatory Items 6 through 10 identifies various NRC issues that revolve around the use of MAAP for analysis.

ISE Confirmatory Items 6 - 10 are submitted for closure. NMP1 has a design basis Appendix R analysis (S22.2-XX-EOP001) that provides a design verified reactor water level response assuming a 45 gpm leakage at rated pressure. The analysis uses safety related GEH software qualified to perform LOCA analyses.

This analysis has been reviewed and the assumptions are consistent with the conditions required to evaluate the FLEX coping strategy. Based on the review of this calculation, the time to reach Top of Active Fuel (TAF) is defined and the FLEX coping strategy was developed.

The MAAP software is not required to evaluate the FLEX strategy or to define the reactor water level response. The Unit 1 MAAP Probabilistic Risk Assessment (PRA) model has been used as a benchmark to the design basis Appendix R analysis and the MAAP PRA model provide consistent results when similar assumptions are applied.

Page 13 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Item # 12: ISE Confirmatory Item 3.2.3.A - The licensee has yet to evaluate containment integrity for Phases 1 through 2 and provide the finalized analysis for review.

ISE Confirmatory Item # 12 is submitted for closure. This item is addressed with NMP1 QIP Open Item #34 which has been completed.

Calculation SO-GOTHIC-ELAP002 "Primary Containment Response Following an Extended Loss of AC Power" has been completed.

The calculation demonstrates that the primary containment parameters (temperature, pressure, level) remain essentially at or below their design limits during Phases 1 and 2 following an ELAP for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

ISE Confirmatory Item # 13: ISE Confirmatory Item 3.2.3.B - A modification to remove water from the torus in Phase 3 using RRC supplied equipment will be evaluated and implemented as required.

ISE Confirmatory Item # 13 is submitted for closure. This item is addressed with NMP1 OIP Open Item #61 which has been deleted. Phase 2 strategies are adequate to maintain or restore key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Containment response analysis identifies that Torus water level is satisfactory and therefore actions to dewater the Torus that support indefinite coping are to be put in place by the support staff during Phase 2 before being required for Phase 3.

ISE Confirmatory Item # 14: ISE Confirmatory Item 3.2.4.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet completed.

Mitigating strategies, including establishing a vent pathway for steam and condensate from the area, were not discussed in the Integrated Plan or during the audit process.

ISE Confirmatory Item # 14 is submitted for closure. This item is addressed with NMP1 QIP Open Item #37 which has been completed.

Calculation SO-GOTHIC-ELAP001 "Reactor Building Response Following an Extended Loss of AC Power" has been completed. The calculation demonstrates that opening various Reactor Building doors and Turbine Building doors/side wall vents in response to the ELAP event are necessary and will ensure that the temperature/pressure rise in the Reactor Building and the long term environmental conditions are acceptable.

Page 14 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP1 Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status 1

ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, Section 5.3.3, Consideration 1, which Started (8/2014) considers the possible failure of seismically qualified electrical equipment by beyond-design-basis seismic events, was not discussed in the Integrated Plan or during the audit process

2.

ISE Open Item 3.2.1.3.A - The coping strategies for maintaining core cooling were updated in the August 27, 2013 Six Month Started (8/2014)

Update. However, the licensee has not yet updated the sequence of events timeline and the discussion of time constraints ISE Confirmatory Items Status

3.

ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event (BDBEE) was not discussed in the Started (2/2014)

Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard

4.

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

5.

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

6.

ISE Confirmatory Item 3.2.1.1.A - MAAP benchmarks must be Submitted for identified and discussed which demonstrate that MAAP4 is an appropriate code for the simulation of an ELAP event

7.

ISE Confirmatory Item 3.2.1.1.B - MAAP Analysis-collapsed Submitted for level must remain above Top of Active Fuel (TAF) and the cool closure (8/2014) down rate must be within technical specification limits Page 15 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP1 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

8.

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

9.

