RS-16-089, Report of Full Compliance with 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)
| ML16188A265 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/01/2016 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16188A291 | List: |
| References | |
| EA-12-049, RS-16-089 | |
| Download: ML16188A265 (14) | |
Text
e!~ Exelon Generation 7
As Order No. EA-12-049 RS-16-089 July 1, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410
Subject:
Report of Full Compliance with 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, "Issuance of Order to Modify 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
Revision O, dated August 2012
- 4. Letter from M. G. Korsnick (GENG) to Document Control .Desk (NRC), Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 26, 2012
- 5. Letter from M. G. Korsnick (GENG) to Document Control Desk (NRC), 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
- 6. Letter from M. G. Korsnick (GENG) to Document Control Desk (NRC), Supplement to 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 March 8, 2013
- 7. Letter from E. D. Dean (GENG) to Document Control Desk (NRC) 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), dated August 27, 2013 Ats/
tJflfL
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 2
- 8. Letter from M. G. Korsnick (GENG) to Document Control Desk (NRG), February 2014 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), dated February 27, 2014
- 9. Letter from M. G. Korsnick (GENG) to Document Control Desk (NRG), August 2014 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), dated August 26, 2014 1O. Letter from M. G. Korsnick (GENG) to Document Control Desk (NRG), February 2015 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), dated February 19, 2015
- 11. Exelon Generation Company, LLC, 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), dated August 28, 2015, Nine Mile Point Nuclear Statiori, Unit 2 (RS-15-219)
- 12. Exelon Generation Company, LLC, 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 049), dated February 26, 2016, Nine Mile Point Nuclear Station, Unit 2 (RS-16-029)
- 13. NRG letter from J. S. Bowen (NRG) to J. A. Spina (GENG), Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plans in Response to Order EA-12-049, (Mitigation Strategies) (TAC Nos. MF1129 and MF1130),
dated December 19, 2013
- 14. NRG Letter, Request for Information Pursuant to Title 1O 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-ichi Accident, dated March 12, 2012
- 15. Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54.(f)
Regarding.Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated December 4, 2015, Nine Mile Point Nuclear Station, Unit 2 (RS 271) .
- 16. Letter from J. Paige (NRG) to P. M. Orphanos (EGG), Nine Mile Point Nuclear Station, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA 051 (TAC Nos. MF1129, MF1130, MF1131, and MF1132), dated April 28, 2015
- 17. Letter from J. Paige (NRG) to B. C. Hanson (EGG), Nine Mile Point Nuclear Station, Unit 2 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies Related to Orders EA-12-049 (CAC No. MF1130), dated February 4, 2016 On March 12, 2012, the Nuclear Regulatory Commission ("NRG" or "Commission") issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference 1) to Exelon Generation Company, LLC (EGG), previously Constellation Energy Nuclear Group, LLC (Exelon, the licensee) for Nine Mile Point Nuclear Station, Unit 2. Reference 1 was immediately effective and directed EGG to
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 3 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 (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision O (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. References 5 and 6 provided the Nine Mile Point Nuclear Station, Unit 2 OIP.
Reference 1 required submission of a status report at six-month intervqls following submittal of the OIP. References 7, 8, 9, 10, 11, and 12 provided the first, second, third, fourth, fifth, and sixth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Nine Mile Point Nuclear Station, Unit 2.
The purpose of this letter is to provide the report of full compliance with 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) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Nine Mile Point Nuclear Station, Unit 2.
Nine Mile Point Nuclear Station, Unit 2 has developed, implemented, and will maintain the guidance and strategies to maintain or restore core cooling, containment function, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event in response to Order EA-12-049. The information provided herein documents full compliance for Nine Mile Point Nuclear Station Unit 2, with Reference 1.
EGC's response to the NRC Interim Staff Evaluation (ISE) open and confirmatory items identified in Reference 13 have been addressed and closed as documented in References 7, 8, 9, 10, 11, and 12, and below, and are considered complete pending N RC closure. 01 P open items have been addressed and closed as documented in References 7, 8, 9, 1O, 11, and 12, and below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in Reference 16, and below, and are considered complete pending NRC closure.
