L-15-219, Fifth 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
| ML15239A290 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse |
| Issue date: | 08/27/2015 |
| From: | Belcher S FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, L-15-219, TAC MF0841, TAC MF0842, TAC MF0961 | |
| Download: ML15239A290 (30) | |
Text
FENOC 76 South Main Street Akron. Ahio 4$48 Samuel L. Belcher President and Chief Nuclear Offtcer August 27,2015 L-15-219 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 FirstEnerqv Nuclear Operatino Companv's (FENOC's) Fifth Sbs-Month Statuq Repoq't in Response to March 12. 2012 Commission Order Modifvinq Licenses wilh Resard to Requirements for Mitioation Strateoies for Bevond-Desisn-B3sis External Events (Order Number EA-12-049) ffAC Nos. MF0841.
MF0842.
and MF0961)
On March 12,2012, the Nuclear Regulatory Gommission (NRC or Commission) issued an order (Reference 1) to FENOC. Reference 1 was immediately effective and directs FENOC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference
- 2) and an overall integrated plan pursuant to Section lV, Condition C. Referenen 2 endorses industry guidance document Nuclear Energy Institute (NEl) 12-06, Revision 0 (Reference
- 3) with clarifications and exceptions identified in Reference
- 2. Reference 4 provided the FENOC initial status report regarding mitigation strategies. Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP).
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station L-15-219 Page 2 content of the status reports. The purpose of this letter is to provide the fifth six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached reports for BVPS and DBNPS (Attachments 1 and 2, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compf iance method, schedule, or need for relietlrelaxation and the basis, if any.
This letter contains no new regulatory commitments. lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.
I declare ulder penalty of perjury that the foregoing is true and correct. Executed on August A 7,2015.
Respectfully, Samuel L. Belcher Attachments:
1, Beaver Valley Power Station Fifth Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
- 2.
Davis-Besse Nuclear Power Station Fifth Six-Month Status Report for the lmplementation of Order EA-12-049, Order Modiffing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
References:
- 1.
NRC Order Number EA-12-049, Order Modiffing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.
NRC f nterim Staff Guidance JLD-lSG-2O12-A1, 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.
NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) lmplementation
- Guide, Revision 0, dated August 2012.
FirstEnergy Nuclear Operating Company's (FENOC's)
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.
FirstEnergy Nuclear Operating Company's (FENOC's)
Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard 2.
3.
4.
5.
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station L-15-219 Page 3 to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),
dated February 27, 2013.
cc: Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS)
NRC Resident Inspector (DBNPS)
NRC Project Manager (BVPS)
NRC Project Manager (DBNPS)
Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments)
Site BRP/DEP Representative (without Attachments)
Utility Radiological Safety Board (without Attachments)
L-15-219 Beaver Valley Power Station Fifth Six-Month Status Report for the lmplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 19 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Beaver Valley Power Station, Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Referen cn 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 MilestoneAccomplishments The following milestone(s) have been completed since January 31,2015 and are current as of July 31, 2015.
Update 4 was submitted o Completed 1R23 outage modifications o Completed the FLEX equipment storage buiHing design o Commenced construction of the FLEX equipment storage building o Completed ordering on-site FLEX equipment o Completed strategy development with the National Strategic Alliance for FLEX Emergency Response (SAFER) Response Center (NSRC) o Completed Phase 3 site access strategies 3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The following milestones replaced the previous milestones of Walk-throughs or Demonstrations and FLEX Equipment Delivered:
. Walk-throughs or Demonstrations-Unit 2
FLEX Equipment Delivered-Unit2 The following milestones were added:
o Walk-throughs or Demonstrations-Unit 1
o FLEX Equipment Delivered-Unit 1
The revised milestone target completion dates do not impact the order implementation date.
L-15-219 Page 2 of 19 Milestone Target Gompletion Date Activity Status (as of 7131l,151 Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Complete 6 Month NRC Status Updates 08/28/16 Started Update 1 08t28t13 Complete Update 2 02128114 Complete Update 3 08128114 Complete Update 4 02t27t15 Complete Update 5 08t28115 Started Update 6*
02t28116 Not Started Undate 7" 08t28t16 Not Started Gomplete FLEX Strategy Review March-2013 Complete Validation September-2O15 Started September-2O16 Walk-th rouohs or Demonstrations-U nit 2 September-2415 Started Walk-through s or De monstration s-U nit 1
- N/A Started Seotember-2016 Gomplete Staffins Analvsis November-2014 Complete Submit NEI 12-01 Phase 1 Staffinq Studv April-2O13 Complete Submit NEI 12-01 Phase 2 Staffins Studv November-2014 Complete Gomplete Plant Modifications November-2016 Started Target plant modifications Aoril-2O13 Complete Unit 1 Modifications complete November-2016 Started Complete 1 R22 outaoe modifications November-2013 Complete Com plete on-line modificafions Seotember-2016 Started Complete 1 R23 outase modificafions May-2015 Complete Complete 1 R24 outaqe modificaffons*
November-2016 Started Unit 2 Modifications complete November-2015 Started Complete 2R1 7 outaqe modificafibns Mav-2014 Complete Com plete on-line modification s
Auqust-2015 Started September-2015 Complete 2R1 I outase modificafibns November-2O15 Started FLEX Storase Complete October-2015 Started Complete Buildinq Desiqn March-2015 Complete Commence Gonstruction March-2015 Complete Complete Construction October-z015 Started River (UHS) Access Gomplete October-z014 Complete Fence & Gate Modification Desisn February-2014 Complete New Fence & Gate Construction Auqust-2014 Complete Securitv Barrier Pipe Penetrations Desr-?n March-2014 Complete Security Barrier Pipe Penetration Construction October-z014 Complete On-site FLEX Equipment October-z015 Started September-2016 Confirm FLEX Equipment Reouirements November-Z013 Complete FLEX Equipment Ordered Aoril-2O15 Complete FLEX Equipment Delivered-Unit 2 October-z015 Started FLEX Equipment Delivered-Unit 1*
N/A Started September-2016 Off-site FLEX Equipment October-z015 Started Develop Strategies with RRC***
June-2015 Gomplete Phase 3 Srfe Access Sfrafeq,'e s in Place June-2015 Complete
Milestone Target Completion Date Activity Status (as of 71311151 Revised Target Gompletion Date Complete Near S/e Sfagrng Location (as needed)
October-z015 Started Procedures Gomplete October-2016 Started PWROG r'ssues NSSS-sp ecific ouidelines June-2013 Complete
/ssue Beaver Valley Unit 2 FLEX Support Guideline /FSG)*
October-z015 Started
/ssue Beaver Vallev Unit 7 FSG*
October-z016 Started
/ssue Maintenance Pracedures October-z015 Started Traininq Gomplete Seotember-2O16 Started Develop Training Plan December-2414 Complete Implement Unit 2 Trainino*
September-2015 Started lmplement Unit 1 Trainins*
September-2016 Started Submit Completion Report January-2017""
Not Started L-15-219 Page 3 of 19
- Milestones added as a result of relief/relaxation for Unit 1 (Reference 4)
- Submittal of completion report occurs after end of refueling outage.
