ML14251A024

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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)
ML14251A024
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/28/2014
From: Mark D. Sartain
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
14-394, EA-12-049
Download: ML14251A024 (35)
v • d • e


Text

A VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 28, 2014 10 CFR 2.202 EA-12-049 Attention: Document Control Desk Serial No.: 14-394 U.S. Nuclear Regulatory Commission NL&OS/MAE: RO Washington, D.C. 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 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-12-0491

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. Virginia Electric and Power Company'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. 12-162B)
3. Virginia Electric and Power Company'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 27, 2014 (Serial No. 12-162E)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 was immediately effective and directed Dominion 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.

The attachment to this letter provides the third six-month status report and an update of milestone accomplishments since the submittal of the prior six-month status report

Serial No.14-394 Docket Nos. 50-338/339 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.

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

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering Attachment (1)

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 Virginia Electric and Power Company. 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.

-77 Acknowledged before me this 2'-e'Uay Of 2014.

My Commission Expires: - I - 1' *

(SEAL) '-.....VickiL- 11,1 .. Notary Public NOTARY PUBLIC Commonwealth of Virginia Reg.

  • 140542 My Commissio Expires May 31, 2018

Serial No.14-394 Docket Nos. 50-338/339 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 13 H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. K. R. Cotton NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.

Glen Allen, Virginia 23060

Serial No.14-394 Docket Nos. 50-338/339 Order EA-1 2-049 Attachment 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 North Anna Power Station Units I and 2 Virginia Electric and Power Company (Dominion)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-1 2-049 Page 1 of 31 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 I Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverse and flexible strategies (FLEX) for North Anna Power Station (NAPS) in response to NRC Order Number EA-12-049 (Reference 2). This attachment provides an update of milestone accomplishments and open items since submittal of the last status report (Reference 13),

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 Modifications
  • Develop Training Plan

" Purchase Equipment

" Receive Equipment

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

The revised milestone and associated target completion dates for 'Implement Modifications' do not impact the Order implementation dates for North Anna Units 1 and 2, but accurately reflect that the Unit 2 modifications will be implemented at the end of the upcoming refueling outage.

Target Activity Revised Target Milestone Completion Date Status Completion Date Submit Integrated Plan February 2013 Complete Develop Strategies October 2013 Complete Develop Modifications July 2014 Complete

Serial No.14-394 Docket Nos. 50-338/339 Order EA-1 2-049 Page 2 of 31 Target Activity Revised Target Milestone Completion Status Completion Date Date Implement Modifications* April 2015* Started Develop Training Plan April 2014 Complete Implement Training September 2014 Started Issue FLEX Support Guidelines and September 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 Complete Validation Walk-throughs or Demonstrations of FLEX Strategies August 2014 Started September 2014*

and Procedures Create Maintenance Procedures* August 2014 Complete Unit 1 Outage Implementation April 2015 Started Unit 2 Outage Implementation October 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, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at NAPS Units 1 and 2 as required by Order Number EA-12-049, dated March 12, 2012. The first and second Six-Month Status Report of the OIP for NAPS were provided by letters dated August 23, 2013 (Reference 11) and February 28, 2014 (Reference 13), respectively. The following are changes to the compliance method information provided in the NAPS OIP and subsequent updates, which continues to meet NEI 12-06 (Reference 3):

a) Dominion no longer plans to pre-stage the 120/240 VAC DGs in the Unit 1 and Unit 2 alleyways. The deployment strategy for the portable 120/240VAC diesel generators (DGs) used to re-power the vital bus circuits has been changed back to the original electrical re-powering strategy, described in Section F1.2 - PWR Portable Equipment Phase 2 of the OIP submitted on February 28, 2013 (Reference 1) with the exception that the DGs are sized for a single generator per unit.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 3 of 31 b) 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 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 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.

c) 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 Nuclear Steam Supply System (NSSS) was revised.

d) Dominion 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, which 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. Dominion 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 for each hose size 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. Therefore, once NRC endorsement of this alternate approach is complete, Dominion will have achieved alternate compliance with the NEI 12-06 N+1 requirement for hoses.

e) 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 7 days.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 4 of 31 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.

f) 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' and 'Performance Criteria' are included as well as associated changes/deletions in footnotes. 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 RelieflRelaxation Dominion expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items The NRC has established an audit process to allow the exchange of information between the licensees and the NRC Staff (Reference 19). Between May 19, 2014 and May 22, 2014, North Anna Units 1 and 2 were the subject of an NRC onsite audit where the site specific aspects of Dominion'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 Dominion 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.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 5 of 31 6.1. Open Items from Overall Integrated Plan The following table provides a summary of the status of Open Items (01) identified by Dominion and documented in Attachment 2B of the NAPS Overall Integrated Plan submitted February 28, 2013 and the status of each item.

