ML14245A051

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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)
ML14245A051
Person / Time
Site: Ginna Constellation icon.png
Issue date: 08/26/2014
From: Korsnick M G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, FLL-14-029
Download: ML14245A051 (35)
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Text

gMaria Korsnlck ASenior Vice President, Northeast Operations A Exe!.on Generation@

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@exeloncorpcom NRC Order No. EA-12-049 FLL-14-029 August 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244

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 M. C. Thadani (NRC) to J. E. Pacher (CENG), R. E. Ginna Nuclear Power Plant -Constellation Energy Nuclear Group's Response to U.S. Nuclear Regulatory Commission's Request for Information, Regarding Near Term Task Force Recommendation 9.3 (TAC No. ME9958), dated April 30, 2013 (ML13109A264)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 12-049 (Reference

1) to Constellation Energy Nuclear Group, LLC (CENG) for R.E. Ginna Nuclear Power Plant, LLC (Ginna). Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Attachment (1) provides the six-month Status Report for Ginna. 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), Ginna 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 required by Section IV.C.2 of NRC Order EA-12-049.

Attachment (1) includes an update of the U. S. Nuclear Regulatory Commission August 26, 2014 Page 2 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 commitment to implement the Ginna improvements related to mitigating strategies (FLEX) derived from the results of the communications assessment will be completed prior to the startup of Ginna following the Fall 2015 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. Executed on the 2 6 th day of August, 2014.Respectfully, Mary G.Ksick MGK/STD Attachment (1) Six-Month Status Report (August 2014) for Mitigation Strategies for Beyond-Design-Basis External Events cc: Regional Administrator, Region I, USNRC NRC Project Manager, NRR -R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector

-R. E. Ginna Nuclear Power Plant Director, Office of Nuclear Reactor Regulation J. A. Kratchman, NRC ATTACHMENT (1)SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS R. E. GINNA NUCLEAR POWER PLANT, LLC August 26, 2014 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The R.E. Ginna Nuclear Power Plant, LLC (Ginna) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2). Subsequently, a supplement to the Ginna OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and associated basis (if applicable).

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

The updated status of the communications assessment interim actions is provided in Section 8.Since submittal of the last status report in February 2014 (Reference 5), Ginna FLEX strategy implementation has progressed with engineering analyses, calculations, and construction that support the mitigation strategies.

As stated in Reference (5), Ginna no longer intends to utilize low leakage Reactor Coolant Pump (RCP) seals for its beyond-design-basis external event mitigation strategies.

This update provides the revised strategy to address the need for Reactor Coolant System (RCS) borated makeup for the conditions with no RCS leakage, and with the highest applicable RCS leakage rate for the RCP seals and unidentified RCS leakage.2 Milestone Accomplishments The following milestone(s) have been completed since submittal of the last status report in February 2014 (Reference

5) and are current as of July 31, 2014.* None 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the Ginna OIP (Attachment 1 -References 1 and 3). It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Page 1 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of Ginna FLEX OIP Milestones Target Revised Target Milestone Completion Activity Completion Date Date Commence Engineering and Design July 2013 Started May 2015*Commence Procurement of Equipment July 2013 Started September 2015 Commence Installation of Equipment July 2013 Started November 2015 Submit 6-Month Status Report August 2013 Complete Develop Strategies/Contract with the November 2013 Started March 2015 Regional Response Center (RRC)Submit 6-Month Status Report February 2014 Complete Complete Engineering and Design March 2014 Started May 2015*Create Maintenance and Testing June 2014 Started October 2015*Procedures Submit 6-Month Status Report August 2014 Complete Procedure Changes Training Material September 2014 Started March 2015 Complete Develop Training Plan November 2014 Started Submit 6-Month Status Report February 2015 Not Started Issue FLEX Support Guidelines April 2015 Not Started November 2015 Perform Walk-throughs or May 2015 Not Started Demonstrations Provide onsite and augmented staffing assessment considering functions May 2015 Not Started related to Near-Term Task Force (NTTF) Recommendation 4.2.Implement Training June 2015 Started Submit 6-Month Status Report August 2015 Not Started Complete Procurement of Equipment September 2015 Not Started Full compliance with EA-12-049 is Fall 2015 Not Started achieved Submit Completion Report December 2015 Not Started* Change since submittal of last six month status report.Page 2 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 4 Changes to Compliance Method The following is a list of the coping strategies that have been changed since the last six month status report with an explanation of the changes. Additional details on how Ginna's OIP complies with the guidance in NEI 12-06 are also provided: a) In accordance with Nuclear Energy Institute (NEI) 12-06, Section 7.3.1, protection of FLEX equipment from high wind hazards can be accomplished by storing equipment in a structure that meets the plant's design basis for high wind hazards (e.g., existing safety-related structure);

or in storage locations designed to or evaluated equivalent to American Society of Civil Engineers (ASCE) 7-10, Minimum Design Loads for Buildings and Other Structures, given the limiting tornado wind speeds from Regulatory Guide 1.76 (Reference 7); or in evaluated storage locations separated by a sufficient distance that minimizes the probability that a single event would damage all FLEX mitigation equipment such that at least N sets of FLEX equipment would remain deployable following the high wind event. Consistent with this guidance, Ginna will take the following approach to protect installed plant equipment and FLEX equipment from high wind hazards, specifically tornados and tornado missiles: " For conservatism, Ginna designed the structural walls and roof of the new "robust structure" housing the "N" set of FLEX mitigation equipment, as well as communications equipment, to the Regulatory Guide 1.76 tornado wind speed and suite of tornado missiles.

However, the building's entranceway and openings (e.g., as needed for ventilation) are designed to withstand the plant's design basis tornado (i.e., 132 miles per hour wind speed) and tornado missile spectrum.

This is consistent with NEI 12-06, Section 7.3.1.1.a." Furthermore, the "+1" equipment (high and low pressure FLEX pumps, hoses and fittings; and 100 kilowatt (kW) diesel generator (DG), cables and connectors) and support equipment (fuel trailer, debris remover, and tow truck) will generally be housed in a New York State (NYS) Building Code commercial structure, in an"evaluated storage location" per NEI 12-06, Section 7.3.1.1.c.

Distance separation is not applicable in this situation, since the means used to minimize the probability that a single event would damage all FLEX mitigation equipment is the use of a robust structure to house the N sets. Any stored mitigation equipment exposed to the wind will be adequately tied down to prevent it from being damaged or becoming airborne, in accordance with NEI 12-06, Section 7.3.1.1.b.

  • Other plant structures and equipment (e.g., fuel or water tanks) which are needed to withstand tornados and tornado missiles will be designed/evaluated to Ginna's current licensing basis tornado: a 132 miles per hour (mph) wind speed (Updated Final Safety Analysis Report (UFSAR) Sections 2.3.2.2 & 3.3.4.1, Reference 8), and missiles consisting of an eight pound steel rod, 1-inch diameter and 3-feet long, traveling at 60% of the tornado wind speed and a 1490 pound wooden utility pole, 13.5-inch diameter and 35-feet long, traveling at 40% of the tornado wind speed (UFSAR Section 3.3.3.1).

