LIC-15-0032, OPPD, Fort Calhoun, Unit 1 - Fourth 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
| ML15058A679 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun |
| Issue date: | 02/27/2015 |
| From: | Dean E Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, LIC-15-0032 | |
| Download: ML15058A679 (16) | |
Text
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fjjjjjfj Omaha Public Puwer Olslrlct 444 South 1 efh Street Mall Omaha, NE 68102-2247 Ll C-15-0032 February 27, 2015 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
Omaha Public Power District's Fourth 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
References:
See Page 3 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was effective immediately and required the Omaha Public Power District (OPPD) 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 (BDBEE). Specific requirements are described in Attachment 2 of the Order.
Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the Overall Integrated Plan (OIP),
which OPPD submitted on February 28, 2013 (Reference 4). In August 2014, OPPD provided the third six-month status report (Reference 7) describing progress made in implementing the requirements of the Order; this letter provides the fourth six-month status report.
The OIP (Reference 4) and subsequent six-month status reports were prepared utilizing NEI guidance (Reference 2) as endorsed with exceptions and clarifications by the NRC in Reference 3.
There are no regulatory commitments contained in this submittal.
If you should have any questions regarding this submittal, please contact Mr. Bill R.
Hansher at (402) 533-6894.
Employment with Equal Opportunity
U. S. Nuclear Regulatory Commission Ll C-15-0032 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 27, 2015.
Respectfully, Edwin D. Dean Plant Manager EDD/JKG/mle
Enclosure:
Fourth Six-Month Status Report for the Implementation of Order EA-12-049 c: B. W. Sheron, Director of Office of Nuclear Reactor Regulation M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager M.A. Brown, NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector
U.S. Nuclear Regulatory Commission LIC-15-0032 Page3 References
- 1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"
dated March 12, 2012 (ML12054A736) (NRC-12-0020)
- 2. Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ML12242A378)
- 3. 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 (ML12229A174)
- 4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District'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 (ML13064A298) (LIC-13-0019)
- 5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First 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," dated August 28, 2013 (ML13268A075) (LIC-13-0123)
- 6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Second 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," dated February 24, 2014 (ML14055A412) (LIC-14-0021)
- 7. Letter from OPPD (E. D. Dean) to NRC (Document Control Desk), "Omaha Public Power District's 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," dated August 27, 2014 (ML14239A679) (LIC-14-0108)
LIC-15-0032 Enclosure Page 1 Fort Calhoun Station, Unit No.1 Fourth 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 The Omaha Public Power District (OPPD) developed an Overall Integrated Plan (Reference 1) 1 documenting the diverse and flexible strategies (FLEX), in response to Reference 2.
This enclosure and its attachments provide an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 Milestone Accomplishments Control Room Heatup Calculation and Water Quality Evaluations are complete.
FLEX Support Guideline Basis Documents and Executive volume have been issued.
Draft Lower Mode FLEX Support Guidelines have been issued.
Beyond-Design-Basis (BDB) Flooding Strategy has been established for all potential flooding elevations.
3 Milestone Schedule Status contains an update to the Milestone Schedule (Reference 1, Enclosure, ) provided with the Overall Integrated Plan.
The status of each milestone is shown, as are revised completion dates. The dates are planning dates subject to change as design and implementation details are developed. Attachment 1 is formatted to align with the table provided in the Nuclear Energy Institute's (NEI) Six-Month Status Report Template and supersedes the Milestone Schedule provided by Reference 1.
The evaluation of FLEX modifications is largely complete. However, the completion date was revised to April 2015 to accommodate incorporation of equipment pre-staging/storage to address BDB flooding.
This also impacted the FLEX strategy evaluation and procedures, development of a training plan and staffing evaluation causing their completion dates to be revised as well. The creation of FLEX Equipment maintenance procedures was adjusted to align with the expected arrival of all FLEX equipment on-site. The revised completion dates do not impact the implementation date of the Order.
4 Changes to Compliance Method There are no changes to the compliance method as documented in the Fort Calhoun Station Overall Integrated Plan (Reference 1). The results of the control room heatup calculation (see Overall Integrated Plan Open Item #2 in Section 6, below) show that control room cooling will not be required for a significantly longer period of time than was assumed in the Overall Integrated Plan timeline. OPPD is evaluating the method that will be used to establish cooling to the control room and will provide an update to the strategy in a future 6-month update.
