NL-16-0022, Sixth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

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Sixth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)
ML16057A158
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 02/25/2016
From: Pierce C
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-16-0022
Download: ML16057A158 (7)
v • d • e


Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN ..\

Fax 205.992.7601 NUCLEAR f£9 2 5 2016 A SOUTHERN COMPANY Docket Nos.: 50-348 NL-16-0022 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (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, dated March 12, 2012.
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012.
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.
4. Joseph M. Farley Nuclear Plant- Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013.
5. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Joseph M. Farley Nuclear Plant- Units 1 and 2 (FNP) 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.1.a of Reference 1. Reference 2 endorses industry guidance document NEI 12-06, Revision 0, (Reference 3) with clarifications and exceptions identified in Reference 2.

U.S. Nuclear Regulatory Commission NL-16-0022 Page2 Reference 4 provided the initial FNP overall integrated plan (OIP). A revised OIP was submitted with the fall 2014 six-month update (Reference 5).

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. The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides 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, if any.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted,

[!t?~

C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS My commission expires:

Enclosure:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

U. S. Nuclear Regulatory Commission NL-16-0022 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Ms. B.L. Taylor, Regulatory Affairs Manager- Farley RType: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Senior Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer

Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Requirements of the Commissi on Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events CEA-12-049) 1 Introduction Joseph M. Farley Nuclear Plant- Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishm ents In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the previous 6-month update, and are current as of December 31, 2015:

  • Develop Strategies (Farley Response Plan) with National SAFER Response Center
  • Develop Operational Procedure Changes
  • Develop Modifications
  • Develop Training Material 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 1).

It 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 Target and Revised Target Completion Dates are based on the approval of one additional refueling cycle for full implementation of the Order for Joseph M. Farley Nuclear Plant- Units 1 and 2 (References 4 & 5).

Target Revised Target Milestone Activity Completion Completion Status Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Unit 2 1st RFO May 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Equipment Procurement Sep 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aug 2014 Complete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Submit 6 Month Status Report Aug 2015 Complete N/A Develop Strategies (Farley Response Plan) with National SAFER Response Center Dec 2015 Complete N/A Develop Operational Procedure Changes Dec 2015 Complete N/A Develop Modifications Dec 2015 Complete N/A Develop FSGs Dec 2015 Complete N/A Develo_Q Training Material Dec 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Phase 2 E_g_uipment Procurement Com_Qiete Mar 2016 In Progress Issue FSGs Mar 2016 In Progress E-1

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation Target Revised Target Activity Milestone Completion Completion Status Date Date Implement Training Mar 2016 In Progress Unit 2 Walk-throughs or Demonstrations Mar 2016 In Progress Unit 2 Implementation Outage

  • Apr 2016 Not Started Submit 6 Month Status Report Aug 2016 Not Started Unit 1 Walk-throughs or Demonstrations Sep 2016 Not Started Unit 1 Implementation Outage
  • Oct 2016 Not Started Submit Completion Report Dec 2016 Not Started
  • Full compliance consistent with NRC-approved extension (ReferenceS) 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Joseph M. Farley Nuclear Plant - Units 1 and 2 requested and received a schedule relaxation of one additional refueling cycle for full implementation of the Order requirements and expects to comply with the relaxed date (References 4 & 5). No additional relief/relaxation is required or anticipated at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items documented in the Interim Staff Evaluation (ISE).

Overall Integrated Plan Open Item Status Structure, content and details of the Farley Farley Response Response Plan will be determined. Plan complete Interim Staff Evaluation Open Item Status ISE was issued on January 17, 2014 (ML13337A584) with no Open Items. N/A 7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for FNP (Reference 3) with no Open Items.

The ISE states that, the NRC concludes that the licensee has provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will E-2

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation meet the requirements of Order EA-12-049 at the Joseph M. Farley Nuclear Plant, Units 1 and2."

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Joseph M. Farley Nuclear Plant - Units 1 and 2, 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-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.
3. NRC Letter, Joseph M. Farley Nuclear Plant- Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0716 and MF0717), dated January 17,2014.
4. Joseph M. Farley Nuclear Plant - Units 1 and 2, Request for Relaxation of Commission Order Modifying Licenses With Regards to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2014.
5. NRC Letter, Joseph M. Farley Nuclear Plant - Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies Beyond Design Basis External Events dated April14, 2014.
6. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but does not constitute a change in strategy:

1. Technical Evaluation (TE} 943740 has been written to track all necessary activities to provide 50.54(hh) connections for Auxiliary Feedwater (AFW) piping as the Alternate Method for providing core cooling via the Steam Generator (SG) FLEX Pump.
2. TE 943464 has been written to track all necessary activities to provide an alternate method for allowing the Reactor Coolant Supply (RCS) FLEX Makeup pumps and FLEX Boron Injection pumps to be powered ("hard wired" as an alternative) directly from the 480 V FLEX generator, bypassing the installed plant connection.

