RA-16-065, Seventh 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 No. EA-12-049)

Seventh 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 No. EA-12-049)

ML16239A034
Person / Time
Site:	Oyster Creek
Issue date:	08/26/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RA-16-065, RS-16-148
Download: ML16239A034 (22)

Text

Exelon Generation Order No. EA-12-049 RS-16-148 RA-16-065 August 26, 2016 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:

Seventh 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)

7. Exelon Generation Company, LLC 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 049), dated February 28, 2014 (RS-14-013)

8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2014 (RS-14-211)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 26, 2016 Page2

9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 27, 2015 (RS-15-022)

10. Exelon Generation Company, LLC Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2015 (RS-15-213)

11. Exelon Generation Company, LLC Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 26, 2016 (RS-16-025)

12. NRC letter to Exelon Generation Company, LLC, Oyster Creek Nuclear Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0824), dated February 19, 2014 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. References 6, 7, 8, 9, 10, and 11 provided the first, second, third, fourth, fifth, and sixth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Oyster Creek Nuclear Generating Station. The purpose of this letter is to provide the seventh 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. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 12.

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 26, 2016 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25th day of August 2016.

Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Oyster Creek Nuclear Generating Station Seventh 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 cc: NRC Regional Administrator - Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station .

NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Mr. John D. Hughey, NRR/JLD/JOMB, 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 Seventh 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 (18 pages)

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 Enclosure Oyster Creek Nuclear Generating Seventh 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),

documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (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 I relaxation and the basis, if any.

2. Milestone Accomplishments

a. Modification development is complete.

b. National SAFER Response Center procedures are implemented.

c. The following milestone schedule status below has been completed since the development of the sixth six-month status report (Reference 15), and is current as of August 1, 2016.

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 T~rget Completion Revised Target Activity Activity Status Date Completion 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 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 1of18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 Target Completion Revised Target Activity Activity Status Date Completion Date Complete with this Update 7 August 2016 submittal Submit Completion Report October 2016 Started No Change Target Completion Revised Target Activity Activity Status Date Completion Date Modification Development .

Modification Development Revised in August August 2016 Complete (All FLEX Phases) 2013 update Modification Implementation October 2016 Started No Change (All FLEX Phases)

Procedures:

Create Site-Specific Procedures October 2016 Started No Change Validate Procedures October 2016 Started No Change (NEI 12-06, Sect. 11.4.3)

Create Maintenance October 2016 Started No Change Procedures Perform Staffing Analysis June 2016 Complete No Change Storage Plan and Construction October 2016 Started No Change FLEX Equipment Acquisition October 2016 Started No Change Training Completion October 2016 Started No Change National SAFER Response Revised in August December 2015 Complete Center 2014 update Full Site FLEX Implementation October 2016 Started No Change Changes to Compliance Method Note: No changes to the compliance method were identified in this update. Changes 1 through 4 listed below were previously identified in the sixth six-month update. Change 5 listed below is not a change to the compliance method, rather it is a verification for the correction of the direction of flow of the Isolation Condenser Check Valves for the Overall Integrated Plan (OIP) conceptual drawings to reflect present design. ECR OC-14-00025 has corrected the direction of 2of18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 flow for Isolation Condenser Check Valves V-14-33 and V-14-35 from the OIP conceptual drawings (page 63 of 64).

Change 1:

General Integrated Plan Elements BWR - Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint. - Item 3; Control Room crew has assessed SBO and plant conditions and declares an Extended Loss of AC Power (ELAP) event.

Reason for Change:

• A review of the timeline and procedure actions has determined the declaration of an ELAP event does not have to occur until 60 minutes into the event. Actions from the SBO procedure will be sufficient to guide the crew actions and deployment of equipment.

Change 2:

General Integrated Plan Elements BWR - Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint. - Items 8 and 15; Continue to maintain critical functions of core cooling (via IC and FLEX Pump injection), containment (via Isolation Condensers) and SFP cooling (FLEX pump injection to SFP).

