ML14251A023

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)

ML14251A023
Person / Time
Site:	Millstone
Issue date:	08/28/2014
From:	Mark D. Sartain Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-393A, EA-12-049
Download: ML14251A023 (40)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com 10 CFR 2.202 EA-1 2-049 August 28, 2014 Attention: Document Control Desk Serial No.: 14-393A U.S. Nuclear Regulatory Commission NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket No.: 50-423 License No.: NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 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

2. Dominion Nuclear Connecticut, Inc.'s Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No.12-161 B)

3. Dominion Nuclear Connecticut, Inc.'s 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 28, 2014 (Serial No. 12-161F)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Dominion Nuclear Connecticut, Inc. (DNC). Reference 1 was immediately effective and directed DNC to develop, implement, and maintain guidance and strategies to maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2) pursuant to Section IV, Condition C. Reference 1 also required submission of a status report at six-month intervals following submittal of the OIP. to this letter provides the third six-month status report and an update of milestone accomplishments since the submittal of the previous six-month status report

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Page 2 of 3 (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis. provides the ventilation strategy, identified as Open Item 17 for the OIP.

This information is provided in the template format used for the originally submitted OIP.

The pages provided in Attachment 2 for Section F5, "Safety Function Support (Ventilation)" supersede Section F5 in the originally submitted OIP.

If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering Attachments (2)

Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me thi j*- 7-day of *,ad( , 2014.

My Commission Expires: 5 -3/--

Notary Public (SEAL) comWNmoas" of Virgiia Reg.*D 140542 CMy~~w helm LV May 31, 2016

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 2100 Renaissance Blvd.

Suite 100 King of Prussia, PA 19406-2713 Mr. M. C. Thadani NRC Senior Project Manager Millstone Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment I Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events August 2014 Millstone Power Station Unit 3 Dominion Nuclear Connecticut, Inc. (DNC)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 1 of 28 Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (OIP)

(Reference 1) documenting the diverse and flexible strategies (FLEX) for Millstone Power Station Unit 3 (MPS3) in response to NRC Order Number EA-12-049 (the Order) (Reference 2). This attachment provides an update of milestone accomplishments and open items since the last. status report (Reference 16), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP, and are current as of July 31, 2014.

" Submit Integrated Plan

" Develop Strategies

" Develop Training Plan

" Purchase Equipment

" Create Maintenance Procedures 3 Milestone Schedule Status The following table provides an update to Attachment 2A of the OIP. It provides the activity status of each item as of July 31, 2014, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates for 'Develop Modifications,' 'Receive Equipment,' 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures,'

and 'Create Maintenance Procedures' do not impact the Order implementation date. The impact of the completion date for 'Implement Training' is discussed in Section 5.

Target Activity Revised Target Milestone Completion Status Completion Date Date Submit Integrated Plan February 2013 Complete Develop Strategies April 2014 Complete Develop Modifications July 2014 Started September 2014*

Implement Modifications November 2014 Started

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 2 of 28 Target Activity Revised Target Milestone Completion Status Completion Date Date Develop Training Plan April 2014 Complete Implement Training September Started April 2015 2014 (See Section 5)

Issue FLEX Support Guidelines and October 2014 Started Associated Procedure Revisions Develop Strategies/Contract with National SAFER Response Center August 2014 Started (NSRC)

Purchase Equipment February 2014 Complete Receive Equipment August 2014 Started September 2014*

Validation Walk-throughs or Demonstrations of FLEX Strategies August 2014 Started September 2014*

and Procedures Create Maintenance Procedures* August 2014 Complete Outage Implementation November 2014 Started Refer to Section 8, Supplemental Information, for an explanation of the change to this Milestone.

4 Changes to Compliance Method By letter dated February 28, 2013, (Reference 1), DNC provided an OIP to address Beyond-Design-Basis (BDB) events at Millstone Power Station Unit 2 (MPS2) and MPS3 as required by Order Number EA-12-049, dated March 12, 2012 (Reference 2). The first Six-Month Status Update of the OIP for both MPS2 and MPS3 was provided by letter dated August 23, 2013 (Reference 14). The second Six-Month Status Update for MPS3 was provided by letter dated February 28, 2014 (Reference 16). The following are changes to the compliance method information provided in the MPS3 OIP and subsequent updates, which continues to meet Nuclear Energy Institute (NEI) 12-06 (Reference 3):

a) Regarding the previously reported strategy for Modes 5 & 6, credit was taken for the Refueling Water Storage Tanks (RWSTs) to provide a borated water source for injection into the Reactor Coolant System (RCS). Although the RWSTs are not missile protected, credit as a borated water source was based on the assumption that it was improbable that both tanks would be destroyed by a single tornado. Subsequently, the strategy has been enhanced to address the scenario that both RWSTs are unavailable. The revised strategy includes the provision to utilize clean water sources onsite (which are protected from a tornado), if both RWSTs are unavailable. If a clean water source is used, flow must be

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 3 of 28 controlled in order to match the rate of water loss (due to boiling) so that dilution of the boron concentration in the RCS does not occur.

b) Based on a study that included a chemical analysis of the various water sources onsite, the preferred order of clean water sources for use in both the primary and secondary sides of the NSSS was revised. Additionally, use of water from Long Island Sound or the onsite pond following a flooding event have been excluded as water sources for either the primary or secondary sides of the Nuclear Steam Supply System (NSSS) since they contain high concentrations of salt. As a last resort, however, they are not excluded as a water source for the Spent Fuel Pool.

c) DNC is pursuing an alternate means of compliance to NEI 12-06, Section 3.2.2, regarding additional "spare" cables and hoses. Typically, the hoses utilized to implement a FLEX strategy are not a single continuous hose, but are composed of individual sections of a smaller length joined together to form a sufficient length. In the case of cables, multiple individual lengths of cable are used to construct a circuit.

Hoses and cables are passive devices that are unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided that the hoses and cables are stored in areas with suitable environmental conditions. The hoses and cables for the FLEX strategies will be stored and maintained in accordance with manufacturers' recommendations including any shelf life requirements. Initial inspections and periodic inspections or testing/replacement will be incorporated into the site's maintenance and testing program and implemented in accordance with Section 11.5 of NEI 12-06.

The industry has proposed for NRC Staff consideration alternate methods of compliance to the N+1 requirement applicable to hoses and cables, as stated in Section 3.2.2 of NEI 12-

06. DNC supports this industry proposal and has adopted the agreed upon method for hoses in that 10% of the total length and at least one of the longest single lengths has been purchased. With regard to cables, the 120/240VAC generators and the 480VAC generators are backups to each other; therefore, only N sets of cables are required. Once NRC endorsement of this alternate approach is complete, DNC will have achieved alternate compliance with the NEI 12-06 N+1 requirement for hoses.

d) The structural integrity of the reactor Containment building will not be challenged due to increasing Containment pressure during a BDB Extended Loss of AC Power (ELAP) event.

Additionally, analysis has shown that any increase in temperature following an ELAP event does not challenge the key parameter instrumentation in the Containment for at least seven (7) days.