- Regional
Response
Genter (RRC) is now called National SAFER Response Center (NSRC) 4 Ghanges to Gompliance ilethod The following change to the compliance method as documented in the OIP (Reference
- 1) is being made. The change does not impact compliance with Nuclear Energy Institute (NEI) 12-06.
o Based on results of the NEI 12-01 Phase 2 staffing study, revisions to the Phase 3 compliance method (as reported in the last six-month update), table top reviews, and other validation activities for FSGs, the BVPS FLEX timeline has been revised from the timeline that was reported in the original OlP. The revised timeline is provided at the end of this report.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ref ief/relaxation of the Referen cn 2 requirement for completion of full implementation for Beaver Valley Power Station Unit No. 1 (BVPS-1) until the completion of the fall of 2016 refueling outage for reactor coolant pump shutdown (RCP) seal installation was granted on May 20,2014 (Reference 4). No relief/relaxation is required at this time for Beaver Valley Power Station Unit No. 2 (BVPS-2).
6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (lSE) (Reference
- 3) and the status of each item.
Overall Inteqrated Plan Open ltem Status Ol 1. Finalize the location of the FLEX storage building. The deployment routes, distances, and Complete. (Described in February-z014 status report L-15-219 Page 4 of 19 Overall Intesrated Plan Open ltem Status times provided in this report are bounded for the currently proposed locations but will be updated as necessary.
and updated in the February
-2015 status report.)
Ol 2. Perform containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.
Complete. (Described in February-z01 5 status report.)
Ol 3. Modify the RWST [refueling water storage tankl at each unit to protect it from tornado missiles or identify a borated source that is protected from tornados and can be utilized to provide core cooling when steam qenerators are not available.
Complete. (Described in February
-2014 status report.)
Interim Staff Evaluation Open ltem Status 3.2.1.6.A Verify that the TDAFW [turbine driven auxiliary feedwaterl pump exhaust stacks are adequatelv protected from tornado missile hazards.
Started.
3.2.1.8.A Verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS [reactor coolant systeml under natural circulation conditions potentiallv involvino two-phase flow.
Complete. (Described in February-201 4 status report.)
ISE Gonfirmatory ltem Status 3.1.1.4.A Confirm that primary and secondary staging areas for the RRC [regional response centerl equipment have been selected and will meet the requirements of the applicable site response plan.
Complete. The primary and secondary staging areas for NSRC (previously called RRC) equipment have been selected and meet the requirements of the site response plan.
3.1.2.4.4 Confirm that the primary and secondary staging areas have been identified and that the plan for the use of offsite resources will comply with NEI 12-06, Section 6.2.3.4 regarding the need to evaluate for flooding hazard. This confirmation should include a description of the methods to be used to deliver the equipment to the site.
Complete. The primary and secondary staging areas for NSRC equipment have been selected. The logistical information associated with the delivery of NSRC equipment is provided in the site SAFER plan.
3.1.3.1.A Confirm that the location of the storage and protection building for FLEX equipment has been identified. Confirm that the FLEX storage buildins is desiqned to withstand tornado missiles at Complete. The BVPS FLEX storage building for N sets of equipment is located west of the protected area (PA). In L-15-219 Page 5 of 19 ISE Confirmatory ltem Status a level equal to, or greater than, the plant's tornado missile design basis.
- addition, the BVPS-1 auxiliary building and BVPS-2 auxiliary building will be used for storing the FLEX RCS boration pumps.
The FLEX storage building is designed to withstand tornado driven missiles.
The BVPS-1 auxiliary building concrete structure, below elevation (EL) 752'-6" and for certain portions above EL 752'-6", is designed for wind pressure resulting from a hypothetical tornado and for the associated missile described in the BVPS-1 Updated Final Safety Analysis Report (UFSAR) Section 2.7.2. The BVPS-1 FLEX RCS boration pumps will be stored on EL 735'-6".
The BVPS-2 auxiliary
- building, below EL773'-6" and for certain portions above EL 773'-6", is tornado protected.
The BVPS-2 FLEX RCS boration pumps will be stored on EL 735'-6".
