ML18207A272

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Documentation of the Completion of Required Actions Taken in Response to the Lessons Learned from the Fukushima Dai-ichi Accident
ML18207A272
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/08/2018
From: Robert Bernardo
Beyond-Design-Basis Management Branch
To: Peters K
Vistra Operations Company
Bernardo R, NRR/DLP, 415-2621
References
Download: ML18207A272 (25)
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 8, 2018 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Comanche Peak Nuclear Power Plant Vistra Operations Company, LLC 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

DOCUMENTATION OF THE COMPLETION OF REQUIRED ACTIONS TAKEN IN RESPONSE TO THE LESSONS LEARNED FROM THE FUKUSHIMA DAI-ICHI ACCIDENT

Dear Mr. Peters:

The purpose of this letter is to acknowledge and document that actions required by the U.S. Nuclear Regulatory Commission (NRC) in orders issued following the accident at the Fukushima Dai-ichi Nuclear Power Station have been completed for Comanche Peak Nuclear Power Plant, Units 1 and 2 (Comanche Peak). In addition, this letter acknowledges and documents that Luminant Generation Company, LLC (now Vistra Operations Company, LLC, the licensee) has provided the information requested in the NRC's March 12, 2012, request for information under Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f),

related to the lessons learned from that accident. Completing these actions and providing the requested information, in conjunction with the regulatory activities associated with the Mitigation of Beyond-Design-Basis Events (MBDBE) rulemaking, implements the safety enhancements mandated by the NRC based on the lessons learned from the accident. Relevant NRC, industry, and licensee documents are listed in the reference tables provided in the enclosure to this letter. The NRC will provide oversight of these safety enhancements through the Reactor Oversight Process (ROP).

BACKGROUND In response to the events in Japan resulting from the Great Tohoku Earthquake and subsequent tsunami on March 11, 2011, the NRC took immediate action to confirm the safety of U.S.

nuclear power plants:

  • On March 18, 2011, the NRC issued Information Notice 2011-05, "Tohoku-Taiheiyou-Oki Earthquake Effects on Japanese Nuclear Power Plants" (Reference 1.1 ). The information notice was issued to inform U.S. operating power reactor licensees and applicants of the effects from the earthquake and tsunami. Recipients were expected to review the information for applicability to their facilities and consider actions, as appropriate.

K. Peters Suggestions contained in an information notice are not NRC requirements; therefore, no specific action or written response was required.

  • On March 23, 2011, the NRC issued Temporary Instruction (Tl) 2515/183, "Followup to the Fukushima Daiichi Fuel Damage Event." The purpose of Tl 2515/183 was to provide NRC inspectors with guidance on confirming the reliability of licensees' strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following events that may exceed the design basis for a plant. The results of the inspection for each licensee were documented in an inspection report (Reference 1.2).
  • On March 23, 2011, the Commission provided staff requirements memorandum (SRM)

COMGBJ-11-0002, "NRC Actions Following the Events in Japan." The tasking memorandum directed the Executive Director for Operations to establish a senior level agency task force, referred to as the Near-Term Task Force (NTIF}, to conduct a methodical and systematic review of the NRC processes and regulations to determine whether the agency should make additional improvements to the regulatory system and make recommendations to the Commission within 90 days for its policy direction (Reference 1.3).

  • On April 29, 2011, the NRC issued Tl 2515/184, "Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs)." The purpose of Tl 2515/184 was to inspect the readiness of nuclear power plant operators to implement SAMGs. The results of the inspection were summarized and provided to the NTIF, as well as documented in a 2011 quarterly integrated inspection report for each licensee (Reference 1.4).
  • On May 11, 2011, the NRC issued Bulletin (BL) 2011-01, "Mitigating Strategies."

BL 2011-01 required licensees to provide a comprehensive verification of their compliance with the regulatory requirements of 10 CFR 50.54(hh}(2), as well as provide information associated with the licensee's mitigation strategies under that section. In 10 CFR 50.54(hh}(2), it states, in part: "Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire .... " BL 2011-01 required a written response from each licensee (Reference 1.5).

  • On July 21, 2011, the NRC staff provided the NTIF report, "Recommendations for Enhancing Reactor Safety in the 21 51 Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" to the Commission in SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan" (Reference 1.6).
  • On October 3, 2011, the staff prioritized the NTIF recommendations into three tiers in SECY-11-0137, "Prioritization of Recommended Actions To Be Taken in Response to Fukushima Lessons Learned." The Commission approved the staff's prioritization, with comment, in the SRM to SECY-11-0137 (Reference 1.7).

A complete discussion of the prioritization of the recommendations from the NTIF report, additional issues that were addressed subsequent to the NTIF report, and the disposition of the issues that were prioritized as Tier 2 or Tier 3 is provided in SECY-17-0016, "Status of Implementation of Lessons Learned from Japan's March 11, 2011, Great Tohoku

K. Peters Earthquake and Subsequent Tsunami" (Reference 12.10). A listing of the previous Commission status reports, which were provided semiannually, can be found in Table 12 in the enclosure to this letter.

The NRC undertook the following regulatory activities to address the majority of the Tier 1 recommendations:

  • On March 12, 2012, the NRC issued Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," and EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," and a request for information under 10 CFR 50.54(f) (hereafter referred to as the 50.54(f) letter) to licensees (References 1.8, 1.9, 1.10, and 1.11, respectively).

  • On June 6, 2013, the NRC issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" (Reference 1.12}, which superseded Order EA-12-050, replacing its requirements with modified requirements.
  • In addition to the three orders and the 50.54(f) letter, the NRC is considering a new regulation ( 10 CFR 50.155, "Mitigation of Beyond-Design-Basis Events"). The draft final rule and supporting documentation were provided to the Commission for approval in SECY-16-0142, "Draft Final Rule - Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49)" (Reference 1.13). The MBDBE rulemaking would consolidate several of the recommendations from the NTTF report. The draft final rule, as provided to the Commission, contains provisions that make generically applicable the requirements imposed by Orders EA-12-049 and EA-12-051 and supporting requirements for the integrated response capability that includes staffing, communications, training, drills or exercises, and documentation of changes. The draft final rule also contains requirements for licensees to consider the effects of the reevaluated seismic and flooding hazard information identified in response to Enclosures 1 and 2 of the 50.54(f) letter. Three proposed regulatory guides (References 1.14, 1.15, and 1.16) were included to provide methods and procedures that the NRC staff considers acceptable for licensees to demonstrate compliance with the MBDBE rule, if approved by the Commission.

This letter acknowledges and documents that the actions required by the NRC in response to the orders, as well as the information provided in response to the March 12, 2012, 50.54(f) letter, have been completed for Comanche Peak. However, the staff is not determining whether the licensee complies with the draft final MBDBE rule. Oversight of compliance with the draft final MBDBE rule at Comanche Peak will be conducted through the ROP, if the Commission approves the rule.