1 Documents referenced in this enclosure are listed in Section 8.
LIC-15-0032 Enclosure Page2 As discussed in previous 6-month updates, OPPD has developed an interim strategy to address BDB flooding. This strategy is similar to that described in Reference 1, Enclosure, Appendix B, Action 24, but involves a slightly different portable equipment configuration to accommodate issues not yet addressed by FLEX modifications.
Results of the Near Term Task Force Recommendation 2.1 flooding hazard re-analysis (Reference 4) indicated that certain Missouri River dam failures might result in floods exceeding the elevation currently addressed by the interim BDB flooding strategy. OPPD has revised the interim BDB flooding strategy to address the potential higher flooding levels. The interim equipment and strategies will be incorporated into the FLEX Overall Integrated Plan. Certain modifications are being considered to improve protection and deployment of the flood mitigation equipment. Once those modifications are finalized, OPPD will describe the integration of the interim flood strategy into the Overall Integrated Plan in a future six-month update.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation OPPD expects to comply with the Order's implementation date and no relief/relaxation is required at this time.
6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item.
Overall Integrated Plan Open Item Status
- 1. Communicate exceptions related to Site Security Not Started Plan or Other License requirements
- 2. Complete Control Room Heatup Calculation Complete
- 3. Complete Reactor Coolant System (RCS) Makeup Started Evaluation with Reactor Coolant Pump (RCP)
Controlled Bleed-off (CBO) Modification
- 4. Develop Playbook Started
- 5. Complete Water Chemistry Impact Analysis and Complete review impact on the strategies
- 6. Complete Core Uncovery Time Evaluation with RCP Started CBO Isolation. (This is subtask of Open Item #3.)
- 7. Evaluate Auxiliary Building Ventilation Requirements Started with Spent Fuel Pool (SFP) Evaporation
- 8. Evaluate Environmental Conditions after Extended Started Loss of AC Power (ELAP) in critical FLEX deployment areas
LIC-15-0032 Enclosure Page 3 Draft Safe_!y Evaluation Open Item Interim Staff Evaluation (ISE) received on February 27, 2014 (Reference 3).
7 Potential Draft Safety Evaluation Impacts Status of this enclosure describes the status of the Open Items and Confirmatory Items from the ISE.
There are no potential impacts to the Draft Safety Evaluation identified at this time.
8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.
- 1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District'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 (ML13064A298), (LIC-13-0019)
- 2. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12054A736), (NRC-12-0020)
- 3. Letter from NRC (J. S. Bowen) to L. P. Cortopassi (OPPD), "Fort Calhoun Station, Unit 1 -
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NO. MF0969)," dated February 27, 2014 (ML14007A693)
- 4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Response to Request for Information Regarding Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident-Fort Calhoun Station Flood Hazard Reevaluation Report," dated February 4, 2015 (LIC-15-0015)
Attachments: 1. FLEX Overall Integrated Implementation Plan Milestone Schedule, Revision 4
- 2. Status of Interim Staff Evaluation Open Item I Confirmatory Items
LIC-15-0032 Enclosure, Attachment 1 Page 1 Fort Calhoun Station EA-12-049 (FLEX) Overall Integrated Implementation Plan Milestone Schedule Revision 4 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in subsequent 6-month status reports.
Target Revised Activity Target Milestone Completion 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 Com_pJete Update 3 Aug. 2014 Complete Update 4 Feb.2015 Complete Update 5 Aug.2015 Not Started Update 6 Feb.2016 Not Started U_pdate 7 Aug. 2016 Not Started FLEX Strategy Evaluation Nov. 2014 Started Apr. 2015 Walk-throughs or Demonstrations Nov. 2016 Not Started Perform Staffing Analysis Sep.2015 Not Started Mar. 2016 Modifications:
Modifications Evaluation Sep.2014 Started Apr. 2015 Design EI}Qineering Aug_2015 Started Implementation Outage Oct. 2016 Not Started Storage:
Stor(!ge Desig_n Engineerii}Q_
Oct. 2015 Started Storage Implementation Apr. 2016 Not Started FLEX Equipment:
Procure On-Site Equipment Mar. 2016 Started Develop Strategies with RRC Mar. 2015 Started Install Off-Site Delivery Station (if Not planned at Not planned at Necessary) this time this time Procedures:
PWROG issues NSSS-specific Jun.2014 Complete guidelines Create Site-Specific FSGs May 2015 Not Started Dec. 2015 Create Maintenance Procedures Feb.2015 Not Started Jun.2016 Training:
Develop Training Plan Nov. 2014 Started Apr. 2015 Training Comglete Sep.2016 Not Started Full Site FLEX Implementation Oct. 2016 Started Submit Completion Report Dec. 2016 Not Started
LIC-15-0032 Enclosure, Attachment 2 Page 1 Status of Interim Staff Evaluation Open Item I Confirmatory Items OPEN ITEMS Item NRC Ref.
