ML14251A035

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)

ML14251A035
Person / Time
Site:	Surry
Issue date:	08/28/2014
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-395, EA-12-049
Download: ML14251A035 (27)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 28, 2014 10 CFR 2.202 EA-12-049 Attention: Document Control Desk Serial No.: 14-395 U.S. Nuclear Regulatory Commission NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY 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-12-049)

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. 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. 12-163B)

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. 12-163E)

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 previous six-month status report (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis.

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 2 of 3 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.

Acknowledged before me this fday of 2014.

My Commission Expires: 5- 31-1-/

2*1 I.

Vicki L. Hull (SEAL)

I NOTARY PUBLIC Commonwe~fth of Virginia Reg. # 140542 My Commission Expires May 31, 2018

-- .L* __ __ " ............ J Notary Public

Serial No.14-395 Docket Nos. 50-280/281 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 II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 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 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 NRC Senior Resident Inspector Surry Power Station

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 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 Surry Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 1 of 23 Six-Month Status Report for the Implementation of Order EA-1 2-049 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 Surry Power Station (Surry) 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 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 OIP

• 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, 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 Surry Units 1 and 2, but accurately reflect that each Unit's modifications will be implemented during the next scheduled refueling outage.

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

Implement Modifications* May 2015* Started Develop Training Plan April 2014 Complete

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 2 of 23 Target Activity Revised Target Milestone Completion Status Completion Date Date Implement Training August 2014 Started Issue FLEX Support Guidelines and Associated Procedure September 2014 Started December 2014*

Revisions Develop Strategies/Contract with National SAFER Response August 2014 Started Center (NSRC)

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

Validation Walk-throughs or Demonstrations of FLEX December 2014 Not Started Strategies and Procedures Create Maintenance Procedures* August 2014 Complete Unit 1 Outage Implementation April 2015 Started May 2015*

Unit 2 Outage Implementation October 2015 Not Started November 2015*

• Refer to Section 8, Supplemental Information, for an explanation of Milestone changes.

4 Changes to Compliance Method By letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at Surry Units 1 and 2 (Reference 1) as required by Order Number EA 049, dated March 12, 2012 (Reference 2). The first and second Six-Month Status Report of the OIP for Surry were provided by letters dated August 23, 2013 (Reference 15) and February 27, 2014 (Reference 16), respectively. The following are changes to the compliance method information provided in the Surry OIP, which continues to meet NEI 12-06 (Reference 3):

a) Regarding the previously reported strategy for Modes 5 and 6 (designated Cold Shutdown and Refueling operational modes for Surry), 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 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.

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 3 of 23 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 Nuclear Steam Supply System (NSSS) was revised. Additionally, use of water from the James River as a water source for either the primary or secondary sides of the NSSS is available, but is only considered a water source of last resort. The James River is also available as a water source for the Spent Fuel Pool.

c) As a result of the water quality chemical analysis and evaluation (see item b above), the draft point for the BDB High Capacity Pump has been changed from the James River to the Settling Pond located adjacent to the site Protected Area (PA). The Settling Pond had previously been identified as an alternate onsite clean water source.

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 that are unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided 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. Consequently, 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.

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

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 4 of 23 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.

g) On July 17, 2014, the SAFER Organization and the staff from Surry Power Station conducted a demonstration of SAFER's ability to activate the SAFER Control Center in Lynchburg, Virginia, as well as the Phoenix Regional Response Center, to deliver Phase 3 offsite equipment to the Surry site in accordance with the SAFER response plan. The NRC audited this Proof of Concept demonstration and provided observations.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date and no required relief/relaxation has been identified at this time.

6 Open Items 6.1 Open Items from Overall Integrated Plan The following table provides a summary of the status of open items documented in B of the Surry 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 Not started.

1 staffing assessment. Scheduled completion date:

December 2014 Preliminary analyses have been performed to determine Complete.

2 the Class 1E battery life based on implementation of load (Reference 16, See Section stripping actions. The final battery life duration will be 4, Item a.)

provided when the analyses are completed.

Preliminary analyses have been performed to determine Complete.

the time to steam generator overfill without operator (Reference 4) action to reduce AFW flow, time to steam generator 3 dryout without AFW flow, and time to depletion of the useable volume of the ECST and ECMT. The final durations will be provided when the analyses are completed.