ISE Confirmatory Item 3.2.1.1..D - MAAP modeling parameters Submitted for must be identified and justified closure (8/2014)

10. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in Submitted for the Integrated Plan must be identified and should be available for closure (8/2014) review

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

12. ISE Confirmatory Item 3.2.3.A - The licensee has yet to Submitted for evaluate containment integrity for Phases 1 through 2 and closure (8/2014) provided the finalized analysis for review

13. ISE Confirmatory Item 3.2.3.B - A modification to remove water Submitted for from the torus in Phase 3 using RRC supplied equipment will be closure (8/2014) evaluated and implemented as required

14. ISE Confirmatory Item 3.2.4.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet Submitted for completed. Mitigating strategies, including establishing a vent closure (8/2014) pathway for steam and condensate from the area, were not discussed in the Integrated Plan or during the audit process

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

Room due to an ELAP event will be provided in the future update Page 16 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP1 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

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

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of commitments, as discussed in the staff analysis (ML13100A236) for Started (8/2014)1 communications assessment, is required

18. ISE Confirmatory Item 3.2.4.6.A - Licensee to provide calculation and basis for use of extrapolated SBO evaluation for Started (8/2014)

Main Control Room habitability

19. ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is completed, the specific details on the protection schemes to Started (2/2014) protect Class 1 E equipment from faults from the portable FLEX equipment will be provided in a future update

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

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

22. ISE Confirmatory Item 3.2.4.1 0.A - The licensee stated that a finalized summary of battery coping time, DC load profile, discussion of loads shed, and minimum DC voltage will be Started (2/2014) provided in a future update

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

24. ISE Confirmatory Item 3.4.B - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant Started (2/2014) connection points was not discussed in the Integrated Plan or during the audit process Page 17 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

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

8 Communications Assessment Interim Action Implementation Status Table 4 provides a listing of the implementing actions documented in the Assessment of Communications during an ELAP (Reference 4).

It provides the status of each action and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. As stated previously, these six month communications assessment interim action updates are not required by any related NRC Order or endorsed guidance for Beyond-Design-Basis External Events. Communications plan interim action status updates will no longer be included in the FLEX Six Month Updates following this edition. This reduction in commitment will align the Exelon Northeast sites (former CENG sites) with the rest of the fleet.

Table 4 Status of NMP1 Communications Assessment Interim Actions Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Fixed Satellite Phones

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

Protected"

2. Install additional antennas, as necessary, to support the use 12/31/2014 of fixed satellite phones at all 8/31/2014 Started Revised to locations; Emergency (8/2014) installation of a Operations Center (EOF) / Joint satellite dish Information Center (JIC)

3. Procure and install fixed satellite phones, additional antennas and uninterruptable power supplies for the Technical Support Center 12/31/2014 Started (TSC) / Operational Support (8/2014)

Center (OSC), Emergency Operations Facility (EOF) and Joint Information Center (JIC)

Page 18 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP1 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

4. Develop Standing Order for Interim actions Standing Order will contain:

Description of the communications equipment purchased for enhancement Complete (see

" Interim storage location of 8/31/2013 the 2/2014 OIP the equipment until final Update) permanent storage is determined

" Conditions describing when equipment will be used

" Instructions for use of the equipment

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

6. Relocate two (2) phones from 12/19/2014 each Control Room to the Date changed to TSC/OSC and EOF be consistent with 8/31/2014 Not Started plans to move/install the fixed satellite phones in all locations Page 19 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP1 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

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

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

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

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

Update)

Facilities

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

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

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

Page 20 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP1 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

5. Procure and install a high power UPS or similar modification providing backup 12/31/2014 Not Started power for the battery chargers for portable satellite phones Communications with Offsite Response Organizations

1. Provide Oswego County Emergency Operations Center (EOC) and Oswego County Complete (see Warning Point (WP) 10/31/2013 the 2/2014 OIP instructions for proper storage Update) and rotation of satellite phone batteries Portable Generators

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

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

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

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

5. Determine a process for Prior to relocating portable generators Startup (S/U) to the appropriate locations to NMP1 RFO Not Started power the necessary 2015 equipment Page 21 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP1 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Site Radio System

1. Procure and install a high power UPS or similar Prior to S/U modification providing backup NMP1 RFO Not Started power for the radio system 2015 repeaters

2. Complete estimates of portable radio battery life and procure Complete (see additional batteries, as 10/31/2013 the 2/2014 Q1P necessary, based on an Update) estimate of minimum talk time to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation Training

1. Evaluate training needs specific Prior to S/U to the use of portable and fixed NMP1 REQ Not Started satellite phones and radios 2015 during an ELAP event