DISCUSSION Mitigation Strategies Order Order EA-12-049, which applies to Comanche Peak, requires licensees to implement a three-phase approach for mitigation of beyond-design-basis external events (BDBEEs). It requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a BDBEE that results in a simultaneous loss of all alternating current (ac) power and loss of

K. Peters normal access to the ultimate heat sink (LUHS). Phases 1 and 2 of the order use onsite equipment, while Phase 3 requires obtaining sufficient offsite resources to sustain those functions indefinitely.

In August 2012, the Nuclear Energy Institute (NEI) issued industry guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," as guidance to comply with the order. The NRC endorsed the guidance in Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) document 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" (Reference 2.1 ). Licensees were required to provide an overall integrated plan (OIP) to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 2.2). The NRC staff provided an interim staff evaluation (ISE) related to the OIP (Reference 2.3). The NRC concluded in the ISE that the licensee provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, including satisfactory resolution of the open and confirmatory items, would meet the requirements of Order EA-12-049 at Comanche Peak. The NRC staff also conducted a regulatory audit of the licensee's strategies and issued a report which documented the results of the audit activities (Reference 2.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter and a final integrated plan (FIP) to the NRC (Reference 2.5). The FIP describes how the licensee is complying with the order at Comanche Peak.

The NRC staff completed a safety evaluation (SE) of the licensee's FIP (Reference 2.6). The SE informed the licensee that its integrated plan, if implemented as described, provided a reasonable path for compliance with Order EA-12-049 at Comanche Peak. The staff then evaluated the implementation of the plans through inspection, using Tl 2515/191, "Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communications/Staffing/Multi-Unit Dose Assessment Plans." An inspection report was issued to document the results of the Tl 2515/191 inspection (Reference 2. 7). The NRC will oversee implementation of the mitigation strategies requirements under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

Phase 3 of Order EA-12-049 required licensees to obtain sufficient offsite resources to sustain the required functions indefinitely. There are two redundant National Strategic Alliance for FLEX Emergency Response (SAFER) Response Centers (NSRCs), one located in Memphis, Tennessee, and the other in Phoenix, Arizona, which have the procedures and plans in place to maintain and deliver the equipment needed for Phase 3 from either NSRC to any participating U.S. nuclear power plant when requested (Reference 2.8). The NRC staff evaluated and inspected the NSRCs and the SAFER program, plans, and procedures (References 2.9 and 2.10). The NRC concluded that licensees may reference the SAFER program and implement their SAFER response plans to meet the Phase 3 requirements of the order. The licensee's FIP (Reference 2.5) includes the plans for utilizing the NSRC equipment at Comanche Peak. In its SE (Reference 2.6), the NRC staff concluded that the licensee has developed guidance that, if implemented appropriately, should allow utilization of offsite resources following a BDBEE consistent with NEI 12-06 guidance and should adequately address the requirements of the order.

K. Peters Spent Fuel Pool Instrumentation Order Order EA-12-051, which applies to Comanche Peak, required licensees to install reliable SFP level instrumentation with a primary channel and a backup channel, independent of each other, and with the capability to be powered independent of the plant's power distribution systems.

The NEI issued NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"' as guidance to be used by licensees to comply with the order. The NRC endorsed this guidance in JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation" (Reference 3.1 ). Licensees were required to provide an OIP to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 3.2). The NRC issued an ISE, providing feedback on the OIP (Reference 3.3). The NRC staff conducted a regulatory audit of the licensee's strategies and issued a report that documented the results of the audit activities (Reference 3.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter to the NRC (Reference 3.5), describing how the licensee complied with the order at Comanche Peak.

The NRC staff completed an SE of the actions taken by the licensee in response to the order (Reference 3.6). The SE informed the licensee that its integrated plan, if implemented as described, provided a reasonable path for compliance with Order EA-12-051 at Comanche Peak. The staff then evaluated the implementation of the plan through inspection, using Tl 2515/191. An inspection report was issued to document the results of the Tl 2515/191 inspection (Reference 3.7). The NRC will oversee implementation of the SFP instrumentation requirements under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

Reliable Hardened Containment Vent Order Order EA-13-109 is only applicable to operating boiling-water reactors (BWRs) with Mark I and Mark II containments. Because the reactors at Comanche Peak are pressurized water reactors with large, dry, ambient-pressure containments, this order is not applicable to Comanche Peak.

Request for Information Under 10 CFR 50.54(f)

The 50.54(f) letter requested operating power reactor licensees to:

  • reevaluate the seismic and flooding hazard at their sites using present-day NRC requirements and guidance, and identify actions that are planned to address plant-specific vulnerabilities associated with the reevaluated seismic and flooding hazard;
  • perform seismic and flooding walkdowns to verify compliance with the current licensing basis; verify the adequacy of current strategies and maintenance plans; and identify degraded, nonconforming, or unanalyzed conditions related to seismic and flooding protection; and
  • provide an assessment of their current emergency communications and staffing capabilities to determine if any enhancements are needed to respond to a large-scale natural emergency event that results in an extended loss of ac power to all reactors at the site, and/or impeded access to the site.

K. Peters In COMSECY-14-0037, "Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluat[i]on of Flooding Hazards" (Reference 6.13), the NRC staff described issues related to the implementation of Order EA-12-049 and the related MBDBE rulemaking, and the completion of flooding reevaluations and assessments. In the SRM to COMSECY-14-0037 (Reference 6.14), the Commission directed the NRC staff to ensure that licensees of operating nuclear power plants address the reevaluated hazard within their mitigation strategies for BDBEE. The SRM also directed the NRC staff to provide a plan for achieving closure of the flooding hazard assessments to the Commission for review and approval. The NRC staff provided this plan in COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants" (Reference 6.16), which the Commission approved in the SRM to COMSECY-15-0019 (Reference 6.17).

Hazard Reevaluations (Enclosures 1 and 2 of the 50.54(f) letter)

Each licensee followed a similar two-phase process to respond to the hazard reevaluations requested by the 50.54(f) letter. In Phase 1, licensees submitted hazard reevaluation reports using NRG-endorsed, industry-developed guidance. The guidance specified that a licensee should determine if interim protection measures were needed while a longer-term evaluation of the impacts of the hazard was completed. The NRC staff reviewed the reevaluated hazard information. Using the reevaluated hazard information and a graded approach, the NRC identified the need for, and prioritization and scope of, plant-specific assessments. For those plants that were required to perform a flooding integrated assessment or a seismic probabilistic risk assessment (SPRA), Phase 2 decisionmaking (as described in a letter dated September 16, 2016 (Reference 5.17)) would determine whether additional plant-specific regulatory actions were necessary. In addition, as discussed in COMSECY-15-0019 and the draft final MBDBE rule, each licensee performed a mitigation strategies assessment (MSA) to confirm that the licensee had adequately addressed the reevaluated hazards within their mitigation strategies developed for BDBEEs.