The following tables provide completion references for each OIP open item, NRC ISE open or confirmatory item, and NRC Audit Report open item.
Overall Integrated Plan Open Items OIP Open Item Completion Response Reference OIP Open Item No. 1 Reference 8 OIP Open Item No. 2 Reference 1O OIP Open Item No. 3 Reference 11 OIP Open Item No. 4 Reference 12 OIP Open Item No. 5 Reference 7 OIP Open Item No. 6 Reference 12 OIP Open Item No. 7 Deleted - Addressed in Reference 9 OIP Open Item No. 8 Reference 1O
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 4 OIP Open Item Completion Response Reference OIP Open Item No. 9 Addressed with this submittal as provided below OIP Open Item No. 10 Addressed with this submittal as provided below OIP Open Item No. 11 Reference 9 OIP Open Item No. 12 Reference 12 OIP Open Item No. 13 Reference 12 OIP Open Item No. 14 Reference 1O OIP Open Item No. 15 Reference 10 OIP Open Item No. 16 Reference 10 OIP Open Item No. 17 Reference 1O OIP Open Item No. 18 Reference 11 OIP Open Item No. 19 Reference 11 OIP Open Item No. 20 Reference 12 OIP Open Item No. 21 Reference 11 OIP Open Item No. 22 Reference 1O OIP Open Item No. 23 Addressed with this submittal as provided below OIP Open Item No. 24 Reference 1O OIP Open Item No. 25 Reference 12 OIP Open Item No. 26 Deleted - Addressed in Reference 11 OIP Open Item No. 27 Reference 12 OIP Open Item No. 28 Reference 12 OIP Open Item No. 29 Reference 12 '
OIP Open Item No. 30 Reference 12 OIP Open Item No. 31 Reference 12 OIP Open Item No. 32 Reference 1O OIP Open Item No. 33 Reference 11 OIP Open Item No. 34 Deleted - Addressed in Reference 11 OIP Open Item No. 35 Reference 11 OIP Open Item No. 36 Deleted - Addressed in Reference 10 OIP Open Item No. 37 Reference 12 OIP Open Item No. 38 Reference 12 OIP Open Item No. 39 Deleted - Addressed in Reference 9 OIP Open Item No. 40 Deleted - Addressed in Reference 7 '
OIP Open Item No. 41 Deleted - Addressed in Reference 7 OIP Open Item No. 42 Reference 11 OIP Open Item No. 43 Reference 1O OIP Open Item No. 44 Reference 11 OIP Open Item No. 45 Deleted - Addressed in Reference 7 OIP Open Item No. 46 Reference 11 OIP Open Item No. 47 Reference 12 OIP Open Item No. 48 Reference 10 OIP Open Item No. 49 Deleted - Addressed in Reference 9 OIP Open Item No. 50 Deleted - Addressed in Reference 9 OIP Open Item No. 51 Deleted - Addressed in Reference 9 OIP Open Item No. 52 Addressed with this submittal as provided below OIP Open Item No. 53 Addressed with this submittal as provided below OIP Open Item No. 54 Addressed with this submittal as provided below
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 5 OIP Open Item Completion Response Reference
. OIP Open Item No. 55 Addressed with this submittal as provided below OIP Open Item No. 56 Addressed with this submittal as provided below OIP Open Item No. 57 Addressed with this submittal as provided below OIP Open Item No. 58 Addressed with this submittal as provided below I OIP Open Item No. 59 Addressed with this submittal as provided below OIP Open Item No. 60 Deleted - Addressed in Reference 7 OIP Open Item No. 61 Reference 12 Interim Staff Evaluation Open Items ISE Open Item Completion Response Reference Item No. 3.1.1.3.A Reference 12 Item No. 3.2.3.B Reference 12 Item No. 3.2.3.C Reference 1O Interim Staff Evaluation Confirmatory Items ISE Confirmatory Item Completion Response Reference Item No. 3.1.1.1.A Reference 11 Item No. 3.1.1.2.A Reference 1O Item No. 3.1 .1.4.A Reference 1O Item No. 3.2.1.1.A Reference 11 Item No. 3.2.1.1.B Reference 11 Item No. 3.2.1.1.C Reference 11 Item No. 3.2.1.1.D Reference 11 Item No.3.2.1.1.E Reference 11