2. Develop and implement training Prior to S/U on the use of backup NMP1 RFO Not Started generators 2015 Page 22 of 23

ATTACHMENT (1)

NMP1 SIX MONTH STATUS REPORT (AUGUST 2014)

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

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February

28. 2013

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

3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 8, 2013

4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letter on Technical Issues for Resolution Regarding Communication Submittals Associated with Near-Term Task Force Recommendation 9.3, dated February 22, 2013

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

6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF1130), dated December 19, 2013

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), February 2014 Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014

9. NEI Position Paper Shutdown and Refueling: ADAMS Accession No. ML13273A514

10. NRC Endorsement of NEI Shutdown and Refueling paper: ADAMS Accession No. ML13267A382 Page 23 of 23

ATTACHMENT (2)

I NMP2 SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENT I

NINE MILE POINT NUCLEAR STATION, LLC August 26, 2014

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The Nine Mile Point Unit 2 (NMP2) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2).

Subsequently, a supplement to the NMP2 OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis (if applicable).

NMP2 developed an Interim Action Implementation Schedule, as part of an Assessment of Communications during an Extended Loss of AC Power (ELAP) (Reference 4). A commitment was made in Reference 4 to include the status of the implementing actions identified in Section 4.12 of the NMP2 communications assessment as part of the Six Month Status Reports prepared pursuant to Section IV.C.2 of NRC Order EA-12-049.

The updated status of the communications assessment interim actions is provided in Section 8. However, these six month communications assessment interim actions updates are not required by any related NRC Order or endorsed guidance for Beyond-Design-Basis External Events.

Nine Mile Point continues to work on implementation plans associated with meeting the guidance in NEI 12-06 (Reference 5) and recognizes the close coordination and relationship to the guidance in NEI 12-01 Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. Communications plan interim action status updates will no longer be included in the FLEX Six Month Updates following this edition. This reduction in commitment will align the Exelon Northeast sites (former CENG sites) with the rest of the fleet.

Since the submittal of the last status report in February 2014 (Reference 8), NMP2 FLEX has progressed with engineering analysis and calculations that support the mitigating strategies and the modification concepts have been refined. Some changes to the mitigation strategies and planned modifications in support of the mitigation strategies have occurred and are explained within this document.

Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued, with review of proposed supporting equipment specifications to allow Regional Center equipment purchases to commence, and initial development of site specific SAFER Response Plan to begin.

By letter dated December 19, 2013, the NRC issued to CENG the Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7).

The Interim Staff Evaluation (ISE) contains open and confirmatory items for which CENG will provide clarifying or additional information in Six Month Status Reports in order for the NRC to determine that the issues are on a path to satisfactory resolution.

Page 1 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference 3), and are current as of July 15, 2014.

" Six Month Integrated Plan Progress Report submitted (8/2013)

Six Month Integrated Plan Progress Report submitted (2/2014)

" Refueling Outage (RFO), including walk downs in support of pending modifications for installation for FLEX strategies (8/2014) 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMP2 OIP (Attachment 4 - References 1 and 3). It provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Any changes to the following target completion dates will be reflected in subsequent Six Month Status Reports.

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

Table 1 Status of NMP2 FLEX OIP Milestones Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Six Month Integrated Plan Progress August 2013 Complete Report Engineering and Design Completion -

January 2014 Started November Equipment Storage Facility 20141 Six Month Integrated Plan Progress February 2014 Complete Report Refueling Outage April 2014 Complete Six Month Integrated Plan Progress August 2014 Complete Report Page 2 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of NMP2 FLEX OIP Milestones (cont'd)

Revised Target Activity Target Milestone Completion Status Completion Date Date Engineering and Design Completion -

November Started Portable Equipment Connections 2014 Six Month Integrated Plan Progress February 2015 Not Started Report Equipment Storage Facility installation June 2015 Started May 2015 Six Month Integrated Plan Progress August 2015 Not Started Report Non-Outage Installation - Portable January 2016 Not Started Equipment Connection Six Month Integrated Plan Progress February 2016 Not Started Report Validation Walkdowns Complete February 2016 Not Started Portable Equipment Procedures March 2016 Started Changes FLEX Training March 2016 Not Started Refueling Outage April 2016 Not Started Outage Installation - Portable May 2016 Equipment Connections Not Started Final Implementation Notification to July 2016 Not Started USNRC Note 1: Revised from previous NMP2 Six Month Status Report which identified July 2014.

