CP-201401055, Third 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)

Third 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)

ML14254A402
Person / Time
Site:	Comanche Peak
Issue date:	08/28/2014
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201401055, EA-12-049, TAC MF0860, TAC MF0861, TXX-14104
Download: ML14254A402 (9)

Text

Rafael Flores Senior Vice President

& Chief Nuclear Officer rafael.flores@luminant.com Luminant Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201401055 Log # TXX-14104 REF 10 CFR 2.202 August 28, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, Third 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) (TAC NOS. MF0860 and MF0861)

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.

NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

3.

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

Revision 0, dated August 2012

4. Luminant Generation Company LLC's Letter TXX-12158, Initial 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 October 25, 2012

5.

Luminant Generation Company LLC's Letter TXX-13030, 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

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued an order (Reference 1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

A member of the STARS Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek A'5'

U. S. Nuclear Regulatory Commission TXX-14104 Page 2 of 2 08/28/2014 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided Luminant Power's initial status report regarding mitigation strategies. Reference 5 provided Luminant Power's overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Carl B. Corbin at 254-897-0121 or carl.corbin@luminant.com.

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

Executed on August 28, 2014.

Sincerely, Luminant Generation Company LLC Rafael Flores By

/AFred*Wl Madden Director, External Affairs

Attachment:

Comanche Peak Nuclear Power Plant's (CPNPP) Third 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 c -

William M. Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Nuclear Power Plant

Attachment to TXX-14104 Page 1 of 7 Comanche Peak Nuclear Power Plant's (CPNPP) Third Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1

Introduction Comanche Peak Nuclear Power Plant (CPNPP) developed an Overall Integrated Plan (Reference 1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan and the first and second Six Month Status Reports (References 3 and 7), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of August 14, 2014.

FLEX Strategy Evaluation - Complete Modifications Evaluations - Complete Storage Design Engineering - Complete Procedures - PWROG issues NSSS-specific guidelines - Complete 3

Milestone Schedule Status The following table provides an update to Attachment 2 of the Overall Integrated Plan (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. Note, italicized items in the following table were not provided as milestone items in Attachment 2 of the OIP. However, these items are added here for consistency with the 6 month status update template and will be carried forward in future 6 month status updates.

Attachment to TXX-14104 Page 2 of 7 Target Revised Target Milestone Completion Activity Status Completion Date*

Date*

Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Aug 2013 Complete Walk-th rouglis or Demonstrations Apr 2015 Not Started Aug 2015 Perform Phase 2 Staffing Analysis Jun 2014 Started Jun 2015 Modifications:

Modifications Evaluation Aug 2013 Complete Develop Unit 1 Modifications Mar 2014 Started Sep 2015 Unit 1 Implementation Outage (1RF18)

Oct 2014 Not Started Apr 2016 Develop Unit 2 Modifications Mar 2015 Started Unit 2 Implementation Outage (2RF15)

Oct 2015 Not Started Storage:

Storage Design Engineering Mar 2014 Complete Storage Implementation Oct 2014 Started Feb 2015 FLEX Equipment:

Procure On-Site Equipment Jul 2014 Started Ju12015 Develop Site Response Plan with NSRC Apr 2014 Started Apr 2015 Install Off-Site Delivery Station (if Necessary)

Not Required Not Required Not Required National Safer Response Center Operational Aug 2014 Started Procedures:

PWROG issues NSSS-specific guidelines May 2013 Complete Issue FSGs Aug 2014 Started Oct 2015 Create Maintenance Procedures Ju12014 Started Oct 2015 Training:

Develop Training Plan May 2014 Started Dec 2014 Implement Training Aug 2014 Started Apr 2015 Full Site FLEX Implementation Oct 2015 Started Apr 2016 Submit Completion Report Feb 2016 Not Started Aug 2016

• Dates were primarily impacted by approval (Reference 8) of schedule relief request (Reference 5) discussed in Section 5.

Attachment to TXX-14104 Page 3 of 7 4

Changes to Compliance Method The following are either changes or clarifications to the compliance method and are in addition to those identified in the First and Second Six Month Status Reports (References 3 and 7).

Phase 3 Electrical Connections The electrical connections to be used in Phase 3 for connecting the large AC generators to the 6900V emergency buses have changed. The preferred connection entails alignment of the generators received from the National Safer Response Center (NSRC) via cables routed manually from the 4160/6900V step-up transformer to the existing electrical connection mounted external to the Safeguards building, currently used by the Alternate Power Diesel Generators. These connections are not protected against all external hazards but will be used if available.