As demonstrated in a Structural Upgrade Program submittal to the NRC (Reference

9) and approved in the Safety Evaluation Report on the Structural Upgrade Program (Reference 10), wind speeds lower than approximately 150 mph cannot provide the necessary aerodynamic lift required for a utility pole to become an airborne missile (UFSAR Section 3.3.5.4.1);

therefore impact considerations for the utility pole are at grade level only.Page 3 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The above tornado protection design criteria are consistent with Ginna's current design basis, and therefore meets the requirements of NEI 12-06, Section 7.3.1.1.b) As a result of the 10 CFR Part 21 report regarding the Westinghouse low leakage RCP seals (Reference 11), Ginna no longer intends to utilize low leakage RCP seals for its beyond-design-basis external event mitigation strategies.

The WCAP-17601 (Reference

12) Section 5.7.1 discussion of Westinghouse Generic Case Results with safe shutdown/low leakage seals is no longer applicable.

The revised strategy addresses the need for additional borated makeup for RCS inventory control for the assumed RCP Model 93 seal leakage.To account for the additional boration requirements for the highest applicable leakage rate for the RCP seals and unidentified RCS leakage, the borated water source will be the Refueling Water Storage Tank (RWST). Ginna will no longer convert the Standby Auxiliary Feedwater Test Tank to a FLEX Boric Acid Storage Tank.A newly installed (and isolated) charging pump powered from the 1 MW SAFW DG, taking suction from the RWST and discharging to the RCS, will be used to provide borated makeup to the RCS. This arrangement will include a discharge line routed through a protected portion of the Auxiliary Building to a newly installed Safety Injection (SI) line connection.

The pump will be manually aligned as required.

Due to expected Reactor Coolant Pump (RCP) seal leakage, the timeline to initiate charging is approximately one hour. The alternate FLEX strategy is to use a diesel driven portable FLEX charging pump taking suction from the RWST, connected via high pressure hose, to a staged connection in the SI system.To provide sufficient capacity of borated water makeup to the RCS, the new charging pump will be capable of pumping 75 gallons per minute (gpm) from the RWST into the RCS at 1575 pounds per square inch (psi). A portable diesel engine driven high pressure pump will be procured to provide alternate borated makeup to the RCS. This pump will also be capable of pumping 75 gpm of borated water from the RWST to the RCS at 1575 psi.c) Section 4.3.2 of WCAP-1 7601 states "There shall be no return to criticality once the loss of all AC power has occurred.

To ensure that the plants remain subcritical, a limit of Kff less than 0.99 (subcritical) is set. The exact needed level of subcriticality is somewhat subjective, but 0.99 was chosen because it provides some margin to account for the best estimate or generic reactor physics parameters assumed in this analysis."* A uniform boron mixing model will be assumed in the ELAP analysis.

This will be in compliance with the recommendations discussed in the Pressurized Water Reactor Owner's Group (PWROG) white paper related to the boron mixing model, and the NRC clarifications, as discussed under bullet #3 below. Ginna will take credit for boron mixing during two phase flow. As documented in the Extended Power Uprate RAI response "Supplemental Response to Requests for Additional Information Regarding Topics Described by Letters Dated August 24, 2005 and October 28, 2005," (Reference

13) RCS mass flow rate increases during two-phase flow (Reference 13, Figure 8). Additional details on the two-phase RCS mass flow increase are documented in proprietary Westinghouse Calculation CN-LIS-05-163,"SBLOCA Cooldown Calculation Results for R.E. Ginna (RGE) Extended Power Uprate and 422V+ Fuel Upgrade Program" (Reference 14). With a rather large Page 4 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS change in mixture density throughout the core/hot leg/SG uphill tube side relative to the downhill side (from SG heat removal), the flow velocity increases.

This continues with increasing void fraction until makeup to the RCS and the decline of decay heat allows the RCS return to a subcooled state. RCS boration to support cooldown will credit the buildup of xenon, and the necessary boration will be completed with at least a one hour margin to the minimum shutdown margin (Kff less than 0.99) to preclude criticality and accounting for the added time necessary for the added borated water to mix with the water in the RCS.A plant specific boron analysis was performed as part of CALC-2014-0002, "Cycle 38 Reactor Engineering Calculations" (Reference

15) to determine boration requirements to ensure that the core remains subcritical throughout the ELAP event for the limiting condition with respect to shutdown margin. Fifteen percent or greater uncertainties were applied to bound the boron concentration calculations for future core designs. Mitigation strategies will ensure that the core remains sub-critical (Ke, less than 0.99) throughout the ELAP event for the limiting condition with respect to shutdown margin, considering both no RCP seal leakage and the maximum RCP seal leakage postulated value. If no RCP leakage occurs during the ELAP event, procedures will direct the operators to establish conditions sufficient for RCS boration by opening a reactor head vent valve or a Power Operated Relief Valve.* Ginna intends to follow the generic approach identified in the PWROG position paper on boron mixing that was submitted to the NRC on August 15, 2013 (Reference 16), subject to the clarifications in the NRC letter to the PWROG, dated January 8, 2014 (Reference 17). Specifically:
i. Strategy timeline will complete boration with at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> margin to preclude criticality (K 9 , less than 0.99) in the most limiting conditions.

ii. Injection will be to the RCS cold legs.iii. Boration will be concluded well within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after shutdown.iv. Boration targets for subcriticality (Ke, less than 0.99) will be based on the most limiting scenario considering no RCS leakage.v. All steam generators will be fed until the required minimum boron injection to support subcriticality (Kerr less than 0.99) has been achieved.vi. The required timing for providing borated makeup to the primary system will consider conditions with no RCS leakage and with the highest applicable leakage rate for the RCP seals and unidentified RCS leakage.vii. For the condition associated with the highest applicable RCS leakage rate, adequate borated makeup will be provided such that the loop flow rate in two-phase natural circulation does not decrease below the loop flow rate corresponding to single-phase natural circulation.

d) NEI 12-06 Section 3 states "The primary FLEX objective is to develop a plant-specific capability for coping with a simultaneous ELAP and LUHS event for an indefinite period through a combination of installed plant capability, portable on-site equipment, and off-site resources.

Each plant will establish the ability to cope for these baseline conditions based on the appropriate engineering analyses and procedural framework." The Ginna procedure for responding to a station blackout is ECA-0.0, "Loss of All AC Power." (Reference

18) ECA-0.0 steps are ordered to provide the best sequence of operator actions to respond to station blackout events. ECA-0.0 directs the operators to verify the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) starts and if it has not, to attempt to start the TDAFWP. As the preferred and procedurally directed source of Page 5 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS water to the steam generators (SGs), if the equipment is available, it will be used. This proceduralized sequence of events is consistent with Ginna's current licensing basis and, since a beyond-design-basis external event may not be readily apparent to the operators, using/crediting available plant equipment for responding to events is preferred and provides operating margin for a beyond-design-basis external event.If the TDAFWP or Condensate Storage Tanks (CSTs) are not available, the procedural direction to use the new 1 megawatt (MW) Standby Auxiliary Feedwater (SAFW) DG to power a Standby Auxiliary Feedwater Pump (SAFWP) and feed the SGs will be a"response not obtained" step in ECA-0.0.In the March 8, 2013 Ginna Overall Integrated Plan (OIP) submittal (Reference 3), Ginna identified one potential deviation/alternate approach to the guidelines in JLD-ISG-2012-01 (Reference
19) and NEI 12-06 (Reference 6). NEI 12-06 initial condition 3.2.1.3(2) states "All installed sources of emergency on-site ac power and SBO Alternate ac power sources are assumed to be not available and not imminently recoverable" and, in Section 2.1, that initial approaches to FLEX strategies will take no credit for ac power supplies.