Multiple Containment cooling methods described in previous submittals are available as options for heat removal to maintain Containment temperature for equipment design limits.

However, they are not required to be specifically designated as primary and alternate strategies. Adequate time is available utilizing equipment from the NSRC to deploy the cooling methods described.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 4 of 28 d) The BDB and NSRC equipment details in OIP Table 1, PWR Portable Equipment Phase 2, and OIP Table 2, PWR Portable Equipment Phase 3, respectively, have changed. Updates to the 'List Portable Equipment,' are included as well as associated changes/deletions in footnotes. Minor changes to the number of components have been included for some of the support equipment categories, but no changes have been made to the quantities of any of the major FLEX components. Revised OIP Tables 1 and 2 are attached.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DNC will comply with the Order implementation date for all items except the completion of BDB operator training. A request to relax Condition A.2 of the Order to allow a delay in the full implementation date until April 30, 2015 was requested by letter dated May 16, 2014 (Reference 18). The NRC granted approval of the relaxation of the order implementation date by letter dated July 3, 2014 (Reference 19).

6 Open Items The NRC has established an audit process to allow the exchange of information between the licensees and the NRC Staff (Reference 21). Between July 21, 2014 and July 25, 2014, MPS2 and MPS3 were the subject of an NRC onsite audit where the site specific aspects of DNC's proposed FLEX Mitigating Strategies were reviewed. During this NRC onsite audit, the staff reviewed site specific documentation and upon completion of the audit, indicated that further review of several items was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA-12-051. These items are identified in the following tables in Section 6.

Note that the tables provided in Sections 6.4 and 6.5 are new and are the result of the ongoing audit process.

6.1. Open Items from Overall Integrated Plan The following table provides a summary of the status of Open Items (01) identified by DNC and documented in Attachment 2B of the MPS3 Overall Integrated Plan submitted on February 28, 2013 and the status of each item.

Overall Inteqrated Plan Open Items 01 # Description Status Started.

1 Verify response times listed in timeline Scheduled completion date: September 2014*

and perform staffing assessment.

Complete.

2 Evaluation of extended battery life with load stripping of all non-essential loads. In the DNC February 28, 2013 OIP submittal for Millstone, the MPS3 Class 1E 125V battery life was "estimated" at between 2 and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 5 of 28 Overall Intearated Plan Open Items 01 # Description Status assuming that load stripping would commence within 45 minutes and be completed within the following 30 minutes. The pending final evaluation of the extended Class 1 E station emergency battery life was identified as Open Item No. 2. The calculation with the stated load stripping assumption has been completed. The evaluated time to battery depletion is 14.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The evaluation considered that the 301B battery was stripped of all loads by the assumed time frame and the 301A battery would carry the necessary instrumentation loads until it reached the minimum voltage for reliable instrument readings in 7.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. At that time, alternate instrument loads for plant monitoring from the 301B battery would be re-connected and would be available for an additional 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The combined time available by this approach (14.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) is sufficient for the implementation of the re-powering strategy for the 120VAC systems as outlined in the OIP submittal, Section F1.2.

(Reference 5)

Preliminary analyses have been Complete.

performed to determine the time to steam generator (SG) overfill without operator (Reference 4) action to reduce auxiliary feedwater 3 (AFW) flow, time to SG dryout without During the July 2014 NRC Onsite Audit, the AFW flow, and time to depletion of the NRC Staff indicated that further review of useable volume of the demineralized this item was not anticipated as DNC water storage tank (DWST). The final proceeds towards compliance for Orders durations will be provided when the EA-12-049 and EA-12-051.

analyses are completed.

The Phase 3 coping strategy to maintain Complete.

Containment integrity is under development. Methods to monitor and (Reference 16) 4 evaluate Containment conditions and depressurize/cool Containment, if necessary, will be provided in a future update.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Pace 6 of 28 Overall Integrated Plan Open Items 01 # Description Status Complete.

The hydraulic calculation for the FLEX pumps deployed using their associated hose networks have confirmed that the primary and alternate connections for core cooling/decay heat removal, Reactor Coolant System (RCS)

Inventory, reactivity control (RCS Injection),

and spent fuel pool (SFP) Make-up strategies Analyses will be performed to develop can be satisfactorily accomplished in response fluid components performance to an ELAP/Loss of Ultimate Heat Sink (LUHS) requirements and confirm fluid hydraulic- event. (Reference 8) related strategy objectives can be met. Hydraulic calculations have confirmed that the SW flows for the Containment cooling options are adequate. (Reference 10)

During the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA-12-051.

A study is in progress to determine the Complete.

design features, site location(s), and number of BDB Storage Building(s). The A single 10,000 sq. ft. Type 1 building is being final design for BDB Storage Building(s) constructed at MPS for storage of BDB will be based on the guidance contained equipment. The building is designed to meet in NEI 12-06, Section 11.3, Equipment the plant's design basis for the Safe Shutdown Storage. A supplement to this submittal Earthquake, high wind hazards, snow, ice and will be provided with the results of the cold conditions, and is located above the flood 6 equipment storage study. elevation from the most recent site flood analysis.

The BDB Storage Building is sited south of the railroad bridge, on the west side of the MPS access road, adjacent to the existing northeast contractor parking lot.

(References 13 and 17)

FLEX Support Guidelines (FSGs) will be Started.

7 developed in accordance with PWROG Scheduled completion date: October 2014 guidance. Existing procedures will be revised as necessary to implement FSGs.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Pace 7 of 28 Overall Integrated Plan Open Items 01 # Description Status Electrical Power Research Institute Complete.

(EPRI) guidance documents will be used to develop periodic testing and EPRI guidance documents have been used, preventative maintenance procedures for where available, to develop the testing and BDB equipment. Procedures will be preventative maintenance strategies for the developed to manage unavailability of sites. Fleet-wide templates have been equipment such that risk to mitigating developed and input into the individual site strategy capability is minimized, maintenance strategies. Specific Periodic Maintenance (PM) procedures based on these strategies will be implemented prior to the 8 required MPS3 compliance date for Order EA-12-049.

A fleet-wide FLEX Strategy Program Document has been developed (Refer to Open Item 9).

The program includes the requirement to manage unavailability of equipment such that risk to mitigating strategy capability is minimized. A fleet-wide procedure has been developed to specifically address equipment unavailability. (Reference 22)

An overall program document will be Complete.

developed to maintain the FLEX strategies and their bases, and provide During the July 2014 NRC Onsite Audit, the configuration control and change NRC Staff indicated that further review of 9 management for the FLEX Program. this item was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 23)

The DNC Nuclear Training Program will Complete.

be revised to assure personnel proficiency in the mitigation of BDB During the July 2014 NRC Onsite Audit, the 10 events is developed and maintained. NRC Staff indicated that further review of These programs and controls will be this item was not anticipated as DNC developed and implemented in proceeds towards compliance for Orders accordance with the Systematic Approach proceeds ard compliancefer s to Training (SAT). EA-12-049 and EA-12-051. (Reference 21)

Complete the evaluation of turbine driven Complete.

