RS-15-099, Report of Full Compliance with 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)

Report of Full Compliance with 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)

ML15183A235
Person / Time
Site:	Calvert Cliffs
Issue date:	07/02/2015
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-099, TAC MF1140, TAC MF1141, TAC MF1142, TAC MF1143
Download: ML15183A235 (34)

Text

Exelon Generation Order No. EA-12-049 RS-15-099 July 2, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Unit 2 Renewed Facility Operating License No. DPR-69 NRC Docket No. 50-318

Subject:

Report of Full Compliance with 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, "Issuance of Order to Modify 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. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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 26, 2012

5. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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

6. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to 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 March 8, 2013

7. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Calvert Cliffs Nuclear Power Plant, 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), dated August 27, 2013

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page2

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) - February 2014 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

9. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) -August 2014 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 26, 2014

10. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) - February 2015 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 20, 2015 (RS 054)

11. Letter from J. S. Bowen (NRC) to J. A. Spina (CENG), Calvert Cliffs 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. MF1142 and MF1143),

dated December 17, 2013

12. NRC Letter, Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012

13. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to March 12, 2012, Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated October 13, 2014

14. Letter from J. Paige (NRC) to M. G. Korsnick (CENG), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1142, MF1143, MF1140, and MF1141), dated February 20,2015

15. Letter from M. G . Korsnick (CENG) to Document Control Desk (NRC), Request for Schedule Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 20, 2015 (RS-15-078)

16. Letter from W. M. Dean (NRC) to G. H. Gellrich (EGC), Calvert Cliffs Nuclear Power Plant, Unit 2 - Relaxation of the Schedule Requirements for Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 4, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRG" or "Commission") issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference1) to Exelon Generation Company, LLC (EGC), previously Constellation Energy Nuclear Group, LLC (Exelon, the licensee) for Calvert Cliffs Nuclear Power Plant, LLC (CCNPP), Units 1 and 2. Reference 1 was immediately effective and directed Constellation Energy Nuclear Group, LLC (GENG) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 3 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.

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 (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision O (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the GENG initial status report regarding mitigation strategies. References 5 and 6 provided the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 OIP and its supplement, respectively.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 7, 8, 9, and 10 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

In Reference 16, the NRC granted a relaxation of the schedule requirement of the Order for full implementation for Calvert Cliffs Nuclear Power Plant, Unit 2 until no later than 60 days following the restart from the Spring 2015 refueling outage to allow sufficient time to complete construction of the FLEX Storage Robust Building, as requested in Reference 15.

The purpose of this letter is to provide the report of full compliance with 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) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Calvert Cliffs Nuclear Power Plant, Unit 2.

Calvert Cliffs Nuclear Power Plant, Unit 2 has developed, implemented, and will maintain the 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 in response to Order EA-12-049. The information provided herein documents full compliance for Calvert Cliffs Nuclear Power Plant, Unit 2 with Reference 1.

OIP open items have been addressed and closed as documented in References 7, 8, 9, and 1O, and below, and are considered complete pending NRC closure. EGC's response to the NRC Interim Staff Evaluation (ISE) open items identified in Reference 11 have been addressed and closed as documented in References 7, 8, 9, and 10, and are considered complete pending NRC closure. EGC's response to the NRC ISE confirmatory items identified in Reference 11 have been addressed and closed as documented in Reference 14. EGC's response to the NRC ISE confirmatory items identified as open in Reference 14 are addressed below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in Reference 14, and below, and are considered complete pending NRC closure. The following table provides completion references for each OIP open item, NRC ISE open or confirmatory item, and NRC Audit Report open item.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page4 Overall Integrated Plan Open Items OIP Open Item Completion Response Reference OIP Open Item No. 1 Reference 10 Reference 8 and updated with this submittal as provided OIP Open Item No. 2 below OIP Open Item No. 3 Reference 1O OIP Open Item No. 4 Reference 10 Reference 7 and updated with this submittal as provided OIP Open Item No. 5 below OIP Open Item No. 6 Reference 1o Reference 7 and updated with this submittal as provided OIP Open Item No. 7 below OIP Open Item No. 8 Reference 10 OIP Open Item No. 9 Reference 1O OIP Open Item No. 10 Reference 8 OIP Open Item No. 11 Reference 7 OIP Open Item No. 12 Reference 8 OIP Open Item No. 13 Reference 1O OIP Open Item No. 14 Reference 1O OIP Open Item No. 15 References 8 and 10 OIP Open Item No. 16 Deleted - Addressed in Reference 7 OIP Open Item No. 17 Reference 1O OIP Open Item No. 18 Reference 8 Reference 8 and updated with this submittal as provided OIP Open Item No. 19 below OIP Open Item No. 20 Deleted - Addressed in Reference 7 Reference 8 and updated with this submittal as provided OIP Open Item No. 21 below OIP Open Item No. 22 Deleted - Addressed in Reference 8 OIP Open Item No. 23 Reference 1O Reference 8 and updated with this submittal as provided OIP Open Item No. 24 below Reference 1O and updated with this submittal as provided OIP Open Item No. 25 below OIP Open Item No. 26 Reference 10 OIP Open Item No. 27 Reference 10 OIP Open Item No. 28 Reference 1O

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 5 OIP Open Item Completion Response Reference OIP Open Item No. 29 Reference 8 Reference 8 and updated with this submittal as provided OIP Open Item No. 30 below Reference 7 and updated with this submittal as provided OIP Open Item No. 31 below OIP Open Item No. 32 Deleted- Addressed in Reference 8 OIP Open Item No. 33 Deleted - Addressed in Reference 7 Reference 8 and updated with this submittal as provided OIP Open Item No. 34 below OIP Open Item No. 35 Deleted - Addressed in Reference 8 OIP Open Item No. 36 Reference 10 OIP Open Item No. 37 Reference 1O OIP Open Item No. 38 Updated with this submittal as provided below OIP Open Item No. 39 Reference 1O OIP Open Item No. 40 Reference 1O OIP Open Item No. 41 Reference 9 Reference 8 and updated with this submittal as provided OIP Open Item No. 42 below Reference 8 and updated with this submittal as provided OIP Open Item No. 43 below OIP Open Item No. 44 Deleted - Addressed in Reference 7 OIP Open Item No. 45 Reference 10 Reference 8 and updated with this submittal as provided OIP Open Item No. 46 below Reference 8 and updated with this submittal as provided OIP Open Item No. 47 below OIP Open Item No. 48 Deleted - Addressed in Reference 8 Reference 8 and updated with this submittal as provided OIP Open Item No. 49 below OIP Open Item No. 50 Reference 7 OIP Open Item No. 51 Deleted - Addressed in Reference 7 OIP Open Item No. 52 Deleted - Addressed in Reference 9 OIP Open Item No. 53 Reference 10 OIP Open Item No. 54 Deleted - Addressed in Reference 8 OIP Open Item No. 55 Reference 1o Reference 8 and updated with this submittal as provided OIP Open Item No. 56 below Reference 8 and updated with this submittal as provided OIP Open Item No. 57 below

