RS-15-061, February 2015 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)

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February 2015 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)
ML15057A044
Person / Time
Site: Ginna Constellation icon.png
Issue date: 02/20/2015
From: Korsnick M
Constellation Energy Nuclear Group, Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-061
Download: ML15057A044 (24)
v • d • e


Text

Maria Korsnick AINOW Exeton Generation, Senior Vice President, Northeast Operations Chief Nuclear Officer, CENG 100 Constellation Way Suite 500P Constellation Energy Nuclear Group, LLC Baltimore, MD 21202 410-470-5133 Office 443-213-6739 Fax www.exeloncorp.com mana.korsnick@exeloncorp.com NRC Order No. EA-12-049 RS-1 5-061 February 20, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244

Subject:

February 2015 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

(1) 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 (ML12054A735)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for R.E. Ginna Nuclear Power Plant, LLC (Ginna). Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Attachment (1) provides the fourth Six-Month Status Report for Ginna pursuant to Section IV, Condition C.2, of Reference (1). This report updates the milestone accomplishments since the submittal of the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

There are no regulatory commitments contained in this letter.

If there are any questions regarding this letter, please contact Thomas Harding Jr. at 585-771-5219.

4(5(

U. S. Nuclear Regulatory Commission February 20, 2015 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 0 th day of February 2015.

Respectfully,

.~4/ThtA Mary G. Korsnick MGK/STD Attachment (1) Six-Month Status Report (February 2015) for Mitigation Strategies for Beyond-Design-Basis External Events cc: Regional Administrator, Region I, USNRC NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant Director, Office of Nuclear Reactor Regulation J. A. Kratchman, NRC

ATTACHMENT (1)

SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS R. E. GINNA NUCLEAR POWER PLANT, LLC February 20, 2015

ATTACHMENT (1)

SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The R.E. Ginna Nuclear Power Plant, LLC (Ginna) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2). Subsequently, a supplement to the Ginna OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This attachment 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 associated basis (if applicable).

Since submittal of the last status report in August 2014 (Reference 4), Ginna FLEX strategy implementation has progressed with engineering analyses, calculations, and construction that support the mitigation strategies.

2 Milestone Accomplishments The following milestone(s) have been completed since submittal of the last status report in August 2014 (Reference 4) and are current as of January 30, 2015.

  • None 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the Ginna OIP (Attachment 1 - References 1 and 3). 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.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table I Status of Ginna FLEX OIP Milestones Target Activity Revised Target Milestone Completion Status Completion Date Date Commence Engineering and Design July 2013 Started May 2015 Commence Procurement of Equipment July 2013 Started September 2015 Commence Installation of Equipment July 2013 Started November 2015 Submit 6-Month Status Report August 2013 Complete Develop Strategies/Contract with the November 2013 Started March 2015 National SAFER Response Center Submit 6-Month Status Report February 2014 Complete Complete Engineering and Design March 2014 Started May 2015 Create Maintenance and Testing June 2014 Started October 2015 Procedures Submit 6-Month Status Report August 2014 Complete Procedure Changes Training Material September 2014 Started March 2015 Complete Develop Training Plan November 2014 Started July 2015 Submit 6-Month Status Report February 2015 Complete Issue FLEX Support Guidelines April 2015 Started November 2015 Perform Walk-throughs or May 2015 Started Demonstrations Provide onsite and augmented staffing assessment considering functions May 2015 Not Started related to Near-Term Task Force (NTTF) Recommendation 4.2.

Implement Training June 2015 Started November 2015*

Submit 6-Month Status Report August 2015 Not Started Complete Procurement of Equipment September 2015 Started Full compliance with EA-12-049 is Fall 2015 Not Started achieved Submit Completion Report December 2015 Not Started

  • Change since submittal of last six month status report.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 4 Changes to Compliance Method The following is a list of the coping strategies that have been changed since the last six month status report with an explanation of the changes. Additional details on how Ginna's OIP complies with the guidance in NEI 12-06 (Reference 5) are also provided:

a) NEI 12-06 Section 6.2.3.2 consideration 1 states: "For external floods with warning time, the plant may not be at power. In fact, the plant may have been shut down for a considerable time and the plant configuration could be established to optimize FLEX deployment. For example, the portable pump could be connected, tested, and readied for use prior to the arrival of the critical flood level. Further, protective actions can be taken to reduce the potential for flooding impacts, including cooldown, borating the RCS, isolating accumulators, isolating RCP seal leak off, obtaining dewatering pumps, creating temporary flood barriers, etc. These factors can be credited in considering how the baseline capability is deployed."

The probable maximum flood at Ginna is caused by an extreme regional precipitation event. NEI 12-06 table 6-1 states that floods caused by regional precipitation events have days of warning time associated with them.

Ginna will procedurally pre-stage FLEX equipment prior to the flood in accordance with ER-SC.2, "High Water (Flood) Plan" (Reference 6). The procedure has two (2) severity levels. Both of these levels can be entered based on either forecasted conditions, or actual conditions. For a lower severity event, the procedure ensures that Diesel Fuel and FLEX Pumps are pre-staged and protected. For a more severe event, the same actions occur, and the unit is brought to hot shutdown. These actions ensure the FLEX equipment remains available for a flooded condition. Additional plant equipment that is not credited during a flood is not credited for Fukushima response.

b) NEI 12-06 Section 6.2.3.2 consideration 2 states: "The ability to move equipment and restock supplies may be hampered during a flood, especially a flood with long persistence. Accommodations along these lines may be necessary to support successful long-term FLEX deployment."

