PLA-7610, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event (NRC Order EA-12-049)

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Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event (NRC Order EA-12-049)
ML17151A292
Person / Time
Site: Susquehanna Talen Energy icon.png
Issue date: 05/31/2017
From: Rausch T
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, PLA-7610, TAC MF0888, TAC MF0889
Download: ML17151A292 (17)
v • d • e


Text

Timothy S. Rausch President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Boulevard TALEN ~

Berwick, PA 18603 ENERGY MAY 3* 1 2017 Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@TalenEnergy.com U.S. Nuclear Regulatory Commission 10 CFR 2.202 Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION REPORT OF FULL COMPLIANCE FOR UNIT 2 WITH MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (NRC ORDER EA-12-049)

PLA-7610 Docket No. 50-388

References:

1. NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, " dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifj1ing Licenses vvith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012
3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, "

Revision 0, dated August 2012

4. PPL Letter (PLA-6923), "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 29, 2012

5. PPL Letter (PLA-6981), "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifj;ing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA 049), "dated Februwy 28, 2013
6. PPL Letter (PLA-7072), "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifj1ing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049), "dated August 26, 2013
7. NRC Order EA-13-109, "Order to Modifj1 Licenses 'I'Vith Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, "

dated Jun e 6, 2013

8. PPL Letter (PLA-7071), "First Six Month Status Report in Response to March 12, 2012 Commission Order Modifj1ing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), " dated August 26, 2013
9. PPL Letter (PLA-7134), "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,'" dated February 20, 2014

Document Control Desk PLA-7610 I 0. NRC Letter from J S. Bowen to T. S. Rausch, "Susquehanna Steam Electric Station, Units I and 2-Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889), "dated Janumy 24, 2014 (ADAMS #ML13339A764)

II. PPL Letter (PLA-7I37), "Second Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated Februmy 28, 2014 I2. NRC Letter from E. J Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units I and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049

'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, "' dated Apri!I5, 2014 (MLI4065A028)

I3. PPL Letter (PLA-7204), "Third Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), " dated August 28, 20I4

14. PPL Letter (PLA-7295), "Fourth Six-Month Status Report in Response to March I2, 20 I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), " dated Februmy 25, 20I5 I5. Talen Letter (PLA-7377), "Fifth Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated August 26, 20I5 I6. Talen Letter (PLA-7438), "Sixth Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated Februmy I8, 20I6
17. Talen Letter (PLA- 7513), "Seventh Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated August I9, 20I6.

I8. Talen Letter PLA-7570, "Eighth Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated February 9, 2017 I9. NRC Letter, Request for Information Pursuant to Title I 0 of the Code of Federal Regulations 50.54(/) Regarding Recommendations 2.I, 2.3, and 9.3, of the Near-Term Task Force Review ofInsights from the Fukushima Dai-ichi Accident, dated March I2, 20I 2

20. PPL Letter (PLA-7283), "Revision I to Fukushima Phase 2 Staffing Assessment,"

dated Februmy 4, 20I5

Document Control Desk PLA-7610 The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna) Unit 2 report of full compliance with the March 12, 2012 Commission Order modifying licenses with regard to requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events (NRC ORDER EA-12-049, Reference 1). This report is being submitted pursuant to Section IV, Condition C.3 , of Reference 1, that required Susquehanna to submit this report upon Unit 2 achieving completion of implementing the requirements ofReference 1. Unit 1 will not be in full compliance with Reference 1 until the EA-13-109 Phase 1 wetwell hardened containment vent system is installed in 2018. A full site compliance report and Final Integrated Plan will be submitted after the Unit 1 work is complete. Enclosure 1 provides an update of milestone accomplishments since the last status report (Reference 18), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Susquehanna. Reference 1 was immediately effective and directs Susquehanna to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities in the event of a beyond-design-basis extemal event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided Susquehanna' s initial status report regarding Mitigation Strategies. Reference 5 provided Susquehanna' s initial Mitigation Strategies Overall Integrated Plan.

Reference 1 requires submission of status reports at six-month intervals following submittal of the Overall Integrated Plan until full compliance is achieved for all units at a site. Reference 3 provides direction regarding the content of the status reports. References 8, 11 , 13, 14, 15, 16, 17, and 18 provided the 6 month status reports for Unit 2 while implementing the Mitigation Strategies.

The Request for Relaxation contained in Reference 9 supersedes the Request for Relief made in Reference 6. The Request for Relaxation is based on NRC mandated changes to the Hardened Containment Vent System implementation dates that impact the Mitigation Strategy Overall Integrated Plan. Specifically, the change in implementation dates for the Hardened Containment Vent Order (NRC Order EA-12-050 was rescinded and superseded by NRC Order EA-13-109) impacts the Mitigation Strategy Overall Integrated Plan and implementation timeline. The NRC approved this relaxation in Reference 12.