- Item No. 3.2.1.2.A Reference 12 Item No. 3.2.2.A Reference 11 Item No. 3.2.3.A Reference 12 Item No. 3.2.4.2.A Reference 12 Item No. 3.2.4.4.A Reference 12 Item No. 3.2.4.4. B Reference 1O and updated with this submittal as provided below Item No. 3.2.4.6.A Reference 1O Item No. 3.2.4.8.A Reference 12 Item No. 3.2.4.8.B Reference 1O Item No. 3.2.4.9.A Reference 1O Item No. 3.2.4.1 O.A Reference 10 Item No. 3.4.A Reference 1O Item No. 3.4.B Reference 1O
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 6 NRC Audit Report Open Items Audit Open Item Completion Response Reference ISE 01 3.2.3.B References 12 and 17 ISE Cl 3.1.1.1.A References 11 and 17 ISE Cl 3.1.1.2.A References 1O and 17 ISE Cls 3.2.1.1.A, 3.2.1.1.B, References 11 and 17 3.2.1.1.C, 3.2.1.1.D, and 3.2.1.1.E ISE Cl 3.2.1.2.A References 12 and 17 ISE Cl 3.2.2.A References 11 and 17 ISE Cls 3.2.3.A, 3.2.4.2.A, References 12 and 17 and SE Review Item 5 ISE Cl 3.4.B, AO 16, *and AO References 11 and 17 17 AO 1 and AO 2 Reference 17 SE Review Item 1 Reference 17 SE Review Item 6 Reference 17 ISE Cl 3.2.4.1 O.A References 1O and 17 ISE Cl 3.2.4.2.A Addressed with this submittal as provided below A020 Addressed with this submittal as provided below The table below documents the completion of the final remaining open actions as identified in Reference 12, and above. As stated above, EGG provides the response for the following items and considers them to be complete for Nine Mile Point Nuclear Station, Unit 2.
Item Description Status OIP Open Item No. 9 NMP2 current capability for on-site Comglete communications utilizes hand-held 450MHz Perform an evaluation radios in the radio-to-radio or 'talk-around' mode of the Uninterruptible with sound powered phones as a backup to meet Power Supply (UPS) FLEX requirements. Small portable generators strategy and design that are stored in the FLEX Storage Building will and implement as be used to recharge radio batteries as needed.
required or formalize The evaluation of the Uninterruptible Power the use of the small Supply (UPS) strategy for the NMP radio system portable gas is complete. A design change is in progress to generators install Uninterruptible Power Supplies for support (communication of the NMP Radio Communication system. This strategies). communication upgrade will be complete by 12/31/2016 to meet Rec 9.3 Communications
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 7 Item Description Status commitments for NMP.
OIP Open Item No. 10 The evaluation of the NMP Radio Communication Com12lete system is complete. Modifications are underway Perform an evaluation to install Uninterruptible Power Supply (UPS) to of the redundant support radio operations on site. This power strategy for communication upgrade will be complete by radio repeaters and 12/31/2016 to meet Rec 9.3 Communications design and implement commitments for NMP. In the interim, the hand-modifications or held 450MHz radios will be used in the radio-to-program matic radio or 'talk-around' mode which does not rely on changes as required. radio repeaters for functionality and meets the NMP2 FLEX on site communication requirements.