Seismic Hazard Reevaluation (Enclosure 1 of the 50.54{f) letter) of the 50.54(f) letter requested each operating power reactor licensee to complete a reevaluation of the seismic hazard that could affect their sites using updated seismic hazard information and present-day regulatory guidance and methodologies to develop a ground motion response spectrum (GMRS). The licensee was asked to compare their results to the safe-shutdown earthquake (SSE) ground motion and then report to the NRC in a seismic hazard screening report. To provide a uniform and acceptable industry response, the Electric Power Research Institute (EPRI) developed a technical report, EPRI 1025287, "Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," and the NRC endorsed the guidance in a letter dated February 15, 2013 (Reference 5.1 ). From November 2012 to May 2014, the NRC and the industry provided guidance for the performance of the reevaluated hazard reviews (References 5.2-5. 7). The licensee provided a seismic hazard screening report for Comanche Peak (Reference 5.8).

If the new GMRS was not bound by the current design basis (CDB) SSE, Enclosure 1 of the 50.54(f) letter requested more detailed evaluations of the impact from the hazard. Also, the licensee was asked to evaluate whether interim protection measures were needed while the more detailed evaluation was completed. By letter dated May 7, 2013, the NRC endorsed industry-developed guidance, a proposed path forward, and schedules, which were provided in a letter from NEI dated April 9, 2013. Attachment 1 of the NEI letter contains EPRI

K. Peters report 300200704, "Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," to provide the guidance needed to perform an evaluation of any needed interim protective measures (Reference 5.3). This expedited seismic evaluation process (ESEP) is a screening, evaluation, and equipment modification process performed by licensees to provide additional seismic margin and expedite plant safety enhancements for certain core cooling and containment components while the more detailed and comprehensive plant seismic risk evaluations are being performed. Comanche Peak was not required to perform an ESEP since the SSE bounds the reevaluated GMRS in the frequency range of 1 to 100 Hertz (Hz) as noted in Reference 5.10.

By letter dated May 9, 2014 (Reference 5.10), the NRC informed licensees of the initial screening and prioritization results based on a review of the licensees' seismic hazard screening reports. The NRC updated the screening and prioritization in a letter dated October 3, 2014 (Reference 5.11 ). The NRC provided the final determination of required seismic evaluations in a letter dated October 27, 2015 (Reference 5.18). These evaluations could consist of an SPRA (Reference 5.1, SPID, Section 6.1.1 ), limited scope evaluations (High Frequency (Reference 5.14) and/or SFP (Reference 5.15)), or a relay chatter evaluation (Reference 5.4). If an SPRA was required, then additional Phase 2 regulatory decisionmaking was required (References 5.16 and 5.17).

The NRC staff completed and documented its review of the licensee's reevaluated seismic hazard in a staff assessment (Reference 5.9). Because the SSE bounds the reevaluated GMRS in the frequency range of 1 to 100 Hz, Comanche Peak was screened out from further seismic assessments.

The NRC staff reviewed the information provided and, as documented in the staff assessment (Reference 5.9), determined that the licensee provided sufficient information in response to of the 50.54(f) letter. The staff acknowledges that all seismic hazard reevaluation activities requested by Enclosure 1 of the 50.54(f) letter have been completed for Comanche Peak. No further information related to the reevaluated seismic hazard is required.

Flooding Hazard Reevaluation (Enclosure 2 of the 50.54{f) letter) of the 50.54(f) letter requested each operating power reactor licensee to complete a reevaluation of applicable flood-causing mechanisms at their site using updated flooding hazard information and present-day regulatory guidance and methodologies. Licensees were asked to compare their results to the CDB for protection and mitigation from external flood events. The NRC developed guidance to conduct the reevaluations (References 6.1 through 6.6). The licensee submitted a flood hazard reevaluation report (FHRR), and 4 subsequent supplements, for Comanche Peak (Reference 6. 7) to the NRC as requested by the 50.54(f) letter. Interim actions to protect against the reevaluated flood hazard were not needed. A regulatory audit to support the review of the FHRR was performed and the results documented in an audit report (Reference 6.8). The NRC staff reviewed the FHRR and provided an interim hazard letter (Reference 6.10) to provide feedback on the staff's review of the flooding hazard reevaluations.

The interim hazard letter was used by the licensee to complete the flood hazard MSA and other flood hazard evaluations. Separately, the NRC staff documented the technical bases for its conclusions in the interim hazard letters by issuing a staff assessment (Reference 6.11 ).

In COMSECY-14-0037 (Reference 6.13), the NRC staff requested Commission direction to more clearly define the relationship between Order EA-12-049, the related MBDBE rulemaking, and the flood hazard reevaluations and assessments. Because the NRC was reevaluating its

K. Peters approach to the flooding evaluations, the NRC provided an extension of the due dates for any integrated assessments in a letter dated November 21, 2014 (Reference 6.12). In the SRM to COMSECY-14-0037 (Reference 6.14), the Commission affirmed that licensees of operating nuclear power plants need to address the reevaluated flooding hazard within their mitigation strategies. The Commission also directed the NRC staff to provide a plan for achieving closure of the flooding portion of NTTF Recommendation 2.1 to the Commission for its review and approval. On May 26, 2015, the NRC deferred, until further notice, the date for submitting the integrated assessment reports (Reference 6.15). On June 30, 2015, the NRC staff provided a plan to the Commission in COMSECY-15-0019 (Reference 6.16). On July 28, 2015, the Commission approved the plan in the SRM to COMSECY-15-0019 (Reference 6.17). On September 29, 2015, the NRC issued a letter to licensees to describe the graded approach to the flood hazard reevaluations approved by the Commission (Reference 6.18).

The COMSECY-15-0019 action plan required the NRC staff to develop a graded approach to identify the need for, and prioritization and scope of, plant-specific integrated assessments and evaluation of plant-specific regulatory actions. The NRC staff's graded approach enabled a site with hazard exceedance above its CDB to demonstrate the site's ability to cope with the reevaluated hazard through appropriate protection or mitigation measures which are timely, effective, and reasonable. Integrated assessments were focused on sites with the greatest potential for additional safety enhancements. New guidance for performing the integrated.

assessments and focused evaluations was developed for this graded approach. The guidance also provided schedule information for submission of any required integrated assessment. On July 18, 2016, the staff issued JLD-ISG-2016-01, "Guidance for Activities Related to Near-Term Task Force Recommendation 2.1, Flooding Hazard Reevaluation, Focused Evaluation and Integrated Assessment" (Reference 6.19). The ISG provided the guidance for Phase 1 flooding assessments, as described in COMSECY-15-0019, and endorsed industry guidance provided in NEI 16-05, "External Flooding Integrated Assessment Guidelines" (Reference 6.19). If an integrated assessment was necessary, then Phase 2 regulatory decisionmaking was required (References 6.23 and 6.24).