The commercial warehouse may be used for storing +1 sets of equipment and is in a diverse location.
All FLEX portable equipment and support equipment will be stored in the new FLEX Equipment Storage BuiHing (FESB), which is robust with respect to all hazards for BVPS-2 compliance. Storage of +1 equipment is contingent on approval of NEI 12-46, Revision 1, or prior approval as L-15-219 Page 6 of 19 ISE Confirmatorv ltem Status an alternate method prior to compliance on both units in fall 201 6.
3.1.3.4.A Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06, Section 7.3.4 regarding high wind hazards.
Complete. The primary and secondary staging areas for NSRC equipment have been selected. The logistical information associated with the delivery of NSRC equipment is provided in the site SAFER plan.
3.1.4.4.A Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06 Section 8.3.4 regarding snow, ice and extreme cold hazards.
Complete. The primary and secondary staging areas for NSRC equipment have been selected. The logistical information associated with the delivery of NSRC equipment is provided in the site SAFER plan.
3.2.1.1.A Confirm that the licensee has verified that reliance on the NOTRUMP code for the ELAP
[extended loss of AC power] analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. This includes specifying an acceptable definition for reflux condensation cooling.
Complete. Report PWROG -14064, Application of NOTRUMP Code Results for PWRs in Extended loss of AC Power Circumstances, shows that for plants with high leakage RCP seals, onset of two phase flow occurs around 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
By reference to report WCAP-fi6A1, Reactor Coolant Sysfem Respon se to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wlcox NSSS Designs, it is apparent that with RCP shutdown seals installed in BVPS RCPs, the decrease in RCS leak rate will maintain inventory to support single phase natural circulation flow for longer than the time required for establishment of shutdown margin.
3.2.1.1
.B Confirm that the application of the WCAP-17601 analvsis simulatinq the ELAP Complete. lt is planned to use the Westinghouse L-15-219 Page 7 of 19 ISE Confirmatory ltem Status transient is properly established.
Generation lll SHIELDO passive thermal shutdown seal (SDS) in each BVPS-1 and BVPS-2 RCP. With the installation of SDSs in BVPS RCPs, maintaining RCS inventory is not a challenge during an EI-AP scenario, as supported by Section 5.7.1 of wcAP-17601.
3.2.1.2.A Confirm that, if the licensee continues to credit SHIELD shutdown seals, as planned, (e.9.,
1 gallon per minute leakage/seal) in the ELAP analyses for the RCS response, then the impacts of the Westinghouse 10 CFR Part 21 report, "Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21:'dated July 26,2013 (ADAMS Accession No. ML13211A168) on the use of the low seal leakage rate in the ELAP analysis are addressed.
Complete. lt is planned to use the Westinghouse Generation lll SHIELD@
passive thermal SDS in each BVPS-1 and BVPS-2 RCP.
The referenced 10 CFR Part?1 report is applicable to the Westinghouse Generation ll RCP shutdown seal. The report does not pertain to the Westinghouse Generation lll SH I ELD@ passive thermal SDS.
3.2.1.2.8 Confirm that if the seals are changed, the acceptability of the seals used is addressed, and the RCP seal leakage rates for use in the EI-AP analysis are justified.
Complete. lt is planned to use the Westinghouse Generation lll SHIELDO passive thermal SDS in each BVPS-1 and BVPS-2 RCP.
The acceptability of the SDS and its leakage rate was addressed for the BVPS application. BVPS-1 and BVPS-2 RCPs are Westinghouse Model 934 RCPs. The maximum steady-state RCS cold leg temperature does not exceed 571"F during the ELAP because the main steam safety valves will limit steam pressure, and with the small decay heat amount (relative to rated thermal power), the RCS cold leg temperature will be within a few degrees of the saturated steam L-15-219 Page I of 19 ISE Confirmatory ltem Status pressure. The maximum RGS pressure during the ELAP (notwithstanding the brief pressure transient d irectly following the reactor trip) remains bounded by TR-FSE 1-P Figure 7.1-2, 93A O-Ring Endurance Testing Depressurization Over 7 Days, for Westinghouse Model 93A RCPs.
A constant seal leakage rate of 1 gallon per minute (gpm) after SHIELD@
seal actuation is assumed, as appropriate, in calculations:
(a) Westinghouse calculation cN-sEE-lll-12-69-NP considers conditions with no RCS leakage for boration inventory purposes (Section 4.3.3) and with the highest applicable leakage rate for the RCP seals (1 gpm per RCP*3RCPs)and u n identified reactor coolant system leakage (1 gpm) for a total of 4 gpm for single-phase natural circulation purposes (Section 4.3.2. 1 ).
(b) The containment temperature response analysis, BVPS calculation 1 0080-DMC-3687, assumes 4 spm RCS leakage.
3.2.2.A Since the RWSTs are not currently fully protected against tornado missiles, confirm that the licensee has completed their review to determine whether or not the RWST will need to be further protected against missile hazards.
Complete. (Described in February-z}1 4 status report.)
3.2.2.8 Confirm that opening doors provides adequate ventilation for SFP [spent fuel pool] area.
Complete. As described in Engineering Evaluation Req uest 60092 4924, opening the large overhead doors is L-15-219 Page 9 of 19 ISE Confirmatory ltem Status adequate to maintain the temperatures in the building less than or equal to 212'F.
High temperature rated hoses and deployment in the building prior to degraded environmental conditions with the ability to select and control function (spray or makeup) and connection point selection from outside the building ensures that SFP strategies can be executed with just the single overhead doors open for buiHing ventilation. Later use of components in the building (such as the SFP cooling pumps) would require forced ventilation to cool and dry the motors. However, the use of any components in the building (other than the FLEX portable equipment) is not required for indefinite copins.