The NRC Order EA-12-049 Compliance Elements Summary provided below and Enclosure 1 to this letter document that Susquehanna Unit 2 has developed, implemented and will maintain the guidance and strategies to maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a Beyond Design Basis Extemal Event and is now in full compliance with the requirements ofNRC Order EA-12-049 (Reference 1). to this letter also documents that Susquehanna Unit 1 has developed, implemented and will maintain the guidance and strategies to maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a Beyond Design Basis Extemal Event and is now in full compliance with the requirements ofNRC Order EA-12-049 (Reference 1), except for the

Document Control Desk PLA-7610 NRC approved Request for Relaxation (Reference 12) regarding implementation of a Severe Accident Capable Hardened Containment Vent System per NRC Order EA-13-109.

NRC ORDER EA-12-049 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Susquehanna Unit 2 as well as the site OIP response submittal (Reference 5 and as updated by the Six-Month Status Reports), the Six-Month Status Repmis (References 8, 11, 13, 14, 15, 16, 17, and 18), and any additional referenced docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies- Complete Susquehanna Unit 2's Mitigation Strategies are in compliance with Order EA-12-049.

There are no strategy related Open Items, Confitmatory Items, or Audit Questions/Audit Report Open Items. The Susquehanna Final Integrated Plan for Mitigation Strategies will be provided after full compliance for Susquehanna Unit 1 is achieved (Spring 2018).

Modifications - Complete The modifications required to support the FLEX Mitigation Strategies for Susquehanna 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 Mitigation Strategies for Susquehanna Unit 2 has been procured in accordance with NEI 12-06, Sections 11.1 and 11.2. The equipment has been received at Susquehanna Unit 2. The equipment was tested and perfmmance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Periodic maintenance and testing will be conducted through the use of the Susquehanna Preventative Maintenance program.

Protected Storage - Complete The FLEX Storage Building that houses most of the equipment required to implement the strategies for Susquehanna Unit 2 has been completed and provides protection from the applicable site hazards. The equipment required to implement the FLEX Mitigation Strategies for Susquehanna Unit 2 is stored in its protected configuration.

Procedures - Complete FLEX Suppmi Guidelines (FSGs) for Susquehanna Unit 2 have been developed and integrated with existing procedures. The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

Document Control Desk PLA-7610 Training -Complete Training for Susquehanna Unit 2 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

Staffing - Complete The Phase 2 Staffing Assessment for Susquehanna has been completed in accordance with 10 CFR 50.54(+/-), "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(+/-) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Tetm Task Force Review oflnsights from the Fukushima Dai-ichi Accident,"

Recommendation 9.3, dated March 12, 2012 (Reference 19). Susquehanna's Staffing Assessment repmi is documented in Reference 20.

National SAFER Response Center -Complete Susquehanna has established a contract with Pooled Equipment Inventory Company (PElCo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER)

Team Equipment Committee for off-site facility coordination. It has been confi1med that PElCo is ready to suppmi Susquehanna with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation -Complete Susquehanna Unit 2 has completed the perfmmance 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) for Order EA-12-049.

FLEX Program Document - Complete Susquehanna has developed a FLEX and SFPI Program Document in accordance with the requirements ofNEI 12-06.

Therefore, Susquehanna Unit 2 has now completed all required actions to be in full compliance with NRC Order EA-12-049.

This letter contains no new or revised regulatory commitments.

If you have any questions regarding this repmi, please contact Mr. Jason Jennings, Manager-Nuclear Regulatory Affairs, at (570) 542-3155.

Document Control Desk PLA-7610 I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Sincerely, : Susquehanna Nuclear, LLC's Unit 2 Full Compliance Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events Copy: NRC Region I Ms. T. Hood, NRC Project Manager Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Ms. L. H. Micewski, NRC Sr. Resident Inspector Mr. M. Shields, PA DEP/BRP

Enclosure 1 to PLA-7610 Susquehanna Nuclear, LLC's Unit 2 Full Compliance Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Enclosure 1 to PLA-7610 Susquehanna Nuclear, LLC's Unit 2 Full Compliance Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Susquehanna Nuclear, LLC (Susquehanna) developed an Overall Integrated Plan (Reference 8.1) documenting the diverse and flexible strategies (FLEX), in response to Reference 8.2. This Unit 2 Full Compliance Report provides an update of milestone accomplishments since submittal of the Eighth Six Month Status Repmi (Reference 8 .18) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

[NOTE: References cited in this enclosure are contained in Section 8.]