Overall Integrated Plan Open Items 01 # Description Status Verify response times listed in timeline and perform staffing Complete.

assessment. (Reference 20)

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

Preliminary analyses have been performed to determine the time Complete.

to steam generator overfill without operator action to reduce AFW 2 flow, time to steam generator dryout without AFW flow, and time (Reference 4) to depletion of the useable volume of the ECST. The final durations will be provided when the analyses are completed.

Preliminary analyses have been performed to determine the Complete.

Class 1 E battery life based on implementation of load stripping (Reference 4) actions. The final battery life duration will be provided when the analyses are completed. During the May 2014 NRC Onsite Audit, the NRC Staff indicated that 3 further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 6 of 31 Overall Integrated Plan Open Items 01 # Description Status The Phase 3 coping strategy to maintain Containment integrity is Complete.

under development. Methods to monitor and evaluate (Reference 13)

Containment conditions and depressurize/cool Containment, if necessary, will be provided in a future update. During the May 2014 NRC Onsite Audit, the NRC Staff indicated that 4 further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

Analyses will be performed to develop fluid components Complete.

performance requirements and confirm fluid hydraulic-related strategy objectives can be met. Hydraulic calculations for the FLEX pumps deployed using their associated hose networks have confirmed that the core cooling/decay heat removal, RCS inventory, and reactivity control (RCS Injection), and SFP make-up strategies can 5 be satisfactorily accomplished in response to an ELAP/Loss of Ultimate Heat Sink (LUHS) event.

(References 6 and 7)

Hydraulic calculations have confirmed that the SW flows for Containment cooling options are adequate.

(Reference 14).

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 7 of 31 Overall Integrated Plan Open Items OI # [Description jStatus A study is in progress to determine the design features, site Complete.

location(s), and number of equipment storage facilities. The final design for BDB equipment storage will be based on the guidance A single 10,000 sq. ft.

contained in NEI 12-06, Section 11.3, Equipment Storage. A Type 1 building is being supplement to this submittal will be provided with the results of constructed at NAPS for the equipment storage study. storage of BDB equipment. The building is designed to meet the plant's design basis for the Safe Shutdown Earthquake, high wind hazards, snow, ice and cold conditions, and will be located above the flood elevation from the most recent site flooding analysis. The BDB Storage Building will be 6 sited in the Owner Controlled Area in the parking lot west of Warehouse #5. This update provides the supplemental information referred to in this open item. (Reference 21)

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

FLEX Support Guidelines (FSGs) will be developed in Started.

accordance with PWROG guidance. Existing procedures will be revised as necessary to implement FSGs. Scheduled completion I_ date: September 2014

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 8 of 31 Overall Integrated Plan Open Items 01 # I Description Status EPRI guidance documents will be used to develop periodic Complete.

testing and preventative maintenance procedures for BDB (Reference 22) equipment. Procedures will be developed to manage unavailability of equipment such that risk to mitigating strategy EPRI guidance capability is minimized. documents have been used, where available, to develop the testing and preventative maintenance strategies for the sites.

Fleet-wide templates have been developed and input into the individual site maintenance strategies. Specific Periodic Maintenance (PM) procedures based on these strategies will be implemented prior to the 8 required North Anna 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.

An overall program document will be developed to maintain the Complete.

FLEX strategies and their bases and provide configuration control (Reference 23) and change management for the FLEX Program.

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that 9 further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 9 of 31 Overall Integrated Plan Open Items OI # Description Status EA-1 2-051.

The Dominion Nuclear Training Program will be revised to assure Complete.

personnel proficiency in the mitigation of BDB events is developed and maintained. These programs and controls will be Documentation of the Job 10 developed and implemented in accordance with the Systematic Analysis performed for Approach to Training (SAT). new operational tasks has been provided via the ongoing NRC audit process. (Reference 19)

Complete the evaluation of TDAFW pump long term operation Complete.

with < 290 psig inlet steam pressure.

TDAFW pump operation 11 and adequate AFW flow to the SGs at SG pressures < 290 psig has been confirmed.

(Reference 5)

Plant modifications will be completed for permanent plant Started.

changes required for implementation of FLEX strategies.

12 Scheduled completion date: See Milestone Schedule above.

Details of the ventilation strategy are under development and will Complete.

