SBK-L-16011, Sixth 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)

Sixth 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)

ML16048A261
Person / Time
Site:	Seabrook
Issue date:	02/11/2016
From:	Dean Curtland NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, SBK-L-16011, TAC MF0836, TAC MF0837
Download: ML16048A261 (17)

Text

ENERGYra February 11, 2016 SBK-L-1601 1 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-000 1 Seabrook Station NextEra Energy Seabrook, LLC's Sixth 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)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012 (ML12054A736)

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, August 29, 2012 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012 (ML12242A378)

4. NextEra Energy Seabrook, LLC'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),

October 26, 2012 (ML12311A013)

5. 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), February 26, 2013 (ML13063A438)

6. NextEra Energy Seabrook, LLC's 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 049), August 28, 2013 (ML13247A178)

7. NextEra Energy Seabrook, LLC's Second Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), February 27, 2014 (ML14064A188)

/

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-1601 1/Page 2

8. NextEra Energy Seabrook, LLC's 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 049), August 26, 2014 (ML14246A193)

9. NextEra Energy Seabrook, LLC's 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 049), February 27, 2015 (ML15068A021)

10. NextEra Energy Seabrook LLC's 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, July 23, 2015 (ML15209A581)

11. NextEra Energy Seabrook, LLC's 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 049), August 26, 2015 (ML15245A531)

12. Seabrook Station, Unit 1 - Relaxation of the Schedule Requirements of Order EA 049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (TAC No. MF0836), October 4, 2015 (ME15244A045)

13. Seabrook Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA 049 and EA-12-051 (TAC Nos. MF0836 AND MF0837), October 28, 2015 (ML15278A200)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra Energy Seabrook). Reference 1 was immediately effective and directed NextEra Energy Seabrook 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 IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the NextEra Energy Seabrook initial status report regarding mitigation strategies. Reference 5 provided the NextEra Energy Seabrook Overall Integrated Plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6, 7, 8, 9, and 11 provided the six-month status reports pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the

U.S. Nuclear Regulatory Commission SBK-L-1601 1/Page 3 requirements of Reference 1. Reference 9 also included the revised FLEX Integrated Plan. The Attachment to this letter provides the sixth six-month update report required by Reference 1 that delineates progress made in implementing the requirements of Reference 1 and an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Michael Os sing, Licensing Manager, at (603) 773-7512.

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

Executed on February I

,,2016.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President cc:

D. Dorman, NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 P. Cataldo, NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratchmann, NRRIJLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Attachment to SBK-L-1601 1 NextEra Energy Seabrook, LLC's Sixth 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)

NextEra Energy Seabrook, LLC's Sixth Six-Month Status Report for the Implementation of Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events' 1

Introduction NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) developed and submitted an Overall Integrated Plan (Reference 5) in response to NRC Order EA-12-049 (Reference 1). The Integrated Plan was subsequently revised to describe Seabrook' s current proposed diverse and flexible coping strategies (FLEX) and submitted with the Fourth Six-Month Status Report (Reference 9).

This Sixth Six-Month Status Report provides an update of milestones and milestone accomplishments since the initial submittal of the Overall Integrated Plan, describes changes to the compliance method, provides an update of the pending and open/confirmatory actions, and provides an update of the Seabrook FLEX Audit open items.

2 Milestone Accomplishments The following milestones have been completed since the Fifth Six-Month Status Report submittal of August 26, 2015 and are current as of January 19, 2016:

Submit sixth 6 month status report.

Install RCP low leakage seals.

Procure SEPS / portable equipment refueling trailer.

• Achieve operational status for offsite resources (SAFER NSRC).

Other significant accomplishments include:

• All outage-required FLEX modifications have been completed.

• The Unit 2 Circulating Water Piping cistern has been completed and filled with water.

• The ESF Bus 5 and 6 cabling for connecting to the NSRC generators has been fabricated.

• The SG and RCS makeup connection modifications for FLEX strategies have been implemented.

• The refueling strategy pumps have been installed in the DG fuel tank rooms.

• The SEPS seismic hardening modification has been completed.

• The FLEX portable equipment has been received on site, tested, and stored at least 1200 feet from the SEPS equipment.