As noted in the interim hazard response letter (Reference 6.10), the reevaluated flood hazard results for local intense precipitation (LIP) and streams and rivers were not bound by the CDB.

Therefore, additional assessments of these flood-causing mechanisms were required. The NRC staff used a graded approach to determine if this site would need to perform an integrated assessment for the reevaluated flooding hazard, or if a focused evaluation would suffice. Based on the graded approach, Comanche Peak completed a focused evaluation (Reference 6.20) to ensure appropriate actions were identified and taken to protect the plant from the reevaluated flood hazard. The NRC staff conducted a regulatory audit (Reference 6.22), completed its review of the focused evaluation (Reference 6.20), and concluded in the staff assessment (Reference 6.21) that the licensee has demonstrated that they have effective flood protection from the reevaluated hazards. Audit results were summarized in the staff assessment. No further regulatory actions are required related to the flood hazard reevaluations.

The NRC staff reviewed the information provided by the licensee and has concluded that sufficient information was provided to be responsive to Enclosure 2 of the 50.54(f) letter. The staff acknowledges that all flooding hazard reevaluation activities requested by Enclosure 2 of the 50.54(f) letter have been completed for Comanche Peak. No further information related to the reevaluated flood hazard is required.

K. Peters Mitigating Strategies Assessment In addition to the closure plan for NTTF Recommendation 2.1, the action plan approved by the Commission in the SRM to COMSECY-15-0019 (Reference 7.4) identified the staff efforts to ensure licensees would address the reevaluated hazard information in their mitigation strategies. Performance of the MSA is necessary to support compliance with the final MBDBE rule, if approved by the Commission.

The objective of the MSA is to determine whether the mitigation strategies developed for Order EA-12-049 can still be implemented given the reevaluated hazard levels. If it was determined that the mitigation strategies could not be implemented for the reevaluated hazard levels, the MSA could provide other options such as performing additional evaluations, modifying existing mitigating strategies, or developing alternate mitigating strategies or targeted hazard mitigating strategies to address the reevaluated hazard levels. In Revision 1 to JLD-ISG-2012-01, the NRC endorsed industry-developed guidance contained in Appendices G and H of NEI 12-06 (Reference 7.5) for completing the MSAs.

The licensee completed both a flood hazard MSA (Reference 7.6) and a seismic hazard MSA (Reference 7.8) for Comanche Peak. A regulatory audit was not required for either MSA. The NRC staff reviewed the MSA submittals, and issued staff assessments (References 7.7 and 7.9) documenting its review. The NRC staff concluded that the licensee has demonstrated that the mitigation strategies appropriately address the reevaluated hazard conditions. Oversight of any changes to existing mitigation strategies, or new strategies, resulting from the MSAs will be included in the longer-term oversight of mitigation strategies through the ROP.

Walkdowns (Enclosures 3 and 4 of the 50.54(f) letter)

Enclosures 3 and 4 of the 50.54(f) letter requested that licensees perform plant walkdowns to verify compliance with the current licensing basis as it pertains to seismic and flood protection.

By letter dated May 31, 2012 (Reference 8.2), the NRC endorsed industry-developed guidance contained in Technical Report EPRI 1025286, "Seismic Walkdown Guidance" (Reference 8.1 ),

for the performance of the seismic walkdowns. By letter dated May 31, 2012 (Reference 9.2),

the NRC endorsed industry-developed guidance contained in NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (Reference 9.1 ), for performance of the flooding walkdowns. The licensee provided a report for both the seismic and flooding walkdowns at Comanche Peak (References 8.3 and 9.3). The NRC performed onsite inspections per Tl 2515/188, "Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns," and Tl 2515/187, "Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns," and documented the inspection results in a quarterly integrated inspection report (References 8.4 and 9.4 ). The NRC staff issued staff assessments for both the seismic and flooding walkdowns (References 8.5 and 9.5). Because there were inaccessible items identified during the initial licensee seismic walkdowns, the licensee submitted a subsequent seismic walkdown report after accessing the areas (Reference 8.5). The NRC documented its review of the subsequent walkdown report in the seismic walkdown staff assessment (Reference 8.6).

The NRC staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosures 3 and 4 of the 50.54(f) letter. The staff acknowledges that all seismic and flooding walkdown activities requested by the 50.54(f) letter have been completed for Comanche Peak.

K. Peters Communications and Staffing (Enclosure 5 of the 50.54{f) letter) of the 50.54(f) letter requested licensees to assess their means to power equipment needed to communicate onsite and offsite during a prolonged station blackout event and to identify and implement enhancements to ensure that communications can be maintained during such an event. Also, licensees were requested to assess the staffing required to fill all necessary positions to respond to a multiunit event with impeded access to the site, or to an extended loss of all ac power for single unit sites. Licensees were requested to submit a written response to the information requests within 90 days, or provide a response within 60 days and describe an alternative course of action and estimated completion dates. The licensee proposed an alternative course of action and schedule for Comanche Peak (Reference 10.2),

which included a 90-day partial response (Reference 10.3). The NRC acknowledged the schedule changes in a letter dated July 26, 2012 (Reference 10.4).

By letter dated May 15, 2012 (Reference 10.1 ), the NRC endorsed industry-developed guidance contained in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," for the performance of the communications and staffing assessments. The licensee provided the communications assessment and implementation schedule for Comanche Peak (Reference 10.5), and the NRC completed a staff assessment of the licensee's communications assessment (Reference 10.6).

Licensees responded to the staffing portion of the 50.54(f) letter in two phases to account for the implementation of mitigation strategies. Phase 1 staffing assessments were based on the existing station blackout coping strategies with an assumption of all reactors at the site being affected concurrently. The Phase 1 staffing assessment is required for multiunit sites and was completed for Comanche Peak (Reference 10. 7). In Phase 2, all licensees assessed the staffing necessary to carry out the mitigation strategies (Reference 10.9). The NRC staff issued staffing assessment response letters (References 10.8 and 10.10) for each submittal. The NRC performed an onsite inspection using Tl 2515/191 to verify that the emergency communications and staffing plans at Comanche Peak have been implemented as described by the licensee (Reference 10.11 ).