Ginna is planning to take credit for a to-be-installed 1 MW SAFW DG, which will not be connected to, and will not be connectable to, the offsite or onsite emergency ac power systems (and thus is not defined as an alternate AC source). This DG will be able to be connected to a SAFWP to provide Phase 1 makeup to a SG for Reactor Coolant System (RCS) cooling and heat removal. These modifications are due to the assumed failure of the TDAFWP and water supply in a beyond-design-basis external event (BDBEE). Additional details are provided in Reference (3) under safety strategy Maintain Core Cooling and Heat Removal (Steam Generators Available).

To elaborate on the proposed use of the "to-be installed" 1 MW SAFW DG, the resulting strategy is considered to be a method of extending Phase 1. The FLEX portion of the strategy includes a combination of the use of existing equipment, the use of newly installed and isolated equipment, and installation of new battery charger capabilities as follows: " Use of two existing SAFWPs with a newly installed (and electrically isolated) 1 MW SAFW DG and a newly installed 160,000 gallon (usable capacity), robustly designed CST, capable of supplying greater than 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of inventory.

The initial installed equipment mitigation strategy is to supply, by manual operator action within 37 minutes, condensate from the tank to the SAFWP(s) to both SGs. The FLEX portion of the strategy would be to use dedicated FLEX pumps to refill the condensate tank from Lake Ontario, and continue to supply the SGs via the SAFWPs. Also, a fuel trailer would be used to resupply the 1 MW SAFW DG. While the new DG fuel tank and CST (with the planned cooldown) capabilities may be less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, timelines being developed show that adequate response time will be available to refill the tanks during an ELAP event.* A newly installed (and isolated) charging pump powered from the 1 MW SAFW DG, taking suction from the RWST and discharging to the RCS, will be used to provide borated RCS makeup to the RCS. This arrangement will include a discharge line routed through a protected portion of the Auxiliary Building to a newly installed Safety Injection (SI) line connection.

The pump will be manually aligned as required.

Due to expected Reactor Coolant Pump (RCP) seal leakage, the timeline to initiate charging is approximately one hour. The alternate FLEX strategy is to use a diesel Page 6 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS driven portable FLEX charging pump taking suction from the RWST, connected via high pressure hose, to a staged connection in the SI system.Ginna will have primary and alternate strategies to provide connections from a portable 100 kW FLEX diesel generator, or the 1 MW SAFW DG, to the AC input of the battery chargers.

Connections using pre-identified cables will be performed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> so that the vital batteries will remain available for continued operation.

The primary Phase 2 coping strategy is to resupply the new CST from Lake Ontario, the Ultimate Heat Sink (UHS), using a portable diesel driven pump and hoses. Core cooling and heat removal will be sustained indefinitely, or until long term recovery actions are determined, using a SAFWP powered by the new 1 MW SAFW DG, with provisions for refilling the new CST and the 1 MW SAFW DG fuel tank.The alternate Phase 2 strategy is to utilize a diesel driven high capacity portable pump to supply the SGs with water from the new CST should the SAFWP become unavailable.

The new CST will be resupplied from Lake Ontario, the UHS, using an additional portable diesel driven pump and hoses. This strategy has the capacity to maintain the required level in the SGs with the SGs at the target pressure of 260 psig, which corresponds to about 410 degrees Fahrenheit (OF) in the cold legs of the RCS. Core cooling and heat removal will be sustained indefinitely, or until long term recovery actions are determined, using the portable diesel driven pump, with provision for refilling the new CST and portable diesel driven pump fuel tank.In the R. E. Ginna Nuclear Power Plant- Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NO.MF1 152), dated February 19, 2014, (Reference

20) the NRC staff considered the design features of the SAFW DG, especially its independence from other plant systems and structures, and found that crediting the SAFW DG is an acceptable alternative to the NEI 12-06 guidance.

The NRC staff also noted that Ginna has an alternate Phase 2 strategy for feeding the SGs for decay heat removal. This strategy utilizes a diesel driven portable FLEX pump, aligned to take suction from the new CST, with the capacity to maintain the required level in the SGs with the SGs at the target pressure of 260 psig, which corresponds to about 410 degrees Fahrenheit (OF) in the cold legs of the RCS.This alternate strategy does not use the SAFW DG or the SAFWPs.The NRC staff also considered if Ginna would need a relaxation from Order EA-12-049 to credit the use of the SAFW DG. The order states, in part, that: These strategies must be capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink and have adequate capacity to address challenges to core cooling, containment, and SFP cooling capabilities at all units on a site subject to this Order.The NRC staff found that Ginna's proposed strategies could demonstrate compliance with the order (assuming satisfactory resolution of the confirmatory items), and therefore that no relaxation to the order is required in order to credit the use of the SAFW DG.e) As stated in the March 8, 2013 OIP submittal, following a loss of Spent Fuel Pool (SFP)cooling the SFP will heat up to a bulk temperature of 2121F, at which time heat removal from the SFP will be due to boiling of the water with the steam removing the heat from the SFP. In these circumstances, a minimum water level of 5'-9" above the top of the fuel has been determined to provide adequate short term shielding.

To maintain SFP Page 7 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS heat removal and to maintain the minimum water level of 5'-9" above the top of the fuel, the primary strategy for Phase 2 SFP cooling and makeup described in the March 8, 2013 OIP is revised as follows: " The March 8, 2013 OIP Alternate Strategy 1 is now the Primary Strategy.

That is, a portable diesel driven pump taking suction on an available water source, including Lake Ontario, will be aligned via hoses tied down at the edge of the SFP to fill the SFP to maintain greater than the minimum water level of 5'-9" above the top of the fuel.* The March 8, 2013 OIP Alternate Strategy 2 becomes Alternate Strategy 1, which implements a strategy similar to the primary strategy above except that water is sprayed into the SFP using the discharge hoses connected to Blitz Fire nozzles.* The March 8, 2013 OIP Primary Strategy will now be Alternate Strategy 2.More details on these strategies can be found in the March 8, 2013 OIP submittal (Reference 3).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ginna expects to comply with the order implementation date and no relief/relaxation is required at this time.6 Open Items from Overall Integrated Plan and Interim Safety Evaluation The following is a list of the open items from the OIP that have been added, deleted, completed, or revised since the last six month status report, with an explanation of the changes: a) General Integrated Plan Elements PWR Open Item 9: Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site.This item is complete.