The alternate connection for Train A entails routing cable through the Safeguards building 810' elevation hallway outer doors to the emergency switchgear buses. The alternate connection for Train B entails routing cable through the Safeguards building 810' elevation hallway outer doors to the Train B Emergency Diesel Generator (EDG). Such connections would allow for repowering of either train's 6900V Safeguards bus. The connections and all associated cabling and components will be protected against all applicable hazards.

The Phase 3 electrical connections are discussed on page 55 of Reference 1.

Phase 3 4160V to 6900V Step-Up Transformer Rather than obtaining the 4160/6900V step-up transformers from the NSRC, Luminant intends to purchase these transformers and store them within the onsite FLEX storage building. During storage, these transformers will be protected from all applicable hazards. The Phase 3 step-up transformers are discussed on page 55 of Reference 1.

Steam Generator Makeup Pump Deployment Deployment of the steam generator make-up pumps will be complete at approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after ELAP initiation, rather than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from Reference 1. These are backup pumps as the turbine driven auxiliary feedwater pumps are not assumed to fail and deployment is therefore not time sensitive. The arrival of limited staff between 6 and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> will be dedicated to performing higher priority activities.

Phase 3 Mobile Boration Unit A mobile boration unit from the NSRC is not required as boric acid batching will be performed in Phase 3 using installed plant equipment following power restoration using the large AC generators. The mobile boration unit is discussed on pages 22 and 45 of Reference 1.

Refueling Water Storage Tank (RWST) Makeup Connection Comanche Peak has significant protected volumes of borated water stored in its two RWSTs and boric acid stored in its Boric Acid Tanks. The installation of the SHIELD reactor coolant pump low leakage seals will limit demand for borated water and boric acid during an Extended Loss of AC Power (ELAP) event. Additionally, installed boric acid batching capability will be restored in Phase 3 following power restoration. Consequently, external makeup to the RWSTs is not required and the makeup connection modification discussed on pages 28 and 30 of Reference 1 will not be performed.

Attachment to TXX-14104 Page 4 of 7 Storage of High Pressure Reactor Coolant System (RCS) Injection Pumps From page 27 of Reference 1, the high pressure RCS injection pumps were intended to be stored (pre-staged) locally near the boric acid tanks or the RCS injection points. However, space limitations and storage restrictions in the proposed areas are sufficiently prohibitive such that the pumps (and associated equipment) will instead be stored in the FLEX storage building. The added task of equipment deployment from the FLEX storage building will not challenge the ability to successfully initiate RCS injection at 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> after ELAP initiation, as required.

From Reference 4, the following were identified as items requiring additional discussion in the Third Six Month Status Report.

Access to Protected Area and Internal Locked Areas Plant procedures should consider the effects of AC power loss on area access, as well as the need to gain entry to the protected area and internal locked areas where remote equipment operation is necessary.

Page 51 of Reference 4 indicates Luminant intended to provide a detailed description for accessing the protected area and internal locked areas in the Third Six Month Status Report. However, after further review, this information was determined to be safeguards related and therefore unable to be discussed herein. This information is to be discussed/reviewed during onsite NRC inspections using safeguards controls.

Preventative Maintenance and Testing Page 61 of Reference 4 indicates Luminant intended to provide a detailed description of its preventative maintenance (PM) and testing plan for FLEX equipment. However, Luminant's PM and testing plan for Comanche Peak specific FLEX equipment is still in development but will be established prior to initial FLEX implementation on Unit 2 in October 2015.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation In Reference 5, Luminant formally requested relief from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan. NRC approval of the requested relief was received in Reference 8, relaxing full order implementation for Comanche Peak Unit 1 until the completion of the spring 2016 refueling outage.

Full order implementation for Comanche Peak Unit 2 is unchanged and will occur upon completion of the fall 2015 refueling outage. The milestone schedule in Section 3 has been updated for consistency with the approved schedule relief. No additional relief is requested herein.

Attachment to TXX-14104 Page 5 of 7 6

Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the 0IP and the status of each item.

Overall Integrated Plan Open Items Status OI1.

Finalize location and protection requirements of FLEX Complete. FLEX equipment will be storage buildings. The storage buildings will be stored in a new single structure designed in accordance with the NEI guidance and the designed as described in Section 4 of applicable hazards.

Reference 7.

012. Perform containment evaluation based on the boundary Complete. The containment analysis conditions described in Section 2 of NEI 12-06. Based on concludes no significant heatup or the results of this evaluation, required actions to ensure pressurization of containment as a maintenance of containment integrity and required result of an ELAP when crediting instrument function will be developed as necessary.

SHIELD. No further action required.

013. Development of refueling equipment specifications, Development of final specifications determination of fuel consumption rates, assessment of for all FLEX equipment has started.

fuel supplies and determination of time frames for refueling of FLEX equipment in Phases 2 and 3 will be developed following generation of specifications for FLEX equipment.