Procedural guidance contained within ER-SC.2 (Reference 6) directs operators to pre-stage equipment prior to an impending flood. Equipment to be pre-staged includes a portable diesel generator, diesel fuel, and FLEX pumps. The event which causes floodwater at plant grade is caused by extreme regional precipitation. NEI 12-06 table 6-1 states that the event would have days of warning time associated with it. This warning time will be accounted for in the development of the detailed event timelines. All actions to pre-stage equipment will be capable of being implemented within the warning time available.

The most bounding flood at Ginna has a relatively short persistence. This has been evaluated per NTTF recommendation 2.1 (Reference 7). The persistence of the flood will not preclude restocking supplies such as diesel fuel.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NEI 12-06 Section 6.2.3.2 consideration 3 states: "Depending on plant layout, the ultimate heat sink may be one of the first functions affected by a flooding condition.

Consequently, the deployment of the FLEX equipment should address the effects of LUHS, as well as ELAP."

During a flood, access to the ultimate heat sink will be temporarily unavailable due to floodwater on site. Results of the NTTF Recommendation 2.1 flooding reevaluation (Reference 7) show that the persistence of the flood is approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Ginna has installed a 160,000 gallon Condensate Storage Tank which has adequate inventory for greater than 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> of heat removal. This tank will be protected from all events (seismic, tornado and flood), and will be used as a heat sink until the ultimate heat sink is available.

c) NEI 12-06 Section 6.2.3.2 consideration 7 states: "Since installed sump pumps will not be available for dewatering due to the ELAP, plants should consider the need to provide water extraction pumps capable of operating in an ELAP and hoses for rejecting accumulated water for structures required for deployment of FLEX strategies."

Ginna has purchased dewatering pumps and hoses for rejecting accumulated water for structures required for deployment of FLEX strategies. Their use is prescribed within procedure ER-SC.2 (Reference 6).

NEI 12-06 Section 6.2.3.2 consideration 8 states: "Plants relying on temporary flood barriers should assure that the storage location for barriers and related material provides reasonable assurance that the barriers could be deployed to provide the required protection."

The required flood barriers used by Ginna are stored immediately adjacent to the openings in which they are to be installed. The installation of these barriers is performed on an annual frequency for testing. Ginna has also validated that the barriers can be installed rapidly during a reasonable simulation performed per Recommendation 2.3 of the March 12, 2012 50.54(f) letter (Reference 8). Additional barriers were purchased for defense-in-depth protection of the Diesel Generator Rooms and the Battery Rooms.

These are not required to mitigate a flood, and are stored in a storage building on-site.

d) The Phase 3 strategy for core cooling, including what equipment will be needed and how, when, and where it will be deployed is basically the Phase 2 strategy supplemented by equipment available from the National SAFER Response Center (NSRC).

The Phase 2 strategy was provided in the August 2014 OIP Update (Reference 4).

Under Phase 3 natural circulation will continue to be maintained via heat removal performed by the S/Gs using a Standby Auxiliary Feedwater (SAFW) pump taking suction on the new SAFW DI Water Storage Tank; or a portable diesel driven pump connected to a primary or alternate SAFW system connection point will be used to provide make-up water to the S/Gs from the new SAFW DI Water Storage Tank or the Discharge Canal.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS To refill the SAFW DI Water Storage Tank, any existing source of demineralized water on site will be preferentially used until the NSRC water treatment system arrives. The bounding FLEX scenario to refill the SAFW DI Water Storage Tank will be to deploy a FLEX diesel driven portable pump with a hard suction hose to take suction from the Discharge Canal and, via a discharge hose connected to the SAFW DI Water Storage Tank, refill the SAFW DI Water Storage Tank. When the NSRC water treatment system arrives, water will be pumped from the discharge canal through the water treatment system to the SAFW DI Water Storage Tank. Alternatively, water can be pumped from the discharge canal through the water treatment system directly to the S/Gs via a SBAFW system connection point. NSRC delivered portable diesel driven pumps provide backup capability to the on-site FLEX pumps.

Connections will be available to supply the 480 Volt vital buses from an NSRC supplied D/G and for connecting NSRC supplied portable pumps and the NSRC supplied water processing unit.

e) The Phase 2 strategy for RCS makeup, including what equipment will be needed and how, when, and where it will be deployed is as follows:

A newly installed charging pump powered from the new 1 MW Standby Auxiliary Feedwater (SAFW) Diesel Generator (DG), taking suction from the Refueling Water Storage Tank (RWST) and discharging to the Reactor Coolant System (RCS), will be used to provide borated makeup to the RCS. This charging pump will be located in the SAFW Building (SAFWB). This arrangement will include one discharge line routed through a protected portion of the Auxiliary Building to newly installed Safety Injection (SI) line connections on both trains (i.e. primary and alternate connections). The new charging pump will be manually aligned as required. The alternate FLEX strategy is to Use a diesel driven portable FLEX charging pump taking suction from the RWST, connected at the SAFWB via a high pressure hose, to a staged connection to the newly installed SI line connections.

