TXX-1602, 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

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

ML16098A341
Person / Time
Site:	Comanche Peak
Issue date:	02/24/2016
From:	Peters K Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-20160135, EA-12-049, TAC MF0860, TAC MF0861, TXX-16027
Download: ML16098A341 (9)

Text

II Luminant Kenneth J. Peters Senior Vice President

& Chief Nuclear Officer (Acting)

Kenneth.Peters@luminant.com Luminant Power PO Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 6565 c 817 776 0037 F 254 897 6652 CP-20160135 Log # TXX-16027 REF 10 CFR2.202 February 24, 2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant Unit 1, Docket No. 50-445, 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) (TAC NOS. MF0860 and MF0861)

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.

Luminant Generation Company LLC' s Letter TXX-12158, 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 25, 2012

5.

Luminant Generation Company LLC'.s Letter TXX-13030, 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

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued an order (Reference 1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant 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,

U. S. Nuclear Regulatory Commission TXX-16027 Page 2 of 2 02/24/2016 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 Luminant Power's initial status report regarding mitigation strategies. Reference 5 provided Luminant Power's 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. 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 attached report provides an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter cohtains no new regulatory commitments.

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

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

Executed on February 24, 2016.

Sincerely, Luminant Generation Company LLC Kenneth J. Peters By:

Site Vice President (Acting)

Attachment:

Comanche Peak Nuclear Power Plant's (CPNPP) 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 c -

William M. Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Stephen A. Monarque, NRR Resident Inspectors, Comanche Peak Nuclear Power Plant

Attachment to TXX-16027 Page 1of7 Comanche Peak Nuclear Power Plant's (CPNPP) 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 Comanche Peak Nuclear Power Plant (CPNPP) developed an Overall Integrated Plan (Reference 1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan and the First, Second, Third, Fourth, and Fifth Six Month Status Reports (References 3, 7, 11, 12 and 14), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of February 12, 2016.

FLEX Strategy Evaluation - Complete Modifications Evaluations - Complete Storage Design Engineering - Complete Procedures - PWROG issues NSSS-specific guidelines - Complete National Safer Response Center (NSRC) Operational - Complete Develop Training Plan - Complete Perform Phase 2 Staffing Study - Complete Develop Unit 2 Modificqtions - Complete Develop Site Response Plan with NSRC - Complete Walk-throughs/Demonstrations - Complete Unit 2 Implementation Outage - Complete Storage Implementation - Complete Procure On-Site Equipment for Unit 2 - Complete Issue FSGs - Complete Create Maintenance Procedures - Complete Implement Training - Complete 3

Milestone Schedule Status The following table provides an update to Attachment 2 of the Overall Integrated Plan (OIP). 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. Note, italicized items in the following table were not provided as milestone items in Attachment 2 of the OIP. However, these items are added here for consistency with the 6 month status update template and will be carried forward in future 6 month status updates.

Attachment to TXX-16027 Page 2 of 7 Milestone Submit 60 Day Status Report Submit Overall Integrated Plan Submit 6 Month Updates:

Updatel Update2 Update3 Update4 Updates Update 6 FLEX Strategy Evaluation Walk-throughs or Demonstrations Perform Phase 2 Staffing Analysis Modifications:

Modifications Evaluation Develop Unit 1 Modifications Unit 1 Implementation Outage (1RF18)

Develop Unit 2 Modifications Unit 2 Implementation Outage (2RF15)

Storage:

Storage Design Engineering Storage Implementation FLEX Equipment:

Procure On-Site Equipment (Unit 1/Umt 2)

Develop Site Response Plan with NSRC Install Off-Site Delivery Station (if Necessary)

National Safer Response Center Operational Procedures:

PWROG issues NSSS-specific guidelines IssueFSGs Create Maintenance Procedures Training:

Develop Training Plan Implement Training Full Site FLEX Implementation Submit Completion Report Target Completion Date Oct 2012 Feb2013 Aug 2013 Feb 2014 Aug2014 Feb 2015 Aug2015 Feb 2016 Aug 2013 Apr 2015 Jun2014 Aug 2013 Mar 2014 Oct 2014 Mar 2015 Oct 2015 Mar 2014 Feb 2015 Jul 2015 Apr 2015 Not Required Aug2014 May2013 Aug2014 Jul 2014 May2014 Apr2015 Oct 2015 Feb 2016 Revised Target Activity Status Completion Date Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete Nov2015 Complete Jun2015 Complete Started Apr 2016 Not Started May2016 Complete Jul 2015 Complete Nov 2015 Complete Complete Nov2015 Started/ Complete May 2016/Nov 2015 Complete Aug 2015 Not Required Not Required Complete Complete Complete Nov 2015 Complete Nov 2015 Complete Dec2014 Complete Nov 2015 Started May 2016 Started Aug2016

Attachment to TXX-16027 Page 3 of 7 4

Changes to Compliance Method There are no changes or clarifications to the compliance method beyond those identified in the First, Second, Third, Fourth and Fifth Six Month Status Reports (References 3, 7, 11, 12 and 14).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation In Reference 5, Luminant formally requested relief from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan. NRC approval of the requested relief was received in Reference 8, relaxing full order implementation for Comanche Peak Unit 1 until the completion of the spring 2016 refueling outage.

Full order implementation for Comanche Peak Unit 2 is unchanged and occurred upon completion of the fall 2015 refueling outage (Reference 15). The milestone schedule in Section 3 has been updated for consistency with the approved schedule relief. No additional relief is requested herein.

Attachment to TXX-16027 Page 4 of 7 6

Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the OIP and the status of each item.

Overall Integrated Plan Open Items Status 011. Finalize location and protection requirements of FLEX Complete. FLEX equipment will be storage buildings. The storage buildings will be stored in a new single structure designed in accordance with the NEI guidance and the designed as described in Section 4 of applicable hazards.