The draft final MBDBE rule would make generically applicable the staffing and communications requirements to support the mitigation strategies. Regulatory Guide 1.228 (Reference 1.16) is expected to endorse, with clarifications, NEI 12-01, NEI 13-06, "Enhancements to Emergency Response Capabilities for Beyond-Design-Basis Events and Severe Accidents" (Reference 11.17), and NEI 14-01, "Emergency Response Procedures and Guidelines for Beyond-Design-Basis Events and Severe Accidents" (Reference 11. 7), to provide acceptable methods for implementing the MBDBE rule requirements, if approved. The NRC will oversee the communications and staffing requirements, and a periodic drill or exercise, under the proposed MBDBE rule requirements, if approved by the Commission, through the ROP.

The NRC staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosure 5 of the 50.54(f) letter. The staff acknowledges that all emergency preparedness communications and staffing activities requested by Enclosure 5 of the 50.54(f) letter have been completed for Comanche Peak. No further information related to the communications and staffing assessments is required.

K. Peters Additional Industry Commitments Update and Maintain Severe Accident Management Guidelines The NRC staff provided the proposed MBDBE rule to the Commission on April 30, 2015, in SECY-15-0065, "Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49)" (Reference 11.1) and the Commission issued the SRM to SECY-15-0065 on August 27, 2015 (Reference 11.2). The Commission approved publication of the proposed rule subject to removal of the proposed requirements pertaining to the SAMGs. The Commission also directed the staff to update the ROP to explicitly provide periodic oversight of industry's implementation of the SAMGs. By letter dated October 26, 2015 (Reference 11.3), NEI described the industry initiative, approved by the Nuclear Strategic Issues Advisory Committee as mandatory for all NEI members, to update and maintain the SAMGs. Specifically, each licensee will perform timely updates of their site-specific SAMGs based on revisions to generic severe accident technical guidelines. Licensees will also ensure that SAMGs are considered within plant configuration management processes. As noted in the NEI letter, the licensee provided a letter (Reference 11.4) to establish a site-specific regulatory commitment for Comanche Peak.

In a letter to NEI dated February 23, 2016 (Reference 11.5), the staff outlined its approach for making changes to the ROP in accordance with the Commission direction. The staff engaged NEI and other stakeholders to identify the near-term and long-term changes to the ROP, consistent with the Commission direction and the licensees' near-term and long-term SAMG commitments. The staff then revised Inspection Procedure 71111.18, "Plant Modifications" (Reference 11.6), to provide oversight of the initial inclusion of SAMGs within the plant configuration management processes to ensure that the SAMGs reflect changes to the facility over time.

Multiunit/Multisource Dose Assessments In COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (Reference 11.13), the NRC staff requested Commission approval to implement the NTTF recommendation concerning multiunit/multisource dose assessments by having licensees document their commitment to obtain multiunit/multisource dose assessment capability by the end of 2014, rather than by issuing an order. Multiunit dose assessment capabilities would be made generically applicable through subsequent rulemaking. The Commission approved the staff's requests in the SRM to COMSECY-13-0010, dated April 30, 2013 (Reference 11.14). The licensee commitments are documented in References 11.8 through 11.11.

The NRC staff included the multiunit/multisource dose assessment requirement in the proposed MBDBE rulemaking (Reference 11.1 ). However, in response to a public comment concerning the 10 CFR 50.109 backfitting justification for the proposed multiple source term dose assessment requirements, the staff determined that this requirement did not meet the criteria for imposition under 10 CFR 50.109(a)( 4)(ii). The NRC staff also concluded that this could not be justified as a compliance backfit or as a substantial safety improvement whose costs, both direct and indirect, would be justified in light of the potential safety gain. Therefore, these requirements were removed from the draft final rule (Reference 11.16).

The licensee provided the requested information and stated that Comanche Peak will have multiunit/multisource dose assessment capabilities (Reference 11.11) by December 31, 2014.

K. Peters The NRC acknowledged the licensee's submittal (Reference 11.12), verified the implementation of these dose assessment capabilities through inspection per Tl 2515/191, and issued an inspection report (Reference 11.15).

CONCLUSION The NRC staff concludes that Luminant Generation Company, LLC (now Vistra Operations Company, LLC), the licensee, has implemented the NRG-mandated safety enhancements resulting from the lessons learned from the Fukushima Dai-ichi accident through its implementation of Orders EA-12-049, EA-12-051, and its response to the 50.54(f) letter at Comanche Peak. No further regulatory decisionmaking is required for Comanche Peak related to the Fukushima lessons-learned.

A listing of the applicable correspondence related to the Fukushima lessons-learned activities for Comanche Peak is included as an enclosure to this letter.

If you have any questions, please contact me at 301-415-2621 or by e-mail at Robert.Bernardo@nrc.gov.