To provide sufficient capacity of borated water makeup to the RCS, the new charging pump will be capable of pumping 75 gallons per minute (gpm) from the RWST into the RCS at 1500 pounds per square inch (psi). A portable diesel engine driven high pressure pump will provide alternate borated makeup capability to the RCS. This pump will also be capable of pumping 75 gpm of borated water from the RWST to the RCS at 1500 psi.

The timing for RCS makeup is variable. At the maximum expected RCS and RCP seal leak rates, it is expected that natural circulation will transition from single-phase loop flow to two-phase loop flow at 2.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Reference 9) from the start of the event and that two-phase loop flow will be less than single-phase loop flow at greater than 10.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> from the start of the event (Reference 9). To comply with NRC endorsement of the boron mixing generic concern (Reference 10), charging will commence prior to 10.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> into the event.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS f) The Phase 3 strategy for RCS makeup, including postulated flow paths (installed pipe, fire hose, etc.) and makeup to the RWST is basically the Phase 2 strategy supplemented by equipment available from the National SAFER Response Center (NSRC).

Prior to depleting the RWST inventory, a mobile boration unit supplied from the NSRC can be utilized to provide an indefinite source of water for Phase 3 boron control/RCS injection. The preferred source of water to supply the mobile boration unit will be the new SAFW DI Water Storage Tank. To refill the SAFW DI Water Storage Tank, any existing source of demineralized water on site will be preferentially used until the NSRC water treatment system arrives. The bounding FLEX scenario to refill the SAFW DI Water Storage Tank will be to deploy a FLEX diesel driven portable pump with a hard suction hose to take suction from the Discharge Canal and, via a discharge hose connected to the SAFW DI Water Storage Tank, refill the SAFW DI Water Storage Tank.

When the NSRC water treatment system arrives, water will be pumped from the discharge canal through the water treatment system to the SAFW DI Water Storage Tank. Boron supplied from the NSRC with the mobile boration unit will be available to mix with the preferential water source for RCS boration/makeup. NSRC delivered portable diesel driven pumps provide backup capability to the on-site FLEX pumps.

Connections will be available to supply the 480 Volt vital buses from an NSRC supplied DIG and for connecting NSRC supplied portable pumps and the NSRC supplied mobile boration and water processing units.

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

6 Open Items from Overall Integrated Plan and Interim Safety Evaluation The following is a list of the open items from the OIP that have been added, deleted, completed, or revised since the last six month status report, with an explanation of the changes:

a) Maintain Core Cooling & Heat Removal (Steam Generators Available)

Open Item 15: Develop and implement procedures to feed S/Gs using a SAFW Pump powered by the new SAFW DIG and taking suction on the new 160,000 gallon CST. Revise procedures to direct Operators to manually establish makeup to the S/Gs via this flow path if the Turbine Driven Auxiliary Feedwater (TDAFW)

Pump fails to deliver water to the S/Gs.

This item is complete. ECA-0.0, "Loss of All AC Power," (Reference 13) Step 6 has the Operators verify adequate TDAFW flow to the S/Gs. If adequate TDAFW flow to the S/Gs is not verified and cannot be established, the Operators are directed to initiate SAFW using the SAFW D/G by referring to ATT-5.5, "Attachment SAFW with Suction from DI Water Storage Tank during SBO," (Reference 14).

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS b) Maintain Core Cooling & Heat Removal (Steam Generators Available)

Open Item 18: Develop and implement procedures/administrative controls to ensure that the new CST maintains a minimum usable volume at all times.

This item is complete. The procedures listed below provide guidance on maintaining a minimum level for the new SAFW DI Water Storage Tank to ensure greater than 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> of water is available:

  • AR-AA-3, "STDBY Aux FW DI Stor Tank Hi Hi / Lo Lo," Rev 00802, NOTE: The following Plant Process Computer System (PPCS) Point IDs can be referenced for information:

o L9774D - high level 320 inches o L9774AD - low level 312 inches

  • A-52.12, "Nonfunctional Equipment Important To Safety," Rev 07400
  • T-44.7, "SAFW DI Water Storage Tank (TCD05) System Alignment and Operation,"

Rev 00000

Rev 01401

Rev 01101

Open Item 20: Identify instrumentation and develop procedures to take field readings of necessary parameters, including PI-430 and LI-427.

This item is complete. Procedure FSG-7, "Loss of Vital Instrumentation or Control Power," (Draft, Reference 15) identifies instrumentation to take field (local) readings (i.e.

containment splice boxes) of necessary parameters, including PI-430 and LI-427, along with guidance to repower instruments of necessary parameters at the instrument racks if field wiring is intact.

d) Maintain Core Cooling & Heat Removal (Steam Generators Available)

Open Item 21: Implement a strategy to connect a portable air compressor at a location/ configuration to support ARV operation.