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 6 OIP Open Item Completion Response Reference Reference 7 and updated with this submittal as provided OIP Open Item No. 58 below Reference 7 and updated with this submittal as provided OIP Open Item No. 59 below OIP Open Item No. 60 Duplicate to OIP Open Item No. 55 OIP Open Item No. 61 Reference 9 OIP Open Item No. 62 Reference 9 OIP Open Item No. 63 Reference 7 OIP Open Item No. 64 Reference 7 OIP Open Item No. 65 Reference 9 OIP Open Item No. 66 Reference 9 OIP Open Item No. 67 Reference 9 OIP Open Item No. 68 Reference 9 OIP Open Item No. 69 Deleted - Addressed in Reference 8 OIP Open Item No. 70 Reference 1O OIP Open Item No. 71 Reference 10 OIP Open Item No. 72 Reference 8 OIP Open Item No. 73 Deleted - Addressed in Reference 8 OIP Open Item No. 74 Deleted - Addressed in Reference 10 OIP Open Item No. 75 Reference 1O Reference 8 and updated with this submittal as provided OIP Open Item No. 76 below OIP Open Item No. 77 Reference 8 OIP Open Item No. 78 Deleted - addressed in Reference 7 OIP Open Item No. 79 Reference 1O OIP Open Item No. 80 Deleted - Addressed in Reference 9 OIP Open Item No. 81 Reference 9 OIP Open Item No. 82 Reference 9 OIP Open Item No. 83 Reference 9 OIP Open Item No. 84 Deleted - Addressed in Reference 1O OIP Open Item No. 85 Deleted - Addressed in Reference 1O OIP Open Item No. 86 Deleted - Addressed in Reference 9 OIP Open Item No. 87 Reference 1O OIP Open Item No. 88 Reference 1O

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 7 OIP. Open Item Completion Response Reference OIP Open Item No. 89 Reference 10 OIP Open Item No. 90 Updated with this submittal as provided below OIP Open Item No. 91 Updated with this submittal as provided below Reference 8 and updated with this submittal as provided OIP Open Item No. 92 below OIP Open Item No. 93 Deleted - Addressed in Reference 8 OIP Open Item No. 94 Reference 1O Interim Staff Evaluation Open Items ISE Open Item Completion Response Reference Item No. 3.2.1.1.A Reference 1O Item No. 3.2.1.1.B Reference 9 Item No. 3.2.1 .8.A Reference 10 Interim Staff Evaluation Confirmatory Items ISE Confirmatory Item Completion Response Reference Item No. 3.1.1 .1.A Reference 10 Item No. 3.1.1.1.B Reference 10 Item No. 3.1.1 .4.A Reference 1O Item No. 3.1.2.2.A Reference 10 Item No. 3.1.2.2.B Reference 10 Item No. 3.1.2.2.C Reference 1o Item No. 3.1 .3.2.A Reference 9 Item No. 3.1.4.2.A Reference 9 Item No. 3.1.4.2.B Reference 9 Item No. 3.2.1 .2.A Reference 9 Item No. 3.2.1.5.A Reference 9 Item No. 3.2.1 .6.A Reference 9 Item No. 3.2.1.6.B Updated with this submittal as provided below Item No. 3.2.1.7.A Reference 9 Item No. 3.2.1.9.C Reference 9 Item No. 3.2.1.9.D Reference 8

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 8 ISE Confirmatory Item Completion Response Reference Item No. 3.2.2.A Reference 9 Item No. 3.2.2.8 Reference 1O Item No. 3.2.3.A References 7 and 10 Item No. 3.2.4.1.A Reference 9 Item No. 3.2.4.2.A Reference 9 Item No. 3.2.4.2.8 Reference 9 Item No. 3.2.4.2.C Reference 9 Item No. 3.2.4.2.D Reference 9 Item No. 3.2.4.2.E Reference 9 Item No. 3.2.4.4.A Reference 9 Item No. 3.2.4.4.8 Reference 9 Item No. 3.2.4.5.A Reference 10 Item No. 3.2.4.6.A Reference 9 Item No. 3.2.4.6.8 Reference 9 Item No. 3.2.4.6.C Reference 9 Item No. 3.2.4.8.A Reference 10 Item No. 3.2.4.8.8 Reference 1o Item No. 3.2.4.9.A Reference 10 Item No. 3.2.4.1 O.A Updated with this submittal as provided below Item No. 3.2.4.10.8 Reference 9 Item No. 3.4.A Reference 10 NRC Audit Report Open Items Audit Open Item Completion Response Reference AQ 3 (AQ 4) Reference 14 AQ 16 (AQ 18) Reference 14 AQ 37 (AQ 47) Reference 14 SE Review Item 1 Reference 14 ISE Cls 3.1.1.4.A, 3.1.2.2.A, 3.1.2.2.8, and 3.2.4.5.A, Staging Updated with this submittal as provided below Areas ISE Cl 3.1.3.2.A, Debris Updated with this submittal as provided below Removal ISE Cl 3.1.4.2.A, Impact of Updated with this submittal as provided below Extreme Temperature

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 9 Audit Open Item Completion Response Reference Environments ISE Cls 3.2.1.6.A, 3.2.1.6.B, and AQ 23 (AQ27), Sequence of Updated with this submittal as provided below Events ISE Cl 3.2.1. 7.A and AQ 38 (AQ 48), Shutdown and Refueling Updated with this submittal as provided below Modes ISE Cl 3.2.1.9.C, Engineering Evaluations of Phase 3 Updated with this submittal as provided below Equipment ISE Cl 3.2.4.9.A and AQ 43 Reference 10 (AQ54), Fuel Oil Consumption ISE Cl 3.2.4.1O.A and AQ 34 Updated with this submittal as provided below (AQ 39), DC Load Shedding ISE Cl 3.4.A, Off-Site Resources Reference 10 AQ 1 (AQ2), Power Supply Updated with this submittal as provided below AQ 21 (AQ 25), DG Sizing Reference 14 Calculations AQ 32 (AQ 37), Electrical Updated with this submittal as provided below Isolation SE Review Item 4, Safety Updated with this submittal as provided below lniection Tanks (SITs)

SE Review Items 5 and 6, RCS Updated with this submittal as provided below Pump Hydraulic Analysis The following table documents the completion of the final remaining open items. As previously stated, EGC provides the response for the following items and considers them to be complete for Calvert Cliffs Nuclear Power Plant, Unit 2.

Item Description Status OIP Open Item No. 2 Com12lete Implement a design change to install Various Engineering Change Packages (ECP) permanent protected FLEX equipment have been prepared to install permanent connection points protected FLEX equipment connection points.