Sincerely,

~~~lManager Beyond-Design-Basis Management Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Documents Related to Required

Response

cc w/encl: Distribution via Listserv

Comanche Peak Nuclear Power Plant, Units 1 and 2 Reference Documents Related to Required Response to the Lessons Learned from the Fukushima Dai-ichi Accident TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Tohoku Earthquake and Subsequent Tsunami Ref.

1.1 NRC Information Notice 2011-05 1.2 NRC Follow-up to the Fukushima Dai-ichi Fuel Dama e Event Temporary Instruction (Tl) March 23, 2011 ML11077A007 2515/183 NRC Tl 2515/183 Inspection May13,2011 ML11133A184 Re ort 2011-010 Summary of Observations - Tl-183 November 28, ML11325A020 2011 1.3 NRC Tasking Memorandum, Staff March 23, 2011 ML110820875 Requirements Memorandum (SRM) to COMGBJ-11-0002 1.4 NRC Availability and Readiness Inspection of SAMG NRC Availability and Readiness April 29, 2011 ML11115A053 Ins ection of SAMG - Tl 2515/184 NRC Integrated Inspection Report July 29, 2011 ML112101634 2011-003 {Tl 2515/184 inspection results NRC Tl 2515/184 Inspection May 26, 2011 ML111470264 Results, Re ion 4 Summa NRC Summary of Tl 2515/184 June 6, 2011 ML11154A109 Results 1.5 NRC Bulletin 2011-01, "Mitigating Strate ies" NRC Bulletin 2011-01 Ma 11,2011 ML111250360 Licensee 30 day response to June 8, 2011 ML11168A076 BL 2011-01 Licensee 60 day response to July 11, 2011 ML11200A132 BL 2011-01 NRC Closeout of BL 2011-01 for April 9, 2012 ML120870576 Comanche Peak 1.6 NRC NTTF Re ort SECY-11-0093 Jul 21, 2011 ML11186A950 1.7 NRC SECY-11-0137, Prioritization of Recommended Actions To Be Taken in Res onse to Fukushima Lessons Learned NRC SECY-11-0137 October 3, 2011 ML11272A111 SRM-SECY-11-0137 December 15, ML113490055 2011 1.8 NRC Order EA-12-049 March 12, 2012 ML12054A735 1 Agencywide Documents Access and Management System (ADAMS)

Enclosure

Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Tohoku Earth uake and Subse uent Tsunami

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NRC Order EA-12-050 March 12, 2012 ML12054A694 NRC Order EA-12-051 March 12, 2012 ML12054A679 NRC Request for Information Under March 12, 2012 ML12053A340 10 CFR 50.54 f the 50.54 f letter 1.12 NRC Order EA-13-109 June 6, 2013 ML13143A321 1.13 NRC SECY-16-0142, "Draft Final Rule: December 15, ML16301A005 Miti ation of Be ond-Desi n-Basis Events" 2016 1.14 Regulatory Guide 1.226, Flexible November 2016 ML16301A128 Mitigation Strategies for Beyond-Design-Basis Events Draft Final Version 1.15 Regulatory Guide 1.227, Wide Range November 2016 ML16211A167 Spent Fuel Pool Level Instrumentation Draft Final Version 1.16 Regulatory Guide 1.228 - Integrated November 2016 ML16218A236 Response Capabilities for Beyond-Design-Basis Events (Draft Final Version Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 2 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Be ond-Desi n-Basis External Events - EA-12-049 Ref 2.1 Guidance for Compliance with EA-12-049 -

Diverse and Flexible Co in Strate ies FLEX Industry Guidance on Diverse and August 21, 2012 ML12242A378 Flexible Coping Strategies (FLEX)

NEI 12-06, Revision 0 NRC endorsement of NEI 12-06, August 29, 2012 ML12229A174 Revision O - JLD-ISG-2012-01, Revision O 2.2 Licensee Overall lnte rated Plan OIP ~',

Licensee OIP submittal ML13071A617 OIP 1st six month status re ort ML13252A077 OIP 2nd six month status re ort ML14071A008 OIP 3rd six month status re ort ML14254A402 OIP 4th six month status re ort ML15069A219 OIP 5th six month status re ort ML15253A372 OIP 6th six month status re ort ML16098A341 2.3 NRC Interim Staff Evaluation of OIP ML13225A575 2.4 NRC audit of EA-12-049 OIP NRC Notification of Audit of EA-12-049 Au ust 28, 2013 ML13234A503 NRC Site S ecific Audit Plan March 26, 2015 ML15076A523 NRC Audit Re ort Au ust 5, 2015 ML15180A261 2.5 Licensee Compliance Letter for EA-12-049 and July 28, 2016 ML16214A251 Final lnte rated Plan FIP 2.6 NRC Safety Evaluation of Implementation of December 14, 2016 ML16334A173 EA-12-049 2.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Pre aredness Information NRC Tl 2515/191 December 23, 2015 ML15257A188 NRC Tl 2515/191 Inspection Report July 9, 2017 ML17192A436 2017-009 2.8 Industry White Paper - National SAFER September 11, ML14259A221 Res onse Centers NSRC 2014 2.9 NRC Staff Assessment of NSRCs September 26, ML14265A107 2014 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 2 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Be ond-Desi n-Basis External Events - EA-12-049 NRC Inspection of Implementation of EA-12-049 Re ardin the use of NSRC NRC Inspection Procedure (IP) 43006 September 30, ML16273A318 2016 NRC Vendor Inspection of the Phoenix January 12, 2017 ML17012A186 NSRC Re ort No. 99901013/2016-201 NRC Vendor Inspection of the Memphis May 5, 2017 ML17117A576 NSRC Re ort No. 99901013/2017-201 NA NRC approval of relaxation request of the April 14, 2014 ML14071A439 schedule requirements for Order EA-12-049 for Comanche Peak, Unit 1 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 3 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation -

EA-12-051

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3.1 Guidance for Compliance with EA-12-051 -

S ent Fuel Pool Instrumentation SFPI Industry Guidance for Compliance with August 2012 ML12240A307 EA-12-051 - NEI 12-02, Revision 1 NRC endorsement of NEI 12-02, August 29, 2012 ML12221A339 Revision 1 - JLD-ISG-2012-03, Revision 0 3.2 Licensee Overall lnte rated Plan OIP Licensee OIP ML13071A344 OIP 1st six month status re ort ML13252A077 OIP 2nd six month status re ort ML14071A009 OIP 3rd six month status re ort ML14253A186 3.3 NRC Interim Staff Evaluation of OIP ML13295A674 3.4 NRC Audit of EA-12-051 NRC Notification of Audit of EA-12-051 March 26, 2014 ML14083A620 NRC Audit Report of Westinghouse August 18, 2014 ML14211A346 SFPI desi n s ecifications March 26, 2015 ML15076A523 Au ust 5, 2015 ML15180A261 3.5 December 16, 2014 ML15016A188 3.6 NRC Safety Evaluation of Implementation of December 14, 2016 ML16334A173 EA-12-051 3.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Pre aredness Information NRC Tl 2515/191 December23,2015 ML15257A188 NRC Tl 2515/191 Inspection Report July 9, 2017 ML17192A436 2017-009 Note: Table 4 relates to the Hardened Containment Vent System and is not applicable to Comanche Peak.

Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 5 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation Guidance Documents 5.1 Screening, Prioritization and Implementation Details SPID Industry Guidance (SPID) - November 2012 ML12333A170 EPRI 1025287 NRC letter endorsin SPID Februa 15, 2013 ML12319A074 5.2 NRC guidance for performing a Seismic November16,2012 ML12286A029 Margin Assessment (SMA) -