13 conform to the guidance given in NEI 12-06. The details of this strategy will be provided at a later date. (Reference 13)

Complete installation of N-9000 RCP seals in 2 of 3 RCPs in Started.

each unit.

14 Scheduled completion date:

April 2015 (Unit 1)

Oct 2014 (Unit 2)

Analyses will be performed to develop electrical components Complete.

performance requirements and confirm electrical loading-related strategy objectives can be met. Final calculations confirming the sizing and loading analysis of the 120VAC, 480VAC, and 4KV generators confirm 15 the electrical loading-related strategy objectives can be met are complete (References 16, 17, & 18).

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 10 of 31 Overall Integrated Plan Open Items 01 # Description Status further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

An evaluation of all BDB equipment fuel consumption and Complete.

required re-fill strategies will be developed. (Reference 21)

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that 16 further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

A lighting study will be performed to validate the adequacy of Complete.

supplemental lighting and the adequacy and practicality of using (Reference 21) portable lighting to perform FLEX strategy actions.

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that 17 further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

A comprehensive study of communication capabilities is being Complete.

performed in accordance with the commitments made in Dominion letter S/N 12-207F dated October 29, 2012 in response A study documenting the to Recommendation 9.3 of the 10 CFR 50.54(f) letter dated communications strategy March 12, 2012. The results of this study will identify the has been completed.

communication means available or needed to implement The plan concludes that command and control of the FLEX strategies at NAPS. FLEX strategies can be 18 Validation of communications required to implement FLEX effectively implemented strategies will be performed as part of Open Item No. 1. with a combination of sound powered phones, satellite phones and hand-held radios.

(Reference 10)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 11 of 31 Overall Integrated Plan Open Items 01 # Description Status During the May 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and

+

EA-1 2-051.

Preferred travel pathways will be determined using the guidance Complete.

contained in NEI 12-06. The pathways will attempt to avoid areas with trees, power lines, and other potential obstructions The soil liquefaction study and will consider the potential for soil liquefaction. has been completed (Reference 8), which supports the location of the storage building and the haul routes. The results will be included with the final design package for the storage 19 building (Reference 9).

During the May 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-1 2-051.

The equipment listed in Table 1 will be received on site. Complete.

20 6.2. Open Items from the Interim Staff Evaluation (ISE)

The following table provides a summary of the Open Items (01) from the NAPS Interim Staff Evaluation (Reference 12) and the current status of each item.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 12 of 31 Interim Staff Evaluation Open Items 01 # Description Status 3.2.1.2.B Demonstration of the acceptability of the use the Flowserve This ISE 01 is being N-9000 seals with the abeyance feature and validation of an addressed through the acceptable leakage rate for these seals. ongoing NRC audit process. (Generic)

(Reference 19) 3.2.1.8.A The Pressurized-Water Reactor Owners Group (PWROG) During the May 2014 submitted to NRC a position paper, dated August 15, 2013 NRC Onsite Audit, the (ADAMS Accession No. ML13235A135 (non-public for NRC Staff indicated proprietary reasons)), which provides test data regarding that further review of boric acid mixing under single-phase natural circulation this item was not conditions and outlined applicability conditions intended to anticipated as ensure that boric acid addition and mixing would occur under Dominion proceeds conditions similar to those for which boric acid mixing data is towards compliance available. During the audit process, the licensee informed the for Orders EA-12-049 NRC staff that its boric acid mixing model is based on the and EA-12-051.

PWROG method. Since the audit discussions, the NRC (References 19 and 21) endorsed the PWROG guidance with several clarifications in letter dated January 8, 2014. The licensee should address the clarifications in alignment with the NRC endorsement letter for the development of an adequate model for determining the mixing of boric acid in the reactor coolant system during natural circulation with the potential for two-

_ phase

_ flow conditions.

6.3. Confirmatory Items from Interim Staff Evaluation (ISE)

The following table provides a summary of the Confirmatory Items (CI) from the NAPS Interim Staff Evaluation (Reference 12) and the current status of each item.