They are summarized below:

1. ECP-14-000024 was prepared to establish contingency actions to provide back-up power to the Mansell RLMS to ensure that the RCS level can be adequately monitored during an ELAP event with the plant in refueling mode and the reactor head removed.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 10 Item Description Status

• Loops for the following instruments have been reconfigured to receive safety-related 120VAC vital power from safety-related instrument buses 2Y01 and 2Y02:

- Reactor cavity temperature

- Safety injection tank level

- Safety injection tank pressure

- Containment temperature

2. ECP-14-000052 provides the necessary electrical modifications to connect:

• FLEX 480VAC 500kW/625kVA portable diesel generators to Unit 2 480 VAC Load Centers 21 B and 24A. This provides the means to restore 480 VAC distribution power essential to the CCNPP Unit 2 FLEX transitional phase (Phase 2) coping strategies to provide power to the battery chargers and other critical AC equipment.

• FLEX 100 kW portable diesel generator to Reactor Motor Control Centers 204 (cross-connected with MCC 214). This provides the means to restore 480 VAC distribution power essential to the CCNPP Unit 2 FLEX transitional phase (Phase 2) coping strategies by providing power to the inverter backup bus (which can power the 120VAC vital instrument bus), the SIT Outlet Motor Operated Valves (MOVs), the AFW Pump Room Vent Fans, and other critical AC equipment.

3. ECP-14-000089 was prepared to install a new, permanent branch tee with a hose connection and an isolation valve in the sat ety related portion of 6" Auxiliary Feedwater motor-driven pump, cross-connect pipe. This new connection provides an additional means of supplying makeup water to the steam generators.

4. ECP-14-000102 was prepared to allow a portable FLEX pump to take suction from

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 11 Item Description Status Refueling Water Tank (RWT) 2TKRWT21 to supply water to the Reactor Coolant System (RCS) using a portable FLEX pump and temporary hose that enters via newly-installed HPSI header connection valves.

5. ECP-14-000375 was prepared to add instrument air connections for connecting a portable air compressor to the instrument air system for each unit.

6. ECP-14-000376 was prepared to accomplish the following:

• The installation of a new missile-protected enclosure around the No. 11 Well Water house power connection.

• A new hose connection to route well water to the 12 Condensate Storage Tank.

OIP Open Item No. 5 Comglete Define implementation routes upon On-site finalizing a location or locations for FLEX equipment storage location(s). Four deployment routes from the FLEX Storage Robust Building have been selected for Phase 2 portable FLEX equipment. One has been defined as the preferred route and three as alternate routes. They are:

• Path 1: (Preferred) Calvert Cliffs Parkway to Camp Canoy Road to road along switchyard to the restored sally port

• Path 2: (Alternate) Calvert Cliffs Parkway to Camp Canoy Road to ISFSI Haul Route

• Path 3: (Alternate) Calvert Cliffs Parkway by the ISFSI to ISFSI Haul Route

• Path 4: (Alternate) Old North Road Off-site Primary and alternate deployment routes for Phase 3 portable FLEX equipment are described in the SAFER Response Plan for

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 12 Item Description Status Calvert *cliffs (CC-CA-118-1001)

OIP Open Item No. 7 Comglete Design and build a protected storage Requirements and options to provide location or locations for the FLEX reasonably protected onsite storage of FLEX equipment. Ensure the design meets portable equipment have been evaluated, the requirements of NEI 12-06. resulting in the selection of FLEX equipment storage building type and location that meet the specific protection requirements described in NEI 12-06.

Onsite FLEX storage consists of one building.

A robust structure, the FLEX Storage Robust Building (FSRB) designed to meet the requirements of NEI 12-06 houses the N equipment and N+ 1 equipment for CCNPP Unit

2. The FSRB is constructed of reinforced concrete approximately 60' wide x 140' long x 21' high and located outside of the Protected Area to the west. The FSRB is designed for seismic, wind, tornado and tornado missiles and flooding conditions. The building is equipped with heating and ventilation units for internal environmental control. The stored equipment is secured to prevent seismic interaction.

OIP Open Item No. 19 Comglete Implement a design change to re- Engineering Change Package, ECP power the [Safety Injection Tank] SIT 000024, was prepared to re-power the Safety level and pressure indicators from a Injection Tank (SIT) level and pressure vital 120 VAC instrument bus. indicators from vital 120 VAC instrument buses 2Y01 and 2Y02 to ensure the SIT wide range level and pressure indication loops are operational during extended loss of AC power (ELAP) events. Work Order C92672259, which implements ECP-14-000024 for Unit 2, has been completed.

OIP Open Item No. 21 Comglete Original ogen item text: Engineering Change Package, ECP Implement design changes to install 000089, was prepared to install a new, "plug and play" protected hose permanent branch tee with a hose connection connections for the portable alternate and an isolation valve in the safety-related

[Auxiliary Feedwater] AFW pump to portion of a 6" Auxiliary Feedwater motor-driven

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 13 Item Description Status AFW on the exterior of the Auxiliary pump, cross-connect pipe. This new Building west wall with piping run to connection provides an additional means of the 27 ft. East penetration Rooms to supplying makeup water to the steam connect to the AFW to SIG headers. generators.

Modified ogen item text:

Work Order C92672325, which implements Utilize flexible hose to connect a FLEX ECP-14-000089 tor Unit 2, has been completed.

pump to a newly installed, dedicated hose connections (one per unit) located on the motor driven AFW pump cross-connect lines on the 5 ft.

elevation of the Auxiliary Building.

OIP Open Item No. 24 Comglete Original 012en item text: Attachments 1 and 2 of FSG-4 list the 125 VDC breakers and 120 V AC breakers which are Implement a design change to clearly opened during the performance of load identify the set of DC load breakers shedding. These breakers have been marked that will either be left energized or load with a sticker with black FLEX lettering over a shed by identifying the selected reflective blue background.

breakers by their unique numbers and load title.

Modified open item text:

Clearly identify (label) the DC load breakers that will be opened to extend battery life.

OIP Open Item No. 25 Comglete Implement a procedure or FSG to FSG-4, ELAP DC Bus Load Shed and perform the DC load shedding. Management, provides actions to remove loads from the 125 VDC batteries to extend battery life during an ELAP and repowering load centers and motor control centers with FLEX equipment.

OIP Open Item No. 30 Comglete Implement a design change to provide Engineering Change Package, ECP dedicated hose connections and 000102, was prepared to provide dedicated piping to the Safety Injection System. hose connections via HPSI header connection by installing 2 new valves and a hose connection to the Safety Injection System.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 14 Item Description Status Work Order C92672289, which implements this portion of ECP-14-000102 for Unit 2, has been completed.