JLD-ISG-2012-04 5.3 Expedited Seismic Evaluation Process ESEP Industry Letter - Proposed path April 9, 2013 ML13101A345 forward for NTTF Recommendation 2.1: Seismic Industry Guidance - Expedited April 2013 ML13102A142 Seismic Evaluation Process (ESEP) -

EPRI 3002000704 NRC letter endorsing the ESEP May 7, 2013 ML13106A331 approach. Extension of ESEP due date to 3/31/14 for Central and Eastern U.S. CEUS sites 5.4 October 3, 2013 ML13281A308 5.5 NRC letter with guidance on the content of February 20, 2014 ML14030A046 seismic reevaluation submittals (includes o erabilit and re ortabilit discussions 5.6 Industry letter on seismic risk evaluations for March 12, 2014 ML14083A596 CEUS lants

5. 7 NRC background paper - Probabilistic seismic May 20, 2014 ML14140A648 hazard anal sis 5.8 Licensee Seismic Hazard Screening Report March 27, 2014 ML14099A197 and an su lements 5.9 NRC Staff Assessment of Reevaluated January 22, 2016 ML16014A125 Seismic Hazard Information Screenin and Prioritization Results 5.10 NRC Letter - Seismic screening and May 9, 2014 ML14111A147 rioritization results for CEUS lants 5.11 NRC Letter - Updated seismic screening and October 3, 2014 ML14258A043 rioritization results 5.12 NRC letter regarding development of Seismic December 10, 2014 ML143076707 Risk Evaluations - suitability of updated seismic hazard information for further assessments Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 5 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation ESEP Submittal and Evaluation Additional Guidance Documents 5.14 High Frequency Program Application Guidance Industry High Frequency Application July 30, 2015 ML15223A095 Guidance - EPRI 3002004396 NRC letter endorsing High Frequency September 17, ML15218A569 A lication Guidance 2015 5.15 S ent Fuel Pool Evaluation Guidance Industry SFP evaluation guidance - February 23, 2016 ML16055A017 EPRI 3002007148 NRC letter endorsing SFP evaluation March 17, 2016 ML15350A158 uidance 5.16 NRC Letter - Treatment of Seismic and September 29, ML15127A401 Flooding Hazard Reevaluations in the Design 2015 and Licensin Basis 5.17 NRC Guidance for Regulatory September 21, ML16237A103 Decisionmaking of reevaluated flooding and 2016 seismic hazards Final Determinations of Required Seismic Evaluations 5.18 NRC Final Determination of Required Seismic October 27, 2015 ML15194A015 Evaluations 5.19 Licensee Required Seismic Evaluation None Required None Required Submittals Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 6 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54{f), Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation

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6.1 NRC prioritization of plants for completing May 11, 2012 ML12097A509 flood hazard reevaluations 6.2 NRC-issued guidance for performing an November 30, 2012 ML12311A214 integrated assessment for external flooding (JLD-ISG-2012-05) 6.3 NRC letter to industry describing when an December 3, 2012 ML12326A912 integrated assessment is expected 6.4 NRC-issued guidance for performing a January 4, 2013 ML12314A412 tsunami, surge, or seiche hazard assessment (JLD-ISG-2012-06) 6.5 NRC letter to industry with guidance on the March 1, 2013 ML13044A561 content of floodinq reevaluation submittals 6.6 NRC-issued guidance for assessing flooding July 29, 2013 ML13151A153 hazards due to dam failure (JLD-ISG-2013-01)

Flood Hazard Reevaluation Report .

6.7 Licensee FHRR Submittal and supplements FHRR submittal package March 12, 2013 ML130840492 FHRR supplement April 4, 2014 ML14100A049 FHRR supplement August 14, 2014, ML14245A136 FHRR supplement September 22, ML15278A306 2015 FHRR supplement February 3, 2016 ML16041A029 6.8 FHRR Regulatory Audit NRC FHRR Site Specific Audit Plan June 11, 2015 ML15148A677 NRC FHRR Audit Report June 9, 2016 ML16131A582 6.9 NRC Inspection of licensee interim actions Per Not Required Not Required Tl 2515/190 6.10 NRC Interim Staff Response to Reevaluated February 11, 2016 ML16041A228 Flood Hazards 6.11 NRC Staff Assessment of FHRR June 13, 2017 ML17067A166 Modified Approach to Flood Hazard Reevaluations 6.12 NRC extension of due dates for Integrated November 21, 2014 ML14303A465 Assessment reports 6.13 NRC COMSECY-14-0037, "Integration of November 21, 2014 ML14309A256 Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards" 6.14 NRC SRM for COMSECY-14-0037 March 30, 2015 ML15089A236 6.15 NRC letter on second extension of due date May 26, 2015 ML15112A051 for flooding integrated assessment reports 6.16 NRC COMSECY-15-0019 "Closure Plan for June 30, 2015 ML15153A104 the Reevaluation of Flooding Hazards" 6.17 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 6 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation 6.18 NRC letter describing the graded approach to flood hazard reevaluation directed by SRM-COMSECY-14-0037 6.19 Floodin Assessment Guidance NEI 16-05, "External Flooding April 2016 ML16165A178 Assessment Guidelines" NRC endorsement of NEI 16 July 11, 2016 ML16162A301 JLD-ISG-2016-01 6.20 Licensee Focused Evaluation Se tember 7, 2017 ML17268A147 6.21 NRC Staff Assessment of Focused Evaluation March 26, 2018 ML18051A809 6.22 Jul 18,2017 ML17192A452 6.23 NRC Letter - Treatment of Seismic and September 29, ML15127A401 Flooding Hazard Reevaluations in the Design 2015 and Licensin Basis 6.24 NRC Guidance for Regulatory Decisionmaking September 21, ML16237A103 of reevaluated floodin and seismic hazards 2016 TABLE 7 Mitigating Strategies Assessments (MSA) i'

' ADAMS Ref Document  !. *** Date Accession No.

7.1 NRC COMSECY-14-0037, Integration of November 21, 2014 ML14309A256 Mitigating Strategies with Hazard Reevaluations 7.2 NRC SRM-COMSECY-14-0037 March 30, 2015 ML15089A236 7.3 NRC COMSECY-15-0019, Closure Plan for June 30, 2015 ML15153A104 Flooding Hazard Re'evaluations 7.4 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 7.5 Process for Mitigating Strategies Assessments (MSA)

Industry Guidance for performing December 2015 ML16005A625 MSAs - NEI 12-06, Revision 2, includinq Appendices E, G, & H NRC endorsement of NEI 12-06, January 22, 2016 ML15357A163 Revision 2 - JLD-ISG-2012-01, Revision 1 7.6 Licensee's MSA submittal - Flooding February 9, 2017 ML17044A009 7.7 NRC Staff Assessment of MSA - Flooding May 9, 2017 ML17111A960 7.8 Licensee's MSA submittal - Seismic January 26, 2017 ML17030A044 7.9 NRC Staff Assessment of MSA - Seismic February 2, 2017 ML17031A005 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 8 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54 , Enclosure 3: Recommendation 2.3 Seismic Walkdown ,...,,.,....-,---,