(TD) auxiliary feedwater (AFW) pump TDAFW pump operation and adequate AFW long term operation with < 290 psig inlet flow to the SGs at SG pressures < 290 psig has 11 steam pressure. been confirmed.

(References 6 and 7)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Pace 8 of 28 Overall Integrated Plan Open Items 01 # Description Status Plant modifications will be completed for Started.

12 permanent plant changes required for See Milestone Schedule above.

implementation of FLEX strategies.

Analyses will be performed to develop Complete.

electrical components performance requirements and confirm electrical Calculations have been completed for the 13 loading-related strategy objectives can be sizing and loading analysis of the 120 VAC, met. 480 VAC, and 4160 VAC generators and confirm the electrical loading-related strategy objectives can be met. (Reference 11)

An evaluation of all BDB equipment fuel Complete.

consumption and required re-fill strategies will be developed. An evaluation of BDB equipment fuel 14 consumption and required refill strategies has been completed and provided as part of the ongoing NRC audit process. (Reference 17)

A lighting study will be performed to Complete.

validate the adequacy of supplemental lighting and the adequacy and practicality A lighting study has been completed validating of using portable lighting to perform FLEX the adequacy of supplemental lighting and the 15 strategy actions. adequacy and practicality of using portable lighting to perform FLEX Strategy actions. This was provided as part of the ongoing NRC audit process. (Reference 17)

A comprehensive study of communication Complete.

capabilities is being performed in accordance with the commitments made A study documenting the communications in DNC letter S/N 12-205F dated October strategy has been completed. The plan 29, 2012 in response to Recommendation concludes that FLEX strategies can be 9.3 of the 10 CFR 50.54(f) letter dated effectively implemented with a combination of March 12, 2012. The results of this study satellite phones, hand-held radios and sound will identify the communication means powered phones. (Reference 9) available or needed to implement command and control of the FLEX strategies at Millstone. Validation of communications required to implement FLEX strategies will be performed as part of Open Item No. 1.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Pac e 9 of 28 Overall Integrated Plan Open Items 01 # Description Status Details of the ventilation strategy are Complete.

under development and will conform to 17 the guidance given in NEI 12-06. The See Attachment 2, OIP Section F5 - Safety details of this strategy will be provided at Functions Support (Ventilation).

a later date.

Preferred travel pathways will be Complete.

determined using the guidance contained in NEI 12-06. The pathways will attempt The soil liquefaction study has been completed to avoid areas with trees, power lines, (Reference 12), which supports the location of and other potential obstructions and will the storage building and the haul routes. The consider the potential for soil liquefaction, results will be included with the final design 18 package for the storage building. (Reference 13)

During the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA-12-051.

The equipment listed in Table 1 will be Started.

19 received on site.

19 rScheduled completion date: September 2014. *

• Refer to Section 8, Supplemental Information, for an explanation of the change to this Open Item.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 10 of 28 6.2. Open Items from Interim Staff Evaluation (ISE)

The following table provides a summary of the Open Items (01) from the MPS3 Interim Staff Evaluation (Reference 15) and the status of each item.

Interim Staff Evaluation Open Items 01 # Description Status 3.2.1.8.A Core Sub-Criticality -The Pressurized Water Complete.

Reactor Owners Group (PWROG) submitted to NRC a position paper, dated August 15, 2013, During the July 2014 NRC Onsite which provides test data regarding boric acid Audit, the NRC Staff indicated that mixing under single-phase natural circulation further review of this item was not conditions and outlined applicability conditions anticipated as DNC proceeds intended to ensure that boric acid addition and towards compliance for Orders mixing would occur under conditions similar to EA-12-049 and EA-12-051.

those for which boric acid mixing data is (References 17 and 21) available.

During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

6.3. Confirmatory Items from Interim Staff Evaluation The following table provides a summary of the Confirmatory Items (CI) from the MPS Unit 3 Interim Staff Evaluation (ISE) and the status of each item.

Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.1.2.A The licensee stated that the haul path from the This ISE Cl is being addressed BDB Storage Building to the MPS3 equipment through the ongoing NRC audit deployment locations and the building process. (References 17 and 21) foundation design evaluations are proceeding for Millstone. Confirm that soil liquefaction is not a concern.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 11 of 28 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.1.3.A The licensee stated that the review for internal During the July 2014 NRC Onsite flooding sources that could result from seismic Audit, the NRC Staff indicated that induced failures and engine-driven or gravity- further review of this item was not drain water sources has not been completed. anticipated as DNC proceeds Also MPS3 does not have a permanent safety- towards compliance for Orders related groundwater removal system installed. EA-12-049 and EA-12-051.

However, the Engineered Safety Features (References 17 and 21) building does have a sump to control groundwater in-leakage. In ETE-CPR-2012-0008, Section 11.1.3.3, the licensee stated that they also have several small pumps and hoses on site for this purpose. Confirm that the impact of this in-leakage is limited, or can be addressed.

3.1.1.4.A The licensee's plan for implementing the use of This ISE Cl is being addressed off-site resources is not complete. The local through the ongoing NRC audit assembly areas have not been identified. The process. (References 17 and 21) licensee is also evaluating the possibility of boat transport for personnel.

3.2.1.A Confirm that the NOTRUMP analysis provided This ISE Cl is being addressed in Section 5.2.1 of WCAP-17601-P, Revision 1 through the ongoing NRC audit is applicable to MPS3 and supports the process.

licensee's sequence of events.

(Generic)

(Reference 21) 3.2.1.1.A Confirm that the use of the NOTRUMP code for This ISE Cl is being addressed the ELAP analysis is limited to the flow through the ongoing NRC audit conditions prior to reflux condensation process.

initiation. This includes specifying an acceptable definition for reflux condensation (Generic) cooling. (Reference 21)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 12 of 28 Interim Staff Evaluation Confirmatory Items CI # Description Status 3.2.1.2.A If the RCP seal leakage rates used in the plant- This ISE Cl is being addressed specific ELAP analyses are less than the upper through the ongoing NRC audit bound expectation for the seal leakage rate process.

discussed in the PWROG position paper addressing the RCP seal leakage (ADAMS (Generic)

Accession No. ML13235A151 (Non-Publicly (Reference 21)

Available)) or justification should be provided for use of a lower value. If the seals are changed to non-Westinghouse seals, the acceptability of the use of non-Westinghouse seals should be addressed, and the RCP seal leakage rates for use in the ELAP analysis should be justified.

3.2.1.2.B For Westinghouse Reactor Coolant Pump This ISE Cl is being addressed (RCP) seals, a discussion (including the through the ongoing NRC audit applicable analysis and relevant seal leakage process.

testing data) should be provided to justify that (1) the integrity of the associated 0-rings will (Generic) be maintained at the temperature conditions (Reference 21) experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is acceptable.