Reason for Change:

• The MAAP analysis (Reference 7) used to predict the peak containment parameters and establish the timing for possible containment venting has been revised. The revised MAAP does not indicate the need for containment venting. Revision 1 adds one (1) additional MAAP case that alters the time of external RPV injection and adjusts isolation condenser operation strategy to prevent collapsed water level in the RPV shroud from dropping below TAF.

o An assumption in the MAAP is the containment vent is opened when RPV level reaches TAF or to stay below the 35 psig containment design pressure as specified in each scenario. Each scenario was reviewed and Cases 5 through 7 require no containment venting. Case 7 will be used to establish the timeline for this event.

Change 3:

General Integrated Plan Elements BWR - Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint. - Item 12; Commence injecting into the reactor using the FLEX pump and restore level to the normal band.

Reason for Change:

• The MAAP analysis (Reference 7) used to predict the peak containment parameters and establish the timing for possible containment venting has been revised. The revised MAAP does not indicate the need for containment venting. Revision 1 adds one (1) additional MAAP case that alters the time of external RPV injection and adjusts isolation condenser operation strategy to prevent collapsed water level in the RPV shroud from dropping below TAF.

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Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 o An assumption in the MAAP analysis (Reference 7, Case 7) is the FLEX pump injection into the RPV is at 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (100 gpm at 160 psig). Prior Case 6 resulted in the collapsed water level in the RPV shroud dropping below TAF for a short period of time. This was the result of RPV water inventory contraction due to the simultaneous operation of both ICs at t=3.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Case 7 provides a strategy that prevents collapsed shroud level from dropping below TAF by initiating external RPV injection earlier {3.3. hours versus 3.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for Case 6) and delay of simultaneous IC operation until the normal RPV water level recovers sometime after 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Change 4:

The following changes were made to the Overall Integrated Plan {OIP) conceptual drawings submitted in the Second Six-Month Status Report (Reference 4) to reflect present design:

• Addition of Core Spray System 2 for core injection for improved control of Reactor water level per ECR OC-14-00025.

• Removal of Feedwater (FW) System for core injection due to inability of available flow to open the FW Check valves and due to high flow rates causing difficulty in managing Reactor water level per ECR-OC-14-00025.

• Removal of Containment Spray System for injection due to the flow path delivering flow rates that are not high enough to fill the spray headers per ECR-OC-14-00025.

Change 5:

The following changes were made to the Overall Integrated Plan (OIP) conceptual drawings to reflect present design:

• ECR OC-14-00025 has corrected the direction of flow for Isolation Condenser Check Valves V-14-33 and V-14-35 from the OIP conceptual drawings (page 63 of 64).

4. Need for Relief/Relaxation and Basis for the Relief/Relaxation None

5. Open Items and Confirmatory items from Overall Integrated Plan and Interim Safety Evaluation The following tables provide a summary of the open and Confirmatory 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 Items Status Sequence of The times to complete actions in the Started:

events Events Timeline are based on operating judgment, conceptual designs, and (p. 10-12) current supporting analyses. The final Detailed designs are completed, and timeline will be time validated once procedures have been developed.

Present plans are to start the time 4of18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 detailed designs are completed and validation process the second week of procedures developed. August 2016.

Sequence of Initial evaluations were used to Complete:

events determine the fuel pool timelines.

Formal calculations will be performed NRC OCGS On-Site FLEX Audit on May 2, (p. 11-12) to validate this information during 2016 closed this item as described development of the spent fuel pool below:

cooling strategy detailed design.

UFSAR Section 9.1.3.2.3 (Reference 19) contains the information regarding the SFP heat load and boil off rates.

It takes "'14.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to reach bulk boiling with an initial water temperature of 90F and a maximum augmented heat load of 20.0MBTU/hr. The boil-off rate is 41.2 gpm which is less than the amount that the OCGS can provide, per its hydraulic Analysis for FLEX Implementation Calculation No. C-1302-917-E310-002,

>250 gpm to the SFP (Reference 18).

Identify how 1. Transportation routes will be Started:

strategies will be developed from the equipment deployed in all storage area to the FLEX staging NRC OCGS On-Site FLEX Audit on May 2, modes (p. 13) areas. 2016 closed this item as described

2. Identification of storage areas is an below:

open item.

3. An administrative program will be 1. Complete:

developed to ensure pathways Four transportation routes have remain clear. Compensatory been defined from two FLEX storage actions will be implemented to pad locations inside the Protected ensure all strategies can be Area. Two transportation routes deployed during all modes of have been defined from each operation. storage pad location due to the 360 degree deployment capability.