3.2.3.4 Confirm that containment evaluations for all phases are performed based on the boundary conditions described in Section 2 of NEI 12-06.
Based on the results of this evaluation, confirm that required actions to ensure maintenance of containment integrity and required instrument function have been developed.
Complete. (Described in February-z01 5 status report).
3.2.4.2.4 Confirm that the licensee has clarified why the Integrated Plan stated the maximum temperature of the Unit 1/Unit 2 AF1 / [auxiliary feedwaterl pump rooms would reach 115.91112.3 degrees Fahrenheit
('F), respectively, while Calculation 8700-DMC-2312, described during the audit process, indicated that the maximum temperature would reach 142.9"F.
Complete. BVPS-1 calculation DMC-2312 and BVPS-2 calculation DMC-0056 determine the average steady state temperature for a station black-out (SBO) situation assuming an initial temperature of 104'F. lt is assumed that no door is opened to create a ventilation path. The results of these calculations are 1 15.9'F for BVPS-1 and 112.3'F for BVPS-2.
L-15-219 Page 10 of 19 ISE Gonfirmatory ltem Status BVPS-1 calculation DMC -2312 determines whether maximum steam leakage from the TDAFW pump would result in a challenge to equipment. The calculation employed a conservative approach and produced an acceptable result (142.9"F) for its stated purpose, so more refined analysis was not performed. This also assumed an initial temperature of 104'F and that no door is opened to create a ventilation path.
3.2.4.2.8 Confirm that the licensee has provided an analysis or calculation to demonstrate that the dissipation of heat generated by the batteries via natural circulation will be adequate to maintain the temperatures in the battery rooms within acceptable levels.
Complete. Per BVPS-1 cafculation DMC-2312, an initial battery room temperature, including the temperature of the heat sinks, is assumed to be 104"F. A station battery discharging in a SBO situation involving a heat generation rate of 1,000 watts results in a steady state room temperature of 1 19.9'F.
Per BVPS-2 calculation DMC-0056, an initial battery room temperature, including the temperature of the heat sinks, is assumed to be 104'F.
A station battery discharging in a SBO situation involving a
heat generation rate of 1,060 watts results in a steady state room temperature of 116'F.
lEEE Std 485-1997 (R2003),
IEEE Recommended Practice for Sizing Lead-Acid Batten'es for Stationary Applications, provides cell correction factors for temperatures from 25'F to 125"F for lead-acid nominal L-15-219 Page11of19 ISE Confirmatorv ltem Status 1.215 specific gravity vented cells. The correction factor at 77'F is 1.000 and at 125"F is 0.850, indicating that battery capacity increases within this temperature range.
It is concluded that the maximum steady state temperature for the BVPS-1 and BVPS-2 safety-related station batteries d ischarging inside their room with no ventilation in operation will not result in ambient temperatures within the battery rooms that would result in battery failures.
3.2.4.2.C Confirm that the licensee has addressed how hydrogen concentration in the battery rooms will be limited to acceptable levels.
Complete. As noted in NRL Regulatory Guide 1.1 28, "...the batteries also release hydrogen (a potential fire hazard) to the battery room during charging.
.." Thus, hydrogen generation is not a concern when the batteries are being discharged. During an ELAP event, the FLEX 480V diesel generators will be deployed to charge the batteries. These generators are also used to reestablish the existing normal exhaust ventilation in the battery rooms. BVPS-1 calculation DMC-3585 and BVPS-2 calculation B-21 1 demonstrate that the existing normal ventilation is capable of removing hydrogen generated while charging batteries.
Therefore, the existing normal ventilation will be available to remove hydrogen generated while charqins the batteries.
3.2.4.6.4 Confirm that the licensee has completed a review of Unit 1 AFW room and developed anv Complete. A MAAP-DBA computer model of the BVPS-1 L-15-219 Page 12 of 19 As indicated in the lSE, the NRC staff review determined that the generic concerns related to shutdown and refueling requirements, battery duty cycles beyond I hours, and maintenance and testing of FLEX equipment are applicable to BVPS. These concerns were resolved generically through the following NRC endorsements of NEI position papers.
o Shutdown/Refueling Modes (ADAMS Accession No. ML1 3267Ag82)
Battery Life lssue (ADAMS Accession No. ML132414188)
Maintenance and Testing (ADAMS Accession No. ML132764224)
FENOC intends to follow the NRC-endorsed guidance for these generic concerns at BVPS.
ISE Confirmatory ltem Status plans required to maintain a suitable environment. AFW pump room was developed using geometrical and heat loading information availabb in existing calculations.
The evaluation is documented in Engineering Evaluation Request 600979836, which describes the methodology, inputs/assumptions, and results/conclusions.
The action of propping open a door or installing temporary portable ventilation has a positive effect at reducing the room temperature.
3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.
Complete. NEI letter on the NSRC Operational Status provides the programmatic aspects and implementation plans for the SAFER program to be in conformance with the applicable portions of NEI 12-06. The NSRCs will also maintain on file an operational checklist annotating the specific criteria that will be validated for each individual licensee to support an operational status.
BVPS has a site specific SAFER plan and a fuel oil contract established.
L-15-219 Page 13 of 19 The response to ISE Open ltem 3.2.1.8.A provided the BVPS resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.
7 Potential lnterim Staff Evaluation lmpacts FENOC is making a change to the compliance method as documented in the OIP (Reference 1). Although the planned change does not impact compliance with NEI 12-06, there is a potential impact on the ISE. The impact may affect Section 3.2.1.6, Sequence of Events.