This item is deleted. The use of air to operate an ARV is not necessary. Local manual operation of the ARVs will be performed to control position.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS e) Maintain Core Cooling & Heat Removal (Steam Generators Available)

Open Item 23: Implement a design change as part of the installation of the new CST to install a mechanical connection that will allow the tank to be refilled from a portable diesel driven pump.

This item is complete. ECP-13-000424, "DDSAFW Project Piping Design and Installation," (Reference 16) installed V-9782, "DI Water Tank Supply Hose Connection Isolation Valve," as part of the modification that allows filling of the SAFW DI Water Storage Tank from a portable diesel driven pump.

f) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 35: Implement a design change to install a pump capable of pumping 75 gallons per minute (gpm) of borated water from the RWST into the RCS at 1575 psi, with discharge piping connected to the Safety Injection System.

This item is revised to state: Implement a design change to install a pump capable of pumping 75 gallons per minute (gpm) of borated water from the RWST into the RCS at 1500 psi, with discharge piping connected to the Safety Injection System.

The injection pressure was reduced from 1575 psi to 1500 during development of the modification package.

g) Maintain RCS Inventory Control / Long Term Subcriticality Open Item 37: Implement a design change to connect a portable diesel engine driven high pressure pump to the RWST and the Safety Injection System, which is capable of pumping 75 gpm of borated water from the RWST to the RCS at 1575 psi.

This item is revised to state: Implement a design change to install a pump capable of pumping 75 gallons per minute (gpm) of borated water from the RWST into the RCS at 1500 psi, with discharge piping connected to the Safety Injection System.

The injection pressure was reduced from 1575 psi to 1500 during development of the modification package.

h) Maintain Containment Open Item 51: Implement a strategy to determine containment pressure after a Tornado Missile event.

This item is complete. Procedure FSG-7, "Loss of Vital Instrumentation or Control Power," (Reference 15) implements a strategy to take a field (local) reading of containment pressure at a containment pressure transmitter using a pressure test gauge, along with guidance to repower a containment pressure instrument if field wiring is intact.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS i) Maintain Spent Fuel Pool Cooling Open Item 57: Perform an analysis to determine if a vent pathway from the SFP is needed for steam and condensate to minimize the potential for steam to cause access and equipment problems in the Auxiliary Building.

This item is complete. Calculation CALC-2014-0006, "Auxiliary Building Environmental Conditions during ELAP," (Reference 17) evaluates the temperature response of Auxiliary Building areas in response to a loss of forced ventilation (HVAC) during an Extended Loss of AC Power (ELAP). The purpose of this analysis is to establish the necessary mitigating actions and required timing of those actions to support the FLEX Overall Integrated Plan (OIP). This GOTHIC calculation evaluates the bounding extreme high and low outside air temperature cases. Compensatory actions are required to maintain the Auxiliary Building within acceptable temperatures. These actions include opening doors and backdraft dampers and will be incorporated into the FLEX strategy and procedures.

The temperature limits for the Auxiliary Building Operating level and above are driven by the limits for the spent fuel level indicator and associated equipment. There are no significant operator actions to be taken on the operating floor of the Auxiliary Building (only traversing the area and opening doors/dampers). For this reason, there are no explicit acceptance criteria for temperatures at this level. All lower level temperatures where work is being performed should be below 110 degrees Fahrenheit which is an acceptable temperature per NUMARC 87-00 (Reference 18). NEI 12-06 allows for reasonable judgments for beyond design basis scenarios; therefore, short durations that cause the temperature to slightly exceed 110 degrees Fahrenheit are deemed acceptable for operator comfort.

j) Safety Function Support Open Item 69: Develop a strategy to protect onsite consumables for use after a BDBEE.

This item is deleted. The current storage locations are adequate for the onsite consumables that are not required for use in a mitigation strategy.

k) Maintain Spent Fuel Pool Cooling Open Item 72: Install wide range SFP level instrumentation in accordance with NRC Order EA-12-051.

This item is complete. Modification ECP-13-000547 (Reference 19) installed two fixed channels of wide-range level indication for the Spent Fuel Pool. (Note: This is not notification that compliance with Order EA-12-051 (Reference 20) is achieved.)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 provides a summary of the open items documented in the OIP and those added in a subsequent six month status report, and the status of each item.

Table 2 Status of FLEX OIP Open Items Ginna OIP Open Items Status

1. Implement a design change to install permanent protected FLEX Started (8/2013) equipment connection points. (also see 01 23)
2. Provide for onsite storage of Phase 2 FLEX components that is Started (2/2014) protected against external events by design or location.

Implement a design change to provide a protected storage location for transportation (equipment and fuel) and debris removal equipment.

Evaluate deployment strategies and deployment routes for hazards impact.

Evaluate requirements and options and develop strategies related to the storage onsite of the FLEX portable equipment.

Establish deployment routes from FLEX equipment storage locations to connection points.

Develop a strategy and purchase equipment to respond to events that may require debris removal such as following a flood, tornado, or snow storm.

Develop a strategy to move FLEX equipment, including providing reasonable protection from a BDBEE.