Transportation routes have been defined in FSG-05 (FLEX Support Guide: Debris Removal and FLEX Equipment Deployment).

2. Complete:

Two storage pads locations have been identified within the protected area: 1) SE location, and 2) NW location. Identification of storage 5 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 areas have been defined in FSG-05 (Debris Removal and FLEX Equipment Deployment).

3. Started:

Action Tracking item is assigned to Ops Support to complete in August 2016.

Identify how the An administrative program for FLEX to Started:

programmatic establish responsibilities, and testing controls will be and maintenance requirements will be NRC OCGS On-Site FLEX Audit on May 2, met (p. 14) implemented. 2016 closed this item as described below:

OCNS FLEX equipment will be tested to ensure it performs its functions prior to accepting the equipment. After acceptance testing, the equipment will be maintained and tested per PMs created using Exelon PM program templates. Exelon's PM program templates were created based on EPRI template recommendations and vendor recommendations.

Shelf life of spare parts will be handled by the preventive maintenance program as laid out in the FLEX Program Document. ATI #01672697-50 was issued to update the Program Document with the required replacement timeframe prior to shelf life expiration -

ATI to complete by FLEX System Manager - September 2016.

Evaluation is assigned to FLEX Program Manager to complete OC Program CC-OC-118: Evaluation to complete September 2016.

Maintain Spent Complete an evaluation of the spent Started:

Fuel Pool Cooling fuel pool area for steam and (p. 36) condensation. NRC OCGS On-Site FLEX Audit on May 2, 2016 closed this item as described below:

The OCGS strategy is to run hoses and perform any actions for SFP makeup 6of18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 prior to the boiling of the SFP. These actions are to be performed prior to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the onset of the event.

OCGS plans to create a vent pathway for the steam/condensate from the boiling of the SFP {119' elevation). The flow path includes the hatch on the 119' elevation which is open to the 23' elevation. On the 23' elevation, doors will be propped open (to atmosphere).

On the roof of the 119' elevation, there is a roof hatch door (to the atmosphere) that will be opened, which will create the chimney effect.

Evaluation assigned to FLEX Mechanical LRE to complete by 8/15/16.

Safety Functions Evaluate the habitability conditions for Started:

Support (p. 44) the Main Control Room and develop a strategy to maintain habitability. NRC OCGS On-Site FLEX Audit on May 2, 2016 closed this item as described below:

A GOTHIC calculation to evaluate the heat-up rate for the Main Control Room is being performed by Enercon, EOC (Engineer of Choice). Action Tracking item assigned to the FLEX Mechanical LRE to complete the Evaluation in August 2016.

Safety Functions Develop a procedure to prop open Complete:

Support (p. 44) battery room doors upon energizing FSG-04 (DC Load Shed) has been the battery chargers to prevent a developed. Section 4.0 of the procedure buildup of hydrogen in the battery addresses blocking open of battery room rooms.

door and ventilating the battery room to prevent H2 buildup.

Sequence of Issuance of BWROG document NEDC- Complete:

events (p. 10) 33771P, "GEH Evaluation of FLEX Implementation Guidelines" on 01/31/2013 did not allow sufficient Reference 3 time to perform the analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document 7 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 prior to commencing regulatory reviews of the Integrated Plan.

Baseline coping In response to NRC Order EA-12-049 Complete:

capability (p. 27) and implementation of EPG Rev 3, containment venting is not required for NRC OCGS On-Site FLEX Audit on May 2, FLEX. Modifications and capabilities of 2016 closed this item as described the Hardened Vent System will be in below:

accordance with OC extension request for EA-13-109.

This is not a current FLEX implementation issue. The revised MAAP evaluation indicates that containment venting is not required to maintain containment pressure within acceptable limits.