• The FLEX Support Guidelines have been developed and reviewed (issuance awaiting final project implementation).

• FLEX training has been provided to site personnel.

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3 Milestone Schedule Status The following provides an update to Attachment 2 of the original submittal of the Seabrook Overall Integrated Plan (OIP) (Reference 5). The table includes the current status of each item and whether the expected completion date has changed. As noted in the original station submittal these dates are planning dates which are subject to change as design and implementation details are developed.

The following milestone target completion dates have been adjusted or added since the last six-month update:

In the original submittal of the OIP in February 2013 (Reference 5), the milestone to "Revise/develop procedures based upon approved strategies and engineering change packages" had a target completion date of December 2014. The procedures have been developed and reviewed, and are ready to issue pending storage of FLEX equipment in the final storage locations as well as procedure validation completion. Validation is in progress, and when complete the procedures will be reviewed and updated as appropriate. The revised target completion date is March 2016, based on when the FLEX equipment will be moved to the final storage locations and the procedures can be issued.

In the original submittal of the QIP in February 2013 (Reference 5), the milestone to "Develop PMs for refueling trailer" had a target completion date of March 2015. This milestone has been extended to March 2016, to be complete prior to final implementation of Order EA-12-049.

In the first six-month update provided March 2012 (Reference 6), the milestone "Conduct walkthroughs / demonstrations of portable equipment connection points" was added with a target completion date of August 2015. These walkdowns are in progress, and the revised target completion date is March 2016.

A new milestone has been added to confirm the move of equipment items from their temporary storage locations to their final storage locations, and to inventory the equipment items in their final storage locations. Target completion date is March 2016.

Revised milestone target completion dates support NextEra Energy Seabrook's full compliance date of May 30, 2016.

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Target Revised Milestone Completion Activity Status Target Date Completion Date Submit Overall nertdFbur203CmleN/

Impiementation Plane eray213Cmlt

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Submit 6 Month Updates:

Update 1 August 2013 Complete N/A Update 2 February 2014 Complete N/A Update 3 August 2014 Complete N/A Update 4 February 2015 Complete N/A Update 5 August 2015 Complete N/A Update 6 February 2016 Complete N/A Prepare engineering change December Cancelled N/A packages for SEPS missile barrier 2014 Prepare engineering change package December Complete N/A for RCP low leakage seals 2014 Prepare bid for construction of March 2015 Cancelled N/A SEPS missile barrier Install RCP shutdown seals in four April 2014 Complete N/A pumps in refueling outage #17 Construct SEPS missile barrier December Cancelled N/A 2014 Revise / develop procedures based December Working March 2016 upon approved strategies and 2014 engineering implementation packages 3 of 13

Target Revised Milestone Completion Activity Status Target Date Completion Date Develop required training for station December Complete N/A staff based upon draft procedure 2014 changes and engineering change packages.

Procure SEPS / portable equipment December Complete N/A refueling trailer 2014 Develop PMs for refueling trailer March 2015 Working March 2016 Store refueling trailer in Service June 2015 Pending March 2016 Water Pump house Off-site resources implementation June 2015 Complete N/A site - RRC operational fall 2015 Conduct walkthroughs /

August 2015 Working March 2016 demonstrations of portable equipment connection points Implement training for station staff September Working N/A 2015 Complete movement of all FLEX March 2016 Pending equipment to final storage locations and complete inventory.

Final implementation - Order full November Working May 2016 compliance letter to NRC 2015 4 of 13

4 Changes to Compliance Method NextEra Energy Seabrook has received feedback in the form of NRC audit questions and subsequent teleconferences with NRC Staff reviewers. The NRC' s Interim Staff Evaluation (ISE) was also received. A revised Integrated Plan and list of pending actions was included in the fourth six-month update to the NRC, dated February 27, 2015 (Reference 9). The onsite NRC FLEX audit was conducted the week of July 27, 2015. Items were reviewed by NRC Staff reviewers, audit questions responded to, and Staff Evaluation items closed or statused as open/pending. The audit report was received October 28, 2015 (Reference 13).