3. Exceptions for the site security plan or other (license/site specific - Complete (See the 10 CFR 50.54x) requirements of a nature requiring NRC approval 2/2014 OIP Update) will be communicated in a future 6-month update following identification.
4. Develop and implement procedures to commence feeding the Started (2/2015) steam generators (S/Gs) from Standby Auxiliary Feedwater (SAFW) powered by the new SAFW Diesel Generator (D/G) and taking suction from the new Condensate Storage Tank (CST) prior to reaching 5 ft in the existing CSTs.
5. Develop and implement a FLEX method / procedure to refill the Started (2/2015) new SAFW CST prior to losing suction.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

6. Develop and implement a program and/or procedure to keep FLEX Not Started equipment deployment pathways clear or with identified actions to clear the pathways.
7. Determine schedule for when NSRCs will be fully operational. Complete (See the 8/2013 OIP Update)
8. Define criteria for the local NSRC staging area by June 2013. Complete (See the 2/2014 OIP Update)
9. Establish a suitable local staging area for portable FLEX Complete (See the equipment to be delivered from the NSRC to the site. 8/2014 OIP Update)
10. Develop site specific playbook for delivery of portable FLEX Started (8/2013)

.equipment from the NSRC to the site.

11. Perform an analysis to determine the diesel driven portable high Started (8/2014) pressure pump upper and lower head requirements to provide for a minimum of 215 gpm to a S/G without causing Reactor Coolant System (RCS) pressure to decrease to the point where nitrogen will be injected from the SI Accumulators, assuming suction is directly from the Ultimate Heat Sink (UHS).
12. Develop and implement procedures to close Safety Injection (SI) Not Started Accumulator injection valves or vent the SI Accumulators prior to nitrogen injection into the RCS.
13. Perform an analysis to determine the time to restore feed to a S/G Deleted (See the if only one S/G was able to be supplied with feedwater after a trip 2/2014 OIP Update) and then feed is lost to that one SIG. This is to account for the reduction in water available for heat removal.
14. Implement the design change to install the 1 MW SAFW DIG, Started (8/2013) 160,000 gallon Condensate Storage Tank (CST), and enclosure meeting the reasonable protection requirements of NEI 12-06.
15. Develop and implement procedures to feed S/Gs using a SAFW Complete (This OIP Pump powered by the new SAFW D/G and taking suction on the Update 2/2015) new 160,000 CST. Revise procedures to direct Operators to manually establish makeup to the S/Gs via this flow path if the Turbine Driven Auxiliary Feedwater (TDAFW) Pump fails to deliver water to the S/Gs.
16. Implement a design change to protect a S/G Atmospheric Relief Started (2/2015)

Valve (ARV) from Tornado Missiles to address reactor core cooling and heat removal using a high capacity portable diesel driven pump.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

17. Perform an analysis to demonstrate adequate manpower, Started (8/2013) communications capability, and habitability for local operation of the S/G ARVs. If this cannot be demonstrated, implement a design change to provide for ARV control from the Control Room for seismic and tornado missile events.
18. Develop and implement procedures/administrative controls to Complete (This OIP ensure that the new CST maintains a minimum usable volume at Update 2/2015) all times.
19. Perform an analysis or implement a design change to qualify S/G Started (2/2014)

Pressure instrumentation for a Tornado Missile event.

20. Identify instrumentation and develop procedures to take field Complete (This OIP readings of necessary parameters, including (Pressure Indicator) Update 2/2015)

PI-430 and (Level Indicator) LI-427.

21. Implement a strategy to connect a portable air compressor at a Deleted (This OIP location/ configuration to support ARV operation. Update 2/2015
22. Develop and implement procedures to refill the new CST from an Revised (See the alternate water source prior depleting the usable volume 2/2014 OIP Update)

(approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the event). Not Started

23. Implement a design change as part of the installation of the new Complete (This OIP CST to install a mechanical connection that will allow the tank to be Update 2/2015) refilled from a portable diesel driven pump.
24. Perform an analysis to establish plant conditions in Phase 1 that Started (2/2014) will allow diesel driven high capacity portable pump to be utilized as soon as plant resources are available to provide defense in depth for maintaining an adequate heat sink should SAFW fail.
25. Implement a design change to install a new isolation valve Started (2/2015) upstream of the FLEX connection to S/G B in case a tornado missile impacts a section of unprotected piping between the SAFW Building and the connection point.
26. Implement a strategy to provide a sustainable source of nitrogen Revised (See the and/or air to the Power Operated Relief Valves (PORVs) to protect 2/2014 OIP Update)

RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops Started (2/2014) filled.

27. Develop and implement procedures to provide guidance for water Not Started solid S/G cooldown using FLEX equipment.
28. Ensure NSRC can supply D/Gs capable of powering vital bus Complete (See the loads. 2/2014 OIP Update)

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

29. Implement a strategy to provide connections to 480 Volt vital Revised (See the busses to be able to connect to NSRC supplied D/Gs. 8/2014 OIP Update)

Started (2/2015)

30. Ensure NSRC can supply a water processing unit. Complete (See the 8/2014 OIP Update)
31. Implement a design change to install low leakage Reactor Coolant Deleted (See the Pump (RCP) seals. The new seals need to be able to withstand 2/2014 OIP Update)

Thot for an extended period of time.