NRC letter (Docket No. 50-219) issued November 16, 2015 approved the Oyster Creek HCVS Order Phase 1 implementation schedule relief request. The Phase 1 schedule is relaxed until January 31, 2020, at which time Exelon will submit a request for relief from the HCVS Order based on the permanent shutdown condition of the plant. (Reference 19)

Reference 10: Oyster Creek Request for Extension to Comply with NRC Order EA-13-109 (06-02-14, RS-14-081)

Reference 11: Oyster Creek Vent Order Extension Request RAI Response (09 14, RS-14-243)

Reference 12: Oyster Creek Vent Order Extension Request Supplemental RAI Response (11-25-14, RS-14-318)

Section Reference Interim Safety Evaluation Open Items Status None None N/A 8 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 Section Interim Safety Evaluation Confirmatory Items Reference Status 3.1.1.3.A Confirm that the licensee develops a Complete:

reference source describing what actions should be taken if instruments were lost FSG-20 (Alternate Instrumentation Reading) due to a seismic event. has been developed to describe what actions should be taken to obtain alternate instrument readings upon a Beyond Design Basis External Event/Extended Loss of AC Power/Seismic Event.

3.1.1.4.A Confirm the location of the off-site staging Complete:

area(s) and acceptability of the access routes considering the seismic, flooding, NRC OCGS On-Site FLEX Audit on May 2, high wind and snow, ice and extreme cold 2016 closed this item as described below:

hazard.

-Helicopter provider information in SAFER Response Plan for OCGS, Rev.001; Appendix 4E.

-"B" Staging Area described in SAFER Response Plan, Rev. 001; Appendix SE.

CC-OC-118-1003, Rev. 3, "Special Congested Area Plan - Oyster Creek Nuclear Generating Station," dated 10/9/2015, shows the travel path from the staging area, Ocean County Airport, to the OCNGS station. SAFER equipment will be moved via ground transport to staging area B (area just east of the QC site). If transportation via ground transport is not feasible, transportation using helicopters is available. Staging area B is in an open area with no surrounding structures or objects that would interfere with movement of equipment to staging area A (FLEX equipment final destination) considering seismic, flooding, high wind, snow, ice and extreme cold conditions.

Deployment/debris removal equipment will be available at the 24-hour time frame to transport equipment the short distance into the PA.

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Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 3.1.2.2.A Confirm that if temporary flood barriers Complete:

are used, they are stored such that they can be easily deployed. Reference 6 3.1.3.1.A Verify that the separation of the planned Complete:

outdoor storage areas is sufficient to preclude damage of both sets of FLEX NRC OCGS On-Site FLEX Audit on May 2, equipment. 2016 closed this item as described below:

There are two storage pads (northwest and southeast pads).

There is a straight line distance of 1200 feet between the two pads.

The FLEX Protection Matrix provides documentation of the Oyster Creek Strategies for equipment storage for each BDBEE including basis for each strategy.

OCGS assessed the historical tornado data from 1950 to 2013 from NOAA National Weather Service. Based on the data the widest tornado path was 750 feet. The overall direction of travel based on the NOAA data has been from the West-Southwest.

OCGS assessment indicated that the axis of separation based on predominant tornado path between the two storage pads is 1050 feet.

OCGS completed an assessment in ECR-OC-14-00027, Outdoor Storage Structures for the Portable FLEX equipment to determine that the FLEX equipment and the concrete blocks used to restrain the FLEX equipment and sea vans is sufficient to prevent seismic interaction at SSE level earthquake for sliding, overturning, and to resist sliding/overturning during a tornado event.

3.1.3.1.B Confirm qualified storage locations for the Started:

hurricane and extreme snow and icing hazards are identified. NRC OCGS On-Site FLEX Audit on May 2, 2016 closed this item as described below:

The Protection Matrix, Section 8.3.1, states 10 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 that the FLEX equipment will be relocated to the Turbine Building and the N+l set located in another truck bay. Action Tracking item has been created to revise OP-OC-108-109-1001, Severe Weather Preparation, to move the equipment as required - completion due date is in August 2016.

3.1.3.2.A Confirm that the licensee's evaluation of Complete:

water quality and resulting action are sufficient to preclude blockage of flow to NRC OCGS On-Site FLEX Audit on May 2, the core or SFP. 2016 closed this item as described below:

Primary suction source:

Chemistry Sample port that is connected to the Discharge Tunnel.

Alternate suction source:

Inside the Intake Structure below the deck plates that are located after the trash racks and traveling screens. Some filtering and debris will be trapped by existing plant equipment.