2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 8.1), and are cunent as of April30, 2017.
  • Completed the Unit 2 Severe Accident Capable Hardened Containment Vent System (Phase 1 Wetwell Vent) modification process and all associated actions to make the U2 HCVs fully functional on April4, 2017. This includes all required testing, procedure development and training. Unit 2 began statiup from the refueling outage on April 7, 2017.
3. Milestone Schedule Status The following table provides an update to Attachment 2, Milestone Schedule, of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the Order implementation date at this time. The Interim Staff Evaluation (IS E) from the NRC (Reference 8.9) was received in time to support implementation of the Mitigation Strategies. The Open Item and Confirmatory Items identified in the ISE were addressed by the Regulatory Audit Process. The NRC performed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Repmi documented the closure status of the Mitigation Strategies issues.

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Enclosure 1 to PLA-7610 Revised Target Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Repmi October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Expected receipt of draft SER September 2013 Complete January 2014 from NRC (or ISE)

Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Complete Update 7 August 2016 Complete Update 8 February 2017 Complete Update 9 August 2017 Not Stalied Update 10 February 2018 Not Stalied FLEX Strategy Evaluation April2015 Complete May 2015 Unit2 FLEX Strategy Evaluation April2016 Complete Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April2015 Complete May 2015 Demonstrations Unit 2 Walk-throughs or April2016 Complete Demonstrations Unit 1 Perform Staffing Analysis October 2014 Complete Modifications:

Modifications Evaluation June 2015 Complete August 2015 Unit 2 Design Engineering- June 2014 Complete Issue Unit 2 Design Change Documents (for all Phases)

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Enclosure 1 to PLA-7610 Revised Target Target Milestone Completion Activity Status Completion Date Date Unit 2 Implementation April2015 Complete May 2015 Outage Unit 1 Design Engineering - June 2015 Complete August 2015 Issue Unit 1 Design Change (except HCVS, Documents (for all Phases) see Ref. 8.11)

Unit 1 Implementation March 2016 Complete April2016 Outage Storage:

Storage Design Engineering May 2014 Complete Storage Implementation - April2015 Complete May 2015 Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site Equipment April2015 Complete May 2015 Contract with Vendor for March 2013 Complete National SAFER Response Center (NSRCs) established Develop Strategies with April2015 Complete Feb 2015 NSRC Establish offsite staging May 2015 Complete location [Install Off-Site Delivery Station (if Necessary)]

National SAFER Response December 2014 Complete Feb 2015 Centers in service for Susquehanna Procedures:

BWROG issue Emergency February 2013 Complete Procedure and Severe Accident Guidelines (EPGs/SAGs) Rev. 3 Page 3 oflO

Enclosure 1 to PLA-7610 Revised Target Target Milestone Completion Activity Status Completion Date Date Procedures Complete Unit 2 April2015 Complete May 2015 FLEX Implementation (including FSGs and maintenance)

Procedures Complete Unit 1 April2016 Complete FLEX Implementation (except HCVS, (including FSGs and see Ref. 8.11) maintenance)

Training:

Develop Training Plan May 2014 Complete February 2016 Complete April2016 Training Complete (except U1 HCVS, see Ref.

8.11)

Unit2 FLEX April2015 Complete May 2015, Implementation April2017 April2016 Complete Unit 1 FLEX Implementation (except HCVS, see Ref. 8. 11 )

April2016 Complete Full Site FLEX Implementation (except U1 HCVS, see Ref.

(except HCVS) 8.11)

Unit 2 Severe Accident April2017 Complete*

Capable Hardened Containment Vent System Phase 1 April2018 Design Started*(non-Unit 1 Severe Accident outage complete, Capable Hardened outage in-Containment Vent System progress),

Phase 1 Non- Outage Installation Statied Page 4 oflO

Enclosure 1 to PLA-7610 Revised Target Target Milestone Completion Activity Status Completion Date Date Unit 1 Severe Accident April2018 Design Statied *,

Capable Hardened Implementation Containment Vent System Not Statied Phase 2 Unit 2 Severe Accident April2019 Design Statied *,

Capable Hardened Implementation Containment Vent System Not Statied Phase 2 August 2019 Not Statied (after HCVS Submit Completion Repmi Order actions are complete per Ref 8.11)*

  • Revised since the six month update submitted Februm*y 9, 2017 (Reference 8 .18)

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Enclosure 1 to PLA-7610

4. Changes to Compliance Method NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

Reference 8.1 provided Susquehanna's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions.

The Reference 8.1 enclosure describes Susquehanna's Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification is required to install a Hardened Containment Vent System.

Thus the Susquehanna response to NRC Order EA-12-049 provided in Reference 8.1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Upon issuance of NRC Order EA-13-109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050.

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference 8.8. This relaxation was granted in Reference 8.11.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation Susquehanna expects to comply with NRC Order EA-12-049, but needs relaxation of the implementation dates. The specific details have been submitted in a separate document (Reference 8.8).

NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

Reference 8.1 provided Susquehanna's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will also affect implementation ofthe Mitigation Strategies NRC Order EA-12-049 actions.

The Reference 8.1 enclosure describes the Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

Thus Susquehanna's NRC Order EA-12-049 response provided in Reference 8.1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

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Enclosure 1 to PLA-7610 Upon issuance ofNRC Order EA-13-109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements ofthe NRC Order EA-12-050.

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved.

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 8.8). This relaxation was granted in Reference 8.11 .

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table and Section 7 provide a summary and status of the open items documented in the Overall Integrated Plan and ISE. The Open Item and Confirmatory Items identified in the ISE were addressed by the Regulatory Audit Process. The NRC perfmmed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Repmi documented the closure status of the Mitigation Strategies issues (Reference 8 .15).

Overall Integrated Plan Open Item Status

1. Phase 3 Shutdown Cooling Capability Complete
2. EOP changes required to support Mitigation Strategies. Complete
3. Develop SSES "Response Plan" for use ofthe National Complete SAFER Response Centers (NSRC).
4. FLEX Equipment Storage Complete
5. Review GEH Repmi NEDC 33771P, GEH Evaluation of Complete FLEX Implementation Guidelines and identify exceptions to the repmi as required in Attachment lB.
6. Determine appropriate use ofRCIC or FLEX pump Complete mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3.
7. Evaluate the impact ofRCIC pump seal failures . EC-050- Complete 1034, Rev. 0 approved 12/13/2013
8. Evaluate potential RCIC pump modifications. Complete
9. Establish method of venting the Refuel Floor. EC-012-6122, Complete Rev 0 approved on 4/29/2014.
10. Evaluate means to assure continued long term gas supply Complete for ADS/SRVs.

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Enclosure 1 to PLA-7610 Overall Integrated Plan Open Item Status

11. Evaluate means to transfer diesel fuel oil from storage tanks Complete to the diesel fueled equipment.
12. Evaluate the effects of injecting Spray Pond water (UHS) to Complete the RPV over a long period of time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or longer.
13. The calculation EC-030-1 006, Rev 14, Control Stmcture Complete Temperature Response to a Station Blackout or Fire Induced Loss of Control Stmcture HV AC was perfmmed.

However, final review and approval of the calculation EC-030-1006, Rev 14, have not been perfmmed. The calculation has now been reviewed and approved.

14. The calculation EC-SBOR-0504, Rev 6, Reactor Building Complete Heatup Analysis during Station Blackout was perfmmed.

However, final review and approval of the calculation EC-SBOR-0504, Rev 6 have not been perfmmed. Revision 7 of this calculation was approved on 3/20/2014. Appendix 0 was added to identify and evaluate mitigating measures that could be implemented to enhance Switchgear and Load Center Room cooling, as needed, for time > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

15. Fuel consumption and refuel intervals will be determined Complete during the procurement process for the 4160VAC generators.
  • Revised since the six month update submitted Febmary 9, 2017 (Reference 8.18)
7. Potential Draft Safety Evaluation Impacts None- Susquehanna received the ISE and closed the Open Item and Confirmatory Items via the audit process. The NRC perfmmed the Mitigation Strategies and Spent Fuel Pool Level Instmmentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies issues (Reference 8.15).

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Enclosure 1 to PLA-7610

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

8.1 PLA-6981, "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 (NRC Order EA-12-049)," dated February 28, 2013.

8.2 NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

8.3 NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, dated August, 2012.

8.4 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.

8.5 PLA-7072, "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2013.

8.6 NRC Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013.

8.7 PLA-7071, "First Six Month Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013.

8.8 PLA-7134, "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' dated February 20, 2014.

8.9 NRC Letter from J. S. Bowen toT. S. Rausch, "Susquehanna Steam Electric Station, Units 1 And 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January 24, 2014 (ADAMS# ML13339A764).

8.10 PLA-7137, "Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28,2014.

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Enclosure 1 to PLA-7610 8.11 NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 ' Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"' dated April15 , 2014 (ML14065A028).

8.12 PLA-7204, "Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 28, 2014.

8.13 PLA-7295, "Fomih Six-Month Status Repmi in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 25, 2015.

8.14 PLA-7377, "Fifth Six-Month Status Repmi in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2015.

8.15 NRC Letter from John D. Hughey toT. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 - Repmi for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April13 , 2015 (ML15089A123).

8.16 PLA-7438, "Sixth Six-Month Status Repmi in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 18, 2016.

8.17 PLA-7513, "Seventh Six-Month Status Repmi in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 19, 2016.

8.18 PLA-7570, "Eighth Six-Month Status Repmi in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 9, 2017.

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