3.2.1.2.C If the seals are changed to the newly designed This ISE Cl is being addressed Generation 3 SHIELD seals, or non- through the ongoing NRC audit Westinghouse seals, justify the acceptability of process.

the use of the newly designed Generation 3 SHIELD seals or non-Westinghouse seals and (Generic) the RCP seal leakages rates for use in the (Reference 21)

ELAP analysis.

3.2.1.3.A Confirm that the licensee has addressed the During the July 2014 NRC Onsite applicability of assumption 4 on page 4-13 of Audit, the NRC Staff indicated that WCAP-17601-P, and confirm that the values further review of this item was not used for the requested parameters in the anticipated as DNC proceeds Westinghouse calculations that were performed towards compliance for Orders using the ANS 5.1 1979 +2 sigma decay heat EA-1 2-049 and EA-12-051.

model bound initial condition 3.2.1.2(1) of NEI (Reference 21) 12-06, Section 3.2.1.2.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 13 of 28 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.1.6.A The licensee stated that for Action Item 11 the During the July 2014 NRC Onsite portable boric acid batching tank will be Audit, the NRC Staff indicated that deployed at 12 - 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, if the Refueling further review of this item was not Water Storage Tank (RWST) is not available, anticipated as DNC proceeds Confirm that the deployment time of 12 - 18 towards compliance for Orders hours is acceptable. EA-1 2-049 and EA-1 2-051.

(References 17 and 21) 3.2.3.A The strategy for Containment cooldown and This ISE CI is being addressed depressurization will be completed per the through the ongoing NRC audit schedule given in the August 23, 2013 6- process.

Month Status Update. The detailed validation analysis will be completed later this year and (See Section 4d and Reference 16) the results will be provided in the February 2014 6-Month Status Update. Confirm that the analysis and the strategy to maintain the Containment parameters within acceptable limits is satisfactory.

3.2.4.2.A Analyses to evaluate the effects of loss of This ISE Cl is being addressed ventilation in various areas are currently through the ongoing NRC audit underway. Upon completion of these process.

analyses, detailed strategies and operator action timelines will be developed for the (See Attachment 2 and Reference implementation of compensatory measures to 17) maintain the area temperatures below the applicable design limits, if necessary. The results will be provided in the February 2014 6-month update. Confirm that the analyses and the compensatory measures show that room temperatures are acceptable to maintain functionality of the equipment needed to carry out the mitigation strategies.

3.2.4.2.B Confirm that the habitability limits of the main This ISE Cl is being addressed control room will be maintained in all Phases of through the ongoing NRC audit an ELAP. process.

(See Attachment 2 and Reference 117)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 14 of 28 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.4.4.A Confirm the adequacy of existing lighting and During the July 2014 NRC Onsite the adequacy of portable lighting to perform Audit, the NRC Staff indicated that FLEX strategy actions. further review of this item was not anticipated as DNC proceeds towards compliance for Orders EA-1 2-049 and EA-1 2-051.

(Reference 17) 3.2.4.4.B Confirm that upgrades to the site's This ISE Cl is being addressed communications systems have been through the ongoing NRC audit completed. process.

(Reference 9) 3.2.4.7.A Westinghouse is currently performing an During the July 2014 NRC Onsite analysis to determine the consequences of Audit, the NRC Staff indicated that usage of impure water sources in the steam further review of this item was not generators. The results of the analysis are anticipated as DNC proceeds expected to provide the allowed time limits on towards compliance for Orders usage of these sources. The NSRC will EA-12-049 and EA-12-051.

provide equipment to initiate residual heat (See Section 4b and Reference 17) removal and water treatment equipment such that heat removal can be ensured for extended durations. Confirm that the analysis results and resultant strategies are acceptable.

3.4.A The licensee's plans for the use of off-site This ISE Cl is being addressed resources conform to the minimum capabilities through the ongoing NRC audit specified in NEI 12-06 Section 12.2, with regard process.

to the capability to obtain equipment and (Reference 21) commodities to sustain and backup the site's coping strategies (item 1). Confirm the licensee addresses the remaining items (2 through 10), or provides an appropriate alternative.

6.4. Audit Questions Reviewed During the MPS Unit 3 NRC Onsite Audit Various MPS3 Audit Questions (AQ) were evaluated during the MPS3 NRC Onsite Audit. The following AQs were evaluated and remained "Open".

Audit NEI 12-06 Section 5.3.2 consideration 1 requires that This AQ is being Question equipment deployment routes to be traveled should be addressed through the

1. 1 reviewed for potential soil liquefaction that could impede ongoing NRC audit equipment movement following a severe seismic event, process.

I I_ , (References 17 and 21)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 15 of 28 Dominion did not provide a definite conclusion regarding the potential for liquefaction along deployment routes or if liquefaction was an issue at MPS. Dominion identified that liquefaction may be a problem but no analysis was provided to evaluate this potential deployment issue. Provide a discussion regarding the potential for seismic event liquefaction that clearly defines this deployment hazard for MSP3. (Reference Item 3.1.1.2.A)

Audit NEI 12-06 Section 5.3.3 Consideration 1 requires that This AQ is being Question seismically qualified electrical equipment can be affected by addressed through the

1. 2 beyond-design-basis seismic events, therefore guidance ongoing NRC audit should be available for determining instrument reading for process.

both main control room (MCR) and non-control room (Reference 24) readouts regarding how and where to measure key instrument readings (e.g. at containment penetrations for in-containment sensors, using a portable instruments).

Dominion's integrated plan did not include providing guidance for this situation. Provide a discussion of how plant staff will determine required key instrument readings if MCR instrumentation is not functioning following a seismic event. (Reference Item 3.1.1.3.A)

+ i Audit On page 104 of 111 Attachment 1A, SOE timeline, This AQ is being Question Dominion indicates for Action Item 1 that, "at the elapsed addressed through the

1. 20 time of 15 seconds, the TDAFW pump starts and AFW flow ongoing NRC audit is verified." Dominion noted that "This is the "original design process.

basis for an SBO event - 50 minutes to SG dryout a." It (References 4, 17, and was also noted (footnote 'a') that this was "previously 21) evaluated in response to 10 CFR50.63 and is in accordance with existing procedures." Clarify whether the TDAFW pump is automatically or manually actuated, and if automatically actuated, the actuation signal used. Address the adequacy of the actuation time of 15 seconds. Also confirm whether the above information regarding TDAFW pump starting time is consistent with that listed in Table 5.2.2-1 of WCAP-1 7601, "Sequence of Events" for the reference case applicable to MPS-3. Table 5.2.2-1 indicates that at 60 seconds, the auxiliary feedwater (AFW) flow begins to all SGs. If the times are consistent, provide the basis to support that the TDAFW pump can start at 15 seconds and that the AFW flow can be supplied to all SGs in 60 seconds. If the WCAP and Dominion noted action times are not consistent, clarify any inconsistencies.