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 5 of 23 Overall Integrated Plan Open Items 01 # Description Status The Phase 3 coping strategy to maintain Containment Complete.

integrity is under development. Methods to monitor and 4 evaluate Containment conditions and depressurize/cool (See Reference 16, Containment, if necessary, will be provided in a future Attachment 2.)

update.

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 be 5 satisfactorily accomplished in response to an ELAP/Loss of Ultimate Heat Sink (LUHS) event. (References 6 and 7)

A hydraulic calculation to confirm that the SW flow to support the Containment cooling options is not required since the source is expected to be gravity fed from the Intake Canal.

A study is in progress to determine the design features, Complete.

site location(s), and number of equipment storage A single 10,000 sq. ft. Type 1 facilities. The final design for BDB equipment storage will building is being constructed be based on the guidance contained in NEI 12-06, at Surry for storage of BDB Section 11.3, Equipment Storage. A supplement to this equipment. The building is submittal will be provided with the results of the designed to meet the plant's equipment storage study. design basis for the Safe Shutdown Earthquake, high 6 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 sited just east of the south employee parking lot, inside the Owner Controlled

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 6 of 23 Overall Integrated Plan Open Items 01 # Description Status Area. The location lies in an area between the Surry Nuclear Information Center and the Intake Canal. This update provides the supplemental information referred to in this open item.

(Reference 11)

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

7 accordance with PWROG guidance. Existing procedures Scheduled completion date:

will be revised as necessary to implement FSGs. December 2014*

EPRI guidance documents will be used to develop Complete.

periodic testing and preventative maintenance procedures for BDB equipment. Procedures will be EPRI guidance documents developed to manage unavailability of equipment such have been used, where that risk to mitigating strategy capability is minimized.

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 site 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 19)

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 7 of 23 Overall Integrated Plan Open Items 01 # Description Status An overall program document will be developed to Complete.

maintain the FLEX strategies and their bases and to The fleet-wide programmatic provide configuration control and change management control procedure has been for the FLEX Program. provided for Staff review through the ongoing NRC audit process. (Reference 20)

The Dominion Nuclear Training Program will be revised Complete.

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

(Reference 18)

Plant modifications will be completed for permanent plant Started.

11 changes required for implementation of FLEX strategies. Scheduled completion date:

See Milestone Schedule above.

The following actions will be completed to qualify the Items (1) and (3): Complete ECMT as a source of water to the TDAFW pump in response to an ELAP/LUHS event: (1) Upgrade the (Reference 11, Section 2.1.6) piping system from the ECMT to the TDAFW pump suction to Seismic Category I (2) Modify the TDAFW 12 pump discharge piping to install local AFW flowrate indication (3) Confirm adequate TDAFW pump NPSH Item (2): Started.

from the ECMT through the idle AFW booster pumps using conservative analysis. Scheduled completion date:

May 2015 (Unit 1)

November 2015 (Unit 2)*

Complete the evaluation of TDAFW pump long term Complete.

operation with </= 290 psig inlet steam pressure.

TDAFW pump operation and 13 adequate AFW flow to the SGs at SG pressures < 290 psig have been confirmed.

(Reference 5)

Details of the ventilation strategy are under development Complete.

and will conform to the guidance given in NEI 12-06. The 14 details of this strategy will be provided at a later date. (See Reference 16, Attachment 2, OIP Section F5.)

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 8 of 23 Overall Integrated Plan Open Items 01 # Description Status Analyses will be performed to develop electrical Complete.

components performance requirements and confirm electrical loading-related strategy objectives can be met. Results for the sizing and loading analysis of the 120VAC and 480VAC generators confirm the electrical loading-related strategy objectives can be met. Final calculations 15 confirming these results have been completed (Reference 13).

Calculations identifying the Phase 3 4160VAC generator load requirements and power cable ampacity rating have been completed (Reference 14).

An evaluation of all BDB equipment fuel consumption and Complete.

required re-fill strategies will be developed including any An evaluation of all BDB 16 gasoline required for small miscellaneous equipment. equipment fuel consumption and required refill strategies has been completed.

(Reference 11)

A lighting study will be performed to validate the Complete.

adequacy of supplemental lighting and the adequacy and A lighting study has been practicality of using portable lighting to perform FLEX completed validating the strategy actions. adequacy of supplemental 17 lighting and the adequacy and practicality of using portable lighting to perform FLEX Strategy actions.