8.1 Industry Seismic Walkdown Guidance with NRC endorsement letter - EPRI 1025286 8.2 NRC letter endorsin EPRI 1025286 8.3 Licensee Seismic Hazard Walkdown Re ort Licensee Seismic Hazard Walkdown November 27, 2012 ML13009A269 Re ort Seismic Hazard Walkdown supplement September 12, ML13267A158 2013 8.4 NRC Ins ection of Seismic Walkdowns NRC Tl 2515/188 Jul 6, 2012 ML12156A052 NRC Integrated Inspection Report May 2, 2013 ML13123A139 2013-002 (Tl 2515/188 inspection results 8.5 Seismic Hazard Walkdown supplement July 1, 2013 ML13192A179 inaccessible item re ort 8.6 NRC Staff Assessment of Seismic Walkdown March 7, 2014 ML14036A036 Re ort includes subse uent walkdown items TABLE 9 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 4: Recommendation 2.3 Floodin, Walkdown

. ADAMS Ref Document Date Accession No.

9.1 Industry Flooding Walkdown Guidance - NEI May 31, 2012 ML12173A215 12-07 9.2 NRC letter endorsing NEI 12-07 Mav 31, 2012 ML12144A142 9.3 Licensee Flooding Hazard Walkdown Report Flooding Hazard Walkdown Report November 27, 2012 ML12340A433 package and any supplements Update to Flooding Hazard Walkdown January 30, 2014 ML14043A105 Report - APM Assessment 9.4 NRC Inspection of Flooding Walkdowns NRC Tl 2515/187 June 27, 2012 ML12129A108 NRC Integrated Inspection Report February 11, 2013 ML13042A290 2012-005 (Tl 2515/187 inspection results) 9.5 NRC Staff Assessment of Flooding Walkdown June 4, 2014 ML14133A254 Report Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE10 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 5: Recommendation 9.3 Emergency Preparedness Communications and Staffin,.,.,.,,.,,,.,;if,,,~..,.,..,,,,..,,,,,,.,

Guidance Documents Industry Guidance for May 2012 ML12125A412 Emergency Preparedness staffing and communications -

NEI 12-01 NRC letter endorsin NEI 12-01 Ma 15, 2012 ML12131A043 10.2 Comanche Peak 60 day response and May 10, 2012 ML12136A473 ro osed alternative course of action 10.3 Comanche Peak 90 day response to June 7, 2012 ML12167A242 communications and staffing information re uests Jul ML12200A106 10.5 Licensee communications assessment and im lamentation schedule Communications assessment October 31, 2012 ML12318A100 Februa 28, 2013 ML13071A349 October 30, 2014 ML14310A819 10.6 NRC staff assessment of licensee's June 3, 2013 ML13141A675 communications assessment 10.7 Licensee Phase 1 staffin assessment June 24, 2013 ML13128A077 10.8 NRC response to licensee's Phase 1 October 23, 2013 ML13233A183 staffin assessment 10.9 Licensee Phase 2 staffin assessment Licensee Phase 2 staffing June1,2015 ML15161A318 assessment for functions related to miti ation strate ies Updated Phase 2 staffing January 20, 2016 ML16047A327 assessment 10.1 O NRC Phase 2 staff assessment March 22, 2016 ML16075A371 res onse 10.11 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Erner enc Pre aredness Information NRC Tl 2515/191 December 23, ML15257A188 2015 NRC Tl 2515/191 Inspection July 9, 2017 ML17192A436 Re ort 2017-009 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE 11 Additional Licensee Commitments - SAMGs and Multisource Dose Assessments

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U date and Maintain SAMGs 11.1 SECY-15-0065: Proposed Rulemaking: April 30, 2015 ML15049A201 Mitigation of Beyond-Design-Basis Events RIN 3150-AJ49 11.2 SRM-SECY-15-0065 Au ust 27, 2015 ML15239A767 11.3 NEI Letter describing industry initiative October 26, 2015 ML15335A442 to u date and maintain SAMGs 11.4 Site Commitment to Maintain SAMGs December 10, 2015 ML15357A050 11.5 NRG letter to NEI describing approach February 23, 2016 ML16032A029 to SAMG oversi ht 11.6 NRG Inspection Procedure 71111.18, November 17, 2016 ML16306A185 "Plant Modifications" 11.7 NEI 14-01, "Emergency Response February 2016 ML16224A619 Procedures and Guidelines for Extreme Events and Severe Accidents, Rev. 1 Multisource Dose Assessments

11.8 NEI Letter: Industry survey and plan for January 28, 2013 ML13028A200 multiunit dose assessments 11.9 NRG Letter to request additional February 27, 2013 ML13029A632 information from NEI on multiunit dose assessment ca abilit 11.10 NEI Letter: Commitment for March 14, 2013 ML13073A522 Implementation of Multiunit Dose Assessment Ca abilit 11.11 Licensee Response Regarding the July 1, 2013 ML18200A178 Capability to Perform Multisource Offsite Dose Assessment 11.12 NRG Acknowledgement of Licensee January 29, 2014 ML13233A205 Dose Assessment Submittals 11.13 COMSECY-13-0010 March 27, 2013 ML12339A262 11.14 SRM-COMSECY-13-0010 A ril 30, 2013 ML13120A339 11.15 NRG Inspection of Licensee Responses to EA-12-049, EA-12-051, and Erner enc Pre aredness Information NRG Tl 2515/191 December 23, 2015 ML15257A188 NRG Tl 2515/191 Inspection July 9, 2017 ML17192A436 Re ort 2017-009 11.16 Draft Final Rule: Mitigation of December 15, 2016 ML16301A005 Beyond-Design-Basis Events NRG SECY-16-0142, Packa e 11.17 NEI 13-06, "Enhancements to February 2016 ML16224A618 Emergency Reponses Capabilities for Beyond Design Basis Accidents and Events, Rev. 1 Comanche Peak Nuclear Power Plant, Units 1 and 2 TABLE12 1,-:--,,,---,-~~,....,.-:=~

NRC Semi-Annual Status Re orts to the Commission 12.1 SECY-12-0025, Enclosure 8, "Proposed February 17, 2012 ML12039A103 Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami" 12.2 SECY-12-0095- Enclosure 1: Six-Month July 13, 2012 ML12165A092 Status Update On Charter Activities -

Februa 2012 - Jul 2012 12.3 SECY-13-0020 -Third 6-Month Status Update February 14, 2013 ML13031A512 On Response To Lessons Learned From Japan's March 11, 2011, Great Tohoku Earth uake And Subse uent Tsunami 12.4 SECY-13-0095 - Fourth 6-Month Status September 6, 2013 ML13213A304 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.5 SECY-14-0046 - Fifth 6-Month Status Update April 17, 2014 ML14064A520 on Response to Lessons Learned From Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.6 SECY-14-0114 - Sixth 6-Month Status Update October 21, 2014 ML14234A498 on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.7 SECY-15-0059 - Seventh 6-Month Status April 9, 2015 ML15069A444 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.8 SECY-15-0128: Eighth 6-Month Status October 14, 2015 ML15245A473 Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.9 SECY-16-0043: Ninth 6 Month Status Update April 5, 2016 ML16054A255 on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earth uake and Subse uent Tsunami 12.10 SECY-17-0016: Status of Implementation of January 30, 2017 ML16356A084 Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subse uent Tsunami

ML18207A272 OFFICE NRR/DLP/PBMB/PM NRR/DLP/PBMB/LA NRR/DLP/PBMB/BC(A) NRR/DLP/PBMB/PM NAME RBernardo Slent BTitus RBernardo DATE 7/25/18 7/26/18 8/1/18 8/8/18 OFFICE NAME DATE

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