(Reference Item 3.2.1.6.A)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 16 of 28 Audit SOE Action Item 5 indicates that the ELAP/LUHS is This AQ is being Question declared at 45 minutes, and SOE Action Item 6 indicates addressed through the

1. 23 that at 50 minutes (5 minutes after the declaration of the ongoing NRC audit ELAP), the operator controls SG atmospheric relief bypass process.

valves and AFW flow locally as an on-going action for (References 4, 17, and cooldown and decay heat removal. The above early 21) initiation of cooldown (5 minutes following ELAP) at 50 minutes appears inconsistent with the information in Item 6 of Attachment 1 B (page 106 of the integrated plan) that indicates that based on the analysis of the plant reference case in Section 5.2.1 of the WCAP-1 7601, plant cooldown begins 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following declaration of the ELAP with cooldown rate of<100F/hr until the SG pressure reaches 290 psig. Clarify this apparent inconsistency for cooldown initiation time. Discuss the operator actions required to control SG atmospheric relief bypass valves and AFW flow and justify that all the required operator actions are reasonably achievable within the required time constraint of 50 minutes during the ELAP conditions. Also specify the required cooldown completion time that is supportable by analysis, and discuss the required action to complete the cooldown and justify that the all the required actions can be accomplished within the completion time. (Reference Item 3.2.1.6.D)

Audit Specify the required cooldown completion time that is This AQ is being Question supportable by adequate analysis. Discuss the required addressed through the

1. 25 action to complete the cooldown and justify that the all the ongoing NRC audit required actions can be accomplished within the completion process.

time. (Reference Item 3.2.1.6.F) (References 17 and 21)

Audit On page 106 of Attachment 1B to Reference 1 it indicates This AQ is being Question that the minimum SG pressure of 290 psig is consistent with addressed through the

1. 27 the existing EOP setpoint to prevent safety injection ongoing NRC audit accumulator nitrogen gas from entering the RCS. Discuss process.

the analysis used to support the SG pressure of 290 psig in (References 17, 21, and preventing the nitrogen into the core. (Reference Item 25) 3.2.1.6.H)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 17 of 28 Audit NEI 12-06, Section 3.2.2, Paragraph (5) provides that: plant This AQ is being Question procedures/guidance should ensure that a flow path is addressed through the

1. 44 promptly established for makeup flow to the steam ongoing NRC audit generator/nuclear boiler and identify backup water sources process.

in order of intended use. This section also specifies that when all other preferred water sources have been depleted, (See Section 4b and lower water quality sources may be pumped as makeup Reference 17) flow using available equipment and that procedures/guidance should clearly specify the conditions when the operator is expected to resort to increasingly impure water sources. Dominion noted for the alternate strategy for RCS makeup, that water would be added to a batching tank and that "Bags of powdered boric acid are easy to deploy to any area of the plant where the batching tanks are required. Water for mixing would be supplied by the BDB High Capacity pump." The water supplies in this instance would be water from either a 3 million gallon site pond or the UHS. Both of these makeup water supplies could potentially contain debris or foreign material. Provide a discussion and analysis of the possible consequences of injecting potentially impure or contaminated water from the UHS or the site 3 million gallon pond into the RCS or the SG's. (Reference Item 3.2.4.5.B) 6.5. Additional Items Reviewed During the MPS Unit 3 NRC Onsite Audit The following table provides a list of the additional Safety Evaluation (SE) Review items identified and evaluated during the MPS Unit 3 NRC Onsite Audit and the status of each item.

Safety WCAP-1 7792-P - Provide a detailed discussion on the This SE Review Item is Evaluation applicability to MPS3 of the recommendations in WCAP- being addressed Review 17792 to vent the RCS while makeup is being provided for through the ongoing Item #1 the mitigating strategies involving RCS makeup and NRC audit process.

boration. This discussion should include if the MPS3 (References 17 and 21) strategy includes venting the RCS, methods of venting, vent operations criteria, related fluid dynamic analysis, involving instrumentation, and related parameter thresholds.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 18 of 28 Safety NSAL-14 On February 10, 2014, Westinghouse issued This SE Review Item is Evaluation Nuclear Safety Advisory Letter (NSAL)-14-1, informing being addressed Review licensees of plants with Standard Westinghouse RCP seals through the ongoing Item #2 that 21 gpm may not be a conservative leakage rate for NRC audit process.

ELAP analysis. This value had been previously used in the ELAP analysis referenced for the use in many (Generic)

Westinghouse pressurized-water-reactors, including the (Reference 21) generic reference analysis in WCAP-17601-P. Therefore, please clarify whether the assumption of 21 gpm of seal leakage per RCP (at 550 degrees F, 2250 psia) remains valid in light of the issues identified in NSAL-14-1. In so doing, please identify the specifics of the seal leak off line design in NSAL and #1 seal faceplate material relative to the categories in NSAL-14-1 and identify the corresponding assumed leakage rate from NSAL-14-1 that is deemed applicable.

Safety Time to reflux cooling - Please clarify whether the intended During the July 2014 Evaluation timeline for aligning the FLEX RCS makeup pump may be NRC Onsite Audit, the Review delayed based on procedural guidance that derives from the NRC Staff indicated Item #3 analysis in WCAP-17792-P, pages 3-10 through 3-16. that further review of Although the staff recognizes that plant operators require this item was not leeway to control pumps and equipment in response to anticipated as DNC plant indications and other symptoms, the staff considers it proceeds towards prudent that equipment alignments proceed as outlined in compliance for Orders the integrated plan to the extent possible. Therefore, EA-12-049 and EA provide justification if the operators would delay the 051.

(References 21 and 26) alignment of the FLEX RCS makeup pump(s) beyond the time specified in the integrated plan based on initial indications that the reactor coolant pump seal leakage is lower than the value assumed in the ELAP analysis.

Safety Human factors questions addressed during walkdowns of This SE Review Item is Evaluation plant equipment as well as in discussion with personnel. being addressed Review through the ongoing Item #4 NRC audit process.

(Reference 21)

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 r r Paae 19 of 28 Safety Please provide adequate basis that, when considering During the July 2014 Evaluation mixing time, there is sufficient flow capacity to support NRC Onsite Audit, the Review borated makeup to both units from a single RCS makeup NRC Staff indicated Item #5 pump taking suction from a portable batching tank. that further review of this item was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA 051.

(Reference 21)

Safety Please provide adequate basis that calculations performed This SE Review Item is Evaluation with the NOTRUMP code (e.g., those in WCAP-17601-P, being addressed Review WCAP-17792-P) are adequate to demonstrate that criteria through the ongoing Item #6 associated with the analysis of an ELAP event (e.g., NRC audit process.

avoidance of reflux cooling, promotion of boric acid mixing) are satisfied. NRC staff confirmatory analysis suggests that (Generic) the need for implementing certain mitigating strategies for (References 21 and 26) providing core cooling and adequate shutdown margin may occur sooner than predicted in NOTRUMP simulations.

Safety ECM Compliance. During the July 2014 Evaluation NRC Onsite Audit, the Review NRC Staff indicated Item #7 that further review of this item was not anticipated as DNC proceeds towards compliance for Orders EA-1 2-049 and EA-1 2-051. (Reference 21)

Safety Security Related Issues. This SE Review Item is Evaluation being addressed Review through the ongoing Item #8 NRC audit process.