I References The following references support the updates to the OIP described in this attachment.
FirstEnergy Nuclear Operating Company's (FENOC'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 27,2013.
NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.
- 3. Beaver Valley Power Station, Units 1 and 2 - Interim Staff Evaluation Related To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies),
dated January 29,2014.
- 4. NRC Letter, Beaver Valley Power Station, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 "lssuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" (TAC No. MF0841),
dated May 20,2014.
1.
2.
L-15-219 Page 14 of 19 BVPS FLEX Timeline Action Item Elapsed Time (Hr:Min)
Action Time constraint YAI Level of Validation (A, B, C, N/A)
Rema rks/Applicability 0
Event Starts N/A Plant @ rc0% power I
0 Commence station blackout coping actions per ECA-0.0 N
2 0:04 Recall Operators N
All shift personnel report to Control Room 3
0:15 Monitor Control Room Temperature N
Prior to 104 deg F, Confrol Room doors are opened for ventilation.
4 Ul - 0:21 U2 - A:24 Troubleshoot EDGs N
Assumed Durations:
Unit l - 12 min (EOP Att 2E)
Unit 2 - 15 min (EOP Att A-1.5) f, 0:30 Declare ELAP Y
(A)
Required by I hour Assumption used in Battery Coping Calculations 6
0:35 Isolate RCP Seals N
Requires RP coverage 7
Unit I 0:40 Unit 2 0245 Presere I train of Batteries Y
(A)
Required by 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Assumption used in Battery Coping Calculations 8
1:00 Commence Initial Damage Assessment N
Determine priorities and available equipment/connection points Revision 4,816115 L-15-219 Page 15 of 19 9
l:03 Initiate ventilation for AFW Room Habitability (Ulonly)&Control AFW Flow Locally (AFW Throttle Valves)
Y (A)
Required by I hour 12 minutes Prevent S/G overfill AFW Throttle Valves located in AFW Room where temperature can reach 125 deg F without ventilation (Unit I onlyn N/A for U2).
10 1:05 Contact SAFER N
SAFER will have equipment on site within} hours of notification. BVPS requires purified water by 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l1 l:20 Vent H2 from MUG N
10M-35.4.J I 20M-35.4.I t2 tz25 Secure Air Side Seal Oil Pump (Unit 2 only)
Y (A)
Required by t hour 30 minutes Assumption used in 2-5 Battery Calculation 13 1:40 Complete Load Shed Y
(A)
Required by 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Assumption used in Bnttery Coping Calculations t4 2:40 Complete Initial Damage Assessment N
Determine priorities and available equipment/connection points 15 2:20 Commence actions for Debris Removal & to deploy FLEX PPDWST Make Up Pumps & Hoses N
Earliest start time based on operator availability. Validated time must be less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 40 minutes.
16 2:25 Commence actions to Open SFP Doors for Ventilation N
Start time based on Phase 2 Staffing Study Tabletop t7 3:15 Open SFP Doors for Ventilation Y
(B)
- Required by 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> Provide heat release path prior to boiling (based on SFP starting temp of 140 deg F)
Revision 4,816115 L-15-219 Page 16 of 19 l8 6:00 Commence actions to deploy FLEX 480VAC Generators
& Cables N
Earliest start time based on personnel & tow equipment availability (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed for completion) t9 6:00 Commence actions to deploy FLEX RCS Boration Pumps & Hoses N
Earliest start time based on personnel beyond minimum staffing required (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed for completion) 20 6:00 Commence actions to deploy FLEX Control Room Portable Ventilation
& Lighting N
Earliest start time based on personnel beyond minimum staffing required (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowed for completion) 2l 6:00 Commence actions to install jumpers between safety related MCCs N
Earliest start time based on personnel beyond minimum staffing required (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed for completion) 22 7:00 Start Make Up to the PPDWST Y
(A)
Required by t hours Based on PPIIWST minimum volume & nominal DHR 23 7:00 Commence actions to deploy and set up Hoses in SFP Building N
Earliest start time based on deployment equipment limitations (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowed for completion) 24 8:00 Portable Lighting &
Ventilation available for Control Room N
25 9:00 SFP hoses deployed in SFP Building Y
(B)
- Required by 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> Boiling in SFP Building (Ul -
13.02; UZ - 13.61; assuming normal heat load & starting temperature of 140 deg F) 26 10:00 FLEX 480VAC Generator deployed for Battery Charging / RCS Boration; Start Charging Battery Y
(B)
Required by 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> based on need to start boration Required by 22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for battery charging per battery coping calculations Revision 4,816115 L-15-219 Page 17 of 19 27 10:00 FLEX RCS Boration Pump deployed to support RCS boration Y
(B)
Required by 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> based on need to start RCS boration 28 10:00 Jumpers installed between safety related MCCs Y
(B)
Required by 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to support SI Accumulators isolation 29 10:00 Commence actions to deploy FLEX Alternate AFW Pumps & hoses N
Earliest start time based on deployment equipment limitations (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowed for completion) 30 l0:00 Commence actions to isolate SI Accumulators N
Earliest start time based on need for FLEX 480VAC Generator deployed and MCC jumpers installed 3l 10:35 Start Control Room Ul Air Recirculation Fan, U2 Supply & Exhaust Fan N
Provides air circulation in the Control Room using power from FLEX 480VAC Generator 32 14:00 SI Accumulators isolated Y
(B)
Required by 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to support RCS cool down below 520 deg F Thot RCS cool down shrinkage is required for BAST injection J J 14:00 FLEX Alternate AFW Pump deployed to support RCS Cool Down &
Depressurization N
Change from TDAFWP to Alternate AFW Pump when S/G pressure no longer supports TDAFWP operation.