Interim Staff Evaluation Confirmatory Items CI # Description Status 3.1.1. 1.A Storage & Protection of FLEX equipment - Confirm final During the May 2014 design of FLEX storage structure conforms to NEI 12-06, NRC Onsite Audit, the Sections 5.3.1, 6.2.3.1, 7.3.1, and 8.3.1 for storage NRC Staff indicated considerations for the hazards applicable to North Anna. that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 21)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 13 of 31 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.1.3.A Procedural Interface Considerations (Seismic) - Confirm FLEX During the May 2014 support guideline to provide operators with direction on how to NRC Onsite Audit, the establish alternate monitoring and control capabilities. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 24) 3.1.1.4.A Off-Site Resources - Confirm RRC local staging area, This ISE Cl is being evaluation of access routes, and method of transportation to addressed through the the site. ongoing NRC audit process. (Reference 19) 3.1.5.2.A In the Integrated Plan, the licensee did not address During the May 2014 considerations for any manual actions required by plant NRC Onsite Audit, the personnel in high temperature conditions as recommended in NRC Staff indicated NEI 12-06, Section 9.3.2. Discuss effects of high that further review of temperatures on any manual action performed by plant this item was not personnel and any applicable contingencies and any related anticipated as procedural changes or enhancements. Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 21) 3.2.1.1 .A Confirm that the use of NOTRUMP code for the ELAP analysis This ISE Cl is being of North Anna is limited to the flow conditions before reflux addressed through the condensation initiates, including specification of an acceptable ongoing NRC audit definition for reflux condensation cooling, process.

(Generic)

(Reference 21) 3.2.1.1.B Confirmation that the generic analysis in Section 5.2.1 of This ISE Cl is being WCAP-17601-P is applicable or bounding with respect to addressed through the North Anna for an appropriate figure of merit for defining entry ongoing NRC audit into the reflux condensation cooling mode. process.

I__ (References 19 and 29)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 14 of 31 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.1.1.C Confirm the consistency of the margin imposed to prevent During the May 2014 accumulator nitrogen injection with the cooldown terminus NRC Onsite Audit, the assumed in WCAP-1 7601-P. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 25) 3.2.1.2.C Confirm that stresses resulting from a cooldown of the RCS During the May 2014 will not result in the failure of seal materials. NRC Onsite Audit, the As applicable, confirm that reestablishing cooling to the seals NRC Staff indicated will not result in increased leakage due to thermal shock. that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(References 25 and 26) 3.2.1.6.A Sequence of Events - Confirm that the final timeline has been This ISE Cl is being time validated after detailed designs are completed and addressed through the procedures are developed. The results will be provided in a ongoing NRC audit future 6-month update. process.

(Reference 19) 3.2.1.8.B Complete calculations demonstrating adequate shutdown During the May 2014 margin for North Anna in ELAP scenarios with and without NRC Onsite Audit, the seal leakage. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 21)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 15 of 31 Interim Staff Evaluation Confirmatory 'Items CI # Description Status 3.2.1.8.C Confirm that shutdown margin calculations will be verified to During the May 2014 remain bounding for future operating cycles and clarify the NRC Onsite Audit, the method that will be used to make this determination. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 19) 3.2.1.9.A Confirm that the licensee provides sufficient BDB RCS During the May 2014 Injections Pumps to conform to the spare capability (N+1) NRC Onsite Audit, the guidance of NEI 12-06, Section 3.2.2. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 21) 3.2.1.9.B Confirm that calculations documenting the AFW supply, SFP During the May 2014 makeup, and RCS inventory hydraulic analysis demonstrate NRC Onsite Audit, the the pumps have adequate capacity for the strategies they NRC Staff indicated support. that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(References 6, 7, and 14) 3.2.2.A SFP venting - Confirm that opening of the roll-up doors would This ISE Cl is being provide an adequate ventilation path for the SFP area. addressed through the ongoing NRC audit process. (Reference 19)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 16 of 31 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.3.A Containment - Confirm Containment analysis to determine During the May 2014 any Containment temperature and pressure actions beyond NRC Onsite Audit, the seven days. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(References 13 and 21) 3.2.4.2.A Ventilation - Equipment Cooling - Confirm development of the This ISE Cl is being ventilation strategy. addressed through the ongoing NRC audit process. (References 13, 19, and 21) 3.2.4.2.B Confirm the adequacy of the battery room ventilation provided During the May 2014 in the context of an ELAP. NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 21) 3.2.4.4.A Verify the lighting study validates the adequacy of During the May 2014 supplemental lighting and the adequacy and practicality of NRC Onsite Audit, the using portable lighting to perform FLEX strategy actions. NRC Staff indicated that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 21) 3.2.4.4.B Communications - Confirm the licensee's proposed This ISE CI is being enhancements and interim measures to the site's addressed through the communications systems and that they have been ongoing NRC audit completed. process.

I_ (References 10 and 19)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 17 of 31 Interim Staff Evaluation Confirmatory Items CI # Description Status 3.2.4.8.A Electrical Power Sources - Confirm load calculations for the This ISE Cl is being phase 2 and 3 FLEX generators will support supplied loads, addressed through the ongoing NRC audit process.