(Reference 21) 7 Potential Safety Evaluation Impacts Section 6.5 provides a list of the additional Safety Evaluation (SE) Review items identified and evaluated during the MPS NRC Onsite Audit and the status of each item.

Additionally, DNC is participating in the ongoing industry effort to develop guidance for the Final Integrated Plan that will support NRC preparation of the Safety Evaluation documenting MPS3 compliance with Order EA-12-049. The format of the Final Integrated Plan is consistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davis memorandum (ML14161A643)(Reference 20).

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 20 of 28 8 Supplemental Information This supplemental information provides details of the changes identified in the status updates above and addresses the following topics: a) a revision to Milestone Task 'Develop Modifications,' b) a revision to Milestone Task 'Receive Equipment,' c) a revision to Milestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures,' d) a revision to Milestone Task 'Create Maintenance Procedures,' e) a revision to Open Item No. 1, and f) a revision to Open Item No. 19.

a. MPS3, Milestone Task 'Develop Modifications': The revision to the scheduled target completion date is needed to obtain final approval of the MPS3 communications upgrade modifications design change.

b. MPS3, Milestone Task 'Receive Equipment': The large majority of the purchased major equipment has been received onsite. However, delivery of the final items has been delayed and is not expected until September 2014. (See also revision to Open Item 19.)

c. MPS3, Milestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures': The revision to the scheduled milestone target completion date is needed to allow for completion of the walk-throughs which are in progress.

d. MPS3. Milestone Task 'Create Maintenance Procedures': The Milestone is to be restated as 'Develop Maintenance Strategies." This change is to revise the current milestone to reflect the intended activity which was to develop the maintenance strategies based on industry and vendor supplied information. As per the response provided above for Open Item 8, the restated task has been completed. The design change implementing the FLEX Mitigating Strategies Program identifies the maintenance strategies required for the FLEX implementation and requires that Periodic Maintenance (PM) procedures be developed. Submittal of requests for creation of these PMs is in accordance with the Design Control Program and will be tracked. The PMs will be prioritized such that the near-term requirements, (e.g., 30 day walkdown inspections) are in-place prior to FLEX Mitigating Strategy implementation date. The PMs for the longer term requirements will be implemented prior to their first performance interval.

e. MPS3. Open Item 1: The Open Item completion date is revised to September 2014.

This Open Item is associated with the validation effort which is targeted to be complete in September 2014.

f. MPS3, Open Item 19: The majority of the purchased major equipment has been received onsite. However, delivery of the final items has been delayed and is not expected until September 2014.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 21 of 28 9 References The following references support the updates to the OIP described in this attachment and are available in ADAMS or have been provided to the staff for their review.

1. DNC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-161B).

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

Revision 0, dated August 2012.

4. Supplement to Overall Integrated Plan in Response to March 21, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events (Order Number EA-12-049), dated April 30, 2013 (Serial No. 12-161C).

5. Calculation 2013-ENG-04501E3, "MP3 BDB Battery Calculation," Rev. 0 dated May 29, 2013.

6. Calculation 97-014, "MP3 AFW System, Determination of AFW Turbine/Pump Speed and AFW System. Flow for Steam Generator Pressures of 185 psig, 600 psig, and 125 psig, and Determination of the Turbine Exhaust Pressure," April 2, 1997 through Change Notice No. 3 dated January 28, 2002.

7. Engineering Technical Evaluation ETE-MP-2013-1037, "MP3 Turbine Driven Aux Feedwater Pump Minimum Continuous Operating Speed," dated March 12, 2013.

8. Calculation 13-015, "MP2 & MP3 FLEX Strategy Hydraulic Calculations," Rev. 0.

9. ETE-CPR-2013-0003, "Beyond Design Basis Communications Strategy/Plan," Rev. 1.

10. Calculation 13-015, "MP2 & MP3 FLEX Strategy Hydraulic Calculations" Rev. 2.

11. Calculation 2013-ENG-04503E3, "Millstone Power Station Unit 3 Beyond Design Basis

- FLEX Electrical 4160V, 4840V and 120VAC System Loading Analysis," Rev. 0.

12. URS Geotechnical Investigation and Engineering Report, "FLEX Storage Building Project, Millstone Power Station, Waterford, Connecticut," dated January 27, 2014.

13.Design Change MPG-13-00010, 'BDB Storage Building/Millstone Power Station/Units 2&3."

14. DNC's 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 23, 2013 (Serial No. 12-161D).

Serial No. 14-393A Docket No. 50-423 Order EA-1 2-049 Attachment 1 Page 22 of 28 15."Millstone Power Station, Units 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies)," dated January 31, 2014.

16.DNC's 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 28, 2014 (Serial No. 12-161F).

17. ETE-CPR-1 2-0008, Rev. 3 "Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document."

18. DNC Letter to NRC, "Millstone Power Station Unit 3 - Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events Dated March 12, 2012 - Relaxation Request," dated May 16, 2014, Serial No.14-251.

19. NRC Letter to DNC, "Millstone Power Station, Unit 3 - Relaxation of Schedule Requirements for Order EA-12-049 'Issuance of Order to modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events',"

dated July 3, 2014.

20. Memorandum from Jack R. Davis, JLD, Office of NRR, to Stewart N. Bailey, Sheena A, Whaley, and Jeremy S. Bowen, "Supplemental Staff Guidance for the Safety Evaluations for Order EA-12-049 on Mitigation Strategies for Beyond-Design-Basis External Events and Order EA-12-051 on Spent Fuel Pool Instrumentation," dated July 1, 2014 (ML14161A643).

21. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate to All Operating Reactor Licensees and Holders of Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigating Strategies Order EA-12-049,"

dated August 28, 2013 (ML13234A503).

22.Procedure CM-AA-BDB-102, "Beyond Design Basis FLEX Equipment Unavailability Tracking."

23. Procedure CM-AA-BDB-10, "Beyond Design Basis FLEX Program."

24. FSG-7, "Loss of Vital Instrumentation or Control Power."

25. Procedure ECA-0.0, "Station Blackout."

26. ETE-CPR-2012-0150, Rev. 1, Add. 0, "Core Cooling Evaluation for Dominion Fleet and Prepared Input for Response to Order EA-12-049."

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 23 of 28 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential I Flexibility) Diverse Uses Performance Maintenance Criteria Maintenance/

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements BDB High Capacity Will follow EPRI diesel-driven pump (2) X X X 1200 gpm @ template and assoc. hoses and 150 psid templte fittings requirements BDB AFW pump (3) and Will follow EPRI assoc. hoses and X 300 gpm @ template fittings 500 psid requirements BDB RCS Injection Will follow EPRI pump (2) and assoc. 45 gpm @

hoses and fittings X 3000 psid template requirements 120/240VAC generators Will follow EPRI (3) and associated x 23.3kW template cables, connectors and requirements switchgear

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-12-649 Attachment 1 Page 24 of 28 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance Maintenance!