Building design supporting the start of construction in August has been completed. Design supporting building services and security access will be completed in November 2014. Overall completion to the Milestone for 'Equipment Storage Facility Installation' remains unaffected.

4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last Six Month Status Report. NMP2 will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures (References 9 and 10).

Page 3 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The following coping strategy changes have occurred since the previous Six Month Status Update provided on February 28, 2014 (Reference 8).

No modifications will be installed to support mitigating strategies for Phase 3. The connection of the majority of Phase 3 equipment will be made to connection points established for Phase 2 equipment and strategies. Resources will be available, and sufficient, at the times required for Phase 3 implementation. The remaining Phase 3 non-redundant equipment will be deployed utilizing field established connections, without the reliance on plug and play type modifications.

Connections for portable FLEX pumps to the Residual Heat Removal system (RHR),

as described in the original 0IP (Reference 3) in the Maintain Core Cooling section, are no longer planned to be external to the Reactor Building. The connections for the portable pumps to be deployed in Phase 2 of the mitigation strategies will now be provided to the RHR systems inside the Reactor Building and will serve to add water to the reactor vessel (consistent with previous strategy) and spent fuel pool (see below). Hoses from the portable pumps will extend into the Reactor Building and breeches of the Reactor Building doors will be required.

The NMP2 0IP (Reference 3) description of the primary connection modification for SFP makeup and preliminary drawings associated with the makeup water capability for the SFP identified that there would be a hard pipe tied into the Emergency Service water makeup line to SFP cooling system return line. This has changed in that the primary injection point for makeup to the SFP will instead be the "B" Residual Heat Removal (RHR) loop. The spent fuel pool cooling assist piping will be utilized to establish the flow path. Connection point to the RHR loop will now be inside the Reactor Building. The "A" RHR loop will be the alternate injection path with a similar configuration.

The FLEX portable pump connection points will be the same connection points utilized for core cooling.

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

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

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Table 2 provides a summary of the open items documented in the 0IP and those added in any subsequent Six Month Status Reports and the status of each item.

Page 4 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The following is a list of the open items from the 0IP that have been added, deleted or completed since the last Six Month Status Report with an explanation of the changes:

1. Maintain Core Cooling - BWR Portable Equipment Phase 2 Open Item #7: Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the dry hydrants will consider Phase 3 requirements.

This item is deleted.

See Open Item # 6 for Phase 2.

No modifications will be installed to support mitigating strategies for Phase 3. Phase 2 mitigation strategies are capable of restoring or maintaining all key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Indefinite coping is achieved via the installation of plant modifications and procedures by the responding support staff for the event. Placing additional equipment in service to support restart of plant equipment (such as Shutdown Cooling) is not necessary to support indefinite coping, is considered to be part of plant recovery, and is therefore not within the scope of the mitigating strategies.

2. Maintain Core Cooling - BWR Portable Equipment Phase 3 Open Item # 39: Perform an analysis to determine the limiting conditions for an RHR loop to be restarted (e.g., RHR room, seals and fluid temperatures) and adjust the strategy to start in Shutdown Cooling (SDC) based on the results of the analysis.

This item is deleted.

Phase 2 mitigation strategies are capable of restoring or maintaining all key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Restoration of RHR in SDC is not necessary to support indefinite coping, is considered to be part of plant recovery, and is therefore not within the scope of the mitigating strategies.

3. Safety Functions Support - BWR Portable Equipment Phase 2 Open Item # 11: Verify plans for the FLEX storage facilities in accordance with NEI 12-06 requirements; also accommodate the storage and availability of fuel for the small gas generators This item is complete. An Exelon fleet design specification has been developed, including all applicable Nine Mile Point site specific design requirements.

Robust structure design work is complete, including those drawings, specifications and calculations that allow for construction to begin and space for the storage of the small gas generators and the fuel for them with the building. All FLEX equipment, including combustible material cabinets and fuel cans for refueling portable generators will be stored in the FLEX storage structure.

Page 5 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Open Item # 49: Perform an analysis of the need for dewatering based on leak rates and flood response capabilities.

This item is deleted. The following is provided in the original 0IP; "Note that this is not a required strategy for core, containment or spent fuel pool cooling but for the long term consideration of normalization of plant systems". Based on this there is no need for dewatering actions to be planned within the scope of the mitigating strategies.