(References 16, 17, 18, and 19) 3.2.4.9.A Fuel Supplies - Confirm the adequacy of the fuel consumption During the May 2014 evaluation. Confirm that the procedural guidance governing NRC Onsite Audit, the re-fueling strategies addresses: (a) how the quality of the fuel NRC Staff indicated oil and gasoline supplies will be controlled in order to ensure that further review of proper diesel or gasoline-powered FLEX equipment operation, this item was not (b) available sources of gasoline and how those sources will anticipated as be protected to ensure availability following a BDB event, and Dominion proceeds (c) if the onsite fuel capacity provides an indefinite supply of towards compliance fuel or if the RRC is capable of providing an indefinite, ongoing for Orders EA-12-049 supply of fuel (both diesel and gasoline), and EA-12-051.

(Reference 21) 3.4.A Confirm the implementation of considerations 2 through 10 in This ISE CI is being NEI 12-06, Section 12.2. addressed through the ongoing NRC audit process.

(Reference 19) 6.4. Audit Question Reviewed During NAPS Onsite Audit Various NAPS Audit Questions (AQs) were evaluated during the NAPS NRC Onsite Audit. The following AQs were evaluated and remained "Open".

Audit Provide the direct current (dc) load profile with the required This AQ is being Question loads for the mitigating strategies to maintain core cooling, addressed through the

  1. 43 containment, and spent fuel pool cooling, ongoing NRC audit process.

(Reference 19)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 18 of 31 6.5. Additional Items Reviewed During NAPS Onsite Audit The following table provides a list of the additional Safety Evaluation (SE) Review items identified and evaluated during the NAPS NRC Onsite Audit and the status of each item.

Safety Feb 2014 Update Section 4a. Portable 120/240VAC DG will During the May 2014 Evaluation now be pre-staged. NRC Onsite Audit, the Review NRC Staff indicated Item #1 that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(See Section 4a.)

Safety SW reservoir and lake are credited as indefinite source of During the May 2014 Evaluation water. SW has a finite volume of water. Therefore, if the SW NRC Onsite Audit, the Review reservoir is used as a source for make-up flow, the SW NRC Staff indicated Item #2 reservoir will eventually need make-up water from the lake. that further review of The licensee is not clear in stating whether the dam forming this item was not the lake is seismically qualified or if a viable suction source anticipated as can be maintained at the lake following a loss of the dam. Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 27)

Safety 1. (RCS Venting) The generic analysis in WCAP-17601-P During the May 2014 Evaluation strictly addressed ELAP coping time without consideration of NRC Onsite Audit, the Review the actions directed by a site's mitigating strategies. WCAP- NRC Staff indicated Item #3 17792-P extends these analytical results through explicit that further review of consideration of mitigating strategies involving RCS makeup this item was not and boration. In support of the RCS makeup and boration anticipated as strategies proposed therein, a generic recommendation is Dominion proceeds made that PWRs vent the RCS while makeup is being towards compliance provided. Please provide the following information in regard to for Orders EA-12-049 this topic: a. Will the mitigating strategy include venting of the and EA-12-051.

RCS? b. If so, please provide the following information: i. The (References 21 and 28) vent path to be used and the means for its opening and closure. ii. The criteria for opening the vent path. iii. The criteria for closing the vent path. iv. Clarification as to whether the vent path could experience two-phase or single-phase liquid flow during an ELAP. If two-phase or liquid flow is a possibility, please clarify whether the vent path is designed to ensure isolation capability after relieving two-phase or liquid flow. If relief of two-phase or liquid flow is to be avoided, please discuss the availability of instrumentation or other means that would ensure that the vent path is isolated prior to

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 19 of 31 departing from single-phase steam flow. vi. If a pressurizer PORV is to be used for RCS venting, please clarify whether the associated block valve would be available (or the timeline by which it could be repowered) in the case that the PORV were to stick open. If applicable, please further explain why opening the pressurizer PORV is justified under ELAP conditions if the associated block valve would not be available.

vii. If a pressurizer PORV is to be used for RCS venting, please clarify whether FLEX RCS makeup pumps and FLEX steam generator makeup pumps will both be available prior to opening the PORV. If they will not both be available, please provide justification. c. If RCS venting will not be used, please provide the following information: i. The expected RCS temperature and pressure after the necessary quantity of borated makeup has been added to an unvented RCS. ii.

Adequate justification that the potential impacts of unvented makeup will not adversely affect the proposed mitigating strategy (e.g., FLEX pump discharge pressures will not be challenged, plant will not reach water solid condition, adequate boric acid can be injected, increased RCS leakage will not adversely affect the integrated plan timeline, etc.).