List Portable LqistPortalen Core Containment SFP

- -Preventive Instrumentation Accessibility Mainte Equipment Maintenance Requirements 120/240VAC generators (8)2 and associated Will follow EPRI cables, connectors and X 5-6.5 kW template switchgear (to power requirements support equipment) 480VAC generators (3) and associated cables, connectors and Will follow EPRI switchgear (to re-power X X X 500 kW template requirements battery chargers, inverters, and Vital Buses)

Portable boric acid Will follow EPRI batching tank (2) 1000 gal template requirements Light plants (2) X Will follow EPRI template requirements

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-1 2-049 Attachment 1 Page 25 of 28 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential I Flexibility) Diverse Uses Performance Maintenance Criteria Maintenance!

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Front end loader (1)2 X Will follow EPRI template requirements Tow vehicles (2) 2 X X X X Will followrequirements template EPRI Hose trailer (2) and Will follow EPRI Utility vehicle (1)2 X X X X template requirements Fans / blowers (10)2 X Will followrequirements template EPRI Air compressors (6) 2 X X Will follow EPRI template requirements Fuel truck (1) with 1,100 X X X X X Will follow EPRI gal. tank and pumps template requirements Fuel carts with transfer Will follow EPRI pumps (2) 2 X X X X X template requirements Communications Will follow EPRI equipment 3 X X X X X template requirements

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Paae 26 of 28 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential I Flexibility) Diverse Uses Performance CriteriaManenc Maintenance!

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Misc. debris removal Will follow EPRI equipment 2 X template requirements Misc. Support Will follow EPRI Equipment 2 X template requirements NOTES:

1. This table is based on one BDB Storage Building containing equipment for both MPS2 and MPS3.

2. Support equipment. Not required to meet N+1.

3. Quantities are identified in ETE-CPR-2013-0003 that was developed in response to the results of the communications study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 27 of 28 Table 2 - PWR Portable Equipment Phase 3 Use and (Potential / Flexibility) Diverse Uses Performance Criteria Maintenance Notes List Portable Quantity Quantity Power Core Cont. Access Instrumentation RCS Preventative Equipment Req'd Provided Cooling Cooling/ Inventory Maintenance

/Unit / Unit Integrity Required Medium Jet Performed by Voltage 2 2 X X X 4.16 KV 1 MW (1)

Generators Turb. NSRC Low Voltage 1 X X X 480VAC 1100 KW Performed by (2)

Generators Turb. NSC2NSRC High Pressure 0 1 Diesel X 3000# 60 GPM Performed by (2)

Injection NSRC Pump S/G RPV Makeup 0 1 Diesel X X 500# 500 GPM Performed by (2)

Pump .NSRC Low Pressure /. :Promdb eu 0 1 Diesel X 300# 2500 GPM Performed by (2)

Medium NSRC Flow Pump Low Pressure/ 150# 5000 GPM Performed by High Flow Diesel X X 500 GPM NSRC (3)

Pump _ _ _ *_"_"___ __._._._.._

Lighting 0 Performed by Towers Diesel 40,000.Lu.NSRC (4)

Serial No. 14-393A Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 1 Page 28 of 28 Table 2 - PWR Portable Equipment Phase 3 Use and (Potential i Flexibility) Diverse Uses Performance Criteria Maintenance Notes List Portable Quantity Quantity Power Core Cont. Access Instrumentation RCS Preventative Equipment Req'd Provided Cooling Cooling/ Inventory Maintenance

/Unit I Unit Integrity Required Diesel Fuel 0 AR N/A X X X X X 500 Gal Performed by (2)

Transfer NSRC Mobile MobilePerform edby Water 0 2 Diesel X <" ..... 4NSRC* X . 150 GPM NerC (2) (5)

Treatment Mobile db Boration 0 1 N/A X 1000 Gal Performey (2)

Skid NSRC Note 1 - NSRC 4KV generator supplied in support of Phase 3 for Core Cooling, Containment Cooling, and Instrumentation FLEX Strategies. (Includes a distribution panel and sufficient cables for connection to site 4kV buses.)

Note 2 - NSRC Generic Equipment - Not required for FLEX Strategy - Provided as Defense-in-Depth.

Note 3 - NSRC Low Pressure / High Flow pump supplied in support of Phase 3 for Core Cooling and Containment Cooling FLEX Strategies.

Note 4 - NSRC components provided for low light response plans.

Note 5 - Usage dependent on Westinghouse Water Quality Study results.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 2 Attachment 2 Overall Integrated Plan - Section F5 Safety Function Support (Ventilation)

I Millstone Power Station Unit 3 Dominion Nuclear Connecticut, Inc. (DNC)

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Attachment 2 Page 1 of 7 F5 - Safety Functions Support (Ventilation)

Determine Baseline coping capability with installed coping 1 modifications not including FLEX modifications.

F5.1 - PWR Installed Equipment Phase I Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions.

Identify methods and strategy(ies) utilized to achieve coping times.

The FLEX strategies for maintenance and/or support of safety functions involve several elements. One element is to ensure that ventilation, heating, and cooling are adequate to maintain acceptable environmental conditions for equipment operation and personnel habitability. Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution under the adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expected following a BDB External Event (BDBEE) resulting in an Extended Loss of AC Power/Loss of Ultimate Heat Sink (ELAP/LUHS). The primary concern with regard to ventilation is the heat buildup which occurs with the loss of forced ventilation in areas that continue to have heat loads.

The key areas identified for all phases of implementation of the FLEX Mitigating Strategy activities are the Main Control Room (MCR), TDAFW Pump Room, Main Steam Valve Building (MSVB), (location of the Atmospheric Dump Valves, ADVs), East & West DC Switchgear (SWGR) Rooms, and the East Motor Control Center (MCC) Rod Drive Room.

These areas have been evaluated to determine the temperature profiles following an ELAP/LUHS event. Results of the evaluations have concluded that for the identified areas, some actions are needed (either short term or long term actions) in order for temperatures to remain within acceptable limits following a BDBEE. The evaluations are based on conservative input heat load assumptions for all areas and with preemptive actions being taken, only when necessary, to reduce heat load or to establish either active or passive ventilation (e.g., portable fans, open doors, etc.)

The Phase 1 actions for ventilation are actions involving existing plant structures, primarily doors, and constitute the short term actions required. The Phase 1/short term actions for the MCR are those required by existing procedures for SBO and require certain instrument cabinets to be opened within 30 minutes. However, for an ELAP, additional cabinets will be opened since the SBO evaluation assumed these additional 1 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Attachment 2 Page 2 of 7 cabinets would receive power for cooling at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the event. This is not the case for an ELAP. The Phase 1 actions for the TDAFW Pump Room, the MSVB, the DC SWGR Rooms (which include the station battery rooms), and the East MCC Rod Drive Room are to open various designated doors within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, respectively.

Details:

F5.1.1 - Provide a brief Confirm that procedure/guidanceexists or will be developed to description of support implementation.