Description Status August 2014 Update 1
3.2.1.6.8 Sequence of Events-Confirm whether the CENTS code IN PROGRESS ELAP reanalysis reflecting the CBO isolation Expect completion to be documented in August modification affected the SOE timeline, and if so, that 2015 Update.
the SOE timeline has been updated and the overall FLEX mitigation strategies reflect these results.
~-
LIC-15-0032 Enclosure, Attachment 2 Page2 Status of Interim Staff Evaluation Open Item I Confirmatory Items CONFIRMATORY ITEMS Item NRC Ref.
Description Status August 2014 Update 1
3.1.1.1.A Protection of FLEX equipment (seismic hazard)-
IN PROGRESS Confirm that all FLEX equipment stored in the auxiliary Expect completion of design documentation by building and the new FLEX Support Building (FSB) are February 2016 Update. Expect completion of seismically restrained to ensure equipment is not building and placement of FLEX equipment by damaged during a seismic event and that the FLEX August 2016 Update.
equipment is not damaged by non-seismically robust equipment due to seismic interactions.
2 3.1.1.2.A Deployment of FLEX equipment (seismic hazard)-
IN PROGRESS Confirm that deployment pathways for the FLEX Expect completion of design documentation by portable equipment are not susceptible to soil February 2016 Update. Expect completion of liquefaction.
building and placement of FLEX equipment by August 2016 Update.
3 3.1.1.3.A Procedural Interfaces (seismic) - Confirm the licensee IN PROGRESS develops (1) methods and locations for alternate Expect completion to be documented in August monitoring of key parameters; (2) guidance on critical 2015 Update.
actions to perform until alternate indications can be obtained; and (3) guidance on control of critical equipment without control power.
4 3.1.1.4.A Off-site Resources - Confirm the location of the off-site STARTED staging area(s) and acceptability of the access routes Expect completion of Regional Response Center considering the seismic, flooding, high wind, snow, ice "Playbook" by February 2016 Update.
and extreme cold hazard.
LIC-15-0032 Enclosure, Attachment 2 Page3 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 5
3.1.2.2.A Deployment (flood) - Confirm the method of accessing IN PROGRESS the ultimate heat sink (UHS), the Missouri River, using A conceptual design has been developed to FLEX equipment during high river levels or a~er floo~
install a FLEX well that will provide a means to waters inundate the site up to the current des1gn bas1s provide makeup water to the Steam Generators, flood elevation of 1014 foot elevation is addressed.
RCS and Spent Fuel Pool via a submersible The plan does not identify the deployed location of the pump. Alternately, subme~sible p~mps p~ocured fire truck or river drafting pump nor how they are for the interim Beyond Des1gn Bas1s flooding may accessed and monitored by plant operators, be used to access flood waters if the FLEX well considering the site's flooded condition.
is not considered a viable option.
Expect completion of design documentation by August 2015 Update. Expect completio~ of well and/or and final placement of FLEX equ1pment for flooding response by August 2016 Update.
6 3.1.3.1.A Protection of FLEX Equipment (high wind hazard)-
IN PROGRESS Confirm the design code used for the FSB for the high Expect completion of design documentation by wind hazard and the method of protection of the N+1 February 2016 Update. Expect completion of FLEX equipment from tornado borne missiles is building by August 2016 Update.
acceptable.
7 3.2.1.1.A CENTS - Confirm that the use of CENTS in the ELAP IN PROGRESS analysis for FCS is limited t~ the flow con~i~ions before Documentation of application of CENTS reflux boiling initiates. This Includes prov1d1ng a limitations regarding reflux boiling will be justification for how the initiation of reflux boiling is.
specifically addressed in the Nuclear _Steam.
defined. Confirm that the reanalysis for the case w1th Supply System (NSSS) timing analys1s that Will the CBO isolated conforms to the above limitations.
be performed to address Open Item #1.