4. Maintain Core Cooling - BWR Portable Equipment Phase 3 Open Item #50: Implement a design change to install permanent 4160 VAC bus connection points to be able to connect to the RRC supplied Diesel Generator (DG), including paralleling capability, as required to connect more than one diesel generator to an electrical bus.

This item is deleted.

Phase 2 mitigation strategies are capable of restoring or maintaining all key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Connecting a RRC 4160 VAC generator to a safety related bus is only needed to support recovery actions and is therefore not within the scope mitigating strategies.

5. Maintain Core Cooling - BWR Portable Equipment Phase 3 Open Item # 51: Implement a design change to receive large capacity RRC pumps to supply the service water distribution header.

This item is deleted.

Phase 2 mitigation strategies are capable of restoring or maintaining all key safety functions for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Given the ability to maintain core makeup as established in Phase 2 indefinitely, large capacity RRC pumps are not required for indefinite coping and therefore restoring service water distribution to place shutdown cooling in service is considered part of plant recovery and is therefore not within the scope of the mitigating strategies.

Page 6 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items NMP2 OIP Open Items Status

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

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

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

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

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

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

7. Perform an analysis to validate the FLEX equipment ability to deliver Deleted (this OIP sufficient flow under all expected conditions. Flow requirements from Update 8/2014) the dry hydrants will consider Phase 3 requirements

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

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

10. Perform an evaluation of the redundant power strategy for radio repeaters and design and implement modifications or programmatic Started (2/2014) changes as required Page 7 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

11. Verify plans for the FLEX storage facilities in accordance with NEI 12-Completed (this 06 requirements also accommodate the storage and availability of fuel OIP Update -

for the small gas generators 8/2014)

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

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

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

15. Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site SAFER Staging Area "C"

16. Establish a suitable local staging area for Phase 3 portable FLEX equipment to be deployed on site SAFER Staging Area "B"

17. Provide the necessary storage facilities in order to provide fuel to the Started (8/2014) transfer pumps during an ELAP event

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

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

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM)

Started (8/2013) recommendation and Electric Power Research Institute (EPRI) guidelines for FLEX equipment

21. Evaluate and implement procedures that direct immediate deployment Started (2/2014) of Phase 2 equipment during Refueling conditions

22. Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport Started (8/2014)

FLEX portable equipment during all modes of operation Page 8 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

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

Operating Procedures (EOPs)

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

25. Evaluate requirements and options and develop strategies related to Started (212014) the storage and transport of the on-site FLEX portable equipment

26. Implement a design change to Reactor Core Isolation Cooling (RCIC) that will support operation of the system at elevated Suppression Pool Not Started temperatures as identified in GEH 000-0155-1545 (BWROG RCIC Pump and Turbine Durability Evaluation - Pinch Point Study)

27. Perform an analysis of long term RCIC Room temperatures (for equipment qualification and habitability) under ELAP conditions considering elevated Suppression Pool and Secondary Containment temperatures

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

29. Perform additional plant specific analysis to verify acceptable Suppression Pool levels during a long term operation of RCIC beginning with suction from the Condensate Storage Tanks (CSTs).

Verify containment limitations are not exceeded

30. Perform an analysis to verify acceptable parameters (e.g., Net Positive Suction Head (NPSH) requirements) for RCIC operation with the higher temperatures and anticipated changes in Suppression Pool level

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

Suppression Pool parameters to support RCIC capability

32. Perform an analysis to identify necessary actions, (e.g., modifications or programmatic changes) to maximize battery coping time to at least Started (8/2014) 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Page 9 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

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

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

35. Perform an analysis to determine the containment pressure profile during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and verify Not Started the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function

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

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

38. Perform an analysis to verify the capability of the portable diesel generator (DG) to power all expected loads

39. Perform an analysis to determine the limiting conditions for an RHR loop to be restarted (e.g., RHR Room, seals and fluid temperatures)

Deleted (this OIP and adjust the strategy to start in Shutdown Cooling (SDC) based on Update.8/2014) the results of the analysis

40. Perform a load distribution analysis for safety related equipment Deleted (see the restoration utilizing either two RRC Diesel Generators paralleled on 8/2013 OIP one 4160 VAC bus or one RRC Diesel Generator on each safety Update) related bus (i.e., one on Division 1 and one on Division 2)