(Reference 11)

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 9 of 23 Overall Integrated Plan Open Items 01 # Description Status A comprehensive study of communication capabilities is Complete.

being performed in accordance with the commitments made in Dominion letter S/N 12-208F dated October 29, A study documenting the 2012 in response to Recommendation 9.3 of the 10 CFR communications strategy has 50.54(f) letter dated March 12, 2012. The results of this been completed. The plan 18 study will identify the communication means available or concludes that FLEX needed to implement command and control of the FLEX strategies can be effectively strategies at Surry. Validation of communications irmplemented with a required to implement FLEX strategies will be performed cimnateion o as part of Open Item No. 1. powered phones, satellite phones and hand-held radios.

(Reference 8)

Preferred travel pathways will be determined using the Started.

guidance contained in NEI 12-06. The pathways will attempt to avoid areas with trees, power lines, and other The soil liquefaction study potential obstructions and will consider the potential for has been completed soil liquefaction. (Reference 9), which supports the location of the storage building and the haul 19 routes. The results will be included with the final design package for the storage building (Reference 10).

A Haul Route Evaluation Report is scheduled for completion in November 2014*.

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

20 Scheduled completion date:

September 2014*

• Refer to Section 8, Supplemental Information, for an explanation of the changes to Open Items.

6.2 Open Items from the Interim Staff Evaluation (ISE)

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

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 10 of 23 Interim Staff Evaluation Open Items 01 # Description Status 3.2.1.8.A Core Sub-Criticality-Verify that Surry will apply the generic This ISE O is being resolution for boron mixing under natural circulation addressed through conditions potentially involving two-phase flow, in the ongoing NRC accordance with the Pressurized-Water Reactor Owners audit process.

Group (PWROG) position paper, dated August 15, 2013 (Generic)

(ADAMS Accession No. ML13235A135 (non-public for (Reference 18) proprietary reasons)), and subject to the conditions provided in the NRC endorsement letter dated January 8, 2014 (ADAMS Accession No. ML13276A183). Alternatively, justify the boric acid mixing assumptions that will ensure adequate shutdown margin exists through all 3 phases of an ELAP event.

3.2.4.10.A Battery Duty Cycle. Verify that the licensee will abide by the This ISE 01 is being generic approach for demonstrating that vented lead-acid addressed through batteries can be credited for durations longer than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or the ongoing NRC justify an acceptable alternate approach. audit process.

(References 16 and 118) 6.3 Confirmatory Items from the Interim Staff Evaluation (ISE)

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

Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.1.2.A Deployment of FLEX equipment- (Seismic Hazard, This ISE Cl is being Flooding). Confirm protection of connections for addressed through maintaining containment-Phase 3. the ongoing NRC audit process.

(References 11 and 18) 3.1.1.3.A Procedural Interface Considerations - Seismic Hazard. This ISE CI is being Confirmation that the Flex Support Guidelines (FSG) being addressed through developed for obtaining local instrument readings addresses the ongoing NRC critical actions to perform until alternate indications can be audit process.

connected. (References 21 and 18) 3.1.1.4.A Off-Site Resources. Confirm ARC local staging area, This ISE Cl is being evaluation of access routes, and method of transportation to addressed through the site. the ongoing NRC

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 11 of 23 Interim Staff Evaluation Confirmatory Items CI # Description Status audit process.

(Reference 18) 3.2.1.A RCS Cooling & RCS Inventory Control. Confirm the This ISE CI is being appropriate use of the analysis from Section 5.2 of WCAP- addressed through 17601-P by demonstrating the important parameters and the ongoing NRC assumptions are representative of Surry. audit process.

(References 22 and 18) 3.2.1.1.A ELAP Analysis - Reliance on the NOTRUMP code for the This ISE Cl is being ELAP analysis of Westinghouse plants is limited to the flow addressed through conditions prior to reflux condensation initiation. This the ongoing NRC includes specifying an acceptable definition for reflux audit process.

condensation cooling. Confirm that the NOTRUMP code is (Generic) used within acceptable limits. (Reference 18) 3.2.1.2.A RCP Seal Leakage. Confirm that, if the seals are changed to This ISE CI is being non-Westinghouse seals, the licensee addresses the addressed through acceptability of the use of non-Westinghouse seals, and the ongoing NRC provides the acceptable justification for the RCP seal audit process.

leakage rates for use in the ELAP analysis, to include (Generic) whether the FlowServe white paper justifies the use of the (Reference 18)

FlowServe N-9000 seals and bounds the 21 gpm/seal leakage rate assumed in the analysis.