Suitable local staging areas have been established for portable FLEX equipment to be delivered from the Regional Response Center (RRC) to the site.Staging Area 'A' is located onsite and consists of multiple areas for portable equipment staging (see attached photo labeled Staging Area 'A'). Staging Area 'B' is located in the currently named contractor parking lot, as well as the area to the west (see attached photo labeled Staging Area 'B'). Staging Area 'C' is located on Rochester International Airport property (see attached photo labeled Staging Area 'C').b) Safety Functions Support Open Item 29: Implement a design change to provide connections to 480 Volt vital busses to be able to connect to RRC supplied D/Gs.This item is revised to state "Implement a strategy to provide connections to 480 Volt vital busses to be able to connect to RRC supplied D/Gs. A design change will not be necessary to connect RRC supplied D/Gs to 480 Volt vital busses.Page 8 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS c) Maintain Core Cooling & Heat Removal and Maintain RCS Inventory

/ Long Term Subcriticality Open Item 30: Ensure RRC can supply a water processing unit.This item is complete.

Ginna is a participant in the RRC reverse osmosis water (RO)purification unit. This RO purification unit will have a mechanical filtration system with an output flow capacity of 500 gallons per minute (gpm). The brackish water RO system will have an output flow capacity of 250 (gpm).d) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 33: Implement a design change to convert the existing SAFW Test Tank to the FBAST with a permanent connection to the new pre-staged high pressure pump and connection(s) for a portable diesel driven pump.This item is revised to state "Implement a design change to connect a new pre-staged high pressure charging pump and FLEX diesel driven portable charging pump to the RWST." Subsequent to the March 8, 2013 OIP submittal (Reference

3) the decision was made not to replace the current Reactor Coolant Pump (RCP) seals with the low leakage seals. The FLEX Boric Acid Storage Tank (FBAST) would not have sufficient capacity to maintain RCS inventory without installing the RCP low leakage seals. To be able to maintain Reactor Coolant System (RCS) inventory and long term subcriticality after an ELAP, a design change will provide the capability to supply borated water from the RWST to the new pre-staged high pressure charging pump and a connectable portable diesel driven pump.e) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 34: Implement a strategy to batch mix boron in the FBAST.This item is deleted. The SAFW Test Tank will not be re-purposed as a FLEX Boric Acid Storage Tank (FBAST). This strategy is not necessary.

f) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 35: Implement a design change to install a pump capable of pumping 22 gallons per minute (gpm) of borated water into the RCS at 2235pounds per square inch gage (psig), or 70 gpm at 1500 psig, from the new FBAST with discharge piping connected to the Charging header.This item is revised to state "Implement a design change to install a pump capable of pumping 75 gallons per minute (gpm) of borated water from the RWST into the RCS at 1575 pounds per square inch (psi), with discharge piping connected to the Safety Injection System." As discussed previously under revised Open Item 33, the decision was made not to replace the RCP seals with a low leakage design. To provide sufficient capacity of borated water makeup to the RCS, a new high pressure pump will be installed, taking suction from the RWST and discharging to the Safety Injection System.Page 9 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS g) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 37: Implement a design change to connect a portable diesel engine driven high pressure pump to the FBAST and the Charging line, which is capable of pumping 20 gpm of borated water from the FBAST to the RCS at 2235 psig.This item is revised to state "Implement a design change to connect a portable diesel engine driven high pressure pump to the RWST and the Safety Injection System, which is capable of pumping 75 gpm of borated water from the RWST to the RCS at 1575 psi." As discussed previously under revised Open Item 33, the decision was made not to replace the RCP seals with a low leakage design. To provide sufficient capacity of alternate borated water makeup, the new portable diesel engine driven high pressure pump will be procured and be connectable to the RWST and Safety Injection System to provide alternate borated makeup to the RCS.h) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 38: Ensure the RRC will supply boric acid for use with the inline blender.This item is revised to state "Ensure the RRC can supply a mobile boration unit." As discussed previously, the decision was made not to convert the SAFW Test Tank to the FBAST. An inline blender will not be necessary to refill the FBAST. To provide the capability for long term borated water makeup, a mobile boration unit can be supplied from the RRC.i) Maintain Core Cooling & Heat Removal (S/Gs Not Available)

Open Item 43: Develop and implement procedures to makeup to the refueling cavity from the new CST, UHS, or FBAST to maintain refueling cavity level and boron concentration.

This item is revised to state "Develop and implement procedures to makeup to the refueling cavity from the new CST, UHS, or RWST to maintain refueling cavity level and boron concentration." The SAFW Test Tank will not be re-purposed as a FLEX Boric Acid Storage Tank (FBAST). The RWST will replace the FBAST as a source of makeup to the refueling cavity to maintain refueling cavity level and boron concentration.

j) Maintain Core Cooling & Heat Removal (S/Gs Not Available)

Open Item 46: Implement a design change to establish provisions for refilling the FBAST with borated water.This item is deleted. The SAFW Test Tank will not be re-purposed as a FLEX Boric Acid Storage Tank (FBAST). This design change is not necessary.

Page 10 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS k) Maintain Core Cooling & Heat Removal and Maintain RCS Inventory

/ Long Term Subcriticality Open Item 53: Ensure the RRC will provide additional portable pumps and equipment to spray water into containment or supply water to the Containment Recirculation Fans/ Coolers.This item is complete.

The RRC has a Low Pressure/Medium Flow Pump and a Low Pressure/High Flow Pump with an available selection of hoses and mechanical connections that can provide for containment spray or supply water to the Containment Recirculation Fans/ Coolers.I) Maintain Spent Fuel Pool Cooling Open Item 56: Revise ER-SFP.2 to provide multiple strategies for establishing a diverse means of SFP makeup for at least 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> without offsite supplies.This item is revised to state "Implement new FSG-11, Alternate SFP Makeup and Cooling, to provide multiple strategies for establishing a diverse means of SFP makeup and cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />." Rather than revising an existing procedure, a FLEX support guideline (FSG) will be used to maintain the Spent Fuel Pool Cooling function for a BDBEE.m) Maintain Spent Fuel Pool Cooling Open Item 59: Ensure the RRC will provide additional portable pumps and equipment to: " provide water from the UHS to the Standby SFP Heat Exchanger to remove heat from the SFP cooling system with the Standby SFP Recirculation Pump; or" provide water to SFP Heat Exchanger A to remove heat from the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A, or" provide a heat exchanger and equipment to provide cooling for the SFP.This item is revised to state "Ensure the RRC will provide additional portable pumps and equipment to:* provide water from the UHS to the Standby SFP Heat Exchanger to remove heat from the SFP cooling system with the Standby SFP Recirculation Pump; or* provide water to SFP Heat Exchanger A to remove heat from the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A." A heat exchanger is not needed from the RRC as the site has multiple heat exchanger options for SFP cooling, including a spare SFP cooling heat exchanger.

This item is complete.