Safety 2. (Westinghouse Standard RCP Seals: NSAL-14-1) On This SE Review Item is Evaluation February 10, 2014, Westinghouse issued Nuclear Safety being addressed through Review Advisory Letter (NSAL)-14-1, which informed licensees of the ongoing NRC audit Item #4 plants with standard Westinghouse RCP seals that 21 gpm process.

may not be a conservative leakage rate for ELAP analysis. (Reference 19)

This value had been previously used in the ELAP analysis referenced by many Westinghouse PWRs, including the 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 and

  1. 1 seal faceplate material relative to the categories in NSAL-14-1 and identify the corresponding presumed leakage rate from NSAL-14-1 that is deemed applicable.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 20 of 31 Safety 4. (RVLIS Measurement Principle) Please clarify whether the During the May 2014 Evaluation reactor vessel level instrumentation system (RVLIS) indication NRC Onsite Audit, the Review provides a measure of collapsed level that can be used with NRC Staff indicated Item #5 Figures 3.3-1 through 3.3-3 of WCAP-17792-P. If the RVLIS that further review of system does not provide an indication of collapsed level, then this item was not please clarify how the required timing for RCS makeup will be anticipated as determined and provide justification. Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 21) 4 t Safety (Timeline to reflux cooling) Please clarify whether procedural During the May 2014 Evaluation guidance for the timing of providing makeup to the reactor NRC Onsite Audit, the Review coolant system is based on analysis in WCAP-17792-P, pages NRC Staff indicated Item #6 3-10 through 3-16. If so, please further provide adequate that further review of justification for basing the timing of primary makeup on the this item was not assumption that reactor coolant pump seal leakage rates that anticipated as are less than the maximum expected value under ELAP Dominion proceeds conditions will not increase. towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 21)

Safety Please provide adequate basis that calculations performed During the May 2014 Evaluation with the NOTRUMP code (e.g., those in WCAP-17601-P, NRC Onsite Audit, the Review WCAP-1 7792-P) are adequate to demonstrate that criteria NRC Staff indicated Item #7 associated with the analysis of an ELAP event (e.g., that further review of avoidance of reflux cooling, promotion of boric acid mixing) are this item was not satisfied. NRC staff confirmatory analysis suggests that the anticipated as need for implementing certain mitigating strategies for Dominion proceeds providing core cooling and adequate shutdown margin may towards compliance occur sooner than predicted in NOTRUMP simulations. for Orders EA-12-049 and EA-12-051.

(Reference 21)

Safety Please provide adequate basis that, when considering mixing This SE Review Item is Evaluation time, there is sufficient flow capacity to support borated being addressed through Review makeup to both units from a single RCS makeup pump taking the ongoing NRC audit Item #8 suction from a portable batching tank. process.

(Reference 19)

Safety Please provide a clearly labeled sketch or marked-up plant This SE Review Item is Evaluation drawing of the plan view of the SFP area, depicting the SFP being addressed through Review inside dimensions, the planned locations/placement of the the ongoing NRC audit Item #9 primary and back-up SFP level sensor, and the proposed process.

routing of the cables that will extend from these sensors (Reference 19) toward the location of the read-out/display device.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 21 of 31 Safety Human factors questions addressed during walkdowns of plant During the May 2014 Evaluation equipment as well as in discussion with personnel. NRC Onsite Audit, the Review NRC Staff indicated Item #10 that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-1 2-049 and EA-12-051.

(Reference 19)

Safety Unprotected water sources in Modes 5 & 6 This SE Review Item is Evaluation being addressed through Review the ongoing NRC audit Item #11 process.

(See Section 4b and References 19 and 21)

Safety Provide details on maintenance and testing and Storage of This SE Review Item is Evaluation 120v/480v pre-staged cables. being addressed through Review the ongoing NRC audit Item #12 process.

(Reference 19)

Safety Provide discussion on evaluation of diesel powered equipment This SE Review Item is Evaluation exhaust regarding habitability of other areas, being addressed through Review the ongoing NRC audit Item #13 process.

(Reference 19)

Safety When do we plan to deploy hoses in SFP prior to bulk boiling During the May 2014 Evaluation to minimize exposure. NRC Onsite Audit, the Review NRC Staff indicated Item #14 that further review of this item was not anticipated as Dominion proceeds towards compliance for Orders EA-12-049 and EA-12-051.

(Reference 21)

Safety Walk-through of building access procedures, to include any This SE Review Item is Evaluation unique access control devices being addressed through Review the ongoing NRC audit Item #15 process.