OIP Open Item No. 31 ComQlete Develop a procedure or FSG to mimic FSG-3, Alternate Low Pressure Feedwater, the AFW makeup strategy described provides the necessary actions to utilize the in ERPIP-611, Attachment 1. FLEX equipment at CCNPP to provide a f eedwater source to the steam generators when the steam driven auxiliary feedwater pumps are no longer available.

This FSG includes a description of the alternate strategy for AFW makeup, as described in ERPIP-611, Attachment 1.

OIP Open Item No. 34 ComQlete Install a design change to add hose Engineering Change Package, ECP connections at 11 and 21 Refueling 000102, was prepared to provide a hose Water Storage Tanks (RWT) for connection to the RWT 2TKRWT21. Work makeup and suction for the FLEX Order C92672307, which implements ECP pumps. 000102 for Unit 2, has been completed.

OIP Open Item No. 38 ComQlete Perform an analysis to determine The following calculations determined the station battery coping time with DC station battery coping time with the load shedding. Analysis should implementation of DC load shedding associated consider battery age, battery with the station response to an ELAP. In performance without battery room calculation CA08256, Battery 11 was shown to ventilation, load, and load duration have a maximum coping time of 7.07 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> prior to completion of DC load during an ELAP event. For Battery 12, shedding. calculation CA08257 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In calculation CA08258, Battery 21 was shown to last 7.33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> until a limiting voltage was reached using an ELAP Model. For Battery 22, calculation CA08259 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The analyses considered battery age, battery performance without battery room ventilation,

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 15 Item Description Status load, and load duration prior to completion of DC load shedding.

OIP Open Item No. 42 Com12lete Implement a design change to Engineering Change Package, ECP connect a FLEX 480 VAC Diesel 000052, provides the necessary electrical generator to either of the A or B train modifications to connect the FLEX 480VAC 480 VAC load centers on each unit to 500kW/625kVA portable diesel generators to provide power to the battery chargers Unit 2 480 VAC Load Centers 21 B and 24A.

and other critical AC equipment. This ECP provides the means to restore 480 VAC distribution power essential to the CCNPP Unit 2 FLEX transitional phase (Phase 2) coping strategies to provide power to the battery chargers and other critical AC equipment.

Work Order C92681886, which implements ECP-14-000052 for Unit 2, has been completed.

OIP Open Item No. 43 ComQlete Implement a design change to provide Engineering Change Package, ECP-14-000052, direct connection of a portable 100 kW provides the necessary electrical modifications diesel generator to reactor [Motor to connect a portable 100 kW diesel generator Control Centers] MCCs 104 or 114 to Reactor Motor Control Centers 204 (cross-and 204 or 214 to provide power to connected to MCC 214) to provide power to the the inverter backup bus (which can inverter backup bus (which can power the power the 120VAC vital bus), the SIT 120VAC vital instrument bus), the SIT Outlet Outlet [Motor Operated Valves] MOVs, Motor Operated Valves (MOVs), the AFW Pump and the AFW Pump Room Vent Fans. Room Vent Fans, and other critical AC equipment.

Work Order C92681886, which implements ECP-14-000052 for Unit 2, has been completed.

OIP Open Item No. 46 ComQlete Implement a procedure to connect a FSG-4, ELAP DC BUS LOAD SHED AND 4160 VAC RRC DG to either of the A MANAGEMENT, has been prepared and or B Train 1E 4160 VAC Buses on approved for use to connect two 4, 160 VAC each unit to provide power for Phase NSRC Gas Turbine Generators (GTG} to either

3. the 14 or 21 4KV buses to provide power for Phase 3, via the 1B or 2A DG disconnects, respectively.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 16 Item Description Status OIP Open Item No. 47 Comglete Develop procedures or FSGs for FSG-4, ELAP DC BUS LOAD SHED AND repowering vital 4160 VAC Class 1E MANAGEMENT, has been prepared and buses from RRC FLEX 4KV DGs. approved for use to connect two 4, 160 VAC NSRC Gas Turbine Generators (GTG) to either the 14 or 21 4KV buses to provide power for Phase 3, via the 1B or 2A DG disconnects, respectively.

OIP Open Item No. 49 Comglete Implement a design change to power Engineering Change Package, ECP containment dome and reactor cavity 000024, was prepared to repower the temperatures instrumentation from a Containment Dome and Reactor Cavity vital 120 VAC instrument bus. temperature instrumentation loops from a vital 120 VAC instrument bus to maintain their functionality during ELAP events.

Work Orders C92672267 and C92672269, which implement ECP-14-000024 for Unit 2, have been completed.

OIP Open Item No. 56 Comglete Implement a design change to provide Engineering Change Package, ECP a 6" hose connection to each RWT. 000102, was prepared to provide a 6" hose connection to the 21 RWT. Work Order C92672307, which implements ECP 000102 for Unit 2, has been completed.

OIP Open Item No. 57 Comglete Original 012en item text: Engineering Change Package, ECP Implement a design change to provide 000105, Fukushima - Related Design Changes dedicated hose connections to the to Implement FLEX Phase 3 Long Term Coping SFP Cooling system. Strategies, was prepared to provide a tool to allow the use of a hose connection for makeup Modifed 012en item text: to the Spent Fuel Pool (SFP) to support FLEX Provide the necessary means (i.e., activities. The tool consists of an 18-inch long temporary equipment, tools and flanged spool piece with a 3-inch hose procedures) to supply makeup water connection. In the event of a BDBEE, the to the SFP via the SFP cooling removal spool piece in either line, 8"-HC4-1038 system. or 8"-HC4-2038 will be removed and replaced with the tool to provide a hose connection that can be used for makeup to the SFP.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 17 Item Description Status Portable FLEX pumps and hoses would be used to provide makeup to the SFP via the SFP Cooling System from the Chesapeake Bay. As part of this design change, a hydraulic analysis was performed in CA09973, Rev. 0, "Hydraulic Analyses for FLEX Portable Pump for SFP Makeup", to size the portable pumps and hoses to ensure adequate flow can be delivered to the SFP based on the requirements provided in NEI 12-06.

OIP Open Item No. 58 Comglete Develop and implement procedures or The FSGs that execute the CCNPP FLEX FSGs that include the SFP Cooling Strategy for Spent Fuel Pool (SFP) cooling are FLEX makeup flow path. described below.

During Phase 1, FSG-15, Alignment for Area Cooling, sets up for ventilation of the SFP area within two hours of the event. FSG-5, Initial Assessment and FLEX Equipment Staging, stages the hoses and pump required for surface cooling of the SFP within eight hours of the event.

During Phase 2, FSG-11, Alternate SFP Makeup and Cooling, provides actions to restore Spent Fuel Pool (SFP) level using the FLEX SFP Makeup Pump (Godwin HL5MS Ori-Prime Pump) and installation of required hoses.