Since the revised Integrated Plan was transmitted to the NRC on February 27, 2015, the following changes have been made to the NextEra Energy Seabrook strategies:

a) The large FLEX portable generator was described as a 250 kW, 480V generator in the February 27, 2015 revised Integrated Plan. During the July, 2015 audit it was noted that the generator actually procured was a 405 kW, 480V generator, and that its maximum loading was slightly less than 405 kW. Subsequent to the audit, it was decided to provide additional operating margin by reducing generator loading. This was done by removing the control room chillers from the list of equipment being energized.

b) Originally the Modes 5 and 6 strategies required use of the personnel hatch to vent containment. This would have required maintaining both personnel hatch doors open during all shutdown conditions, or opening a hatch door under pressure. An alternate option has been chosen, to use existing Combustible Gas Control (CGC) system piping as the vent path. At the beginning of each outage in Mode 5, prior to draining either the primary or secondary sides of the SGs, a vent path will be installed on a section of CGC piping inside containment to allow venting to outside containment if an ELAP occurs.

The final FIP will include analysis supporting this strategy.

Additionally, interim actions have been implemented to provide the new SFP Level Indication equipment an alternate power source until FLEX is fully implemented at Seabrook. A portable generator has been stationed in the "B" Diesel Generator Building, to be deployed to provide power to the SFP Level Indication equipment during an extended loss of power event.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation On July 23, 2015, NextEra Energy Seabrook submitted Reference 10 requesting schedule relaxation from the Order requirements for completion of full implementation from November 2015 to May 30, 2016. The request for relaxation was based on the development of a second set of strategies. On October 4, 2015, the NRC authorized this relaxation (Reference 12), noting:

a) Seabrook has already developed procedures and has trained personnel on how to operate the SEPS and realign plant cooling to the service water cooling tower.

b) During the delay, portable equipment onsite will be stored more than 1200 feet from the SEPS equipment to provide protection by separation.

c) The service water pumphouse modification and final implementation will occur prior to the next hurricane season.

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6 Open Items from Overall Integrated Plan and NRC Interim Staff Evaluation /TER The following Table provides a summary of the Pending Items documented in the Overall Integrated Plan:

Overall Integrated Plan Pending Actions Status Revise ECA-0.0 to include steps to transition to In Progress. ECA-0.0 (revised and FLEX Support Guidelines (FSGs) when an extended awaiting issuance) provides the loss of offsite power event is in progress. This transitions to FSG-0.0 and FSG-0. 1.

determination will delineate future procedural strategies and transitions.

2 Develop FSG-0.0 attachments to include a SEPS Complete. FSG-0.0 Attachments A and load reduction method for an extended loss of offsite B provide for maintaining loads within power event to control SEPS loading within the the capacity of one SEPS engine.

capacity of one engine.

3 A seismic evaluation will be conducted on the Complete, no credit will be taken for connections that penetrate the upper half of the the non-seismic volume in the CST.

Condensate Storage Tank (CST) to determine if NextEra Energy Seabrook can take credit for the entire tank volume for Phase 1 & 2 event coping.

4 Develop FSG-0.0 to add a step to manually Complete shutdown the motor-driven Emergency Feedwater (EFW) pump if the Turbine Driven (TD)EFW pump is running satisfactorily.

5 Add an Attachment to ES-0.2, ES-0.3 and ES-0.4 In Progress. This is addressed in FSG-that provides a table of electrical loads for 0.0 (developed and awaiting issuance) responding to an extended loss of offsite power and not in ES-0.2, ES-0.3, and ES-0.4.

event.

6 Develop a SEPS generator set (genset) refueling In Progress. FSG-5 provides refueling strategy from 1) an offsite supplier outside a 25 mile strategies, offsite supplier contract radius from the station (primary strategy), and 2) the update is in progress.

Emergency Diesel Generator (EDG) fuel oil storage tanks using a refueling trailer stored in the Service Water (SW) Pumphouse (backup strategy). This strategy will include provisions for refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event that only a single SEPS is functional.

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Status 7

Develop FSG-5 and FSG-5.1 to include a step for implementation of a SEPS genset refueling strategy.