32. Perform an analysis to validate that a FLEX Boric Acid Storage Deleted (See the Tank (FBAST) with a boron concentration of at least 2750 parts per 2/2014 OIP Update) million (ppm) and no more than 3050 ppm, and containing a minimum usable volume of 7000 gallons, is sufficient to maintain the reactor subcritical at Beginning of Life (BOL) or End of Life (EOL) conditions with Tave at or near no-load Tave, and at EOL conditions with a cooldown to 350 0 F. (Analysis must be bounding for current and future cycles.)
33. Implement a design change to connect a new pre-staged high Revised (See the pressure charging pump and FLEX diesel driven portable charging 8/2014 OIP Update) pump to the RWST. Started (8/2014)
34. Implement a strategy to batch mix boron in the FBAST. Deleted (See the 8/2014 OIP Update)
35. Implement a design change to install a pump capable of pumping Revised (This OIP 75 gallons per minute (gpm) of borated water from the RWST into Update 2/2015) the RCS at 1500 pounds per square inch (psi), with discharge Started (8/2013) piping connected to the Safety Injection System.
36. Develop and implement procedures to initiate RCS boration prior to Started (2/2015) commencing RCS cooldown to provide margin to prevent re-criticality.
37. Implement a design change to connect a portable diesel engine Revised (This OIP driven high pressure pump to the RWST and the Safety Injection Update 2/2015)

System, which is capable of pumping 75 gpm of borated water Started (8/2014) from the RWST to the RCS at 1500 psi.

38. Ensure the NSRC can supply a mobile boration unit. Revised (See the 8/2014 OIP Update)

Started (2/2014)

39. Perform an analysis to determine minimum RCS makeup flow Started (2/2014) sufficient for simultaneous core heat removal and boron flushing for Mode 5, loops not filled and pressurizer manway not removed.
40. Perform an analysis to determine the transition point from gravity Started (2/2015) fill of the refueling cavity to when forced makeup is required.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

41. For Mode 5, Loops Not Filled, and Pressurizer Manway Not Started (2/2014)

Removed, RCS Heat Removal will be by RCS Bleed and Feed.

Items under consideration are:

" Establish RCS feed path using low pressure pump capable of

[To Be Determined] gpm at > 50 psig and a maximum discharge pressure of 410 psig to the RCS.

  • Establish sufficient RCS bleed path (PORVs, Reactor Head Vents)
  • Implement a strategy to provide a connection point for Instrument Air to Containment (01 47)
  • Establish feed to available S/Gs Partial strategy for consideration - Fill available S/Gs to provide limited heat sink function and additional time before boiling of the coolant occurs. Existing procedural guidance for Water Solid S/G Cooldown provides guidance that can be modified for use with a high flow portable diesel driven pump to maintain the limited heat sink function.
  • If Water Solid S/G Cooldown is effective to maintain core cooling and heat removal, secure RCS Bleed and Feed and maintain Pressurizer Level.
42. Perform an analysis to determine RCS vent path requirements for Started (2/2014)

Mode 5 with PORV vent path.

43. Develop and implement procedures to makeup to the refueling Revised (See the cavity from the new CST, UHS, or RWST to maintain refueling 8/2014 OIP Update) cavity level and boron concentration. Not Started
44. Perform a boron mixing analysis for the effects on RCS boron Deleted (See the concentration by providing unborated water to the refueling cavity 2/2014 OIP Update) via the transfer canal from the Auxiliary Building to Containment.
45. Evaluate the viability of feed and bleed for available S/Gs to Started (2/2014) provide a limited heat sink function and additional time before boiling of the coolant occurs as a parallel mitigating strategy during Modes 5 & 6. This analysis must address reflux condensation and its potential effects on reactor shutdown margin.
46. Implement a design change to establish provisions for refilling the Deleted (See the FBAST with borated water. 8/2014 OIP Update)
47. Implement a strategy to provide a connection point for Instrument Revised (See the Air to Containment. 2/2014 OIP Update)

Started (2/2014)

48. Perform an evaluation to determine a method for recirculation Started (2/2014) cooling of the RCS if the Auxiliary Building Sub-basement is flooded by Tornado Missiles damaging non-protected tanks on the Auxiliary Building Operating Floor.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

49. Perform an analysis to determine the containment pressure profile Revised (See the during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and 2/2014 OIP Update) determine the mitigating strategies necessary to ensure the Started (2/2014) instrumentation and controls in containment which are relied upon by the Operators are sufficient to perform their intended function.
50. Perform an analysis of the containment function to determine the Started (8/2014) mitigating strategy acceptance criteria for an ELAP / LUHS event.
51. Implement a strategy to determine containment pressure after a Revised (See the Tornado Missile event. 8/2013 OIP Update)

Complete (This OIP Update 2/2015)

52. Develop the Phase 3 strategy after the containment pressure Started (2/2015) analysis is completed as described in Maintain Containment, PWR Portable Equipment Phase 2.
53. Ensure the NSRC will provide additional portable pumps and Complete (See the equipment to spray water into containment or supply water to the 8/2014 OIP Update)

Containment Recirculation Fans / Coolers.