Reference 7. Per Reference 13, the associated Confirmatory Item (CI 3.1.1.1.A) is closed. No further action required.

012. Perform containment evaluation based on the boundary Complete. The containment analysis conditions described in Section 2 of NEI 12-06. Based on concludes no significant heatup or the results of this evaluation, required actions to ensure pressurization of containment as a maintenance of containment integrity and required result of an ELAP when crediting instrument function will be developed as necessary.

SHIELD. Per Reference 13, the NRC has reviewed the containment analysis, found no discrepancies and closed the associated confirmatory items noted in Reference 4. No further action required.

013. Development of refueling equipment specifications, Significant volumes of fuel are stored determination of fuel consumption rates, assessment of onsite in multiple redundant fuel oil fuel supplies and determination of time frames for storage tanks protected against all refueling of FLEX equipment in Phases 2 and 3 will be external hazards. Per Reference 13, developed following generation of specifications for NRC review has confirmed CPNPP FLEX equipment.

has adequate protected fuel capacity.

No further action required.

014. Finalize FLEX strategies and required modifications Comanche Peak FLEX strategies following resolution of low-leakage RCP seal credit the use of SHIELD low-leakage performance issue.

seals as approved in Reference 9.

Preparation of design modifications for installation of SHIELD on Unit 1 during the spring 2016 refueling outage are in progress. SHIELD installation on Unit 2 occurred during the fall 2015 refueling outage.

Attachment to TXX-16027 Page 5 of 7 Draft Safety Evaluation and Interim Staff Evaluation (ISE) are assumed synonymous. The following are additional Open Items documented in the Interim Staff Evaluation (Reference 4). These open items will be carried forward in future 6 month status updates until confirmation is received from the NRC that the items may be closed. Luminant Power is participating in the voluntary NRC audit process described in References 6 and 13.

Interim Staff Evaluation Open Items Status 3.2.1.2.A Regarding the RCP seals, the only 0-ring of interest Reference 9 documents NRC with the safe shutdown low-leakage (SHIELD) installed acceptance of SHIELD for use in is the RCP seal sleeve to shaft 0-ring. Qualification of ELAP evaluations. Luminant has the RCP seal sleeve to shaft 0-ring will be tracked as confirmed the reactor coolant system part of the SHIELD redesign to confirm the delayed pressure and temperature limits of cooldown, as documented in the Integrated Plan, is Reference 9 will be met during an acceptable. CPNPP will align with testing results to be ELAP event at Comanche Peak.

documented in the forthcoming SHIELD white paper.

However, per Reference 13, this item remains open pending NRC review of the reactor coolant pump 0-ring material.

3.2.1.2.C If the RCP seals are changed to the newly designed Reference 9 documents NRC Generation 3 SHIELD seals, or non-Westinghouse seals, acceptance of SHIELD for use in the acceptability of the use of the newly designed ELAP evaluations. Item 4 of the Generation 3 SHIELD seals, or non-Westinghouse seals limitations and conditions from should be addressed, and the RCP seal leakages rates for Reference 9 restricts the seal leakage use in the ELAP analysis should be provided with rate to a constant 1.0 gallon per acceptable justification. During the audit process the minute after SHIELD actuation. Any licensee stated that CPNPP uses the Westinghouse deviation from this restriction will be model93A RCPs crediting SHIELD for FLEX strategies.

justified.

Testing and qualification of SHIELD is ongoing and the licensee is closely following the re-design of SHIELD and will modify analyses and FLEX strategies if needed, based on the conclusions of the SHIELD white paper.

3.2.1.8.A The Pressurized Water Reactor Owners Group Per Reference 10, the NRC has (PWROG) submitted to NRC a position paper, dated endorsed the PWROG position paper August 15, 2013 (ADAMS Accession No. ML 13235A with restrictions. Luminant has 132, non-public, proprietary), which provides test data evaluated the impact of these regarding boric acid mixing under single-phase natural restrictions on the CPNPP FLEX circulation conditions and outlines applicability boration strategy and confirmed keff conditions intended to ensure that boric acid addition will be maintained less than 0.99 and mixing would occur under conditions similar to throughout an ELAP event.

those for which boric acid mixing data is available.

However, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and did not endorse this position paper. As such, ensuring adequate mixing of boric acid into the RCS under ELAP conditions is an open item for CPNPP.

Attachment to TXX-16027 Page 6 of 7 7

Potential Draft Safety Evaluation Impacts Any potential impact to the Interim Staff Evaluation has been previously discussed in Section 4 of this letter.

8 References The following references support th~ updates to the OIP described in this attachment.

1.

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.

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.

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), dated August 28, 2013.

4.

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.

5.

Comanche Peak Nuclear Power Plant (CPNPP), Docket Nos. 50-445 and 50-446, Request for Schedule Relaxation for the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated February 12, 2014.

6.

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.

7.

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), dated February 27, 2014.

8.

NRC Letter from Eric J. Leeds to Mr. Rafael Flores, "Comanche Peak Nuclear Power Plant, Unit 1

-Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," April 14, 2014.

9.

NRC Letter from Jack Davis to Mr. James A. Gresham, ADAMS Accession No. ML14132A128, May 28, 2014.

10. NRC Letter from Jack Davis to Mr. Jack Stringfellow, ADAMS Accession No. ML13276A183, January 8, 2014.

Attachment to TXX-16027 Page 7 of 7

11. 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), dated August 28, 2014.

12. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Fourth Si.X-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)," dated February 26, 2015.

13. NRC Letter from Stephen Monarque to Mr. 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.

14. 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)," dated August 27, 2015.

15. 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-12-049) (TAC NOS. MF0860 AND MF0861)dated November 18, 2015.