CP-201500995, Compliance with NRC Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design-Basis External Events (Order Number EA-12-049)

Compliance with NRC Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design-Basis External Events (Order Number EA-12-049)

ML15331A037
Person / Time
Site:	Comanche Peak
Issue date:	11/18/2015
From:	Flores R, Thomas McCool Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201500995, EA-12-049, TAC MF0860, TAC MF0861, TXX-15137
Download: ML15331A037 (8)

Text

Rafael Flores Luminant Power Senior Vice President PG Box 1002

& Chief Nuclear Officer 6322 North F'M 56 rafael.flores@lu minant.corn Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201500995 REF 10 CFR 2.202 Log # TXX-15137 November 18, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket No. 50-446, Compliance with NRC Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design-Basis External Events (Order Number EA 049) (TAC NOS. MF0860 AND MF0861)

REFERENCE:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events, dated March 12, 2012.

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and required Luminant Power to implement mitigation strategies for beyond-design-basis external events. Specific requirements are outlined in Attachment 2 of Reference 1.

Pursuant to Section IV, Condition C.3 of Reference 1, the Attachment to TXX-15137 provides a summary of Comanche Peak Nuclear Power Plant Unit 2 full compliance with the requirements of Attachment 2 of Reference 1.

This letter contains no new regulatory commitments.

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

U. S. Nuclear Regulatory Commission TXX-1 51 37 Page 2 of 2 11/18/2015 I state under penalty of perjury that the foregoing is true and correct.

Executed on November 18, 2015.

Sincerely, Luminant Generation Company LLC Rafael Flores B:Thomas(-i.McCool Vice President Nuclear Engineering and Support Attachment Comanche Peak Nuclear Power Plant (CPNPP) Unit 2, Compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design-Basis External Events c- William M Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Stephen A. Monarque, NIRR Baiwant K. Singal, NRR Resident Inspectors, Comanche Peak

Attachment to TXX-i15137 CPNPP Unit 2 Compliance with NRC Order EA-12-049 Page 1 of 6 Comanche Peak Nuclear Power Plant (CPNPP) Unit 2, Compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Luminant Generation Company LLC (Luminant Power) developed an Overall Integrated Plan (OIP)

(References 5, 6 and 7) to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mifigation Strategies for Beyond-Design-Basis External Events (References 1 and 3). As required by the order, Luminant Power has submitted OIP status updates at six month intervals (References 11, 12, 13, 17, and 19). The information provided herein, as well as the implementation of the ODIP, documents compliance with Order EA-012-049 for Comanche Peak Nuclear Power Plant (CPNPP) Unit 2.

2. Open Item Resolution FLEX issues from the NRC Audit Report (Reference 18) have been addressed by Luminant Power. The FLEX issues that were identified as open and pending by the NRC Audit Report (Reference 18) are listed below:

ISE Confirmatory Items (ISE CI) - ISE CI 3.2.1.2.A and 3.2.4.4.B Audit Questions (AQs) - AQ-27, AQ-30 Licensee-identified OIP Ols - CPNPP has no open or pending licensee-identified open items.

Additional SE needed information - SE-2, SE-S As result of conmmunications between the NRC staff and Luminant Power, responses to address the above six open items have been uploaded to the NRC ePortal. These six open items are considered complete pending NRC review and closure.

Attachment to TXX-1 5137 CPNPP Urnit2 Comptiance with NRC Order EA-12-049 Page 2 of 6

3. Milestone Schedule - Complete Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete ________

Submit Overall Integrated Plan Feb 2013 Complete ________

Submit 6 Month Updates:_______

UpaeIAug 2013 Complete _______

Upae2Feb 2014 Complete Upae3Aug 2014 Complete Upae4Feb 2015 Complete Upae5Aug 2015 Complete FLEX Strategy Evaluation Aug 2013 Complete Walk-throughs or Demonstrations Apr 2015 Complete Nov 2015 Perform Phase 2 Staffing Analysis Jun 2014 Complete Jun 2015 Modifications Evaluation Aug 2013 Complete Develop Unit 2 Modifications Mar 2015 Complete Jul12015 Unit 2 lImplementation Outage (2RF15) Oct 2015 Complete Nov 2015 Storage:

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

Procure On-Site Equipment Jul12015 Complete Nov 2015 Develop Site Response Plan with NSRC Apr 2015 Complete Aug 2015 Install Off-Site Delivery Station (if Necessary) Not Required Not Required Not Required National Safer Response Center Operational Aug 2014 Complete Procedures:

PWROG issues NSSS-specific guidelines May 2013 Complete Issue FSGs Aug 2014 Complete Nov 2015 Create Maintenance Procedures Jul 2014 Complete Nov 2015 Training:

Develop TrainingPlan May 2014 Complete Dec 2014 Implement Training Apr 2015 Complete Nov 2015 Full Site FLEX Implementation Oct 2015 Started May 2016 Submit Unit 2 Completion Report Feb 2016 Complete Nov 2015

Attachment to TXX-1 51 37 CPNPP Unit 2 Comptiance with NRC Order EA-12-049 Page 3 of 6

4. Order EA-12-049 Compliance Elements Summary The elements identified below for CPNPP Unit 2 as well as the FLEX GIP (Reference 7), the 6-Month Status Reports (References 11, 12, 13, 17, and 29), demonstrate compliance with Order EA-12-049. Luminant Power voluntarily participated in the online NRC ePortal and NRC Audit process (virtual and onsite) (References 8, 9, 10, 15, and 18). The CPNPP, Units 1 and 2, Final Integrated Plan for mitigating strategies will be provided upon full compliance for CPNPP, Unit 1 (Spring 2016). NRC Order EA-12-051 (Reference 2) was implemented for CPNPP Units 1 and 2 in the fall of 2014 as reported in Reference 14.