(Reference 19)

Serial No.14-394 Docket Nos. 50-338/339 Order EA-1 2-049 Page 22 of 31 7 Potential Safety Evaluation Impacts Section 6.5 provides a list of the additional Safety Evaluation (SE) Review items identified and evaluated during the NAPS NRC Onsite Audit and the status of each item.

Additionally, Dominion 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 NAPS's 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 15).

8 Supplemental Information This supplemental information provides details of the changes identified in the status updates above and addresses a) Open Item 14, b) the Milestone Task 'Implement Modifications,' c) the Milestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures' and d) the Milestone Task 'Create Maintenance Procedures' as follows:

a) NAPS, Open Item 14: The revision to the status wording more accurately reflects the status for each North Anna Unit. The split completion schedule reflects the current outage schedules.

b) NAPS, Milestone Task 'Implement Modifications': The revision separates Units 1 and 2 to more accurately reflect the actual tasks as they will occur for each NAPS Unit.

The updated completion schedules accurately reflect the current outage schedules.

The revised Milestone Tasks and Completion Schedules are as follows:

Milestone Task: Implement Unit 1 Modifications Completion Schedule: April 2015 Milestone Task: Implement Unit 2 Modifications Completion Schedule: October 2014 c) NAPS, Milestone Task 'Validation Walk-throuqhs 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) NAPS, 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

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 23 of 31 PMs for the longer term requirements will be implemented prior to their first performance interval.

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. "Virginia Electric and Power Company'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. 12-162B).
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. 12-162C).
5. Dominion Calculation ME-0968, "Evaluation of the TDAFW Pump Performance at Low Steam Generator Pressures," August 2013.
6. Dominion Calculation ME-0965, "Evaluate the BDB High Head Injection pump for Beyond Design Basis (BDB) at the primary and alternative supply locations in Modes 1-4, and the BDB AFW Pump in Modes 5 and 6," Revision 0.
7. Dominion Calculation ME-0966, "Beyond Design Basis (BDB) - BDB High Capacity Pump and BDB AFW Pump Hydraulic Analysis for Spent Fuel Pool Makeup and AFW Injection at NAPS Units 1 and 2," Revision 0.
8. Geotechnical Engineering Report, "BDB FLEX Storage Building," North Anna Power Station, Louisa, VA, Schnabel Reference #13613081, October 3, 2013, Addendum 1.
9. Design Change NA-1 3-00016, "BDB Storage Building/ North Anna Power Station/ Units 1

& 2."

10. ETE-CPR-2013-0003, "Beyond Design Basis Communications Strategy/Plan," Rev. 1
11. "Virginia Electric and Power Company'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 049)," dated August 23, 2013 (Serial No. 12-162D).

12."North Anna Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies)," dated January 29, 2014.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 24 of 31

13. "Virginia Electric and Power Company'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 049)," dated February 28, 2014 (Serial No. 12-162E).
14. Dominion Calculation ME-12126, "FLEX Beyond Design Basis (BDB) Service Water (SW)

Containment Integrity Strategy Hydraulic Analysis," Rev 0.

15. 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).
16. Dominion Calculation EE-0863, "NAPS BDB FLEX Electrical 480 and 120 VAC System Loading Analysis," Rev. 1 (Unit 1).
17. Dominion Calculation EE-0865, "NAPS BDB FLEX Electrical 480 and 120 VAC System Loading Analysis," Rev. 0 (Unit 2).

18.Dominion Calculation EE-0871, "NAPS BDB FLEX Electrical 4160VAC System Loading Analysis," Rev. 0.

19. 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).

20. Dominion Letter to NRS titled "North Ann Power Station Units 1 and 2, March 12, 2012 Information Request, Phase 2 Staffing Assessment Report," dated May 7, 2014 (SN:14-199)
21. ETE-CPR-2012-0012, Rev. 4, "Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document."

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. FlowServe document, "White Paper on the Response for the N-Seal Reactor Coolant Pump (RCP) Seal Package to Extend Loss of AC Power (ELAP)," Rev. 0 dated February 11, 2014 (Proprietary)
27. North Anna Power Station Updated Final Safety Analysis Report (UFSAR), Section 3.8.3.1.
28. FSG-8, "Alternate RCS Boration."
29. ETE-CPR-2012-0150, Rev. 1, Add. 0, "Core Cooling Evaluation for Dominion Fleet and Prepared Input for Response to Order EA-1 2-049."