54. Implement a strategy to provide for a protected makeup connection Revised (See the to the Spent Fuel Pool (SFP) cooling piping to provide makeup to 2/2014 OIP Update) the SFP that exceeds SFP boil-off and provide a means to supply Started (2/2014)

SFP makeup without accessing the SFP walkway.

55. Provide the necessary connecting hoses and/or equipment to work Started (2/2014) with existing pumps and water sources for filling the SFP.
56. Implement new FSG-1 1, Alternate SFP Makeup and Cooling, to Revised (See the provide multiple strategies for establishing a diverse means of SFP 8/2014 OIP Update) makeup and cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Started (2/2015)
57. Perform an analysis to determine ifa vent pathway from the SFP is Complete (This OIP needed for steam and condensate to minimize the potential for Update 2/2015) steam to cause access and equipment problems in the Auxiliary Building. (also see 01 62)
58. SFP Water Level instrument numbers will be provided upon Complete (See the detailed design completion. 2/2014 OIP Update)
59. Ensure the NSRC will provide additional portable pumps and Complete (See the equipment to: 8/2014 OIP Update)
  • provide water from the UHS to the Standby SFP Heat Revised (See the Exchanger to remove heat from the SFP cooling system with 8/2014 OIP Update) the Standby SFP Recirculation Pump; or
  • provide water to SFP Heat Exchanger A to remove heat from the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

60. Implement a strategy to supply the battery chargers from the 1 MW Revised (See the DIG using existing plant equipment connection points. 8/2014 OIP Update)

Started (2/2014)

61. Implement a strategy to supply the battery chargers from a 100 kW Revised (See the D/G using existing plant equipment connection points. 8/2014 OIP Update)

Started (2/2014)

62. Perform GOTHIC calculations consistent with NUMARC 87-00, Started (8/2013)

Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, to determine the effects of a loss of HVAC during an ELAP for the following areas:

  • Intermediate Building, TDAFW Pump and ARV/ (Safety Valve (SV) areas
  • Auxiliary Building, Refueling Water Storage Tank (RWST) area
  • Battery Rooms, Relay Room, and Control Room
63. Perform an analysis to evaluate the Battery Room low temperature Started (2/2014) for an ELAP event, assuming -16 0 F air temperature to determine if, and when, Battery Room heating is required.
64. Implement a strategy for accessing the UHS for all BDBEEs and to Revised (See the meet required deployment times. This must also address how 2/2014 OIP Update) debris in the UHS or other raw water sources will be filtered / Started (2/2014) strained and how the resulting debris will effect core cooling.
65. Implement a strategy to provide for transferring diesel fuel from the Revised (See the DIG A and DIG B Fuel Oil Storage Tanks (FOSTs) to a fuel 2/2014 OIP Update) transfer vehicle. Started (2/2014)
66. Perform an analysis to provide a basis that the Offsite DIG FOSTs Started (8/2014) are reasonably protected from BDBEEs.
67. Develop the strategy to transfer fuel from protected fuel storage Started (8/2014 locations to FLEX equipment.
68. Develop strategies to provide for emergency lighting to support Started (2/2014)

Operator actions after a BDBEE.

69. Develop a strategy to protect onsite consumables for use after a Deleted (This OIP BDBEE. Update 2/2015)
70. Develop and implement procedures to establish battery room Not Started ventilation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the event to prevent exceeding the unacceptable hydrogen concentration limit of 2%, once the GOTHIC analysis has been completed as discussed in Phase 2.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Ginna OIP Open Items Status

71. Table 3 lists Phase 3 Response Equipment / Commodities that are Deleted (See the being considered for pre-staging at an offsite location. These 2/2014 OIP Update) include:
  • Radiation Protection Equipment
  • Commodities - Food, Potable Water
  • Diesel Fuel
  • Heavy Equipment - Transportation, Debris Removal
  • Portable Lighting
  • Portable Toilets
72. Install wide range SFP level instrumentation in accordance with Complete (This OIP NRC Order EA-12-051. Update 2/2015)
73. Implement a strategy to provide cooling water to the RHR Heat Started (2/2014)

Exchangers using a portable diesel driven pump.

74. Any additional non-safety equipment will be identified and Started (2/2014) evaluated for suitability in the mitigation strategies Table 3 provides a summary of the open and confirmatory items documented in the Ginna Interim Staff Evaluation (ISE) (Reference 21) and the status of each item following the issuance of the ISE.

Table 3 Status of Interim Safety Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status None ISE Confirmatory Items Status

1. ISE Confirmatory Item 3.1.1.A - Confirm that the licensee Started (8/2014) addresses the results of the seismic and flooding re-evaluations pursuant to the NRC's 50.54(f) letter of March 12, 2012.
2. ISE Confirmatory Item 3.1.1.1.A - Protection, seismic - confirm that Started (8/2014) large portable FLEX equipment such as pumps and power supplies would be secured as appropriate to protect them during a seismic event and that stored equipment and structures would be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