The RRC has a Low Pressure/Medium Flow Pump and a Low Pressure/High Flow Pump with an available selection of hoses and mechanical connections that can provide water from the UHS to the Standby SFP Heat Exchanger or to SFP Heat Exchanger A.Page 11 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS n) Safety Functions Support Open Item 60: Implement a design change to install connection points needed to supply the battery chargers from the 1 MW D/G.This item is revised to state "Implement a strategy to supply the battery chargers from the 1 MW D/G using existing plant equipment connection points." A design change is not necessary to connect the 1 MW D/G to the battery chargers.o) Safety Functions Support Open Item 61: Implement a design change to install connection points needed to supply the battery chargers from the 100 kW D/G.This item is revised to state "Implement a strategy to supply the battery chargers from the 100 kW D/G using existing plant equipment connection points." A design change is not necessary to connect the 100 kW D/G to the battery chargers.Page 12 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 provides a summary of the open items documented in the OIP and those added in a subsequent six month status report, and the status of each item.Table 2 Status of FLEX OIP Open Items Ginna OIP Open Items Status 1. Implement a design change to install permanent protected FLEX Started (8/2013)equipment connection points. (also see 01 23)2. Provide for onsite storage of Phase 2 FLEX components that is Started (2/2014)protected against external events by design or location.Implement a design change to provide a protected storage location for transportation (equipment and fuel) and debris removal equipment.

Evaluate deployment strategies and deployment routes for hazards impact.Evaluate requirements and options and develop strategies related to the storage onsite of the FLEX portable equipment.

Establish deployment routes from FLEX equipment storage locations to connection points.Develop a strategy and purchase equipment to respond to events that may require debris removal such as following a flood, tornado, or snow storm.Develop a strategy to move FLEX equipment, including providing reasonable protection from a BDBEE.3. Exceptions for the site security plan or other (license/site specific -Complete (See the 10 CFR 50.54x) requirements of a nature requiring NRC approval 2/2014 OIP Update)will be communicated in a future 6-month update following identification.

4. Develop and implement procedures to commence feeding the Not Started steam generators (S/Gs) from Standby Auxiliary Feedwater (SAFW) powered by the new SAFW Diesel Generator (D/G) and taking suction from the new Condensate Storage Tank (CST) prior to reaching 5 ft in the existing CSTs.5. Develop and implement a FLEX method / procedure to refill the Not Started new SAFW CST prior to losing suction.Page 13 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 6. Develop and implement a program and/or procedure to keep FLEX Not Started equipment deployment pathways clear or with identified actions to clear the pathways.7. Determine schedule for when RRCs will be fully operational.

Complete (See the 8/2013 OIP Update)8. Define criteria for the local RRC staging area by June 2013. Complete (See the 2/2014 OIP Update)9. Establish a suitable local staging area for portable FLEX Complete (This OIP equipment to be delivered from the RRC to the site. Update 8/2014)10. Develop site specific playbook for delivery of portable FLEX Started (8/2013)equipment from the RRC to the site.11. Perform an analysis to determine the diesel driven portable high Started (8/2014)pressure pump upper and lower head requirements to provide for a minimum of 215 gpm to a S/G without causing Reactor Coolant System (RCS) pressure to decrease to the point where nitrogen will be injected from the SI Accumulators, assuming suction is directly from the Ultimate Heat Sink (UHS).12. Develop and implement procedures to close Safety Injection (SI) Not Started Accumulator injection valves or vent the SI Accumulators prior to nitrogen injection into the RCS.13. Perform an analysis to determine the time to restore feed to a S/G Deleted (See the if only one S/G was able to be supplied with feedwater after a trip 2/2014 OIP Update)and then feed is lost to that one S/G. This is to account for the reduction in water available for heat removal.14. Implement the design change to install the 1 MW SAFW D/G, Started (8/2013)160,000 gallon Condensate Storage Tank (CST), and enclosure meeting the reasonable protection requirements of NEI 12-06.15. Develop and implement procedures to feed S/Gs using a SAFW Not Started Pump powered by the new SAFW D/G and taking suction on the new 160,000 CST. Revise procedures to direct Operators to manually establish makeup to the S/Gs via this flow path if the Turbine Driven Auxiliary Feedwater (TDAFW) Pump fails to deliver water to the S/Gs.16. Implement a design change to protect a S/G Atmospheric Relief Not Started Valve (ARV) from Tornado Missiles to address reactor core cooling and heat removal using a high capacity portable diesel driven pump.Page 14 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 17. Perform an analysis to demonstrate adequate manpower, Started (8/2013)communications capability, and habitability for local operation of the S/G ARVs. If this cannot be demonstrated, implement a design change to provide for ARV control from the Control Room for seismic and tornado missile events.18. Develop and implement procedures/administrative controls to Not Started ensure that the new CST maintains a minimum usable volume at all times.19. Perform an analysis or implement a design change to qualify S/G Started (2/2014)Pressure instrumentation for a Tornado Missile event.20. Identify instrumentation and develop procedures to take field Started (8/2013)readings of necessary parameters, including (Pressure Indicator)

PI-430 and (Level Indicator)

LI-427.21. Implement a strategy to connect a portable air compressor at a Not Started location/

configuration to support ARV operation.

22. Develop and implement procedures to refill the new CST from an Revised (See the alternate water source prior depleting the usable volume 2/2014 OIP Update)(approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the event). Not Started 23. Implement a design change as part of the installation of the new Started (8/2013)CST to install a mechanical connection that will allow the tank to be refilled from a portable diesel driven pump.24. Perform an analysis to establish plant conditions in Phase 1 that Started (2/2014)will allow diesel driven high capacity portable pump to be utilized as soon as plant resources are available to provide defense in depth for maintaining an adequate heat sink should SAFW fail.25. Implement a design change to install a new isolation valve Not Started upstream of the FLEX connection to S/G B in case a tornado missile impacts a section of unprotected piping between the SAFW Building and the connection point.26. Implement a strategy to provide a sustainable source of nitrogen Revised (See the and/or air to the Power Operated Relief Valves (PORVs) to protect 2/2014 OIP Update)RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops Started (2/2014)filled.27. Develop and implement procedures to provide guidance for water Not Started solid S/G cooldown using FLEX equipment.
28. Ensure RRC can supply D/Gs capable of powering vital bus loads. Complete (See the 2/2014 OIP Update)Page 15 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 29. Implement a strategy to provide connections to 480 Volt vital Revised (This OIP busses to be able to connect to RRC supplied D/Gs. Update 8/2014)Not Started 30. Ensure RRC can supply a water processing unit. Complete (This OIP Update 8/2014)31. Implement a design change to install low leakage Reactor Coolant Deleted (See the Pump (RCP) seals. The new seals need to be able to withstand 2/2014 OIP Update)Thot for an extended period of time.32. Perform an analysis to validate that a FLEX Boric Acid Storage Deleted (See the Tank (FBAST) with a boron concentration of at least 2750 parts per 2/2014 OIP Update)million (ppm) and no more than 3050 ppm, and containing a minimum usable volume of 7000 gallons, is sufficient to maintain the reactor subcritical at Beginning of Life (BOL) or End of Life (EOL) conditions with Tave at or near no-load Tawe, and at EOL conditions with a cooldown to 350 0 F. (Analysis must be bounding for current and future cycles.)33. Implement a design change to connect a new pre-staged high Revised (This OIP pressure charging pump and FLEX diesel driven portable charging Update 8/2014)pump to the RWST. Started (8/2014)34. Implement a strategy to batch mix boron in the FBAST. Deleted (This OIP Update 8/2014)35. Implement a design change to install a pump capable of pumping Revised (This OIP 75 gallons per minute (gpm) of borated water from the RWST into Update 8/2014)the RCS at 1575 pounds per square inch (psi), with discharge Started (8/2013)piping connected to the Safety Injection System.36. Develop and implement procedures to initiate RCS boration prior to Not Started commencing RCS cooldown to provide margin to prevent re-criticality.
37. Implement a design change to connect a portable diesel engine Revised (This OIP driven high pressure pump to the RWST and the Safety Injection Update 8/2014)System, which is capable of pumping 75 gpm of borated water Started (8/2014)from the RWST to the RCS at 1575 psi.38. Ensure the RRC can supply a mobile boration unit. Revised (This OIP Update 8/2014)Started (2/2014)39. Perform an analysis to determine minimum RCS makeup flow Started (2/2014)sufficient for simultaneous core heat removal and boron flushing for Mode 5, loops not filled and pressurizer manway not removed.40. Perform an analysis to determine the transition point from gravity Not Started fill of the refueling cavity to when forced makeup is required.Page 16 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 41. For Mode 5, Loops Not Filled, and Pressurizer Manway Not Started (2/2014)Removed, RCS Heat Removal will be by RCS Bleed and Feed.Items under consideration are: " Establish RCS feed path using low pressure pump capable of[To Be Determined]