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

42. Evaluate a strategy to provide a vent pathway for steam and Started (2/2014) condensate from the SFP or justify why it is not needed Page 10 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

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

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

45. Perform an analysis to evaluate long term temperature profiles in the Deleted (see the NMP2 Main Control Room (MCR) under ELAP condition (Phase 1) 8/2013 U

IP Update)

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

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

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

49. Perform an analysis of the need for dewatering based on leak rates Deleted (this OIP and flood response capabilities Update 8/2014)

50. Implement a design change to install permanent 4160 VAC bus connection points to be able to connect to the RRC supplied Diesel Deleted (this OIP Generator, including paralleling capability, as required to connect Update 8/2014) more than one Diesel Generator to an electrical bus

51. Implement a design change to receive large capacity RRC pumps to Deleted (this OIP supply the service water distribution header Update 8/2014)

52. Design and implement a modification that provides for connection of a Started (8/2014)

FLEX portable pump to makeup to the SFP

53. Implement a design change to install connections for FLEX portable Started (8/2014) pumps to RHR for both RHR 'A' and 'B'

54. Implement a design change to install portable generator connections Started (8/2014) for 600 VAC primary (2EJS*US1) and alternate (2EJS*US3) busses Page 11 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

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

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

57. Revise current EOPs to implement EOP actions necessary to support the strategy to terminate emergency depressurization to preserve Started (2/2014)

RCIC operation

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

59. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event to include Started (8/2014) both primary and alternate strategies Deleted (see the

60. Develop and implement procedures that provide direction for 8/2013 (eP restoration of SFP cooling during ELAP conditions (Phase 3)

Update)

61. Implement a design change to install permanent dry hydrants in the Not Started intake structure for FLEX portable pump suctions Page 12 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 provides a summary of the open and confirmatory items documented in the NRC's NMP2 ISE (Reference 7) and the status of each item.

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

1.

ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, Section 5.3.3, Consideration 1, which considers the possible failure of seismically qualified electrical Started (8/2014) equipment by beyond-design-basis seismic events, was not discussed in the Integrated Plan or during the audit process

2.

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

3.

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

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

ISE Confirmatory Items Status

4.

ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event (BDBEE) was not discussed in the Started (2/2014)

Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard

5.

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

Integrated Plan or during the audit process. Deployment of temporary flood barriers, restocking of supplies in the context of a flood with long persistence and the potential impact of surface icing were also not addressed Page 13 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

6.

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

7.

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

8.

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

9.

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

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

11. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in Started (2/2014) the Integrated Plan must be identified and should be available for review

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

13. ISE Confirmatory Item 3.2.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet completed.

Started (2/2014)

Mitigating strategies were not discussed in the Integrated Plan or during the audit process Page 14 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

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

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

16. ISE Confirmatory Item 3.2.4.4.A - The potential restoration of a portion of the Emergency Lighting System when Division I 600 VAC Unit Substation 2EJS*US1 (or alternatively Division II 2EJS*US3) is repowered is currently under evaluation. NMP2 will provide a summary of the restoration of Emergency Lighting expected to be restored in a future update

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of communication commitments as discussed in the staff analysis (ML13100A236)

Not Started is required

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

(SBO) evaluation for Main Control Room habitability

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

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

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

22. ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, DC load profile, Started (8/2014) discussion of loads shed, and minimum DC voltage will be provided in a future update Page 15 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

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

24. ISE Confirmatory Item 3.4.8 - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant Not Started connection points was not discussed in the Integrated Plan or during the audit process 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 Communications Assessment Interim Action Implementation Status Table 4 provides a listing of the implementing actions documented in the Assessment of Communications during an ELAP (Reference 4).

It provides the status of each action and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. As stated previously, these six month communications assessment interim action updates are not required by any related NRC Order or endorsed guidance for Beyond-Design-Basis External Events. Communications plan interim action status updates will no longer be included in the FLEX Six Month Updates following this edition. This reduction in commitment will align the Exelon Northeast sites (former CENG sites) with the rest of the fleet.