Complete. FSG-5.1.1 Develop a FSG for refueling SEPS from the EDG Complete. FSG-5.1.1 fuel oil storage tanks using a portable refueling trailer. Utilize the information contained in existing procedure 0S51061.02, 'Receipt of SEPS Fuel Oil',

for development of the FSG.

9 Develop FSG-5 to include direction for connecting Complete.

the backup diesel-driven air compressor to the Service Air system to restore Instrument Air system pressure.

10 Develop required preventive maintenance actions In Progress.

and surveillance test procedures for the refueling trailer to be procured and stored in the SW Pumphouse.

11 Revise AOPs to include transitions to FSG-1 1 and In Progress. 0S1213.01, OS1213.02, FSG-14 when Extended Loss of all AC Power and 0S1246.01 (developed and (ELAP) is in progress for shutdown mode strategies, awaiting issuance) will provide transitions to FSG-14. OS1215.07 (developed and awaiting issuance) will provide the transition to FSG-1 1.

12 Conduct an engineering evaluation to determine if Complete. SEPS missile protection will the existing hurricane enclosures for the SEPS not be added. Other missile protected gensets provide adequate missile protection. If strategies are being added.

protection is not adequate, develop a design change (BC) to add missile protection for the SEPS gensets.

13 Evaluate the 'seismic robustness' of SBPS and Complete. BC 282774 Fukushima determine if enhancements are needed with respect SEPS Foundations and Exhaust to the new Ground Motion Response Spectrum Seismic Upgrade and BC 282825 (GMRS) data for the site.

Fukushima SEPS components Seismic Upgrades.

14 Once the site flooding re-evaluation is completed in In Progress. The Seabrook Flooding accordance with Recommendation 2.1 of the RFI Hazard Reevaluation Report was letter, determine if additional flood protection is submitted 9-25-15 and is currently in necessary for SEPS5.

NRC review.

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Overall Integrated Plan Pending Actions San Status 15 16 Formalize the Engineering assessment of ELAP load capacity for a single SEPS genset and modify procedural guidance in the applicable Emergency Operating Procedures (EOPs) and FSGs, as necessary.

Complete. FSG-0.0 Evaluate SEPS snow removal plan and revise the plan as necessary.

In Progress. While SEPS missile protection will not be added, the snow removal plan is being reviewed to ensure the refueling trailer path to SEPS is cleared.

17 Determine if a quantity of diesel fuel will be In Progress. The existing contract with provided from the National SAFER Response an offsite supplier outside the 25 mile Centers (NSRCs) along with requested Phase 3 radius is being updated.

portable equipment. If not, establish a contract with a fuel supplier outside a 25 mile radius from the plant to provide fuel within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of a Beyond Design Basis External Event (BDBEE).

18 Develop a FSG for staging and deployment of Phase Complete. FSG-4, FSG-4.1, FSG-13, 3 equipment from the RRCs into the Protected Area FSG-13.1 (PA).

19 Develop a FSG for connecting the two 1MW Complete. FSG-4.1 generators from the NSRC to 4.16 KY Emergency Buses E5 and E6 and a 1MW generator from the NSRC to 480V Buses E53 and E63.

20 Develop a FSG for refueling the NSRC generators Complete. FSG-5.1.1 or incorporate this action into the SEPS refueling FSG.

21 Install low leakage RCP seals on all four RCPs to Complete. All four seals installed minimize RCS leakage into Containment, during OR17.

22 Based on PWROG guidance, determine if new FSGs Complete, new FSGs are being are required that incorporate the existing guidance developed for Steam Generator (SG) provided in SAG-i, 'Inject to the SGs', and SAG-3, and RCS injection in the event SEPS is

'Inject to the RCS' or whether transition points to unavailable using alternate FLEX RCS these two Severe Accident Management Guidelines makeup connections. This is (SAMGs) should be added to the applicable EOPs.

independent of SAMG guidance.

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Overall Integrated Plan Pending Actions Status 23 Develop a method for obtaining local readings for Complete. FSG-7 and FSG-7. 1.1 the 12 critical parameters identified in the Integrated Plan and include in site procedures as appropriate.

24 Develop Westinghouse FSGs to support ELAP Complete. FSG-0.1 directs the strategies with SEPS unavailable, response to ELAP with SEPS unavailable.