gpm at > 50 psig and a maximum discharge pressure of 410 psig to the RCS.* Establish sufficient RCS bleed path (PORVs, Reactor Head Vents)* Implement a strategy to provide a connection point for Instrument Air to Containment (01 47)" Establish feed to available S/Gs Partial strategy for consideration

-Fill available S/Gs to provide limited heat sink function and additional time before boiling of the coolant occurs. Existing procedural guidance for Water Solid S/G Cooldown provides guidance that can be modified for use with a high flow portable diesel driven pump to maintain the limited heat sink function.* If Water Solid S/G Cooldown is effective to maintain core cooling and heat removal, secure RCS Bleed and Feed and maintain Pressurizer Level.42. Perform an analysis to determine RCS vent path requirements for Started (2/2014)Mode 5 with PORV vent path.43. Develop and implement procedures to makeup to the refueling Revised (This OIP cavity from the new CST, UHS, or RWST to maintain refueling Update 8/2014)cavity level and boron concentration.

Not Started 44. Perform a boron mixing analysis for the effects on RCS boron Deleted (See the concentration by providing unborated water to the refueling cavity 2/2014 OIP Update)via the transfer canal from the Auxiliary Building to Containment.

45. Evaluate the viability of feed and bleed for available S/Gs to Started (2/2014)provide a limited heat sink function and additional time before boiling of the coolant occurs as a parallel mitigating strategy during Modes 5 & 6. This analysis must address reflux condensation and its potential effects on reactor shutdown margin.46. Implement a design change to establish provisions for refilling the Deleted (This OIP FBAST with borated water. Update 8/2014)47. Implement a strategy to provide a connection point for Instrument Revised (See the Air to Containment.

2/2014 OIP Update)Started (2/2014)48. Perform an evaluation to determine a method for recirculation Started (2/2014)cooling of the RCS if the Auxiliary Building Sub-basement is flooded by Tornado Missiles damaging non-protected tanks on the Auxiliary Building Operating Floor.Page 17 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 49. Perform an analysis to determine the containment pressure profile Revised (See the during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and 2/2014 OIP Update)determine the mitigating strategies necessary to ensure the Started (2/2014)instrumentation and controls in containment which are relied upon by the Operators are sufficient to perform their intended function.50. Perform an analysis of the containment function to determine the Started (8/2014)mitigating strategy acceptance criteria for an ELAP / LUHS event.51. Implement a strategy to determine containment pressure after a Revised (See the Tornado Missile event. 8/2013 OIP Update)Started (2/2014)52. Develop the Phase 3 strategy after the containment pressure Not Started analysis is completed as described in Maintain Containment, PWR Portable Equipment Phase 2.53. Ensure the RRC will provide additional portable pumps and Complete (This OIP equipment to spray water into containment or supply water to the Update 8/2014)Containment Recirculation Fans / Coolers.54. Implement a strategy to provide for a protected makeup connection Revised (See the to the Spent Fuel Pool (SFP) cooling piping to provide makeup to 2/2014 OIP Update)the SFP that exceeds SFP boil-off and provide a means to supply Started (2/2014)SFP makeup without accessing the SFP walkway.55. Provide the necessary connecting hoses and/or equipment to work Started (2/2014)with existing pumps and water sources for filling the SFP.56. Implement new FSG-1 1, Alternate SFP Makeup and Cooling, to Revised (This OIP provide multiple strategies for establishing a diverse means of SFP Update 8/2014)makeup and cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Not Started 57. Perform an analysis to determine if a vent pathway from the SFP is Started (2/2014)needed for steam and condensate to minimize the potential for steam to cause access and equipment problems in the Auxiliary Building. (also see 01 62)58. SFP Water Level instrument numbers will be provided upon Complete (See the detailed design completion.

2/2014 OIP Update)59. Ensure the RRC will provide additional portable pumps and Complete (This OIP equipment to: Update 8/2014)* provide water from the UHS to the Standby SFP Heat Revised (This OIP Exchanger to remove heat from the SFP cooling system with Update 8/2014)the Standby SFP Recirculation Pump; or" provide water to SFP Heat Exchanger A to remove heat from the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A.Page 18 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 60. Implement a strategy to supply the battery chargers from the 1 MW Revised (This OIP D/G using existing plant equipment connection points. Update 8/2014)Started (2/2014)61. Implement a strategy to supply the battery chargers from a 100 kW Revised (This OIP D/G using existing plant equipment connection points. Update 8/2014)Started (2/2014)62. Perform GOTHIC calculations consistent with NUMARC 87-00, Started (8/2013)Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, to determine the effects of a loss of HVAC during an ELAP for the following areas:* Intermediate Building, TDAFW Pump and ARV/ (Safety Valve (SV) areas* Auxiliary Building, Refueling Water Storage Tank (RWST) area* Battery Rooms, Relay Room, and Control Room" Standby Auxiliary Feedwater Building 63. Perform an analysis to evaluate the Battery Room low temperature Started (2/2014)for an ELAP event, assuming -16°F air temperature to determine if, and when, Battery Room heating is required.64. Implement a strategy for accessing the UHS for all BDBEEs and to Revised (See the meet required deployment times. This must also address how 2/2014 OIP Update)debris in the UHS or other raw water sources will be filtered / Started (2/2014)strained and how the resulting debris will effect core cooling.65. Implement a strategy to provide for transferring diesel fuel from the Revised (See the D/G A and D/G B Fuel Oil Storage Tanks (FOSTs) to a fuel 2/2014 OIP Update)transfer vehicle. Started (2/2014)66. Perform an analysis to provide a basis that the Offsite D/G FOSTs Started (8/2014)are reasonably protected from BDBEEs.67. Develop the strategy to transfer fuel from protected fuel storage Started (8/2014 locations to FLEX equipment.

