RA-14-002, 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 (EA-12-049)

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 (EA-12-049)

ML14059A220
Person / Time
Site:	Oyster Creek
Issue date:	02/28/2014
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RA-14-002, RS-14-013
Download: ML14059A220 (17)

Text

1 Exelon Generation Order No. EA-12-049 RS-14-013 RA-14-002 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. NRC Order Number EA-12-049, " Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) , dated October 25, 2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) , dated February 28, 2013 (RS-13-023)

6. Exelon Generation Company, LLC 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 049), dated August 28, 2013 (RS-13-125)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2014 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in 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 the EGC initial status report regarding mitigation strategies. Reference 5 provided the Oyster Creek Nuclear Generating Station overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Oyster Creek Nuclear Generating Station. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1.

The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2014.

Respectfully submitted ,

David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Oyster Creek Nuclear Generating Station Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events

u.s. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Ms. Jessica A. Kratchman , NRR/JLD/PMB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig , NRR/DSS/SCVB, NRC Mr. Peter Bamford, NRR/DPR/MSD/MSPB, NRC Manager, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Enclosure Oyster Creek Nuclear Generating Station Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (13 pages)

Enclosure Oyster Creek Nuclear Generating Second Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Oyster Creek Nuclear Generating Station developed an Overall Integrated Plan (Reference 1 in Section

8) , documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief / relaxation and the basis, if any.

2 Milestone Accomplishments None 3 Milestone Schedule Status The following provides an update to Attachment 2 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.

Milestone Schedule Target Revised Target Activity Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Contract with RRC Complete Submit 6 Month Updates:

Update 1 August 2013 Complete Complete with Update 2 February 2014 this submittal Update 3 August 2014 Not Started Update 4 February 2015 Not Struted Update 5 August 2015 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started Page 1 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Target Revised Target Activity Completion Activity Status Completion Date Date Submit Completion Report October 2016 Not Started Modification Development &

Implementation:

Modification Development (All FLEX August 20 15 Not Started August 2016 Phases)

Modification Implementation (All FLEX October 2016 ot Started Phases)

Procedures:

Create Site-Specific Procedures October 2016 Started Validate Procedures (NEI 12-06, Sect.

October 2016 Not Started 11.4.3)

Create Maintenance Procedures October 2016 Started Perform Staffing Analysis June 2016 Not Started Storage Plan and Construction October 2016 Not Started FLEX Equipment Acquisition October 2016 Started Training Completion October 2016 ot Started Regional Response Center Operational December 2015 Started December 2014 Unit 1 FLEX Implementation October 2016 ot Started Full Site FLEX Implementation October 2016 Not Started Page 2 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28, 2014 4 Changes to Compliance Method The following changes / clarifications were made to the Overall Integrated Plan (OIP) and conceptual drawings (Attachment 1) supporting the Overall Integrated Plan compliance method as documented in the last status report. (Reference 1 and Reference 4).

1. Updated conceptual drawing set to clarify and correct submitted OIP drawings.

Added conceptual drawings for Containment Spray System 2 connection from the FLEX manifold.

Added the drawing for Fuel Oil transfer connections from the protected / credited Fuel Oil tank.

Note:

Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies.

Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the Overall Integrated Plan for Oyster Creek during a scheduled six month update. This update will include any changes to the initial designs as submitted in the February 28 , 2013 Overall Integrated Plan.

(Attachment 1, Drawing set)

2. Page 19 of 64 of Oyster Creek OIP Maintain Core Cooling BWR Portable Equipment Phase 2:

Add Reference to MAAP 6 OC_FLEX_CASE6.INP, ]/30/2013 Explanation of change: In Phase II after declaration of Extended Loss of AC power (ELAP) the cool down rate transitions from lOaF per hour to 50°F per hour as indicated in the OIP timeline Page 57 of 64 . The supporting MAAP run was not referenced.

Page 3 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28, 2014

3. Change description of Page 29 of 64 of Oyster Creek OIP Maintain Containment BWR Portable Equipment Phase 2 Oyster Creek will utilize pOltable equipment to provide shell-side makeup to the Isolation Condenser. Utilization of the Isolation Condenser as the RPV Pressure Control Mechanism will eliminate the need for EMRV operation and the subsequent heat addition to the containment.

During Phase 2 Isolation Condenser makeup will be provided by the FLEX pump taking suction from the URS (Intake or Discharge canal) . The pump has the capacity to make up to the Reactor and the Isolation Condenser shells. Connections can also be made from the FLEX manifold (Reactor Building 23 ' NOlth) to Containment Spray System 2 at a two inch piping connection.

The new seismic connections are in the conceptual design phase and will be located inside the Reactor Bujlding North side. This central location will provide connections for the Reactor, Isolation Condenser shell , Containment Spray, and Spent Fuel Pool makeup. The FLEX pump will take suction from the Intake or Discharge canal and hoses will be run to the new connections.

Page 32 of 64 of Oyster Creek OIP Added descliption of connection to Containment Spray System 2 Modifications Connections will be added to Core Spray system 1 fire water to Core Spray piping, Isolation Condenser common drain, and Containment Spray System 2 Drywell spray header piping.