Barnegat Bay- or any open body of water.

A barrel strainer will be installed at the end of that suction hose and will be submerged several feet below the water surface level.

Furthermore, having the suction several feet below the water surface level will prevent wind/flood debris that will typically be floating from clogging the strainer.

Regardless of FLEX pump location - suction strainers are installed on the suction hose to provide additional filtering - an OC evaluation was completed satisfactorily in assessing the required reactor flow rates using the present FLEX strainer design.

3.2.1.1.A Confirm that benchmarks are identified Complete and discussed that demonstrate the MAAP is an appropriate code for the simulation of an ELAP event at your facility. Reference 6 3.2.1.1.B Confirm that the collapsed level remains Complete above Top of Active Fuel (TAF) and the 11 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 cool down rate remains within technical specifications limits.

Reference 6 3.2.1.1.C Confirm that MAAP is used in accordance Complete with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.

Reference 6 3.2.1.1.D Confirm that the licensee identifies and Complete justifies the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP Application Guidance, Reference 6 Desktop Reference for Using MAAP Software, Revisions 2" (Electric Power Research Institute Report 1020236). This should include response at a plant-specific level regarding specific modeling options and parameter choices for key models that would be expected to substantially affect the ELAP analysis performed for that licensee's plant. Although some suggested key phenomena are identified below, other parameters considered important in the simulation of the ELAP event by the vendor/ licensee should also be included.

a. Nodalization

b. General two-phase flow modeling

c. Modeling of heat transfer and losses

d. Choked flow

e. Vent line pressure losses

f. Decay heat (fission products I actinides I etc.)

3.2.1.1.E Confirm that the specific MAAP analysis Complete case that was used to validate the timing of mitigating strategies in the Integrated Plan is identified and available on the Reference 6 ePortal for NRC staff to view. Alternately, a comparable level of information may be included in the supplemental response. In either case, the analysis should include a plot of the collapsed vessel level to confirm that TAF is not reached (the elevation of the TAF should be provided) and a plot of the temperature cool down 12 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 to confirm that the cool down is within technical specifications limits.

3.2.1.3.A The SOE final timeline will be time Not Started:

validated once detailed designs are Detailed designs have been completed.

completed and procedures are developed.

Procedure FSG drafts will be completed in The licensee should provide the results for August 2016. SOE final timeline validation NRC staff review. will commence post FSG completion.

Expected date to perform timeline validation is August 2016.

3.2.4.2.A The licensee stated that battery room Started:

ventilation to address high/low temperatures and prevention of hydrogen NRC OCGS On-Site FLEX Audit on May 2, buildup will be addressed through 2016 closed this item as described below:

procedure changes and that the proposed methods of ventilation, open doors and Battery Rooms Locations:

fans, will be confirmed during the detailed Battery A/B: 35' elevation design process. Battery C: 23' elevation For High/Low temperatures - Open:

Action Tracking items have been created and are tracking completion of GOTHIC calculations for the A, B, and C Battery Rooms - due date August 2016.

For Hydrogen Buildup - Open:

FSG-04, Rev. Draft: DC Load Shed Step 4.0 - provide ventilation and opening of doors for A/B battery room.

FSG-12: Restoration of Plant Loads with the FLEX Generator - Restores C Battery Room ventilation.

Time to reach 1% H2 in the Battery Rooms:

Cale No. - C-1302-735-E320-050, Rev. 0:

Oyster Creek Batteries A, B, and C Hydrogen Calculation:

Battery Room A/B - reach 1% Hydrogen without ventilation:

77°F - 218.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 100°F - 87.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Battery Room C - reach 1% Hydrogen without ventilation:

77°F - 78.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 100°F - 31.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 13 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 3.2.4.4.A The NRC staff has reviewed the licensee Started:

communications assessment (ADAMS Accession Nos. ML12306A199 and NRC OCGS On-Site FLEX Audit on May 2, ML13056A135) in response to the March 2016 closed this item as described below:

12, 2012 50.54(f) request for information letter for OCNGS and, as documented in OCNGS will not be making any the staff analysis (ADAMS Accession No. modifications to the communications ML13114A067) has determined that the systems. Satellite phones have been assessment for communications is purchased for offsite communications. On reasonable, and the analyzed existing site, the sound powered phones will be systems, proposed enhancements, and staged in appropriate locations and the interim measures will help to ensure that radio repeater located in the Upper Cable communications are maintained. Spreading Room will be powered from a Verification of required upgrades has been generator located on or near the Heater identified as a confirmatory item. Bay roof.