68. Develop strategies to provide for emergency lighting to support Started (2/2014)Operator actions after a BDBEE.69. Develop a strategy to protect onsite consumables for use after a Started (2/2014)BDBEE.70. Develop and implement procedures to establish battery room Not Started ventilation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the event to prevent exceeding the unacceptable hydrogen concentration limit of 2%, once the GOTHIC analysis has been completed as discussed in Phase 2.Page 19 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status 71. Table 3 lists Phase 3 Response Equipment

/ Commodities that are Deleted (See the being considered for pre-staging at an offsite location.

These 2/2014 OIP Update)include:* Radiation Protection Equipment" Commodities

-Food, Potable Water* Diesel Fuel* Heavy Equipment

-Transportation, Debris Removal* Boric Acid* Portable Lighting* Portable Toilets 72. Install wide range SFP level instrumentation in accordance with Started (8/2013)NRC Order EA-12-051.

73. Implement a strategy to provide cooling water to the RHR Heat Started (2/2014)Exchangers using a portable diesel driven pump.74. Any additional non-safety equipment will be identified and Started (2/2014)evaluated for suitability in the mitigation strategies I Table 3 provides a summary of the open and confirmatory items documented in the Ginna Interim Staff Evaluation (ISE) (Reference
20) and the status of each item following the issuance of the ISE.Table 3 Status of Interim Safety Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status None ISE Confirmatory Items Status 1. ISE Confirmatory Item 3.1.1.A -Confirm that the licensee Started (8/2014)addresses the results of the seismic and flooding re-evaluations pursuant to the NRC's 50.54(f) letter of March 12, 2012.2. ISE Confirmatory Item 3.1.1.1.A

-Protection, seismic -confirm that Started (8/2014)large portable FLEX equipment such as pumps and power supplies would be secured as appropriate to protect them during a seismic event and that stored equipment and structures would be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

Page 20 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status 3. ISE Confirmatory Item 3.1.1.3.A

-Procedural Interfaces

-seismic -Started (8/2014)confirm that a reference source for the plant operators is provided that provides approaches to obtaining necessary instrument readings to support the implementation of the coping strategies.

4. ISE Confirmatory Item 3.1.4.2.A

-Snow, ice and extreme cold -Started (8/2014)confirm that potential loss of access to the UHS and flow path due to extreme low temperatures, e.g., due to ice blockage or formation of frazil ice, is assessed and resolved.5. ISE Confirmatory Item 3.2.1.A -Confirm resolution of open item to Not Started develop and implement procedures to close SI accumulator injection valves or vent the SI accumulators prior to nitrogen injection into the RCS.6. ISE Confirmatory Item 3.2.1.B -Confirm evaluation of the Not Started recommendation to consider the prioritization of staging portable equipment that may be required to isolate/vent the accumulators when certain cooldown maneuvers are necessitated.

7. ISE Confirmatory Item 3.2.1.1.A-Confirm completion of timelines Started (8/2014)used in conjunction with the thermal hydraulic analysis to document the duration of each phase for each critical function, and the basis for the duration.8. ISE Confirmatory Item 3.2.1.2.A-RCP seals -Confirm that, if RCP Started (8/2014)seals are changed to non-Westinghouse seals, the acceptability of the use of non-Westinghouse seals is addressed, and the RCP seal leakage rates for use in the ELAP analysis are provided with acceptable justification.
9. ISE Confirmatory Item 3.2.1.2.B

-High temperature RCP seal Started (8/2014)concern -If applicable, confirm justification that (1) the integrity of the associated 0-rings will be maintained at the temperature conditions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.

10. ISE Confirmatory Item 3.2.1.8.A

-The licensee informed the NRC Started (8/2014)staff of its intent to abide by the generic approach described in the PWROG August 15, 2013 position paper related to modeling the timing and uniformity of boric acid mixing within the RCS under natural circulation conditions potentially involving two-phase flow.Confirm that the additional conditions discussed in the NRC endorsement letter are satisfied, and that boration requirements are met.Page 21 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status 11. ISE Confirmatory Item 3.2.1.9.A

-Confirm design information and Started (8/2014)supporting analysis developed for portable equipment that provides the inputs, assumptions, and documented analyses that the mitigation strategy and support equipment will perform as intended.12. ISE Confirmatory Item 3.2.3.A -Containment analysis -Confirm Started (8/2014)completion of containment analysis and incorporation of results into mitigation strategies.

13. ISE Confirmatory Item 3.2.4.2.A

-Ventilation

-confirm completion Started (8/2014)of GOTHIC calculations and incorporation of results into mitigation strategies.

14. ISE Confirmatory Item 3.2.4.4.A

-Emergency lighting -confirm Started (8/2014)development of lighting strategies.

15. ISE Confirmatory Item 3.2.4.4.B

-Communications

-confirm Started (8/2014)completion of upgrades.16. ISE Confirmatory Item 3.2.4.5.A-Protected Area Access -confirm Started (8/2014)that strategies are in place to allow access to protected areas as needed to execute mitigation strategies.

17. ISE Confirmatory Item 3.2.4.8.A

-Confirm that the final electrical Started (8/2014)design has the necessary electrical isolations and protections.

18. ISE Confirmatory Item 3.3.1.A- Confirm sufficient quantities of Started (8/2014)FLEX equipment to meet N+1.7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation as this time.Page 22 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 8 Communications Assessment Interim Actions Status Table 4 provides a listing of the implementing actions documented in the Assessment of Communications during an ELAP (Reference 4). It provides the status of each action, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Beginning with the February 2015 update, Ginna will no longer include the status of the communications assessment interim actions as discussed in the cover letter.Table 4 Status of Communications Assessment Interim Actions Revised Communications Assessment Target Target Completion Status Tre Implementing Actions Date Completion Date Fixed Satellite Phone System and Antennas 1. Determine the status of existing fixed 12/31/2013 Complete (See the satellite phone system and antennas in 8/2013 OIP Update)terms of suitability of being"Reasonably protected" 2. Install fixed satellite antennas/dishes to 8/31/2014 Revised (This OIP Prior to support the use of fixed satellite Update 8/2014) refueling phones at all onsite locations (Control Started (8/2014) outage Room, Technical Support Center startup Fall (TSC), and Operational Support Center 2015*(OSC)).3. Stage portable satellite dishes to Prior to New (This OIP support the use of fixed satellite refueling Update 8/2014)phones at all onsite locations (Control outage Not Started Room, TSC, and OSC). startup Fall 2015 NAB, TSC and Service Buildings 1. Determine whether or not the Nuclear 12/31/2013 Complete (See the Assurance Building (NAB), TSC and 2/2014 OIP Update)Service Building are "reasonably protected." Portable Satellite Phones 1. Stage portable satellite phones Complete Complete (See the 8/2013 OIP Update)Page 23 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Target Revised Communications Assessment Completion Status Target Implementing Actions Date Completion Date 2. Stage portable satellite phone batteries 10/31/2013 Complete (See the and chargers in the applicable 2/2014 OIP Update)Emergency Response Organization (ERO) Facilities.