It also installs the FLEX SFP Makeup spool piece in the SFP Heat Exchanger Room. The Shift Manager will determine whether to set up the FLEX SFP Makeup pump and hose trailer at either the Circulating Water Discharge Structure or the Intake Structure opening behind the Traveling Screens.

During Phase 3, FSG-11 is utilized to monitor and maintain SFP level between 50 and 67 feet by using the FLEX SFP Makeup Pump by injecting Chesapeake Bay water into the SFP system. An alternate method would utilize an NSRC portable pump as the motive force for SFP make-up.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 18 Item Description Status FSG-ATT, Attachments, provides the operating instructions for the major pieces of FLEX equipment, which are used to provide temporary power, water, air, etc., during an ELAP. Attachment 105, FLEX SFP Makeup Pump, provides the operating instructions for the SFP Makeup Pump.

OIP Open Item No. 59 ComQlete Develop procedures or FSGs that Actions described in the referenced FSGs are mimic the ERPIP-612 sections for similar to those presented in ERPIP-612. These SFP makeup and SFP spray. FSGs, which implement the CCNPP FLEX Strategy for Spent Fuel Pool (SFP) cooling, are described below.

During Phase 1, FSG-15, Alignment for Area Cooling, sets up for ventilation of the SFP area within two hours of the event. FSG-5, Initial Assessment and FLEX Equipment Staging, stages the hoses and pump required for surface cooling of the SFP within eight hours of the event.

During Phase 2, FSG-11, Alternate SFP Makeup and Cooling, provides actions to restore Spent Fuel Pool (SFP) level using the FLEX SFP Makeup Pump (Godwin HL5MS Ori-Prime Pump) and installation of required hoses.

It also installs the FLEX SFP Makeup spool piece in the SFP Heat Exchanger Room. The Shift Manager will determine whether to set up the FLEX SFP Makeup pump and hose trailer at either the Circulating Water Discharge Structure or the Intake Structure opening behind the Traveling Screens.

During Phase 3, FSG-11 , Alternate SFP Makeup and Cooling, is utilized to monitor and maintain SFP level between 50 and 67 feet by using the FLEX SFP Makeup Pump by injecting Chesapeake Bay water into the SFP system.

An alternate method would utilize an NSRC portable pump as the motive force for SFP make-up.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 19 Item Description Status FSG-ATT, Attachments, provides the operating instructions for the major pieces of FLEX equipment which are used to provide temporary power, water, air, etc., during an Extended Loss of AC Power (ELAP). Attachment 105, FLEX SFP Makeup Pump, provides the operating instructions for the SFP Makeup Pump.

OIP Open Item No. 76 Com12lete Implement a design change to modify To be fully compliant with Recommendation the Fixed Dedicated Satellite Phone 9.3, Exelon Generation Company (EGG)

System to provide protection from purchased and distributed portable, Iridium external hazards, and transmitter and satellite phones with 24-hr batteries.

antennas protected from seismic, wind, and wind-driven missiles, including back-up power supply capable of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operation for the system.

OIP Open Item No. 90 ComQlete Provide a procedure governing the Consumables (as identified in Response to maintenance and distribution of the Open Item 89 in the February 2015 Status consumables that will be stocked to Report) are stored in a designated area within support at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of site the Technical Support Center (TSC). The TSC

.operation independent of offsite is an environmentally controlled location. An support. inventory listing of the consumables will be maintained within the designated FLEX Consumables area. The storage area is administratively controlled.

CCNPP does not have a specific procedure developed for FLEX consumables.

Maintenance of the supplies being held in the TSC will be per existing CCNPP normal stock process of maintaining "min/max" quantities on hand. ERPIP-8.1, EQUIPMENT CHECKLIST, provides Emergency Response Organization (ERO) Facility Inventory Checklists for use during periodic inventory verifications, drills and exercises, and actual events. This existing process will confirm the designated consumables are in their designated area and food consumables are within their shelf life.

Reorderinq and replacement of items

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 20 Item Description Status approaching end of shelf life will be done as appropriate.

OIP Open Item No. 91 Comglete Develop a strategy to protect onsite The following represents the CCNPP strategy consumables for use after a BDBEE. for protecting onsite consumables for use after a BDBEE:

• Consumables (as identified in Response to Open Item 89) are stored in a designated area within the TSC. The TSC is an environmentally controlled location. An inventory listing of the consumables will be maintained within the designated FLEX Consumables area. The storage area is administratively controlled.

• Food consumables include bottled water and protein/Power Bars. Bottled water has a shelf life of 2+ years; protein/Power Bars typically have a shelf life of 1-2 years.

• Maintenance of supplies being held in the TSC will be per the existing normal stock process of maintaining "min/max quantities on hand. ERPIP-B.1, EQUIPMENT CHECKLIST, provides Emergency Response Organization (ERO) Facility Inventory Checklists for use during auditing, drills and exercises, and actual events.

This existing process will confirm the designated consumables are in their designated area and food consumables are within their shelf life; reordering and replacement of items approaching end of shelf life will be done as appropriate.

OIP Open Item No. 92 Comglete Develop equipment operating FLEX Operating Guides are prepared for all procedures or FSGs, considering portable FLEX and support equipment ( e.g.,

vendor technical manual operating 100 kW DGs, 500 kW DGs, Air Compressors, procedures, for each of the pieces of Alternate Feedwater Pump, SFP Makeup portable FLEX equipment that will be Pump, Wheeled Bobcat, Front Loader, Tow procured. Truck, etc.). A typical Operating Guide includes sections for Precautions, Pre-Start Checks,

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 21 Item Description Status Startup, Monitoring, Manual Shutdown, and Emergency Shutdown. They include annotated photos of equipment and are based on vendor technical manual operating procedures. They are laminated and attached to the respective equipment.

The FLEX Operating Guides are also attachments to FSG-ATT, FSG Attachments.

ISE Cl No. 3.2.1.6.B Comglete The licensee has not completed final The validation of FLEX strategies and analysis regarding validation of the procedures has been performed using a series action times reported in the Sequence of simulator scenarios, plant walk-downs, and of Events, including any SOE changes table-top discussions. The validations were that may result from ongoing performed following a formal Validation Test evaluations for: RCP seal leakage, Plan, which provided reasonable assurance plant specific CENTS analysis, and that the required tasks, manual actions and any revised battery load shed decisions for FLEX strategies are feasible and analysis. may be executed within the constraints of the Overall Integrated Plan (OIP) Sequence of Events. Each validation plan performed a qualitative assessment of the margin between the time taken for a time-sensitive action (TSA) under normal conditions versus the time required to implement the strategy under a simulated BDBEE.

A fin al analysis was performed to show that FLEX strategies including TSAs could be performed within the time and resource constraints of the 01 P and Phase 2 Staffing Assessment. This independent analysis assured that the testing methods and results were valid and that all assumptions made were reasonable.