014. Finalize FLEX strategies and required modifications Comanche Peak FLEX strategies following resolution of low-leakage RCP seal credit the use of SHIELD low-leakage performance issue.

seals as approved in Reference 9.

Preparation of design modifications for installation of SHIELD are in progress.

Attachment to TXX.14104 Page 6 of 7 Draft Safety Evaluation and Interim Staff Evaluation are assumed synonymous. The following table provides a summary of additional Open Items documented in the Interim Staff Evaluation (Reference 4).

These open items will be carried forward in future 6 month status updates. Luminant Power is participating in the voluntary NRC audit process described in Reference 6.

Interim Staff Evaluation Open Items Status 3.2.1.2.A Regarding the RCP seals, the only O-ring of interest Reference 9 documents NRC with the safe shutdown low-leakage (SHIELD) installed acceptance of SHIELD for use in is the RCP seal sleeve to shaft O-ring. Qualification of ELAP evaluations. Item 2 of the the RCP seal sleeve to shaft O-ring will be tracked as limitations and conditions from part of the SHIELD redesign to confirm the delayed Reference 9 restricts the maximum cooldown, as documented in the Integrated Plan, is steady-state RCS cold leg temperature acceptable. CPNPP will align with testing results to be to 571'F during an ELAP. The main documented in the forthcoming SHIELD white paper.

steam safety valve lift setpoints for Comanche Peak Units 1 and 2 ensure this temperature limit will be met.

3.2.1.2.C If the RCP seals are changed to the newly designed Reference 9 documents NRC Generation 3 SHIELD seals, or non-Westinghouse seals, acceptance of SHIELD for use in the acceptability of the use of the newly designed ELAP evaluations. Item 4 of the Generation 3 SHIELD seals, or non-Westinghouse seals limitations and conditions from should be addressed, and the RCP seal leakages rates for Reference 9 restricts the seal leakage use in the ELAP analysis should be provided with rate to a constant 1.0 gallon per acceptable justification. During the audit process the minute after SHIELD actuation. Any licensee stated that CPNPP uses the Westinghouse deviation from this restriction will be mode193A RCPs crediting SHIELD for FLEX strategies.

justified.

Testing and qualification of SHIELD is ongoing and the licensee is closely following the re-design of SHIELD and will modify analyses and FLEX strategies if needed, based on the conclusions of the SHIELD white paper.

3.2.1.8.A The Pressurized Water Reactor Owners Group Per Reference 10, the NRC has (PWROG) submitted to NRC a position paper, dated endorsed the PWROG position paper August 15, 2013 (ADAMS Accession No. ML 13235A with restrictions. Luminant Power is 132, non-public, proprietary), which provides test data currently assessing the impact of regarding boric acid mixing under single-phase natural these restrictions on the CPNPP FLEX circulation conditions and outlines applicability strategy for maintaining conditions intended to ensure that boric acid addition subcriticality.

and mixing would occur under conditions similar to those for which boric acid mixing data is available.

However, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and did not endorse this position paper. As such, ensuring adequate mixing of boric acid into the RCS under ELAP conditions is an open item for CPNPP.

Attachment to TXX-14104 Page 7 of 7 7

Potential Draft Safety Evaluation Impacts Any potential impact to the Interim Staff Evaluation has been previously discussed in Section 4 of this letter.

8 References The following references support the updates to the OIP described in this attachment.

1. Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 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.

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.

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, First 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) (TAC Nos. MF0860 and MF0861), dated August 28, 2013.

4.

NRC Interim Staff Evaluation, "Comanche Peak Nuclear Power Plant, Units 1 And 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0860 and MF0861)," dated December 19, 2013.

5.

Comanche Peak Nuclear Power Plant (CPNPP), Docket Nos. 50-445 and 50-446, Request for Schedule Relaxation for the 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) (TAC Nos. MF0860 and MF0861), dated February 12, 2014.

6.

NRC Letter from Jack R. Davis to All Operating Reactor Licensees and Holders of Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049," August 28, 2013.

7. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Second 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) (TAC Nos. MF0860 and MF0861), dated February 27, 2014.

8.

NRC Letter from Eric J. Leeds to Mr. Rafael Flores, "Comanche Peak Nuclear Power Plant, Unit 1

- Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," April 14, 2014.

9.

NRC Letter from Jack Davis to Mr. James A. Gresham, ADAMS Accession No. ML14132A128, May 28, 2014.

10. NRC Letter from Jack Davis to Mr. Jack Stringfellow, ADAMS Accession No. ML13276A183, January 8, 2014.