34 l4:00 Commence RCS Cool Down to 425 deg F Thot (Unit l) 445 deg F Thot (Unit 2) & RCS Boration N
RCS boration, cool down &
depressurization cornmences when FLEX portable equipment is staged & operators available for local confrol of ASDVs.
Revision 4,8/6115 L-15-219 Page 18 of 19 Target Temperature Basis: Ul-prevent SI accum N2 injection; UZ - TDAFWP critical speed steam pressure (Note: if SI accumulators are isolated, limit does not apply) 35 14:00 Commence deployment of FLEX SFP Make Up Pumps & Hoses N
Earliest start time based on deployment equipment limitations (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowed for completion) 36 14:30 Commence FLEX Portable Equipment Refueling N
Based on 250 gph use for the 480VAC generators
& 5 gph use for PPDWST Make Up Pumps 37 14:40 Complete Cool Down to 520 deg F Thot /
Commence Boration Y
Required by 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to establish RCS pressure (<1500 psig) & volume for boration 38 16:00 FLEX SFP Make Up Pumps & Hoses deployed Y
(c)
Required by 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> Prevent SFP level decrease below 15 ft above top of fuel assemblies 39 20:00 Complete RCS Cool Down to 425 deg F Thot (Unit l),
445 deg F Thot (Unit 2)
N 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allotted for controlled cool down on natural circulation 40 22244 Complete RCS Boration Y
(B)
Required by 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> 61105 gal of high concentration boric acid from the Boric Acid Storage Tanks injected into the RCS at 12 gpm to maintain sub-criticality Allows I hour for mixing to achieve required concentration by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 4l 25:00 Commence set up of Water Purification Units from NSRC N
First equipment from NSRC begins to arrive on site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following notification Revision 4,816115 L-15-219 Page 19 of 19
- Actual historical times to boiling immediately following refueling outages have always been greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AFW: Auxiliary Feed Water ASDV - Atmospheric Steam Dump Valve BAST - Boric Acid Storage Tank DHR - Decay Heat Removal EDG - Emergency Diesel Generator EOP : Emergency Operating Procedure F: Fahrenheit gph : gallons per hour gpm - gallons per minute MCC - Motor Conftol Center MUG: Main Unit Generator PPDWST : Primary Plant Demineralized Water Storage Tank psig : pounds per square inch RCP - Reactor Coolant Pump RCS - Reactor Coolant System RP : Radiation Protection RWST - Refueling Water Storage Tank S/G : Steam Generator SI: Safety Injection TDAFWP : Turbine Driven Auxiliary Feed Water Purnp Thot: RCS Hot Leg Temperature 42 30:00 Determine timing for Cool Down & Depressurization of RCS to Mode 4 Conditions N
Minimize RCS inventory loss &
energy input into containment 43 36:00 Change to RWST for Boration / Make Up N
BAST inventory is expended by 4l hours 44 48:00 Provide Purified Water to the S/Gs to maintain Secondary Heat Sink Y
(c)
Required by 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Satisfactory S/G heat exchange capability can be maintained until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Requires water purification units from the NSRC.
45 72:00 Provide ability to make up to Borated Water Source (Rwsr)
N Borated water used to borate RCS / make to RCS or SFP inventory needs to be replenished. Requires mobile boration units from the NSRC.
Revision 4,816/15 L-15-219 Davis-Besse Nuclear Power Station Fifth Six-Month Status Report for the f mplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of I 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),
documenting the diverse and flexible strategies (FLEX), in response to Referenre2.
This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 MilestoneAccomplishmente The fof fowing milestone(s) have been completed since January 31,2A15 and are current as of July 31, 2015.
o Update 4 was submitted o Commenced construction of FLEX storage building 3 Milestone Schedule Statue The following provides an update to Attachment 2of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The revised milestone target completion dates do not impact the order implementation date.
L-15-219 Page 2 of 8
- Modifications are targeted for 1R19 and on-line; none targeted for 1R18.
- Submittal of completion report occurs after end of refueling outage.
Milestone Target Completion Date Activity Status (as of 71311151 Revised Target Gompletion Date Submit FLEX lntegrated lmplementation Plan 02t28t13 Complete 6 Month NRC Status Updates 02t28t16 Started Update 1 08t28t13 Complete Update 2 02t28114 Complete Update 3 08t28t14 Complete Update 4 02t27 t15 Complete Update 5 08t28t15 Started Update 6 02t28t16 Not Started Validation April-2016 Not Started May-2016 Wal k-th ra us h s ar D e m on stratian s April-2016 Not Started Mav-2016 Complete Staffinq Analvsis October-z015 Started Submit NEI 12-01 Phase 2 Staffins Studv October-2015 Started Complete Plant Modifications ApriF2016 Started Mav-2016 Tarset plant modifications Mav-2013 Complete Mod ifications complete April-2016 Started May-2016 Complete 1Rl8 outaqe modifications June-2014 Complete*
Complete on-line modification s
January-2016 Started Complete 1 Rl9 outase modifications April-2016 Started May-2016 Complete Comm u n icatian s Modification s April-2016 Started Mav-2016 Complete SFP Level lndication Modificafions April-2016 Started FLEX Storage Complete AoriL2016 Started May-2016 Complete Buildins Desi,sn June-2015 Started September-2015 Commence Construction June-2O15 Complete Complete Construction Aoril-2016 Started May-2016 On-site FLEX Equipment February-z016 Started Confirm FLEX Equipment Requirements October-2A14 Complete FLEX Eauipment Ordered October-z915 Started Februarv-2016 FLEX Equipment Delivered February-2O16 Started March-2O16 Off-site FLEX Equipment Februarv-2016 Started Develop Sfrafe.qrbs with RRC***
October-2015 Started Phase 3 Srfe Access Strateqies in Place October-z015 Started Complete Near Sde Sfagrng Location (as needed)
Februarv-2O16 Started Procedures Gomplete April-2016 Started Mav-2016 PWROG r'ssues NSSS-sp ecific,suidelines Ausust-2013 Complete
/ssue Davis-Besse FLEX Strate,qv Guidelines April-2016 Started Mav-2016
/ssue Maintenance Procedures April-2016 Started Mav-2016 Traininq Gomplete April-2016 Not Started Mav-2016 Develop Training Plan September-201 5 Started lmplement Traininq April-2016 Started Mav-2016 Submit Gompletion Report June-2016**
Not Started Julv-2016*"
L-15-219 Page 3 of 8 4 Changes to Compliance Method The following change to the compliance method as documented in the OIP (Reference
- 1) is being made. The change does not impact compliance with Nuclear Energy Institute (NEl) 12-06.