OIP Open Item No. 23 NMP2 Emergency Operating Procedures (EOPs) Com12lete were upgraded to EPG/SAGs revision 03 and Develop issued on May 2, 2016.
procedures/guidelines FLEX Support Guidelines (FSG) have been to address the criteria developed and issued on or before May 6, 2016 in NEI 12-06 to for NMP2 in order to address the criteria in NEI support existing 12-06 that support EOPs. They are as follows:
symptom based strategies in the
- N2-SOP-01, Station Blackout/ELAP Emergency Operating Procedures (EOPs).
- N2-SOP-02, Station Blackout/ELAP Support Procedure
- N2-DRP-FLEX-MECH, Emergency Damage Repair - BOB/FLEX Pump Deployment Strategy
- N2-DRP-FLEX-ELEC, BOB/FLEX Generator Deployme~t Strategy
- S-DRP-OPS-004, Refueling Diesel Driven Portable Equipment OIP Open Item No. 52 The design change to provide a modification at Com12lete NMP2 that will provide a make-up to the Spent Design and implement Fuel Pool (SFP) with a FLEX portable pump a modification that (ECP-13-001035) was completed on May 4, provides for 2016.
connection of a FLEX portable pump to makeup to the SFP.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 8 Item Description Status OIP Open Item No. 53 The design change to provide a modification at ComQlete NMP2 that will provide a make-up to RHS 'A' and Implement a design 'B' with a FLEX portable pump (ECP-13-001035) change to install was completed on May 4, 2016.
connections for FLEX portable pumps to RHR for both RHR 'A' and 'B'.
OIP Open Item No. 54 The design change to provide a modification at ComQlete NMP2 that will provide portable generator Implement a design connections for 2EJS*US1 and 2EJS*US3 (ECP-change to install 13-001068) was completed on May 4, 2016.
portable generator connections for 600 VAC primary (2EJS*US 1) and alternate (2EJS*US3) busses.
OIP Open Item No. 55 NMP2 Emergency Operating Procedures (EOPs) ComQlete were upgraded to EPG/SAGs Revision 03 and Revise procedures to issued on May 2, 2016. Procedure OP-NM-101-provide reactor 111-1001 Transient Mitigation Guidelines was pressure control revised to include the pressure control strategy to direction during an be used during an ELAP event and was issued on ELAP event. April 29, 2016.
OIP Open Item No. 56 NMP2 procedure N2-SOP-01, Station ComQlete BlackouVELAP has been revised to vent Main Develop and Turbine/Generator hydrogen as soon as the implement procedure Turbine/Generator stops rotating or within two direction to ensure hours, break Main Condenser Vacuum a*nd then that the Main Turbine vent hydrogen after the Turbine/Generator stops Hydrogen is vented rolling, which is prior to battery depletion. This prior to battery procedure was issued on May 2, 2016.
depletion.
OIP Open Item No. 57 NMP2 Emergency Operating Procedures (EOPs) ComQlete were upgraded to EPG/SAGs Revision 03 and Revise current EOPs issued on May 2, 2016. The changes made to implement EOP provide the allowance to stop emergency actions necessary to depressurization if RCIC is the only injection support the strateqy to source to the RPV that is available, in order to
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 9 Item Description Status terminate emergency preserve the motive force necessary for RCIC depressurization to operation.
preserve RCIC operation.
OIP Open Item No. 58 Power to operate SRVs is from safety related ComQlete batteries. FLEX generator deployment during Develop and Phase 2 ensures that the power for operation of implement procedures SRVs is sustained. To provide for a long term to provide direction for pneumatic supply to SRVs, the following NMP2 re-energizing the procedures were revised to include direction for Solenoid Operated replenishment of SRV pneumatic receivers during Valves (SOVs) and an ELAP event. The procedures were issued on ensuring long term or before May 6, 2016 pneumatic supply during an ELAP.