LIC-15-0032 Enclosure, Attachment 2 Page4 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 8
3.2.1.2.8 RCP Seal Leakage Rates - Confirm the selection and IN PROGRESS justification for the seal leakage rates assumed in the Documentation of the effects of isolation of CBO ELAP analysis from the initiation of the ELAP event to on RCS leak rates will be specifically addressed the time frame when subcooling in the RCS cold legs in the NSSS timing analysis that will be decreases to less than 50 degrees F. Confirm the performed to address Open Item #1.
calculated maximum temperature and pressure, and minimum subcooling in the RCS cold legs during the ELAP before isolation of the CBO. Confirm the seal leakage rates per RCP before and after isolation of the CBO used in the ELAP reanalysis for determination of the SOE and associated time limes.
9 3.2.1.3.A Decay Heat - Confirm the key physics parameters used IN PROGRESS for each of the decay heat evaluation scenarios to Documentation of the validity of the design inputs ensure that the FCS ELAP response is conservative will be provided in the NSSS timing analysis that relative to the ANS standard.
will be performed to address Open Item #1.
10 3.2.1.4.A Initial Values for Key Plant Parameters and IN PROGRESS Assumptions-Confirm which inputs and assumptions Documentation of the validity of the design inputs are appropriate relative to being plant specific or and assumptions will be provided in the NSSS derived from WCAP-17601-P.
timing analysis that will be performed to address Open Item #1.
11 3.2.1.5.A Monitoring Instrumentation and Controls - Confirm IN PROGRESS suitability of EFWST level monitoring instrumentation The ability to monitor EFWST level locally will be considering the environmental conditions in the addressed as part of the alternate monitoring auxiliary building following an ELAP event.
locations conceptual design discussed in Confirmatory Item #3.
LIC-15-0032 Enclosure, Attachment 2 Page 5 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 12 3.2.1.5.8 Monitoring Instrumentation and Controls - Confirm NOT STARTED suitability of existing or replacement SIT level Environmental conditions inside containment instrumentation considering the environmental following an ELAP event will be established as conditions in the containment following an ELAP event.
part of the NSSS analysis that will be conducted to address Open Item #1. It is expected that the current instrumentation will be qualified to continue to operate in the predicted environment.
In the event that the instruments cannot be qualified, a modification will be initiated to replace one or more with qualified instruments.
13 3.2.1.8.A Core Sub-Criticality - Confirm that the reanalysis IN PROGRESS discussed in Confirmatory Item 3.2.1.1.A continues to Documentation of the validity of the boron-mixing align with the generic resolution for boron mixing under model during natural circulation conditions will be natural circulation conditions potentially involving two-provided in the NSSS timing analysis that will be phase flow, in accordance with the Pressurized-Water performed to address Open Item #1.
Reactor Owners Group position paper, dated August 15, 2013 (ADAMS Accession No. ML13235A135 (nonpublic for proprietary reasons)), and subject to the conditions provided in the NRC endorsement letter dated January 8, 2014 (ADAMS Accession No. ML13276A183) following SOE and FLEX mitigation strategy impacting changes.
14 3.2.4.1.A Equipment Cooling (Water) - Confirm installed charging NOT STARTED pumps can operate during an ELAP considering the Expect completion to be documented in August loss of support equipment.
2015 Update.
LIC-15-0032 Enclosure, Attachment 2 Page6 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 15 3.2.4.2.A Equipment Cooling (Ventilation)- Confirm that the NOT STARTED licensee addresses environmental conditions in the Expect completion to be documented in August vicinity of and access to all deployed FLEX equipment in the auxiliary building, to ensure continuous 2015 Update.
equipment operation and acceptable human performance.
16 3.2.4.2.8 Equipment Cooling (Ventilation) - Confirm that the IN PROGRESS licensee addresses environmental conditions in the Expect completion to be documented in August main control room (CR) and the need for ventilation prior to re-establishing power to the CR ventilation fans 2015 Update.
using the FLEX DG at approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> after the ELAP as indicated on the SOE timeline.
17 3.2.4.2.C Equipment Cooling (Ventilation) - Confirm the NOT STARTED acceptability of the battery room temperatures (extreme Expect completion to be documented in August hot or extreme cold) on battery performance.
2015 Update.
18 3.2.4.2.0 Equipment Cooling (Ventilation) - Confirm the NOT STARTED acceptability of the hydrogen buildup in the battery Expect completion to be documented in August room during charging.