3. Update work instructions for portable 10/31/2013 Complete (See the satellite phone inventory.

2/2014 OIP Update)4. Develop/update preventive 12/31/2013 Complete (See the maintenance and testing procedures 2/2014 OIP Update)for portable satellite phones, batteries and chargers.5. Include information on portable satellite 12/31/2013 Complete (See the phone locations and usage in 2/2014 OIP Update)procedures.

6. Stage off-site portable off-site satellite 12/31/2013 Complete (See the phones. 2/2014 OIP Update)7. Procure and install a high power UPS 12/31/2014 Deleted (This OIP or similar modification providing backup Update 8/2014)power for the battery chargers for portable satellite phones.Page 24 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS TargetRevised Communications Assessment Target ret Competin SttusTarget Implementing Actions Date Completion Date Fixed Satellite Phones 1. Procure and install fixed satellite 12/31/2014 Not Started Prior to phones, additional antennas, and refueling uninterruptable power supplies for the outage TSC/OSC, Control Room, Emergency startup Fall Operations Facility (EOF), Joint 2015*Information Center (JIC), and Wayne and Monroe Counties Emergency Operations Centers (EOCs) and Warning Points (WPs). Include the capability to power the portable satellite phone battery chargers.2. Develop/update preventative 8/31/2014 Not Started Prior to maintenance and testing procedures refueling for fixed satellite phones. outage startup Fall 2015*3. Include information on fixed satellite 12/13/2013 Complete (See the phone locations and usage in 2/2014 OIP Update)procedures.
4. Provide instructions for use of fixed 12/31/2014 Not Started Prior to satellite phones at each location.

refueling outage startup Fall 2015*Page 25 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Target Revised Communications Assessment Completion Status Target Implementing Actions Date Completion Date Communication with ORO Facilities

1. Provide each Offsite Response 8/31/2013 Complete (See the Organization (ORO) identified in 2/2014 OIP Update)Section 4.3 of the Communications Assessment with instructions for proper storage and rotation of satellite phone batteries.
2. Install fixed satellite dish at Wayne and Prior to New (This OIP Monroe Counties Emergency refueling Update 8/2014)Operations Centers (EOCs) and outage Not Started Warning Points (WPs) startup Fall 2015 Portable Generators
1. Develop portable generator fueling 12/31/2013 Complete (See the plan to ensure ability to provide power 2/2014 OIP Update)for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.2. Develop procedures to maintain and 12/31/2013 Complete (See the test the portable generators.

2/2014 OIP Update)3. Update work instructions to inventory 12/31/2013 Complete (See the portable generators and ensure 2/2014 OIP Update)adequate volume of fuel.4. Develop preventive maintenance 12/31/2013 Complete (See the procedure for portable generators fuel 2/2014 OIP Update)supply.5. Determine a process for relocating 12/31/2013 Complete (See the portable generators to the appropriate 2/2014 OIP Update)locations to power the necessary equipment.

Training 1. Evaluate training needs specific to the 10/31/2015 Not Started use of portable and fixed satellite phones, and radios during an ELAP event.Page 26 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Revised Communications Assessment Completion Status Target Implementing Actions Date Completion Date 2. Develop and implement training on the 10/31/2015 Not Started use of backup generators.

3. Revise EPIP-1-18 as described in 10/31/2013 Complete (See the Section 4.11 of Reference 4 2/2014 OIP Update)Brief appropriate personnel on the contents of this procedure.

APC Back-UPS ES 750 1. Determine whether APC Back-UPS ES 12/31/2013 Deleted (See the 750 is high enough above ground 2/2014 OIP Update)elevation in the On-Site Telephone Building to be protected from flooding.Portable Radios 1. Procure and install a high power UPS 10/31/2015 Not Started or similar modification providing backup power for the radio system repeaters.

2. Complete estimates of portable radio 10/31/2013 Complete (See the battery life and procure additional 2/2014 OIP Update)batteries as necessary based on an estimate of minimum talk time to ensure 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation.
3. Procure and stage portable radio Prior to New (This OIP repeaters(s) with generator(s) to refueling Update 8/2014)extend range of portable radios outage Not Started startup Fall 2015* Change since submittal of last six month status report.Page 27 of 32 ATTACHMENT (1)6-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 attachment.
1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), "Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (FLL-13-007).
2. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.3. 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 (FLL-13-015).
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 (FLL-13-011).
5. 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 (FLL-14-004).
6. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," dated August 2012.7. NRC Regulatory Guide 1.76, "Design-Basis Tornado and Tornado Missiles for Nuclear Power Plants," Revision 1 8. Updated Final Safety Analysis Report, Revision 24 9. Letter from R. W. Kober (RG&E) to Director of Nuclear Regulation (NRC), "Structural Upgrade Program SEP Topics, 11-2.A, 111-2, 111-4.A and 111-7.B," dated July 13, 1984 10. Letter from C. Stahle (NRC) to R. W. Kober (RG&E), "Safety Evaluation Report on the Structural Upgrade Program," dated March 24 1987 11. Letter from J. A. Gresham (Westinghouse) to Document Control Desk (NRC), "Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21," dated July 26, 2013 (ML1321 1A168)12. WCAP-17601-P, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," Revision 0 13. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), "Supplemental Response to Requests for Additional Information Regarding Topics Described by Letters Dated August 24, 2005 and October 28, 2005," dated January 11, 2006 (ML060180262)
14. CN-LIS-05-163, "SBLOCA Cooldown Calculation Results for R.E. Ginna (RGE) Extended Power Uprate and 422V+ Fuel Upgrade Program," Revision 0 (Proprietary)

Page 28 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 15. CALC-2014-0002, "Cycle 38 Reactor Engineering Calculations," Revision 0 16. Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG), August 15, 2013 (Proprietary) (ML13235A135)

17. Letter from J. Davis (NRC) to J. Stringfellow (PWROG) regarding request to endorse the Westinghouse position paper entitled 'Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)," made available in your letter dated August 16, 2013, dated January 8, 2014 (ML1 3276A1 83)18. ECA-0.0, "Loss of All AC Power," Revision 03800 19. U.S.NRC JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0 (ML12229A174)
20. Letter from J. S. Bowen (NRC) to M. G. Korsnick (CENG), "R. E. Ginna Nuclear Power Plant-Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF1 152)," dated February 19, 2014 (ML14007A704)

Page 29 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Stagqing Area 'A'Page 30 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Staging Area 'B'Page 31 of 32 ATTACHMENT (1)6-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Staging Area 'C'Page 32 of 32

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