The following discussion details a significant change to the coping strategies planned for the Davis-Besse Nuclear Power Station OIP:
o OIP Open ltem (Ol 1) - Finalize locations for FLEX storase buildings.
Deplovment routes. distances.
and times contained in the submittal are bounded for the currentlv proposed locations but will be updated as necessary: A separate FLEX storage building has been eliminated from the FLEX mitigation strategies. Rather than utilizing a separate, newly constructed FLEX storage
- building, the primary (or N) FLEX equipment will be stored in other robust structures (Auxiliary Building or Emergency Feedwater Facility) constructed to withstand design basis high wind, missile (airborne object), seismic, flooding, and ambient temperature/snodice events or stored in diverse locations consistent with the requirements of NEI 12-06. Because the change to the storage locations results in equipment being stored within the protected area, overall deployment times are not significantly impacted. While deployment time to locations inside the protected area are decreased by a few minutes, deployment times to the areas outside the protected area are increased by a few minutes.
Actual deployment times will be confirmed during strategy validation in accordance with industry guidance.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.
6 Open ltems from Overall Integrated Plan and Interim Steff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (lSE) and the status of each item.
Overall Intesrated Plan Open ltem Status Ol 1. Finalize locations for FLEX storage buildings.
Deployment routes, distances and times contained in the submittal are bounded for the currently proposed locations but will be updated as necessary.
Started.
Ol 2. Finalize the strategy for providing a protected source of borated water to support FLEX strategies.
Complete. (Described in August-2014 status report and updated in Febru ary-2015 status report.)
Attachment 2
L-15-219 Page 4 of I Ol 3. Determine if a mobile boration unit and/or water purification unit is required to support the FLEX res.
Complete. (Described in Aug ust-2014 status report)
Interim Staff Evaluation Open ltem Status 3.2.1.2.A Verify the following with respect to reactor coolant pump (RCP) seals:
(1) the DBNPS [Davis-Besse Nuclear Power Stationl plant condition during an EIAP
[extended loss of all alternating current power] is bounded by the seal leakage test conditions with respect to relevant parameters.
(2) the pop-open failure mechanism resulting from hydraulic instability that is discussed in WCAP-16175-P and WCAP-17601-P would not occur or would be bounded by the assumed leakage rate.
(3) a basis for the assumed leakage rate of 2 gpm
[gallons per minute] is justified in light of recommendations for a larger value of leakage for similarly designed RCPs and seals discussed in WCAP-16175-P and WCAP-17601-P.
(4) the modeling of the pressure-dependence of the seal leakage rate is justified.
(5) the seal design performance under stresses induced by the cooldown of the RCS [reactor coolant systeml is iustified.
Started.
3.2.1.4.A Verify that any industry-identified gaps and recommendations applicable to the generically developed mitigating strategies proposed for DBNPS are addressed (e.g., those documented in WCAP-17792-P (transmittal letter located at ADAMS Accession No. ML1 4037M37) and the appropriate revision of the PWROG's [Pressurized Water Reactors Owners Groupl Core Cooling Management Interim Position Paper).
Started.
3.2.1.6.8 Verify that a revised sequence of events that is consistent with the final EL.AP analyses is developed.
Started.
3.2.1.8.A Verify resolution of the generic @ncern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.
Started.
L-15-219 Page 5 of 8 ISE Confirmatory ltem Status 3.1.1. 1.A Confirm that the diesel-driven service water pumps have deployment and storage plans developed in accordance with the provisions of NEI lNuclear Enersv Institutel 12-06.
Started.
3.1.1.2.A Confirm that the routes that plant operators will have to access to deploy and control the strategy will only require access through seism ical ly robust structures.
Started.
3.1.1.2.8 Confirm that, if power is required to operate the storage building doors, either power supplies will be available to operate the doors or the doors will be equipped with manual overrides to permit manual door openinq.
Started.
3.1.1.3.4 Confirm that guidance is provided for critical actions to perform until alternate indications can be connected and on how to control critical equipment without associated control power.
Not Started.
3.1.1.4.4 Confirm the RRC [regional response center] local staging area, evaluation of access routes, and method of transportation to the site.
Started.
3.1.2.4 Confirm that the licensee has identified the warning time and persistence of the external flooding hazard.
Started.
3.1.2.2.A Confirm that the licensee plans to conform to deployment consideration 1 and 2 of NEI 1 2-06, Section 6.2.3.2.