E-3

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN ..\

Fax 205.992.7601 NUCLEAR f£9 2 5 2016 A SOUTHERN COMPANY Docket Nos.: 50-348 NL-16-0022 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (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, dated March 12, 2012.
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012.
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.
4. Joseph M. Farley Nuclear Plant- Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013.
5. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Joseph M. Farley Nuclear Plant- Units 1 and 2 (FNP) 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.1.a of Reference 1. Reference 2 endorses industry guidance document NEI 12-06, Revision 0, (Reference 3) with clarifications and exceptions identified in Reference 2.

U.S. Nuclear Regulatory Commission NL-16-0022 Page2 Reference 4 provided the initial FNP overall integrated plan (OIP). A revised OIP was submitted with the fall 2014 six-month update (Reference 5).

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. The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides 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, if any.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted,

[!t?~

C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS My commission expires:

Enclosure:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

U. S. Nuclear Regulatory Commission NL-16-0022 Page3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President - Farley Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Ms. B.L. Taylor, Regulatory Affairs Manager- Farley RType: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Senior Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer

Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Requirements of the Commissi on Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation Joseph M. Farley Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report Regarding Mitigation Strategies for Beyond-Design-Basis External Events CEA-12-049) 1 Introduction Joseph M. Farley Nuclear Plant- Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishm ents In addition to the submittal of status reports, the following milestone(s) directly related to FLEX implementation have been completed since the previous 6-month update, and are current as of December 31, 2015:

  • Develop Strategies (Farley Response Plan) with National SAFER Response Center
  • Develop Operational Procedure Changes
  • Develop Modifications
  • Develop Training Material 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan (Reference 1).

It 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 Target and Revised Target Completion Dates are based on the approval of one additional refueling cycle for full implementation of the Order for Joseph M. Farley Nuclear Plant- Units 1 and 2 (References 4 & 5).

Target Revised Target Milestone Activity Completion Completion Status Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Unit 2 1st RFO May 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Initiate Phase 2 Equipment Procurement Sep 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Submit 6 Month Status Report Aug 2014 Complete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Submit 6 Month Status Report Aug 2015 Complete N/A Develop Strategies (Farley Response Plan) with National SAFER Response Center Dec 2015 Complete N/A Develop Operational Procedure Changes Dec 2015 Complete N/A Develop Modifications Dec 2015 Complete N/A Develop FSGs Dec 2015 Complete N/A Develo_Q Training Material Dec 2015 Complete N/A Submit 6 Month Status Report Feb 2016 Complete N/A Phase 2 E_g_uipment Procurement Com_Qiete Mar 2016 In Progress Issue FSGs Mar 2016 In Progress E-1

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation Target Revised Target Activity Milestone Completion Completion Status Date Date Implement Training Mar 2016 In Progress Unit 2 Walk-throughs or Demonstrations Mar 2016 In Progress Unit 2 Implementation Outage

  • Apr 2016 Not Started Submit 6 Month Status Report Aug 2016 Not Started Unit 1 Walk-throughs or Demonstrations Sep 2016 Not Started Unit 1 Implementation Outage
  • Oct 2016 Not Started Submit Completion Report Dec 2016 Not Started
  • Full compliance consistent with NRC-approved extension (ReferenceS) 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Joseph M. Farley Nuclear Plant - Units 1 and 2 requested and received a schedule relaxation of one additional refueling cycle for full implementation of the Order requirements and expects to comply with the relaxed date (References 4 & 5). No additional relief/relaxation is required or anticipated at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items documented in the Interim Staff Evaluation (ISE).

Overall Integrated Plan Open Item Status Structure, content and details of the Farley Farley Response Response Plan will be determined. Plan complete Interim Staff Evaluation Open Item Status ISE was issued on January 17, 2014 (ML13337A584) with no Open Items. N/A 7 Potential Interim Staff Evaluation Impacts The NRC issued an Interim Staff Evaluation (ISE) for FNP (Reference 3) with no Open Items.

The ISE states that, the NRC concludes that the licensee has provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, will E-2

Enclosure to NL-16-0022 Sixth Six-Month Status Report of FLEX Implementation meet the requirements of Order EA-12-049 at the Joseph M. Farley Nuclear Plant, Units 1 and2."

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Joseph M. Farley Nuclear Plant - Units 1 and 2, 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-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.
3. NRC Letter, Joseph M. Farley Nuclear Plant- Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0716 and MF0717), dated January 17,2014.
4. Joseph M. Farley Nuclear Plant - Units 1 and 2, Request for Relaxation of Commission Order Modifying Licenses With Regards to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2014.
5. NRC Letter, Joseph M. Farley Nuclear Plant - Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies Beyond Design Basis External Events dated April14, 2014.
6. Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2- Farley Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but does not constitute a change in strategy:

1. Technical Evaluation (TE} 943740 has been written to track all necessary activities to provide 50.54(hh) connections for Auxiliary Feedwater (AFW) piping as the Alternate Method for providing core cooling via the Steam Generator (SG) FLEX Pump.
2. TE 943464 has been written to track all necessary activities to provide an alternate method for allowing the Reactor Coolant Supply (RCS) FLEX Makeup pumps and FLEX Boron Injection pumps to be powered ("hard wired" as an alternative) directly from the 480 V FLEX generator, bypassing the installed plant connection.

E-3

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