- N2-SOP-01, Station Blackout/ELAP
- N2-SOP-02, Station Blackout/ELAP Support Procedure
- N2-DRP-FLEX-MECH, Emergency Damage Repair - BOB/FLEX Pump Deployment Strategy OIP Open Item No. 59 NMP2 procedure N2-DRP-FLEX-MECH, ComQlete Emergency Damage Repair - BOB/FLEX Pump Develop procedures Deployment Strategy was developed and issued to implement the on May 6, 2016. This procedure provides the connection of a FLEX actions necessary to deploy a FLEX portable portable pump to pump to makeup water to the SFP during an makeup water to the ELAP event and includes both primary and SFP during an ELAP alternate strategies.
event to include both primary and alternate strategies.
ISE Confirmatory Communication equipment necessary to support ComQlete Item No. 3.2.4.4.B FLEX strategy implementation at NMP2 is in place. Initial communication announcements to Follow-up of on-site personnel during a BOB external event communication will be via the Plant Paging and Announcement commitments as system which are battery backed-up. If the Plant discussed in the staff Paging and Announcement system is not analysis available for on-site communications, bullhorns (ML 131 OOA236) is are available in the FLEX Storage Building for required. use for notification of site personnel. Onsite communications can be performed usinQ either
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 10 Item Description Status the installed sound powered phone system or the 450 MHz hand-held radios utilized in the 'talk-around' or radio-to-radio mode of operation.
Offsite communications can be made utilizing portable satellite phones staged in each NMP Main Control Room and Technical Support Center. Spare batteries and battery chargers for portable communications equipment can be powered from the small portable generators that are stored in the FLEX Storage Building. The remaining NMP modifications for communication upgrades are scheduled to complete on or before December 31, 2016 as delineated in NRG Staff analysis document (ML 131 OOA236) Table 1.
NRG Audit Report The effects of loss of HVAC in an extended loss Comglete Open Item of AC power event are being addressed for both ISE 01 3.2.4.2.A (SE equipment operability and habitability and have Tracker Item 15-A) - been incorporated into the FLEX strategies. The Ventilation and EQ environmental conditions in the areas that contain the critical equipment, which is relied upon by the operators, and in the areas where operators will require access, has been evaluated via review of existing calculations and/or development of new calculations. These areas include: Primary Containment, Secondary Containment, Control Building (Control Room and Battery Rooms), and RCIC Pump Room. Equipment operability and habitability are confirmed for all the concerned areas. To protect station personnel from the adverse effects of performing FLEX related mitigation actions in thermally elevated environments, an evaluation of the plant areas requiring access for mitigation actions was performed and compensatory actions or restrictions were identified and incorporated into procedures. The detailed response for this item has been provided on the ePORTAL for NRG staff review.
NRG Audit Report NMP2 is located on the southeastern shore of Comglete Open Item AQ 20 (SE Lake Ontario, which is the ultimate heat sink for Tracker Item 20-B) - the plant. Nine Mile Point has chosen to use Lake RCS Makeup Ontario as the primary water source throughout the ELAP/LUHS event. This allows the FLEX strategy to position the FLEX Pumps at a source
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 11 Item Description Status that can provide make-up water to the RPV, Primary Containment, and Spent Fuel Pool that is unlimited. When faced with the choice. of injection of low quality water or no injection, the action will always be to inject low quality water which is consistent with EPRI Severe Accident Management Guidance Technical Basis Report (EPRI Report 1025295) Volume 2, Section DD.
NMP2 EOPs require that injection sources be selected based on core and debris cooling requirements, reliability, resource requirements, effects on other severe accident response strategies, and the quality of the water source.
Raw water sources should generally be used only as a last resort. If other systems become available, injection lineups should be shifted to higher quality sources to minimize use of raw water. This strategy will ensure cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after commencing injection from the UHS. During this time, Nine Mile Point will develop recovery methods that will utilize a clean source of water. The recovery methods could i.nclude transition back to the reactor water grade sources, arranging for clean water sources, or other methods to filter water prior to injecting into the core. The detailed response for this item has been provided on the ePORTAL for NRC staff review.
MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Dav Status Report October 26, 2012 Submit Overall Integrated Plan February 28, 2013 Contract with National SAFER Response Center March 3, 2015 Six Month Integrated Plan Progress Report August27,2013 Engineering and Design Completion - Equipment November 2014 Storage Facility Six Month lnteqrated Plan Progress Report February 27, 2014 Engineering and Design Completion - Portable November 2014 Equipment Connections Six Month lnteqrated Plan Progress Report August26,2014
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 12 Milestone Completion Date Six Month lntemated Plan ProQress Report February 19, 2015 Six Month lntearated Plan Progress Report August28,2015 Six Month lnteqrated Plan ProQress Report February 26, 2016 Non-Outage Installation - Portable Equipment February 2016 Connection Validation Walkdowns Complete March 2016 Portable Equipment Procedures Changes March 2016 FLEX Traininq March 2016 Outaqe Installation - Portable Equipment Connections May 2016 Equipment Storaqe Facility Installation May 2015 Unit 2 Implementation Date May 5, 2016 Final Implementation Notification to USNRC (with this July 2016 submittal)
ORDER EA-12-049 COMPLIANCE ELEMENTS
SUMMARY
The elements identified below for Nine Mile Point Nuclear Station, Unit 2 as well as the site 01 P response submittal (References 5 and 6), the 6-Month Status Reports (References 7, 8, 9, 10, 11, and 12), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.
Strategies - Complete Nine Mile Point Nuclear Station, Unit 2 strategies are in compliance with Order EA-12-049.
There are no strategy related Open Items, Confirma~ory Items, or Audit Questions/Audit Report Open Items. The Nine Mile Point Nuclear Station, Unit 2 Final Integrated Plan for mitigating strategies is provided with this letter as Enclosure 1.
Modifications - Complete The modifications required to support the FLEX strategies for Nine Mile Point Nuclear Station, Unit 2 have been fully implemented in accordance with the station design control process.
Equipment - Procured and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for Nine Mile Point Nuclear Station, Unit 2 has been procured in accordance with NEI 12-06, Sections 11.1 and 11.2, received at Nine Mile Point Nuclear Station, Unit 2, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.
Maintenance and testing will be conducted through the use of the Nine Mile Point Nuclear Station, Unit 2 Preventative Maintenance program such that equipment reliability is maintained.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 13 Protected Storage - Complete The storage facilities required to implement the FLEX strategies for Nine Mile Point Nuclear Station, Unit 2 have been completed and provide protection from the applicable site hazards.
The equipment required to implement the FLEX strategies for Nine Mile Point Nuclear Station, Unit 2 is stored in its protected configuration.
Procedures - Complete FLEX Support Guidelines (FSGs) for Nine Mile Point Nuclear Station, Unit 2 have been developed, and integrated with existing procedures. The FSGs and affected existing procedures have been validated and are available for use in accordance with the site procedure control program.
Preventive maintenance actions have been developed for FLEX equipment including procedures for functional and performance testing.
Training - Complete
. Training for Nine Mile Point Nuclear Station, Unit 2 has been completed in accordance with an accepted training process as described in NEI 12-06, Section 11.6.
Staffing - Complete The Phase 2 staffing study for Nine Mile Point Nuclear Station, Unit 2 has been completed in accordance with J OCFR50~54(f), "Request for Information Pursuant to Title 1O 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-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 14), as documented in Reference 15.
National SAFER Response Center - Complete EGC 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 Nine Mile Point Nuclear Station, Unit 2 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.
Validation - Complete EGC has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) I Final Integrated Plan (Fl P) for Order EA-12-049.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 July 1, 2016 Page 14 FLEX Program Document - Established The Nine Mile Point Nuclear Station, Unit 2 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of July 2016.
Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Enclosure:
Nine Mile Point Nuclear Station, Unit 2 Final Integrated Plan Document - Mitigating Strategies NRG Order EA-12-049 cc: Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region I NRG Senior Resident Inspector - Nine Mile Point Nuclear Station NRG Project Manager, NRR - Nine Mile Point Nuclear Station Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRG Mr. Jason C. Paige, NRR/JLD/JOMB, NRG