Started.
3.1.3.1.A Confirm that the chosen storage locations are sufficiently separated in distance and axially from the typical tornado path as compared to the local tornado data for tornado width.
Complete. (Described in Aug ust-z91tr.
status report)
Update: See Section 4 above.
3.2.1.1.A Confirm that reliance on the RELAPS/MOD2-B&W code in the ELAP analysis for Babcock and Wilcox plants is limited to the flow conditions prior to boiler-condenser cooling initiation.
Started.
3.2.1.1.8 Confirm that the licensee has:
(1) ldentified the specific analysis case(s) from WCAP-17792-P that are being referenced as the basis for demonstrating the acceptability of the mitigating strategies for DBNPS, and (2) Provided justification that the analyses from WCAP-17792-P that are being credited for DBNPS are adequately representative of the actual plant design, FLEX equipment, and planned mitigatinq strategies.
Started.
L-15-219 Page 6 of 8 ISE Confirmatory ltem Status 3.2.1.1
.C Confirm the continuity of natural circulation by demonstrating the adequacy of the modeling of operator actions associated with primary-to-secondary heat transfer.
Started.
3.2.1.2.8 Confirm that either:
(1) closure of valve MU38 will not be credited in the ELAP analysis for DBNPS, or (2) procedures to close valve MU38 prior will be implemented to provide assurance that its closure can be credited in the ELAP analysis.
Complete. Procedures are to be implemented providing guidance that reactor coolant pump seal return valve, MU38, is closed by a time critical action within 10 minutes of the event. Deep load shedding, which could remove control power, is not initiated until 15 minutes after the event.
3.2.1.3.4 Confirm the basis for the decay heat modeling assumptions present in the analysis credited for DBNPS in WCAP-17792-P, which was not available to the staff durinq the audit.
Started.
3.2.1.3.8 Confirm that the cooldown directed by the DBNPS mitigating strategy is consistent with the capabilitv of the atmospheric vent valves.
Started.
3.2.1.6.4 Confirm licensee's hydraulic analysis supports that injecting borated water into the RCS within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the event is initiated will maintai n su bcriticalitv.
Started.
3.2.1.8.B Confirm adequate shutdown margin for ELAP scenarios:
(1) with the highest applicable reactor coolant system leakage, and (2) with no reactor coolant system leakage. In addition, confirm that core reload calculation procedures would ensure that these shutdown margin calculations remain bounding for future fuel cycles.
Started.
3.2.1.8.C Confirm that adequate RCS venting capability exists to support the ELAP mitigating stratesv for DBNPS.
Started.
3.2.3.4 Confirm that the containment pressure and temperature after an event initiated in Modes 1 through 4 will stay at acceptable levels during Phases 1, 2, and 3 and that no additional installed equipment or operator actions are required to maintain containment integrity.
Started.
3.2.4.4.A Confirm that upgrades to the site's communications systems have been completed.
Started.
ISE Confirmatory ltem Status 3.2.4.8.A Clarify the discrepancy between the Integrated Plan stated size of the Phase 2 FLEX 480v [volt] portable DGs [diesel generators]
(500kW
[kilowatt])
and the stated size of the Phase 2 FLEX 480v portable DGs in response to the sizing audit question (600kW).
Started.
3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.
Started.
Attachment 2
L-15-219 Page 7 of 8 As indicated in the lSE, the NRC staff review determined that the generic concerns related to shutdown and refueling requirements, battery duty cycles beyond I hours, and maintenance and testing of FLEX equipment are applicable to DBNPS. These concerns were resolved generically through the following NRC endorsements of NEI position papers.
. Shutdown/Refueling Modes (ADAMS Accession No. ML132674382) o Battery Life lssue (ADAMS Accession No. ML13241A188) o Maintenance and Testing (ADAMS Accession No. ML132764224)
FENOC intends to follow the NRC-endorsed guidance for these generic concerns at DBNPS.
ISE Open ltem 3.2.1.8.A tracks the resolution of the generic concern associated with the modeling of the timing and unifonnity of the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.
7 Potential Interim Staff Evaluation lmpacts FENOC is making a change to the compliance method as documented in the OIP (Reference 1). Although the planned change does not impact compliance with NEI 12-06, there is a potential impact on the lSE. The impact may affect the following sections: (1) Section 3.1.1.1, Protection of FLEX Equipment
- Seismic Hazard; (2)
Section 3.1.1.2, Deployment of FLEX Equipment
- Seismic Hazard; (3) Section 3.1.2.1,
Protection of FLEX Equipment
- Flooding Hazard; (4) Section 3.1.2.2, Deployment of FLEX Equipment
- Flooding Hazard; (5) Section 3.1.3.1, Protection of FLEX Equipment
- High Wind Hazard; (6) Section 3.1.3.2, Deployment of FLEX Equipment
- High Wind Hazard; (7) Section 3.1.4.1, Protection of FLEX Equipment
- Snow, lce and Extreme Cold Hazard; (8) Section 3.1.4.2, Deployment of FLEX Equipment-Snow, lce and Extreme Cold Hazard; (9) Section 3.1.5.1, Protection of FLEX Equipment
- High L-15-219 Page 8 of 8 Temperature Hazard; (10) Section 3.1.5.2, Deployment of FLEX Equipment
- High Temperature Hazard; and (1 1) Section 3.2.1.9, Use of Portable Pumps.
8 References The following references support the updates to the OIP described in this attachment.
- 1. FirstEnergy Nuclear Operating Company's (FENOC'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 27,2013.
- 2. NRC Order Number EA-1 2-049, Order Modiffing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.