2015 Update.
19 3.2.4.4.A Lighting-Confirm the lighting provisions for all areas NOT STARTED within the auxiliary building where FLEX equipment is Expect completion to be documented in August deployed as well as the outdoor areas where FLEX 2015 Update.
equipment is deployed.
20 3.2.4.4.8 Communications-Confirm that upgrades to the site's IN PROGRESS communications systems have been completed.
Expect completion to be documented in August 2015 U_Q_date.
I I
I I
LIC-15-0032 Enclosure, Attachment 2 Page 7 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 21 3.2.4.5.A Protected and Internal Locked Area Access-Confirm NOT STARTED how the provisions for access to protected areas and Expect completion to be documented in August internally locked areas are incorporated into the FLEX 2015 Update.
mitigation strategies.
22 3.2.4.7.A Water Sources-Confirm that the licensee addresses COMPLETE the impacts of water chemistry from the various onsite A water chemistry evaluation (SL-011688, sources for potential use in FLEX strategy installed and "Evaluation of Alternate Cooling Water Sources portable equipment.
for Use in Mitigating a Beyond Design Basis External Event") was conducted to determine the viability of existing water sources to support FLEX makeup needs regarding maintenance of heat transfer and corrosion resistance. FLEX strategies use insights from this report to prioritize water sources and determine when and how to utilize Regional Response Center equipment.
23 3.2.4.8.A Electrical Power Sources-Confirm the technical basis IN PROGRESS for the selection and size of the FLEX generators to be Expect completion to be documented in August used in support of the coping strategies and the 2015 Update.
planned approach for fault protection and electrical separation between existing power sources and the FLEX power sources.
24 3.2.4.9.A Portable Equipment Fuel - Confirm the total fuel IN PROGRESS consumption needs when FLEX equipment designs are Expect completion to be documented in August finalized.
2015 Update.
LIC-15-0032 Enclosure, Attachment 2 PageS Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 25 3.2.4.10.A Load Reduction to Conserve DC Power-Confirm if the ON HOLD non-1 E battery modification becomes a plan revision to OPPD has evaluated the ELAP capabilities of extend the battery life of the existing Class 1 E current class 1 E DC batteries, along with other batteries and that any changes to the FLEX mitigation applications requiring portable generators to strategies have been incorporated.
support FLEX strategies and has concluded that restoration of power to a battery charger prior to depletion of the current batteries provides more benefits than adding a non-1 E battery to increase the depletion time on the 1 E batteries. OPPD has placed this modification on hold pending the completion of the design for EC 60820, "2016 RFO Electrical Connections-FLEX." Once the successful design of the FLEX electrical distribution strategy is assured, OPPD will cancel the non-1 E battery modification.
LIC-15-0032 Enclosure, Attachment 2 Page 9 Status of Interim Staff Evaluation Open Item I Confirmatory Items Item NRC Ref.
Description Status August 2014 Update 26 3.3.1.A Use of Portable Pumps - Confirm that the number of IN PROGRESS FLEX pumping equipment for accessing the UHS OPPD currently plans to install a qualified well as during the Phase 2 coping strategies me~ts the sp_are a diverse means of supplying ultimate heat sink (N+1) capability. One fire truck and two nver draft1ng (UHS) water. The use of the river drafting pumps pumps are provided to access the UHS. Confir_m and/or the fire truck would then become the whether the river drafting pumps alone can ach1eve the second "qualified" strategy for accessing the mitigation strategy objectives (without the use of the_
UHS. This approach is consistent with the fire truck) during both the flooded and non-flooded s1te penultimate paragraph in NEI 12-06, Section conditions. Alternately, confirm implementation of a 3.2.2, which states, "it is also acceptable to have qualified well as a diverse alternate source of a long multiple strategies to accomplish a function." EC term water supply.
64447 is being developed to design the FLEX well. If, during the design process, it is determined that a qualified well cannot be constructed, OPPD will re-evaluate the capabilities of the existing draft pump/fire truck strategy to ensure that the N+1 requirement is met.
Expect completion of design documentation by August 2015 Update. Expect completion of well and/or and final placement of FLEX equipment for flooding response by August 2016 Update.
27 3.4.A Off-Site Resources-Confirm how conformance with IN PROGRESS NEI 12-06, Section 12.2 guidelines 2 through 10 will be Expect completion of Regional Response Center met.
"Playbook" by February 2016 Update.