A time-motion study (CC-VP-001, Rev. O) was conducted to validate that DC load shedding can be accomplished on each unit in one hour using the FLEX Support Guideline. The time-motion study for both units demonstrated that the deep load shed can be accomplished in 50 minutes using one operator; much less than the one hour required for one unit.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 22 Item Description Status Attachment 8 of the CCNPP Program Document (CC-CA-118) shows the Sequence of Events Timeline and validation tests associated with time-constrained activities.

ISE Cl No. 3.2.4.1 O.A Com12lete On page 19 of the Integrated Plan, the FSG-4, ELAP DC Bus Load Shed and licensee identified Open Items: to Management, provides actions to remove loads implement a design change to clearly from the 125 VDC batteries to extend battery identify the set of [DC] load breakers life during an ELAP and repowering load that will either be left energized or load centers and motor control centers with FLEX shed by identifying the selected equipment. Attachments 1 and 2 of FSG-4 list breakers by their unique numbers and the 125 VDC breakers and 120 VAC breakers load title; to implement a procedure or which are opened during the performance of FSG to perform the [DC] load load shedding. These breakers have been shedding; and to complete a time- marked with a sticker with black FLEX lettering motion study to validate that DC load over reflective blue background.

shedding can be accomplished on each unit in one hour. A time-motion study (CC-VP-001, Rev. 0) was conducted to validate that DC load shedding can be accomplished on each unit in one hour using the FLEX Support Guideline. The time-motion study for both units demonstrated that the deep load shed can be accomplished in 50 minutes using one operator; much less than the one hour required for one unit.

The following calculations determined the station battery coping time with the implementation of DC load shedding associated with the station response to an ELAP. In calculation CA08256, Battery 11 was shown to have a maximum coping time of 7.07 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> during an ELAP event. For Battery 12, calculation CA08257 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In calculation CA08258, Battery 21 was shown to last 7 .33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> until a limiting voltage was reached using an ELAP Model. For Battery 22, calculation CA08259 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 23 Item Description Status Complete ISE Cl No. 3.1.1.4.A The CCNPP SAFER Response Plan (Playbook)

ISE Cl No. 3.1.2.2.A has been finalized and is now CCNPP ISE Cl No. 3.1.2.2.B procedure CC-CA-118-1001, Revision 0.

ISE Cl No. 3.2.4.5.A The CCNPP SAFER Response Plan (CC-CA-Staging Areas, Deployment Routes, 118-1001, Revision O) has been posted to the and Offsite Resources CCNPP ePortal 1 for NRC review.

Complete ISE Cl No. 3.1.3.2.A Credited debris removal equipment is stored in the FLEX Storage Robust Building (FSRB).

Debris Removal The FSRB is a reinforced concrete structure approximately 60' wide x 140' long x 21' high, located outside of the Protected Area to the west. The FSRB has been designed for seismic, wind, tornado and tornado missiles and flooding conditions. The building is equipped with heating and ventilation units for internal environmental control. The stored equipment will be secured to prevent seismic interaction.

The list of the credited debris removal equipment has been posted to the CCNPP ePortal 1 for NRC review.

Complete ISE Cl No. 3.1.4.2.A In accordance with AREVA NP Inc., "Regional Response Center Equipment Technical Impact of Extreme Temperature Requirements," Document No. 51-9199717-Environments 008, equipment that will be deployed in outdoor locations following a BDBEE shall be procured to the following environmental requirements:

• Equipment (e.g., diesel engines, generators, pumps) shall be capable of continuous duty rated output at an ambient temperature of 130°F. If equipment is not available with this capability, applicable de-rating factors may be applied as long as the performance requirements (power, voltage, flow, pressure, etc.) are met.

• Equipment shall be capable of continuous operation at an ambient temperature of

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 24 Item Description Status

- 40°F. If equipment is not available with this capability, the equipment may be procured on the basis of the historical low temperature recorded at Lusby, MD in February 1996 of - 9°F.

• Equipment shall be rated for operation up to a minimum of 100 feet above mean sea level.

The above criteria were applied in the procurement of both Phase 2 and Phase 3 equipment for CCNPP. A combination of the following has been applied to ensure compatibility with the above requirements:

• Review of Vendor Material/information

• Specification prior to purchase

• Test Data from the factory or local site acceptance test (SAT)

• Engineering assessment where applicable

• Strategy adjustment or plant modification to ensure that environmental conditions are properly considered (e.g., instructions within procedures to drain hoses to prevent freezinQ when pumps are secured)

Complete ISE Cl No. 3.2.1.6.A Attachment 8 of the CCNPP Program ISE Cl No. 3.2.1.6.B Document (CC-CA-118) shows the Sequence AO 23 (AQ 27) of Events Timeline and validation tests associated with time-constrained activities. It is Sequence of Events cross-referenced to the Validation Plan.

It has been posted to the CCNPP ePortal 1 for NRC review.

Complete ISE Cl 3.2.1.7.A On Page 3 of the CCNPP Overall Integrated AQ 38 (AQ 48) Plan (OIP), in the paragraph titled "Implementation Capability Requirements Shutdown and Refueling Modes Overview," it is stated that permanent plant equipment, cooling and makeup water inventories, and fuel for FLEX equipment

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 25 Item Description Status contained in systems or structures with designs that are robust with respect to seismic events, floods, high winds and associated missiles are available, and that installed equipment that is not robust is assumed to be unavailable. On Page 21 in the paragraph titled "Hot Standby, Hot Shutdown, Cold Shutdown, and Refueling (Modes 3 - 6)", it is stated that if the reactor vessel head is removed and the refueling pool (RFP) is or can be filled, then decay heat is removed by the RFP via a gravity fill line-up to the RFP from the refueling water tank (RWT).

The RWT does not have the requisite wind-driven missile protection. The following provides the technical justification for assuming that the RWT (which is installed equipment that is not robust) is available for use.

The referenced paragraph on Page 21 of the 01 P describes the strategy for maintaining core cooling in Mode 6 when the reactor vessel head is removed and decay heat is removed via heat up and boil off of the water in the Refueling Pool (RFP). The strategy credits the Refueling Water Tanks (RWTs) if one is available.

However, if the RWTs are not available, the RFP can be refilled to compensate for boil off from any available water storage tank or the Ultimate Heat Sink (Chesapeake Bay). The strategy description has been updated as follows:

If the reactor vessel head is removed and the refueling pool (RFP) is or can be filled, then decay heat is removed via heat up and boil off of the water in the RFP. Per AOP-38, if RFP level is< 57 ft., then a gravity fill line-up is established to gravity fill the RFP from the same unit's RWT (primary connection point). The RWTs are 420,000 gallon stainless steel seismic Category 1 water storage tanks.

However, as stated earlier, the RWTs are not protected from wind-driven missiles.