Action Tracking item has been created to track completion of the following:

"FSG for Communications Plan Cl 3.2.4.4.A.

- Confirm that communication enhancements credited in the NRC's communication assessment (ADAMS Accession No. ML13114A067) are completed as planned. Note: ML1206A199 Att. 7 and ML13114A067 Enc 7 for additional information."

Due date for completion of the FSG is 9/14/16.

3.2.4.8.A Confirm the procedures to isolate the vital Complete USS's from the generator.

FSG-07: Line Up of USS 1A2/1B2 for Re-Powering from FLEX Generator has been developed.

3.2.4.8.A Ensure that the diesel generator is Complete - Reference 8 - Fleet FLEX equipped with overload protection in the Generator Specification No. FUKGEN-001 generator skid. Rev. 2; Reference 9 - Exelon Fukushima FLEX 500 KW Portable Generator Submittal Rev. 0.

The diesel generator is equipped with overload protection. Per Oyster Creek Technical Evaluation, circuit breakers on the Diesel Generators are 3 Phase, 600V, 14 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 800A Molded Case Circuit Breakers. The 3.0A Micrologic Trip Unit's Long Time Pick-up is set to 1 for a current sensor rating of 800A.

3.2.4.8.B Confirm/review technical basis and/or Complete:

calculations provided as basis for the generator sizing.

Reference 13 3.2.4.10.A Confirm completion of analysis to Complete:

determine battery coping time with no actions and with battery load shed. NRC OCGS On-Site FLEX Audit on May 2, 2016 closed this item as described below:

Nexus Report 12-4159.0CGS, Rev. 0: Exelon Corporation Oyster Creek Generating Station (OCGS) Battery Coping Evaluation Report (Reference 20) has evaluated the following:

Battery Coping:

Battery B - 5.85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> (w/o DC load shed),

18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> (w/ DC load shed)

Battery C - 14.28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> (w/o DC load shed),

25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> (w/ DC load shed)

Battery (BOP) A - 7.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (w/o DC load shed), 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> (w/ DC load shed)

Note: Vital Battery B and Care used for FLEX Battery Information:

Battery B-AT&T Round Cell KS 20472L, 1062 ampere-hours (AH) at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> rate to 1.83V, 60 Cells Battery C- GNB: NCN- 17, 1176 ampere-hours (AH) at the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> rate to 1.83V, 60 Cells Battery A - AT&T Round Cell KS 20472L, 1062 ampere-hours (AH) at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> rate to 1.83V, 60 Cells Minimum DC voltage 109.8 VDC Minimum Battery Room Temperature Battery B - battery is inoperable if battery drops to less than 60°F Battery C - battery is inoperable if battery drops to less than S0°F 3.4.A NEI 12-06, Section 12.2 lists minimum Complete:

capabilities for offsite resources for which Oyster Creek has executed contractual 15 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016 each Licensee should establish the agreements with Pooled Equipment availability. Confirm implementation of Inventory Company (PEICo) which allows Guidelines 2 through 10 in NEI 12-06, for the capabilities (considerations) in Section 12.2. Section 12.2 of NEI 12-06. National SAFER Response Center, NSRC, submitted a paper to the NRC detailing the capability and ability to meet all of NEI 12-06 Section 12.2 considerations (ML1425A223).

6. Potential Draft Safety Evaluation Impacts Note: No additional Potential Draft Safety Evaluation Impacts were identified in this update. The Potential Draft Safety Evaluation Impact stated below was previously identified in the fifth six month update.