3.2.1.2.B RCP Seal Leakage. Confirm FlowServe white paper justifies This ISE Cl is being that the integrity of the 0-rings will be maintained above the addressed through temperature conditions experienced during the ELAP event the ongoing NRC (approximately 556 OF) and if the SG PORV modification to audit process.

add a protected backup air bottle system has an impact in the (Generic) analysis. (Reference 18) 3.2.1.9.A Use of Portable Pumps. Confirm that intermittent RCS This ISE Cl is being injection by alternating between units is adequate using only addressed through one RCS injection pump. the ongoing NRC audit process.

(References 11 and 18) 3.2.1.9.B Use of Portable Pumps. Confirm the capacity of one high This ISE Cl is being capacity pump can supply 300 gpm AFW flow to each unit's addressed through SG and 500 gpm to the dual unit SFP simultaneously. the ongoing NRC audit process.

(References 6 and 11) 3.2.3.A Containment. Confirm the Phase 3 coping strategy for This ISE Cl is being containment is appropriate. addressed through the ongoing NRC

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 12 of 23 Interim Staff Evaluation Confirmatory Items Cl # Description Status audit process.

(References 16 and 18) 3.2.4.2.A Ventilation - Equipment cooling. Confirm that the licensee's This ISE CI is being ventilation strategy adequately supports equipment cooling, addressed through the ongoing NRC audit process.

(References 16 and 18) 3.2.4.4.A Communications. Confirm that upgrades to the site's This ISE Cl is being communications systems have been completed. addressed through the ongoing NRC audit process.

(References 8 and 18) 3.2.4.6.A Personnel Habitability- Elevated Temperature. Confirm This ISE Cl is being appropriate plans are made to account for the results of the addressed through ventilation study for personnel habitability when complete. the ongoing NRC audit process.

(References 11 and 18) 3.2.4.8.A Electrical Power Source/Isolation and Interactions. Confirm This ISE Cl is being that 2MW portable DGs are adequate to supply loads addressed through assumed in Phase 3. the ongoing NRC audit process.

(References 14 and 18) 3.4.A Confirm the licensee's arrangements for off-site resources This ISE CI is being addresses the guidance of Guidelines 2 through 10 in NEI addressed through 12-06, Section 12.2. the ongoing NRC audit process.

(Reference 18) 7 Potential Safety Evaluation Impacts 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 Surry'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 (Reference 17).

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 13 of 23 8 Supplemental Information This supplemental information provides details of the changes identified in the status updates above and addresses the following topics: a) the Milestone Task 'Develop Modifications', b) the Milestone Task 'Implement Modifications,' c) the Milestone Task 'Issue FSGs and Associated Procedure Revisions,' d) a revision to Milestone Task 'Receive Equipment,' e) a revision to Milestone Task 'Create Maintenance Procedures,' f) the Milestone Task 'Unit 2 Outage Implementation,' g) a revision to Open Item No. 7, h) a revision to Open Item No. 12, i) a revision to Open Item No. 19, and j) a revision to Open Item No. 20.

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

b. Surry, Milestone Task 'Implement Modifications': The revision separates Units 1 and 2 to more accurately reflect the actual tasks as they will occur for each Surry 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: May 2015 Milestone Task: Implement Unit 2 Modifications Completion Schedule: November 2015

c. Surry, Milestone Task 'Issue FSGs and Associated Procedure Revisions': The revision to the scheduled milestone target completion date allows for completion of the Surry FSGs in line with the schedule for validation and training on the FSGs. (See also revision to Open Item 7.)

d. Surry, Milestone Task 'Receive Equipment': 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. (See also revision to Open Item 20.)

e. Surry, 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.

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 14 of 23

f. Surry, Milestone Task 'Unit 1 Outage Implementation' and 'Unit 2 Outage Implementation'-: The Milestone Task dates are revised to reflect the current outage schedules which have been moved to May 2015 and November 2015, respectively.

g. Surry, Open Item 7: The Open Item completion date is revised to December 2014. The revision to the scheduled milestone target completion date allows for completion of the Surry FSGs in line with the schedule for validation and training on the FSGs.

h. Surry, Open Item 12: The revision to the status wording more accurately reflects the status for each Surry Unit. The split completion schedules reflect the current outage schedules.

i. Surry, Open Item 19: The liquefaction aspect of this item has been completed.