If the RWT of the opposite unit remains available, it may be used to refill the RFP by

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 26 Item Description Status connecting a FLEX portable pump to the RWT FLEX connection of the opposite unit, or by gravity transfer of the water from the opposite unit's RWT to the RWT FLEX connection for the unit in Mode 6 via the spent fuel pool system as described in ERPIP-0611, "Severe Accident Management Restorative Actions," Attachment 1, "Alternate Water Sources". For both of these options the RCS Injection FLEX connection for the unit in Mode 6 would be used to deliver the water into the RFP.

If neither RWT is available, the RFP may be refilled from any available water storage tank (11 CST, 12CST, 21 CST, 11 DWST, 11 PWST, 12 PWST), well water, or the Ultimate Heat Sink (Chesapeake Bay) using a FLEX portable pump and the RCS injection FLEX connection for the unit in Mode 6.

Complete ISE Cl No. 3.2.1.9.C Engineering Change Package ECP 000105, Fukushima - Related Design Changes Engineering Evaluations of Phase 3 to Implement FLEX Phase 3 Long Term Coping Equipment Strategies for Core and Containment cooling and Spent Fuel Pool Level Control, provides the engineering to implement the CCNPP FLEX Phase 3 strategies to connect NSRC equipment for Saltwater System makeup and Boric Acid addition.

As part of these design changes, hydraulic analyses were performed in 1) CA09991, Rev.

O, "Hydraulic Evaluation of the FLEX Pump Connection to the Salt Water System", to verify the adequacy of the National SAFER Response Center (NSRC) high flow/low pressure pump to provide adequate makeup to the SW system, and 2) in CA09973, Rev. 0, "Hydraulic Analyses for FLEX Portable Pump for SFP Makeup", to size the portable pumps and hoses to ensure adequate flow can be delivered to the SFP based on the requirements provided in NEI 12-06.

ECP-14-000153, Fukushima 4kV bus

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 27 Item Description Status connections of FLEX NSRC Diesel Generators, provides the engineering to implement the CCNPP FLEX Phase 3 strategy to connect two 1 MW, 4160 VAC NSRC gas turbine generators FSG-4, ELAP DC BUS LOAD SHED AND MANAGEMENT, has been prepared and approved for use to connect two 4, 160 V AC NSRC Gas Turbine Generators {GTG) to either the 14 or 21 4KV buses to provide power for Phase 3, via the 1B or 2A DG disconnects, respectively.

CA09991, CA09973, ECP-14-000105, ECP 000153 and FSG-4 have been posted to the CCNPP ePortal for NRC review. The paths to these documents in the ePortal are given in the notes to this table.

Complete ISE Cl No. 3.2.4.10.A Exelon Generation Company understands that AO 34 (AO 39) the NRC requests ERPIP-0653 in support of ISE Cl 3.2.4.1 O.A. The title of this ERPIP is DC Load Shedding "Alternate Low Pressure Feedwater", and is not the procedure related to DC Load Shedding.

The CCNPP procedure applicable to DC Load Shedding is FSG-4, "ELAP DC Bus Load Shed and Management".

FSG-4 provides actions to remove loads from the 125 voe batteries to extend battery life during an ELAP and repowering load centers and motor control centers with FLEX equipment.

FSG-4 has been posted to the CCNPP ePortal 1 for NRC review.

A time-motion study (CC-VP-001 , Rev. 0) was conducted to validate that DC load shedding can be accomplished on each unit in one hour using the FSG. The time-motion study for both units demonstrated that the deep load shed can be accomplished in 50 minutes using one operator; much less than the one hour required for one unit.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 28 Item Description Status CCN0012-17-STUDY-001, Rev. 0, Analysis of Calvert Cliffs DC Systems in Support of INPO Event Report 11-4 has been superseded by detailed DC system analyses. To confirm the safety-related station batteries will support the vital instrumentation required for the Phase 1 FLEX mitigation strategy at Calvert Cliffs until the Phase 2 diesel generators are deployed, the following calculations have been prepared corresponding to safety-related station batteries:

• CA08256 - Battery 11 Load Shed Coping Time for ELAP Event

• CA08257 - Battery 12 Load Shed Coping Time for ELAP Event

• CA08258 - Battery 21 Load Shed Coping Time for ELAP Event

• CA08259 - Battery 22 Load Shed Coping Time for ELAP Event In addition, these calculations determined the station battery coping time with the implementation of DC load shedding associated with the station response to an ELAP:

• In calculation CA08256, Battery 11 was shown to have a maximum coping time of 7.07 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> during an ELAP event.

• For Battery 12, calculation CA08257 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

• In calculation CA08258, Battery 21 was shown to last 7.33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> until a limiting voltage was reached using an ELAP Model.

• For Battery 22, calculation CA08259 showed the minimum voltage was reached beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, thus the

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 29 Item Description Status maximum credited time was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Complete AQ 1 (AQ2) The three FLEX Storage Robust Building (FSRB) equipment openings, specifically the Power Supply outside Barrier 1 Missile Doors and the interior roll-up doors intended for equipment deployment do not require electrical power to be opened in order to access or be closed to isolate the stored FLEX equipment. They can be manually opened with a less than or equal to 50-lb force. There are also two personnel access doors that do not require electrical power to open or close.

The requested final design drawings and pictures of the FSRB doors have been posted to the CCNPP ePorta1 1 for NRC review.

Complete AQ 32 (AQ 37) Single line diagrams showing the connection points for the Phase 2 and Phase 3 FLEX Electrical Isolation diesel generators and gas turbine generators have been posted to the CCNPP ePortal 1 for NRC review.

SE Review Item 4 For maximum Safety Injection Tank (SIT) Complete injection, assuming the Technical Specification Safety Injection Tanks (SIT) minimum level, SIT isolation is expected to occur at approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> into the event when a height of 1O inches is reached.

Power supplies to the SIT wide range level and N2 pressure indicators are being modified (completed for Unit 2 FLEX implementation) to provide continuous power from safety-related 120 V AC instrument power to the level and pressure indicators. Control Room operators will be able to closely monitor SIT level and N2 pressure as the SITs discharge into the RCS.

Emergency Operating Procedure EOP-7-2, directs recording initial SIT levels and pressures prior to the start of the RCS cooldown.

Based on a CCNPP reference simulator validation of the CCNPP EOP-7-2, Appendix 1 ELAP cooldown, conducted November 12, 2014, SIT discharge into the RCS began at

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 30 Item Description Status approximately the five hour mark {293 minutes) of the event just as the RCS cooldown was terminated and RCS temperature stabilized at 340°F (120 PSIA S/G pressure). Level in all four SITs continued to slowly lower over the next 15.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. SIT level lowered by a total of 168 inches over this period of time. Given a normal SIT level of approximately 194 inches, final SIT level reached approximately 26 inches.