ECR (Engineering Change Request) QC 14-00025 update to the Oyster Creek Interim Staff Response (Reference ML14030AS13) related to the OIP for makeup to the Reactor Vessel and Recirculation Pump's seal leakage states the following:

"Make up to the Reactor Vessel is commenced 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (based on the revised MAAP run, Reference 5 to ECR OC 14-0002S) from the start of the event. The flow rate credited by the MAAP is 100 gpm. It is postulated that this flow rate will be delivered, at the same time as the makeup to the Isolation Condensers (IC). This is a reasonable maximum requirement as the Isolation Condenser makeup will be cycled on and off as needed and RPV makeup will be slowed considerably when Reactor Level is brought back into its normal band.

Once re-established, the amount of makeup is to account for inventory loss. A maximum make up flow of SO gpm to the Reactor Pressure Vessel is required to keep the core covered. This is derived from a 5 gpm leak rate from each of the five Reactor Recirculation Pumps' seals when the pumps stop because of the Extended Loss of AC Power (ELAP) that is postulated. (S pumps XS gpm = 2S gpm total).

The leakage rate is derived from Atomic Energy Canada Limited (AECL) reports ET-S-331, Testing of the CAN2A Seal Cartridge under Station Blackout Conditions, and ET-5-426, Testing of the CAN2A Seal Cartridge under Station Blackout Conditions - Phase 2 (References 2.9 and 2.9A to ECR QC 14-0002S).

Note that the AECL reports were done for Nine Mile Point. The Recirculation Pumps at Oyster Creek use the same AECL seals. Attachment 12 to ECR OC 14-0002S provides data that the Nine Mile Point Unit 1 seals use the same design as Oyster Creek.

Tech Spec 3.3.D, allows a 5 gpm Unidentified Leakage limit and a 2S gpm Total (Identified +

Unidentified) leakage limit. Therefore, the normal allowable leak rate is added to the 2S gpm and the makeup rate is SO gpm. Furthermore, four of the five Reactor Recirculation pumps will be isolated (per the time line in the OIP) at three hours. Therefore, actual lost inventory at three hours postulating maximum Tech Spec allowable leakage is 30 gpm."

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Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016

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

1. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, 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)

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. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, 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 EA-12-049), dated August 28, 2013 (RS-13-125)

4. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, 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 EA-12-049), dated February 28, 2014 (RS-14-013)

5. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated August 28, 2014 (RS-14-211)

6. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, Fourth 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 EA-12-049), dated February 27, 2015 (RS-15-022)

7. MAAP Analysis Oyster Creek Generating Station Document Number OC-MISC-010

8. Fleet FLEX Generator Specification No. FUKGEN-001 Rev. 2

9. Exelon Fukushima FLEX 500KW Portable Generator Submittal Rev. O

10. Oyster Creek Request for Extension to Comply with NRC Order EA-13-109, dated June 2, 2014 (RS-14-081)

11. Oyster Creek Vent Order Extension Request RAI Response, dated September 26, 2014 (RS-14-243)

12. Oyster Creek Vent Order Extension Request Supplemental RAI Response, dated November 25, 2014 (RS-14-318)

13. Oyster Creek AR 2386806 EOl, Fukushima FLEX Electrical Mitigation Strategy Technical Evaluation 17 of 18

Oyster Creek Nuclear Generating Station Seventh Six Month Status Report for the Implementation of FLEX August 2016

14. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated August 28, 2015 (RS-15-213)

15. Exelon Generation Company, LLC letter to NRC, Oyster Creek Nuclear Generating Station, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated February 26, 2016 (RS-16-025)

16. OCGS UFSAR (Oyster Creek Generating Station Updated Final Safety Analysis Report)

17. SAFER Response Plan for OCGS Rev. 001

18. Cale No. - C-1302-917-E310-002, Hydraulic Analysis for FLEX Implementation

19. 2015-11-16: NRC relaxation of Oyster Creek wetwell vents ML15092A159

20. Nexus Report 12-4159. OCGS, Rev. 0: Exelon Corporation Oyster Creek Generating Station (OCGS)

Battery Coping Evaluation Report

21. Cale No. - C-1302-735-E320-050, Rev. 0: Oyster Creek Batteries A, B, and C Hydrogen Calculation

22. QC Protection Matrix: Documentation of Oyster Creek Strategies for equipment storage for each BDBEE including basis for each strategy (Passport ATI 02656138-07)

23. ECR-14-00027, Outdoor Storage Structures for the Portable FLEX equipment

8. Attachments None 18 of 18