Electlical connections for the 480VAC USS's will also be made. Connections will be located at a central location at the North side of the Reactor Building. All connections will be accessible from the NW or NE airlocks.

Page 4 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28, 2014

4. Change description of Page 38 of 64 of Oyster Creek OIP Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 2:

The FLEX diesel driven portable pump will be positioned near the intake structure and the discharge hose will be run to a pipe manifold on Reactor Building 23' NOlth. This manifold will then feed an installed piping riser from Reactor Building 23' to the Reactor Building 95' elevation. The piping riser will terminate at Reactor Building 95' North wall and will have installed valves with hose connections. The piping riser end, located on the Reactor Building 95' North wall, will then be used to make-up to the following using hoses:

• Spent Fuel Pool (SFP) B.5.b diffuser feed connection.

• Spent Fuel Pool 250 gpm spray.

• Isolation Condenser makeup.

On the Reactor Building 95' elevation a hose will run down the North West stair well to the existing B.5.b fuel pool connection. The spent fuel pool B.5.b connection feeds the spent fuel pool diffuser header that supplies water to the fuel pool. At approximately T=12 hours (see spent fuel pool timeline in Phase 1), the FLEX pump will be started, the spent fuel pool make-up piping pressUlized, and make-up flow established via the spent fuel pool make-up connection on the 95' piping riser.

The 250 gpm spray flow will be provided by a FLEX pump taking suction from the intake or discharge structure and supply water to the manifold installed on Reactor Building 23' NOlth.

The manifold will then supply water to the fuel pool and Isolation Condenser makeup riser (Reactor Building 23' NOlth) that terminates on the Reactor Building 95' North elevation. A hose will be lowered from the Reactor Building 119' South East equipment hatch to connect with an oscillating spray nozzle to spray over the Spent Fuel Pool. This approach is modeled after CUITent B.5.b procedures and approaches the fuel pool from the farthest point possible on the 119' elevation. This approach also considers the CUlTent plant procedures for bridge "parking" when the refueling bridge is not in use and the affects of the refueling bridge's location on fuel pool spray patterns.

Evaluation of the Spent Fuel Pool area for steam and condensation has not yet been performed.

The results of this evaluation and the vent path strategy, if needed, will be provided in a future six (6) month update.

5 Need for RelieflRelaxation and Basis for the Relief/Relaxation Oyster Creek expects to comply with the order implementation date and no relief/relaxation is required at this time.

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Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28, 2014 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Section Reference Overall Integrated Plan Open Item Status Sequence of events The times to complete actions in the Events Timeline are based on Not Started (p. 10-12) operating judgment, conceptual designs , and CUlTent supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures developed.

Sequence of events Initial evaluations were used to determine the fuel pool timelines. Not Started (p.11-12) Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.

Identify how Transportation routes will be developed from the equipment Not Started strategies will be storage area to the FLEX staging areas. An administrative deployed in all program will be developed to ensure pathways remain clear or modes (p. 13) compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation.

Identification of storage areas and creation of the administrative program are open items.

Identify how the An administrative program for FLEX to establish responsibilities, Started programmatic and testing & maintenance requirements will be implemented.

controls will be met (p. 14)

Maintain Spent Fuel Complete an evaluation of the spent fuel pool area for steam and Not Started Pool Cooling (p.36) condensation.

Safety Functions Evaluate the habitability conditions for the Main Control Room Started Support (p. 44) and develop a strategy to maintain habitability.

Safety Functions Develop a procedure to prop open battery room doors upon Started Support (p. 44) energizing the battery chargers to prevent a buildup of hydrogen in the battery rooms.

Sequence of events Issuance of BWROG document NEDC-33771P, "GEH Evaluation Completed.

(p. 10) of FLEX Implementation Guidelines" on 01131/2013 did not allow sufficient time to perform the analysis of the deviations between Exelon 's engineering analyses and the analyses contained in the BWROG document prior to commencing regulatory reviews of the Integrated Plan. This analysis is expected to be completed, documented on Attachment 1B, and provided to the NRC in the August 2013 six month status update.

Page 6 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28 , 2014 Section Reference Overall Integrated Plan Open Item Status Baseline coping In response to NRC Order EA-12-049 and implementation of EPG Not Started capability (p. 27) Rev 3, containment venting will be part of the strategies. As part of the B.S.b response Oyster Creek incorporated Extensive Damage Mitigation Guidelines and developed procedure EDMG-SPX9 Manually Opening Containment Vent Valves in a B.S.b Event. This procedure is designed to allow operation of the Hardened Vents with no air supply, AC or DC power available.

Convert, EDMG-SPX9 Manually Opening Containment Vent Valves to FSG procedure.

Draft Safety Evaluation / Audit Questions Open Item Status 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. Oyster Creek Nuclear Generating Station's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) ," dated February 28, 2013.

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

3. NEI 12-06, Rev. 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 20] 2.

4. Oyster Creek Nuclear Generating Station's, First Six Month Status Report for the Implementation of FLEX dated August 28 , 2013.

9 Attachments . Updated Conceptual Design Drawings Page 7 of 13

Oyster Creek Nuclear Generating Station Second Six Month Status Report for the Implementation of FLEX February 28 , 2014 Attachment 1.

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