Conservatively assuming starting SIT level at Technical Specification minimum level of 187 inches, final SIT level would equal 19 inches.

These levels are above the ELAP cooldown minimum SIT level of 1O inches to prevent N2 injection into the RCS.

The motor control centers that supply power to the SIT outlet MOVs will be re-energized at approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> into the event. Also, at approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> power will be restored to a vital 480 VAC load center which will allow a Charging Pump to be started for RCS makeup and boration. FLEX Support Guidelines will direct SIT isolation after pumped RCS makeup begins.

Plant reference simulator validation of the CCNPP EOP-7-2, Appendix 1 ELAP RCS Cooldown was used. The SIT volume is a fixed value of 2025 cubic feet. The SIT height is a fixed value of 33.75 feet. The CCNPP Simulator THOR thermal-hydraulic model performs complex calculations to determine the level in the tank as well as pressure.

EOP-7-2, Station Blackout, Appendix 1, Initial ELAP RCS Cooldown, Block step B, RCS Cooldown provides guidance to operators to stop the RCS cooldown and raise RCS pressure to prevent N2 gas intrusion into the RCS.

SE Review Items 5 and 6 Calculation No. CA08576 was performed to Complete determine the hydraulic requirements tor a RCS Pump Hydraulic Analysis portable FLEX pump and hoses to provide required make-up from the following make-up

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 31 Item Description Status sources of water to the Reactor Coolant System (RCS) during Beyond-Design-Basis External Events (BDBEE) at Calvert Cliffs Nuclear Power Plant Units 1 and 2:

1) The Refueling Water Tank (RWT)

2) A tank in the tank yard

3) Well water

4) The Ultimate Heat Sink (Chesapeake Bay)

The hydraulic calculation was performed such that it can be applicable to either a centrifugal pump or a positive displacement pump. It provides a basis for sizing either a centrifugal pump or positive displacement pump for the application. The calculation data were provided to the pump vendor as a sizing basis for the positive displacement pump used for RCS makeup.

In response to the staff's request that EGC provide justification for using lower rated hoses than the hydraulic analysis recommends, the following explanation is provided.

CCNPP uses hoses with a design pressure that is below the shutoff head for the RCS makeup pump for FLEX. For FLEX, the positive displacement pumps are provided with pressure relief valves. These valves are provided by the pump vendor and are sized for the rated flow of the pump. Thus, a pressure relief valve provides overpressure protection for the downstream hoses that are connected to the pump to ensure that the pump does not over pressurize the hose. The relief valve is to be set at a maximum allowable pressure equal to the design pressure of the hose. Thus, the presence of a relief valve allows the use of a hose pressure rating that is below the shutoff pressure rating of the pump.

Calculation No. CA08576 has been posted to the CCNPP ePortal 2 for NRC review.

Notes:

1. Path to document in CCNPP ePortal:

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 32

• 2014 NRC CCNPP Onsite FLEX Audit

• Documents Provided in Support of Unit 2 FLEX Compliance Letter

2. Path to document in CCNPP ePortal:

• 2014 NRC CCNPP Onsite FLEX Audit

• Calculations MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 26, 2012 Submit Overall Integrated Plan February 28, 2013 Submit Supplement to Overall lnteqrated Plan March 8, 2013 Contract with National SAFER Response Center January 17, 2013 Submit 6 Month Updates:

Update 1 August 27, 2013 Update 2 February 27, 2014 Update 3 August26,2014 Update 4 February 20, 2015 Modification Development:

Phase 2 modifications October 6, 2014 National SAFER Response Center Operational Februarv 26, 2015 Procedure Development:

Strategy procedures April 10, 2015 Validate Procedures (NEI 12-06, Sect. 11.4.3) March 27, 2015 Staffing analysis October 13, 2014 Modification Implementation Phase 2 modifications March 6, 2015 Storage plan and construction April 8, 2015 FLEX equipment acquisition March 6, 2015 Traininq completion April 10, 2015 Unit 2 implementation date May 10, 2015 ORDER EA-12-049 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Calvert Cliffs Nuclear Power Plant, Unit 2 as well as the site OIP response submittal (References 5 and 6), the 6-Month Status Reports (References 7, 8, 9, and 10), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies - Complete Calvert Cliffs Nuclear Power Plant, Unit 2 strategies are in compliance with Order EA-12-049.

There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 33 Open Items. The Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Final Integrated Plan for mitigating strategies will be provided upon full compliance for Calvert Cliffs Nuclear Power Plant, Unit 1 (Spring 2016}.

Modifications - Complete The modifications required to support the FLEX strategies for Calvert Cliffs Nuclear Power Plant, Unit 2 have been fully implemented in accordance with the station design control process.

Equipment - Procured and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for Calvert Cliffs Nuclear Power Plant, Unit 2 has been procured in accordance with NEI 12-06, Section 11.1 and 11 .2, received at Calvert Cliffs Nuclear Power Plant, Unit 2, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Maintenance and testing will be conducted through the use of the Calvert Cliffs Nuclear Power Plant, Unit 2 Preventative Maintenance program such that equipment reliability is achieved.

Protected Storage - Complete The storage facility required to implement the FLEX strategies for Calvert Cliffs Nuclear Power Plant, Unit 2 has been completed and provides protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Calvert Cliffs Nuclear Power Plant, Unit 2 is stored in its protected configuration.

Procedures - Complete FLEX Support Guidelines (FSG), for Calvert Cliffs Nuclear Power Plant, Unit 2 have been developed, and integrated with existing procedures. The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

Training - Complete Training for Calvert Cliffs Nuclear Power Plant, Unit 2 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

Staffing - Complete The Phase 2 Staffing Assessment (Reference 13) for Calvert Cliffs Nuclear Power Plant has been completed as required by 10CFR50.54(f), "Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 12). The Phase 2 Staffing Assessment was conducted using NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities; an approach endorsed by the NRC.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 2, 2015 Page 34 National SAFER Response Center - Complete EGC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support Calvert Cliffs Nuclear Power Plant, Unit 2 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site-specific SAFER Response Plan.

Validation - Complete EGC validated FLEX strategies in accordance with the NEI FLEX Validation Process. This consisted of validating the feasibility of individual strategies identified in the Overall Integrated Plan (OIP) for Order EA-12-049 using the graded approach described in the NEI guidance document and an integrated review to ensure that adequate resources (personnel, equipment, materials) are available to implement the individual strategies to achieve the intended results.

FLEX Program Document - Established The Calvert Cliffs Nuclear Power Plant, Unit 2 FLEX Program Document (CC-CA-118) has been developed in accordance with the requirements of NEI 12-06.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of July 2015.

Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector- Calvert Cliffs Nuclear Power Plant NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRC Ms. Mandy K. Halter, NRR/JLD/PPSD/JOMB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC S. Gray, MD-DNR