Page 16 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP2 Communications Assessment Interim Actions Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Fixed Satellite Phones

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

Protected"

2. Install additional antennas as necessary to support the use of 12/31/2014 fixed satellite phones at all 8/31/2014 Started (8/2014)

Revised to locations Emergency installation of a Operations Center (EOF) / Joint satellite dish Information Center (JIC)

3. Procure and install fixed satellite phones, additional antennas and uninterruptable power supplies for the Technical Support Center 12/31/2014 Started (8/2014)

(TSC) / Operational Support Center (OSC), Emergency Operations Facility (EOF), and the Joint Information Center JIC

4. Develop Standing Order for Interim actions.

Standing Order will contain:

" Description of the communications equipment purchased for enhancement Complete (See Interim storage location of 8/31/2013 the 2/2014 OIP the equipment until final Update) permanent storage is determined

" Conditions describing when equipment will be used

" Instructions for use of the equipment Page 17 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP2 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date

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

6. Relocate two (2) phones from 12/19/2014 each Control Room to the Date changed to TSC/OSC and EOF be consistent with 8/31/2014 Not Started plans to move/install the fixed satellite phones in all locations

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

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

9. Include information on fixed 10/31/2014 satellite phone locations and Date changed to usage in procedures be consistent with 12/31/2013 Started (2/2014) plans to move/install the fixed satellite phones in all locations Page 18 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP2 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Portable SitellitePhones

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

Update)

Facilities

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

3. Develop/update preventive Complete (see maintenance and testing 12/31/2013 the 2/2014 0IP 2/28/2014 procedures for portable satellite Update) phones, batteries and chargers

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

5. Procure and install a high power.UPS or similar modification providing backup 12/31/2014 Not Started power for the battery chargers for portable satellite phones Commun ications with,Offsite Response Organizations

1. Provide Oswego County Emergency Operations Center (EOC) and Oswego County Complete (see Warning Point (WP) 10/31/2013 the 2/2014 OIP instructions for proper storage Update) and rotation of satellite phone batteries Page 19 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP2 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Portable.Generato.rs

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

2. Develop procedures to maintain Complete (see and test the portable 12/31/2013 the 2/2014 0IP 1/31/2014 generators Update)

3. Update work instructions to Complete (see inventory portable generators 12/31/2013 the 2/2014 01P 1/31/2014 and ensure adequate volume of Update) fuel

4. Develop preventive Complete (see maintenance procedure for 12/31/2013 the 2/2014 0IP 1/31/2014 portable generators fuel supply Update)

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

1. Procure and install a high power UPS or similar Prior to S/U modification providing backup NMP1 RFO Not Started power for the radio system 2015 repeaters

2. Complete estimates of portable radio battery life and procure Complete (see additional batteries as 10/31/2013 the 2/2014 01P necessary based on an estimate of minimum talk time Update) to ensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation Page 20 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 4 Status of NMP2 Communications Assessment Interim Actions (cont'd)

Communications Assessment Target Revised Target Implementing Actions Completion Status Completion Date Date Training

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

2. Develop and implement training Prior to S/U on the use of backup NMP1 RFO Not Started generators 2015 Page 21 of 22

ATTACHMENT (2)

NMP2 SIX MONTH STATUS REPORT (AUGUST 2014)

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

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28.2013

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

3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 8, 2013

4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letter on Technical Issues for Resolution Regarding Communication Submittals Associated with Near-Term Task Force Recommendation 9.3, dated February 22, 2013

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

6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF1130), dated December 19, 2013

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014

9. NEI Position Paper Shutdown and Refueling: ADAMS Accession No. ML13273A514

10. NRC Endorsement of NEI Shutdown and Refueling Paper: ADAMS Accession No. ML13267A382 Page 22 of 22

v t e Letter Sequence Other
TAC:MF1129, (Approved, Closed)
Initiation Request, Request Acceptance... Supplement Administration Questions 5 June 2013 Answers 5 July 2013 Results Approval Other: L-14-028, August 2014 Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), L-14-031, August 2014 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), ML13225A584, ML13254A279, ML13281A205, ML13338A663, ML13338A664, ML14069A180, ML15110A026, ML15289A526, RS-15-057, February 2015 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-15-058, February 2015 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-15-117, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-15-207, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-16-029, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-16-032, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
MONTHYEAR2014-02-18 [Table View]

L-14-028, August 2014 Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

Text

Subject:

References:

Navigation menu

Search