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 25 of 31 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential/ Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance I List Portable Preventive Equipment Core Containment SEP Instrumentation Accessibility Maintenance Requirements BDB High Capacity diesel- Will follow EPRI driven pump (2)6 X X X 1200 gpm @ template and assoc. hoses 150 psid requirements and fittings BDB AFW pump 300 gpm @ Will follow EPRI (3) and assoc. X template hoses and fittings 500 psid requirements BDB RCS Injection Will follow EPRI pump (2)5 and 45 gpm @ Wilate X 3000 psid template assoc. hoses and fittings requirements 120/240VAC generators (3) 3 Will follow EPRI and associated X 40 kW template cables, connectors requirements and switchgear

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 26 of 31 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential! Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibilit Maintenance Requirements 120/240VAC generators (8)2 and associated Will follow EPRI cables, connectors X 5-6.5 kW template and switchgear (to requirements power support equipment) 480VAC generators (2)3 and associated cables, connectors Will follow EPRI and switchgear (to X X 350 kW template re-power battery requirements

chargers, inverters, and Vital Buses)

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

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 27 of 31 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential/Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable Core Containment SFP Instrumentation Accessiblit Preventive Equipment Maintenance Requirements Will follow EPRI Light plants (2)2 X template requirements Will follow EPRI Front end loader (1) 2 X template requirements Will follow EPRI Tow vehicles (2) 2 X X X X template requirements Hose trailer (2) Will follow EPRI and Utility vehicle X X X X template (1)2 requirements Fans / blowers Will follow EPRI (10)2 X template requirements Air compressors Will follow EPRI (6)2 X X template requirements

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 28 of 31 Table I - PWR Portable Equipment Phase 21 Use and (Potential/ Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Fuel truck (1) with Will follow EPRI 1,100 gal. tank X X X X X template and pumps requirements Fuel carts with Will follow EPRI transfer pumps (2) X X X X X template 2 requirements Communications Will follow EPRI equipmenti4 X X X X X template requirements Misc. debris Will follow EPRI removal X template equipment 2 requirements Misc. SWill follow EPRI Equipment 2 X template requirements

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 29 of 31 Table I - PWR Portable Equipment Phase 21 Use and (Potential / Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable Preventive Equipment Core Containment SFP Instrumentation Accessibilit Maintenance Requirements NOTES:

1. This table is based on one BDB Storage Building.
2. Support equipment. Not required to meet N+1.
3. 480VAC generators are an alternate strategy to the 120/240VAC generators. Therefore, only N is required.
4. 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.
5. One BDB RCS Injection pump can be shared between units if necessary. A BDB RCS Injection pump from the RRC will be deployed from the RRC by 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, if required, to replace an inoperable on-site BDB RCS Injection pump.
6. One BDB High Capacity pump is needed to implement the FLEX core and SFP cooling strategies. This pump is stored in the Type 1 BDB Storage Building and protected from hazards. The 50.54(hh)(2) high capacity pump is credited to meet the N+1 requirement as a backup to the BDB High Capacity pump. This pump is stored onsite in a location other than the BDB Storage Building.

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 30 of 31 Table 2 - PWR Portable Equipment Phase 3 Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance Notes List Quantity Quantity Power Core Cont. Access Instrumentation. RCS Preventative Portable Req'd Provided Cooling Cooling/ Inventory Maintenance Equipment /Unit I Unit Integrity Required Medium Jet Performed Voltage 2 3 Turb. X X X 4.16 KV 1 MW by RRC (1)

Generators Low Jet Performed Voltage 0 1 Turb X X X 480VAC 1100 KW by RRC (2)

Generators T bRC High Pressure 1 Diesel 3000# 60 GPM (2)

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

Pump Low Pressure 2500 Performed Diesel X X 300# GPM by RRC (2)

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

High Flow Pump _.__ _ ...

Lighting 0 1 Diesel X 40,000 Lu Performed (4)

Towers by RRC

Serial No.14-394 Docket Nos. 50-338/339 Order EA-12-049 Page 31 of 31 Table 2 - PWR Portable Equipment Phase 3 Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance Notes List Quantity Quantity Power Core Cont. Access Instrumentation. RCS Preventative Portable Req'd Provided Cooling Cooling/ Inventory Maintenance Equipment /Unit I Unit Integrity Required Diesel Fuel 0 AR N/A X X X X X 500 Gal Performed (2)

Transfer by RRC Mobile Performed (2)

Water 0 2 Diesel X X 150 GPM Treatment ., .. . Tretmntby* RRC (5)

Mobile Boration 0 1 N/A X 1000 Gal Performed (2)

Skid , Skid*. *=

.by RRC Note 1 - RRC 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 - RRC Generic Equipment - Not required for FLEX Strategy - Provided as Defense-in-Depth.

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

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

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

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