Procedures I Strategies I Guidelines The Unit 3 Loss of AC Power (EOP 35, ECA-0.0) directs actions to be taken within the MCR. FSG-4 will direct the action to open instrument cabinet doors in addition to those required by ECA-0.0 The FLEX Strategy Guideline FSG-5 will include the actions to open the various designated doors to allow for natural circulation of air where necessary. These actions alone will ensure that the temperatures in the affected rooms remain acceptable.

No other actions are required to maintain equipment operation or personnel habitability following an ELAP/LUHS event in Phase 1.

F5.1.2 - Identify List modifications and describe how they support coping time.

modifications No ventilation related modifications are required for any phase of the ELAP/LUHS response.

F5.1.3 - Key List instrumentationcredited for this coping evaluation phase.

Parameters No key ventilation parameters have been identified as required to maintain acceptable equipment and personnel environments for any phase of the ELAP/LUHS response.

Notes:

The information provided in this section is based on the following reference(s):

- Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document, ETE-CPR-2012-0008, Rev. 3.

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Attachment 2 Page 3 of 7 FS - Safety Functions Support (Ventilation)

F5.2 - PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy(ies)utilized to achieve coping times.

Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution under the adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expected following a BDBEE resulting in an ELAP/LUHS. The ventilation related actions that are taken in Phase 1 are expected to dissipate the minimal heat loads from the DC battery sources and residual heat loads in the de-energized equipment. However, Phase 2 introduces additional loads when the BDB 480 VAC diesel generator is placed into service.

Evaluations have demonstrated that no additional actions, other than the doors opened in Phase 1, are necessary to maintain acceptable temperatures in the areas required to implement the Phase 2 FLEX Strategies.

An additional concern is related to the Unit 3 battery rooms. Once the BDB 480 VAC diesel generators are available, charging of the station Class 1E batteries will begin. In order to prevent a buildup of hydrogen in the battery rooms, the battery room exhaust fans (supplied by the 480 VAC diesel Generators) will be energized. In addition, the open doors to the battery rooms are to be closed to ensure the effectiveness of the exhaust fans.

Details:

F5.2.1 - Provide a brief Confirm that procedure/guidanceexists or will be developed to description of support implementation with a description of the procedure/

Procedures I Strategies strategy/guideline.

I Guidelines The FLEX Strategy Guideline, FSG-4, will include the actions to repower the battery room exhaust fans and to close the designated battery room doors.

F5.2.2 - Identify List modifications necessary for phase 2 modifications No ventilation related modifications are required for any phase of the ELAP/LUHS response.

F5.2.3 - Key Parameters List instrumentationcredited or recovered for this coping evaluation.

No key ventilation parameters have been identified as required to maintain acceptable equipment and personnel environments

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F5.2 - PWR Portable Equipment Phase 2 for any phase of the ELAP/LUHS response.

F5.2.4 - Storage I Protection of Equipment:

Describe storaqe I protection plan or schedule to determine storaae reauirements Seismic List how equipment is protected or schedule to protect No Phase 2 BDB equipment is required.

Flooding List how equipment is protected or schedule to protect No Phase 2 BDB equipment is required.

Severe Storms with High List how equipment is protected or schedule to protect Winds No Phase 2 BDB equipment is required.

Snow, Ice, and Extreme List how equipment is protected or schedule to protect Cold No Phase 2 BDB equipment is required.

High Temperatures List how equipment is protected or schedule to protect No Phase 2 BDB equipment is required.

F5.2.5 - Deployment Conceptual Design Strategy Modifications Protection of connections

a. Identify Strategy including Identify modifications Identify how the connection how the equipment will be is protected deployed to the point of use.

There is no deployment of No ventilation related No ventilation related supplemental ventilation modifications are needed to connections are needed to equipment in the support the implementation support the implementation ELAP/LUHS coping of the ELAP/LUHS coping of the ELAP/LUHS coping strategies. Where strategies. strategies.

necessary, ventilation is provided by the strategy utilizing existing plant equipment that is repowered

Serial No. 14-393A Docket Nos. 50-423 Order EA-12-049 Attachment 2 Page 5 of 7 F5 - Safety Functions Support (Ventilation)

F5.2 - PWR Portable Equipment Phase 2 by the 480 VAC DG.

Although no additional compensatory cooling measures, other than those identified above, are expected to be necessary, for defense in depth, the operating staff will periodically monitor area temperatures to insure habitability and equipment survivability conditions are acceptable. Additional natural convection flow paths or portable ventilation fans and/or stand alone AC units may be utilized if the area temperature measurements indicate unacceptable increasing trends.

Notes:

The information provided in this section is based on the following reference(s):

- Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document, ETE-CPR-2012-0008, Rev. 3.

Serial No. 14-393A Docket No. 50-423 Order EA-12-049 Attachment 2 Page 6 of 7 F5 - Safety Functions Support (Ventilation)

F5.3 - PWR Portable Equipment Phase 3 Provide a general descriptionof the coping strategiesusing phase 3 equipment including modifications that are proposed to maintain and/orsupport safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution under the adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expected following a BDBEE resulting in an ELAP/LUHS. Any additional heat loads added as a result of Phase 3 repowering efforts utilizing the 4kV generator from the NSRC are addressed by the existing ventilation systems repowered by either the BDB 480 VAC diesel generator or the 4kV generator received from the NSRC. Therefore, no Phase 3 actions are required to maintain equipment operation or personnel habitability.

Details:

F5.3.1 - Provide a brief Confirm that procedure/guidanceexists or will be developed to description of supportimplementation with a description of the procedure/

Procedures I Strategies strategy/guideline.

I Guidelines No procedures/strategies are required to maintain any Phase 3 equipment operation or personnel habitability following an ELAP/LUHS event.

F5.3.2 - Identify List modifications necessary for phase 3 modifications No ventilation related modifications are required for any phase of the ELAP/LUHS response.

F5.3.3 - Key Parameters List instrumentationcredited or recovered for this coping evaluation.

No key ventilation parameters have been identified as required to maintain acceptable equipment and personnel environments for any phase of the ELAP/LUHS response.

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F5.3 - PWR Portable Equipment Phase 3 F5.3.4 - Deployment Conceptual Design Strategy Modifications Protection of connections

a. Identify Strategy including Identify modifications Identify how the connection how the equipment will be is protected deployed to the point of use.

There is no required No ventilation related No ventilation related deployment of supplemental modifications are needed to connections are needed to ventilation equipment in the support the implementation support the implementation ELAP/LUHS coping of the ELAP/LUHS coping of the ELAP/LUHS coping strategies for Phase 3. strategies. strategies.

Although no additional cooling measures are necessary, the operating staff will periodically monitor area temperatures to insure habitability and equipment survivability conditions are acceptable. Additional natural convection flow paths or portable ventilation fans and/or stand alone AC units may be utilized if the area temperature measurements indicate unacceptable increasing trends.

Notes:

The information provided in this section is based on the following reference(s):

- Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document, ETE-CPR-2012-0008, Rev. 3.