25 Develop BC to use existing below grade Unit 2 Complete. BC 282982 modifies the Circulating Water (CW) abandoned piping section below grade Unit 2 Circ water piping as a holding tank for credited makeup in SG to be used as a cistern for injection injection strategies.

water.

26 Perform analysis to qualify Unit 2 CW piping as a Complete. Documented in BC 282982 credited makeup source in seismic and missile Fukushima FLEX Unit 2 CW Pipe related events.

Water Storage.

27 Perform analysis for containment pressure &

Complete. C-X-1-28 141 Containment temperature response after installation of RCP Response During ELAP - Gothic shutdown seals to ensure containment integrity is not challenged without containment cooling.

28 Perform analysis for SG feedwater quality Complete. C-X-1-20720-CALC, S/G requirements to ensure continued SG heat sink Water Quality Analysis Through 72 capability for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following loss of AC power.

Hours 29 Perform analysis for RCS boration and cooldown Complete. CN-SEE-II-15-3-Revision 1 strategies to support FSG development.

30 Complete SG, Spent Fuel Pool (SFP), and RCS Complete. C-X-1-20718-CALC makeup hydraulic analysis for FLEX strategies in Diverse and Flexible Coping Strategy modes 1-6.

Hydraulic Analysis 31 Complete FSG setpoint calculations and basis.

In Progress.

32 Complete FLEX equipment storage building Complete. EC 282582 FLEX Portable analysis and develop BC for SW pumphouse Equipment Storage.

building moods.

33 Complete site flooding analysis and add any interim In Progress.

actions to OS 1200.03, Severe Weather Conditions.

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Overall Integrated Plan Pending Actions Status 34 Procure site FLEX portable equipment to augment Complete.

Seabrook BDBEE response strategies.

35 Complete ECs for plant system FLEX connections Complete. EC 282580 for Fire Tanks, EFW pumphouse, Demineralized Water Storage Tanks (DWSTs), and Positive Displacement Charging pump.

36 Complete Analysis for > 8 hrs heat removal using Complete. C-X-1-20719-CALC CST.

Determination of Water Inventory Required for RCS Heat Removal During ELAP 37 Revise the NextEra Energy Nuclear Training Complete Program to assure personnel proficiency in the mitigation of BDBEE is adequate and maintained.

38 Complete the travel route soil liquefaction study.

Complete. This study has been provided to the NRC for their review.

39 Modify the SWPH entrance with a new Barrier I In Progress missile door to allow for rapid deployment with missile protection.

7 Interim Staff Evaluation Open/Confirmatory Item Status Open/Confirmatory Item Status 3.2.4.8.A Verify that the enclosure for the SEPS DGs and switchgear SEPS-Closed SWG-1 provides sufficient protection of the equipment from seismic events and wind driven missiles.

3.1.1.1.A Protection of FLEX equipment from seismic and high wind Closed hazards - Confirm that the PDDPs and hose trailers will be adequately protected from seismic and high wind hazards.

3.1.1.2.A Confirm that at least one connection point for each use of a PDDP Closed (see is protected from a seismic event (includes access to the connection point and actiowon, ui areas the operators have to access to deploy or control the PDDP).

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3.1.1.2.B Confirm that a tow vehicle for FLEX equipment movement is Closed reasonably protected from a seismic event, flooding event, and high wind event.

3.1.1.3.A Procedural interface for seismic hazards -Confirm that operators Closed have procedural guidance and references for the methods of obtaining local readings for critical parameters to support the implementation of the coping strategy, consistent with the guidelines in Section 3.2.1.10 of NEI 12-06.

3.1.1.4.A Off-Site Resources - Confirm the location of the local staging area Closed for the RRC equipment, and that access routes to the site, the method of transportation, and the drop off area have been properly evaluated for all applicable hazards.

3.1.5 High temperature - Confirm that the effects of high temperature have Closed been considered in the procurement, protection, and deployment of FLEX equipment.

3.2.1.7.A Confirm that portable FLEX equipment is included in the Closed licensee's program to maintain equipment available for deployment in shutdown and refueling modes.