4.1 Strategies - Complete CPNPP Unit 2 strategies are in compliance with Order EA-12-049. All strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items have been addressed as noted in Reference 18 with the exception of the six open items related to Order EA-12-049. The six open items have been addressed and uploaded to the NRC ePortal and are considered complete pending NRC closure.

4.2 Modifications - Complete The modifications required to support the FLEX strategies for CPNPP Unit 2 have been fully implemented in accordance with the station processes.

4.3 Equipment - Procurement and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for CPNPP Unit 2 has been procured, received at CPNPP, initially tested and performance verified as recommended in accordance with NET 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide (Reference 4) and is available for use. Maintenance and testing requirements are included in the CPNPP Preventative Maintenance Program such that equipment reliability is monitored and maintained.

4.4 Protected Storage - Complete The storage facility required to implement the FLEX strategies for CPNPP Unit 2 has been constructed and provides adequate protection from the applicable site hazards. The equipment required to implement the FLEX strategies for CPNPP Unit 2 is stored in its protected configuration.

4.5 Procedures - Complete FLEX Support Instructions (FSIs) for CPNPP Unit 2 have been developed and integrated with existing procedures. The FSGs and applicable procedures have been verified and are available for use in accordance with the site procedure control program.

4.6 Training - Complete Training for CPNPP Unit 2 has been completed in accordance with an accepted training process, as recommended in NET112-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide (Reference 4).

Attachment to TXX-1 51 37 CPNPP Unit 2 Comptiance with NRC Order EA-12-049 Page 4 of 6 4.7 Staffing - Complete The CPNPP Phase 2 staffing assessment for CPNPP (Reference 16) has been completed in accordance with 10 CFR 50.54(f) letter (Reference 20). The commitments in Reference 16 (which included Phase 2 staffing assessment gaps) have been completed.

4.8 National Safer Response Centers - Complete Luminant Power 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 CPNPP with Phase 3 FLEX equipment stored in the Natilonal SAFER Response Centers in accordance with the site specific SAFER Response Plan.

4.9 Validation - Complete Luminant Power 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) (Reference 7) for Order EA-12-049 (including the Six-Month Status Reports) (References 11, 12, 13, 17, and 19) using the graded approach described in the NET guidance document (Reference 4) and an integrated review to ensure that adequate resources (personnel, equipment, materials) are available to implement the individual strategies to achieve the intended results.

4.10 FLEX Program Document - Complete The CPNPP FLEX Program Document (STA-250 "Beyond Design Basis External Events (BDBEE) FLEX Program") has been developed in accordance with the requirements of NE1 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Reference 4).

Attachment to TXX-1 51 37 CPNPP Unit 2 Compliance with NRC Order EA-12-049 Page 5 of 6

5. References

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

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

4. NEI112-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012

5. Luminant Generation Company LLC's Letter TXX-12158, Initial Status Report in Response to March 12, 2012 Comumission Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External events (Order Number EA-12-049), dated October 25, 2012

6. NRC Letter from Michele G. Evans to All Operating Power Reactors and Holders of Construction Permits, "Status of 60-Day Response To Orders Modifying Licenses Regarding Recommendations 4.2, 5.1, And 7.1 of The Near-Term Task Force Related To The Fukushima Dai-Ichi Nuclear Power Plant Accident" dated November 29, 2012

7. Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 28, 2013.

8. NRC Letter from David L. Skeen to All Operating Power Reactors and Holders of Construction Permits, "Online Reference Portal For Nuclear Regulatory Commission Review Of Fukushima Near-Term Task Force Related Documents" dated August 1, 2013

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

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

11. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), letter TXX-13129 dated August 28, 2013.

12. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), letter TXX(-14025 dated February 27, 2014.

Attachment to TXX-1 51 37 CPNPP Unit 2 Compliance with NRC Order EA-12-049 Page 6 of 6

13. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), letter TXX-14104 dated August 28, 2014.

14. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, Compliance with NRC Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC NOS. MF0862 AND MF0863), letter TXX-14132 dated December 16, 2014

15. NRC Letter from Stephen Monarque to Rafael Flores, "Comanche Peak Nuclear Power Plant, Units 1 And 2 - Plan For The Onsite Audit Regarding Implementation Of Mitigating Strategies Related To Order EA-12-049 (TAC NOS. MF0860 AND MF0861)" dated March 26, 2015

16. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 And 50-446, Submittal of Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing) and Updated Commitments Regarding Recommendation 9.3 (Communications and Staffing) (TAC NOS. ME8686 and ME8687), letter TXX-15084 dated June 1, 2015

17. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MvF0861), letter TXX-15035 dated February 26, 2015.

18. NRC Letter from Stephen Monarque to Rafael Flores, "Comanche Peak Nuclear Power Plant, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies Related to Order EA-12-049 (TAC Nos. MF0860 and MF0861), dated August 5, 2015.

19. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, 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 Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861)," letter TXX-15124 dated August 27, 2015.

20. NRC Letter from Eric J. Leeds to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 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-chi Accident" dated March 12, 2012