However, the documentation of the evaluation of the haul routes for obstacles is still in progress and will be completed by November 2014.

j. Surry, Open Item 20: 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.

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 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. 12-163B).

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. Virginia Electric and Power Company 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. 12-163C).

5. Dominion Calculation ME-0969, "Evaluation of the TDAFW Pump Performance at Low Steam Generator Pressures," August 2013.

6. Dominion Calculation ME-0967, "Beyond Design Basis (BDB) - BDB High Capacity Pump and BDB AFW Pump Hydraulic Analysis for Spent Fuel Pool Makeup and AFW Injection at SPS Units 1 and 2," Rev. 0.

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 15 of 23

7. Dominion Calculation ME-0964, "Evaluate the 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," Rev. 0.

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

9. Geotechnical Engineering Report, BDB FLEX Storage Building, Surry Power Station, Surry County, VA, Schnabel Reference #13613080, September 19, 2013, including Addendum No. 1.

10. Design Change SU-13-00015, BDB Storage Building/ Surry Power Station/ Units 1 & 2.

11. ETE-CPR-2012-0011, Rev. 3, "Beyond Design Basis - FLEX Strategy Overall Integrated Plan Basis Document."

12. NRC Letter from Jeremy S. Bowen (NRC) to David A. Heacock (Dominion), "Surry Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)," dated February 19, 2014.

13.Calculation EE-0864, Rev 2, "FLEX Electrical 480VAC and 120VAC System Loading Analysis."

14.Calculation EE-0872, Rev. 0, "SPS BDB FLEX Electrical 4160VAC System Loading Analysis."

15.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. 12-163D).

16.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 27, 2014 (Serial No. 12-163E).

17. 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).

18. 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).

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 16 of 23

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

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

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

22. 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.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 17 of 23 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 Accessibility Maintenance Requirements BDB High Capacity diesel- 1200 gpm Will follow EPRI driven pump (2)6 X X X 150 psid template and assoc. hoses requirements and fittings BDB AFW pump 300 gpm @ Will follow EPRI (3) and assoc. X 500 psid template hoses and fittings 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.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 18 of 23 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential / Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable Preventive Equipment Core Containment SEP Instrumentation Accessibility 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.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 19 of 23 Table 1 - PWR Portable Equipment Phase 21 Use and (Potential/Flexibility)Diverse Uses Performance Maintenance Criteria Maintenance /

List Portable ListPortablen Core Containment SFP Instrumentation Accessibility Preventive Mainte Equipment Maintenance Requirements Will follow EPRI Light plants (2)2 X template requirements Front end loader Will follow EPRI (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

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 20 of 23 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 Accessibiity Maintenance Requirements Air compressors XXtmlt Will follow EPRI (6) 2 X X template 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 X X X X X template (2)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

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 21 of 23 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 Accessibility Maintenance Requirements Will follow EPRI Misc. Support Equipment 2 X template requirements NOTES:

1. This table is based on one BDB Storage Building.

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

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.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 22 of 23 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 (2) by RRC Generators High Pressure 0 1 Injcton 0 Diesel ieel;, i X 3000# 60 GPM Performed (2)

Injection by RRC Pump _ _ _

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

Pump Low Pressure/ 0D l0 2500 Performed Medium GPM by RRC Flow Pump I Low Pressure 1 1 Diesel X 5000 Performed High Flow GPM by RRC (3)

Pump _ _ _ __ _...... ._.___

Lighting 0 01 1 Diesel Diesel X .40,000

.; :Performed Lu (4)

Towers by RRC

Serial No.14-395 Docket Nos. 50-280/281 Order EA-12-049 Page 23 of 23 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 Coolingl Inventory Maintenance Equipment /Unit I Unit Integrity Required Diesel Diesel Fuel Performed 0 AR N/A X X X X X 500 Gal by RRC (2)

Transfer b R Mobile I Performed (2) 0 2 Diesel X X 150 GPM PerrC (2)

Water by RRC (5)

Treatment Mobile Boration 0 1 N/A X 1000 Gal Performed (2) by RRC Skid 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.