3.2.1.9.A Use of portable pumps - Confirm that appropriate procedural Closed 3.2A1.9.B Confirm availability of the fire main to provide a suction source Closed 3.2.2.A Confirm that the PDDPs and hose trailers are incorporated into the Coe FLEX guidelines for makeup and spray to the SFP.

3.2.4.4.A Confirm that adequate portable lighting is available for operator use Closed during an ELAP event.

3.2.4.4.B The NRC staff has reviewed the licensee communications Closed assessment (ADAMS Accession Nos. ML 123 11A34 and ML13060A048) and has determined that the assessment and planned upgrades are reasonable (ADAMS Accession No. ML13102A254). Confirm that the upgrades have been completed.

3.2.4.7.A Confirm the source of water to be used for makeup to the service Closed water cooling basin tower by the portable diesel-driven cooling tower makeup pump.

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.9 3.2.4.8.B Confirm that any SEPS missile barrier modifications do not Closed interfere with the ability to remove snow from the SEPS DGs air intake system.

3.2.4.9.A Confirm that the refueling strategy for SEPS has been changed to Closed require refueling to begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event.

3.3.1.A Confirm that the PDDPs will be included in the maintenance and Closed testing (M&T) program in conformance with the Electric Power Research Institute report on M&T.

3.3.2.A Confirm that the configuration control of FLEX strategies conforms Closed to the guidance of Section 11.8 of NEI 12-06.

3.4.A Offsite resources - Confirm that NEI 12-06, Section 12.2 guidelines 2 Closed through 10, regarding minimum capabilities for offsite resources, have been adequately addressed.

8 July 2015 Audit Open Item Status The following Table provides a summary of the Open Items from the July 2015 audit.

July 2015 Audit Open Item Status 1 ISE Cl 3.1.1.2.A, Deployment Paths -

The evaluation has been provided During the audit walkdown, the staff noted non-seismic and the staff is currently reviewing piping above the FLEX low pressure pump hose the evaluation.

deployment path. The staff requested that the licensee make available an evaluation of the non-seismic piping over the FLEX deployment paths.

2 AQ 3, Soil Liquefaction -

The evaluation has been provided The staff requested that the licensee make available the and the staff is currently reviewing soil liquefaction assessments performed on the the evaluation.

deployment routes.

3 AQ 19, Heat Tracing -In process.

The staff requested that the licensee make available a heat tracing analysis for equipment required to cope with an ELAP.

4 AQ 33, Non-Safety Related Equipment -

The staff is currently reviewing the The licensee indicated that the U2 piping cistern is evaluation.

seismically protected and made available a seismic evaluation.

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.1 July 2015 Audit Open Item Status SE Review Item 12, Missile Protection -

The staff is currently reviewing the The licensee made available its missile protection evaluation.

evaluation of the TDEFWP exhaust.

6 SE Review Items 14, 15, and 20, Heat-up Calculations -

The staff requested the following actions regarding temperature heatup calculations and associated ventilation actions:

1. The staff requested that the control room temperature extrapolation be formally documented.

2. The staff requested that the battery rooms' temperature extrapolation for both hot and cold outside ambient conditions be formally documented.

3. The staff requested that the essential switch gear rooms' temperature extrapolation be formally documented considering the additional heat loads being added by the restoration of electric power during Phases 2 and 3 of the ELAP event.

4. The staff requested that the emergency feedwater pumphouse temperature extrapolation be formally documented.

5. The staff requested that the main steam and fee dwater pipe chase's temperature extrapolation be formally documented. In addition, the staff requested that the licensee make available an evaluation of the impact of any uninsulated atmospheric steam dump valve (ASDV) piping, if the ASDVs are in service during the ELAP. The staff noted that the evaluation should include justification that the actions that need to be performed in the chases (i.e., connection of the FLEX low pressure pump to the SG feed lines) are capable of being accomplished with the conditions that will exist in those areas. Lastly, the staff requested that the licensee make available an evaluation of the environmental qualification of the ASDV nitrogen supply system.

6. The staff requested that the licensee make available the containment pressure and temperature calculation.

7. The staff requested that the licensee make available the ventilation actions (e.g., open doors, stage temporary ventilation, etc.) as a result of the heat-up calculations for the rooms listed above.

In process.

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