3. ISE Confirmatory Item 3.1.1.3.A - Procedural Interfaces - seismic - Started (8/2014) confirm that a reference source for the plant operators is provided that provides approaches to obtaining necessary instrument readings to support the implementation of the coping strategies.
4. ISE Confirmatory Item 3.1.4.2.A - Snow, ice and extreme cold - Started (8/2014) confirm that potential loss of access to the UHS and flow path due to extreme low temperatures, e.g., due to ice blockage or formation of frazil ice, is assessed and resolved.
5. ISE Confirmatory Item 3.2.1.A - Confirm resolution of open item to Started (2/2015) develop and implement procedures to close SI accumulator injection valves or vent the SI accumulators prior to nitrogen injection into the RCS.
6. ISE Confirmatory Item 3.2.1.B - Confirm evaluation of the Started (2/2015) recommendation to consider the prioritization of staging portable equipment that may be required to isolate/vent the accumulators when certain cooldown maneuvers are necessitated.
7. ISE Confirmatory Item 3.2.1.1.A - Confirm completion of timelines Started (8/2014) used in conjunction with the thermal hydraulic analysis to document the duration of each phase for each critical function, and the basis for the duration.
8. ISE Confirmatory Item 3.2.1.2.A - RCP seals - Confirm that, if RCP Started (8/2014) seals are changed to non-Westinghouse seals, the acceptability of the use of non-Westinghouse seals is addressed, and the RCP seal leakage rates for use in the ELAP analysis are provided with acceptable justification.
9. ISE Confirmatory Item 3.2.1.2.B - High temperature RCP seal Started (8/2014) concern - If applicable, confirm justification that (1) the integrity of the associated 0-rings will be maintained at the temperature conditions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.
10. ISE Confirmatory Item 3.2.1.8.A - The licensee informed the NRC Started (8/2014) staff of its intent to abide by the generic approach described in the PWROG August 15, 2013 position paper related to modeling the timing and uniformity of boric acid mixing within the RCS under natural circulation conditions potentially involving two-phase flow.

Confirm that the additional conditions discussed in the NRC endorsement letter are satisfied, and that boration requirements are met.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Items Status

11. ISE Confirmatory Item 3.2.1.9.A - Confirm design information and Started (8/2014) supporting analysis developed for portable equipment that provides the inputs, assumptions, and documented analyses that the mitigation strategy and support equipment will perform as intended.
12. ISE Confirmatory Item 3.2.3.A - Containment analysis - Confirm Started (8/2014) completion of containment analysis and incorporation of results into mitigation strategies.
13. ISE Confirmatory Item 3.2.4.2.A -Ventilation - Confirm completion Started (8/2014) of GOTHIC calculations and incorporation of results into mitigation strategies.
14. ISE Confirmatory Item 3.2.4.4.A - Emergency lighting - Confirm Started (8/2014) development of lighting strategies.
15. ISE Confirmatory Item 3.2.4.4.B - Communications - Confirm Started (8/2014) completion of upgrades.
16. ISE Confirmatory Item 3.2.4.5.A - Protected Area Access - Confirm Started (8/2014) that strategies are in place to allow access to protected areas as needed to execute mitigation strategies.
17. ISE Confirmatory Item 3.2.4.8.A - Confirm that the final electrical Started (8/2014) design has the necessary electrical isolations and protections.
18. ISE Confirmatory Item 3.3.1.A - Confirm sufficient quantities of Started (8/2014)

FLEX equipment to meet N+1.

7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation as this time.

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SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 8 References The following references support the updates to the OIP described in this attachment.

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), "Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (FLL-13-007).
2. 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.
3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), "Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 8, 2013 (FLL-13-015).

4. Letter from M. G. Korsnick (Exelon Generation) to Document Control Desk (NRC), "August 2014 Six-Month Status Report in response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2014 (FLL-14-029).
5. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," dated August 2012.
6. ER-SC.2, "High Water (Flood) Plan," Revision 01001
7. FHR-REPORT, "Fukushima Flood Hazard Reevaluation Report," Revision 001
8. Letter from Mohan C. Thadani (NRC) to Mary G. Korsnick (CENG), "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, and R. E. Ginna Nuclear Power Plant - Staff Assessment of Flooding Walkdown Reports Supporting Implementation of Near-Tear Task Force Recommendation 2.3 Related to the Fukushima Dai-lchi Nuclear Power Plant Accident,"

Dated June 26, 2014 (ML14170B022)

9. RWA-1 323-003, "Ginna RELAP5 ELAP Analysis for Mode 1," Revision 0
10. Letter from J. Stringfellow (NRC) to PWROG Program Management Office (Westinghouse Electric Company LLC, regarding endorsement of the Westinghouse position paper entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG),."

(ML13276A183)

11. UFSAR, "Updated Final Safety Analysis Report," Revision 25
12. SBO-PROGPLAN, "Station Blackout Program PROGPLAN Ginna Station," Revision 008
13. ECA-0.0, "Loss of All AC Power," Revision 03900
14. ATT-5.5, "Attachment SAFW with Suction from DI Water Storage Tank during SBO,"

Revision 00000

15. FSG-7, "Loss of Vital Instrumentation or Control Power," DRAFT
16. ECP-13-000424, "DDSAFW Project Piping Design and Installation," Revision 0000 Page 20 of 21

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

17. CALC-2014-0006, "Auxiliary Building Environmental Conditions during ELAP," Revision 0
18. NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors"
19. ECP-13-000547, "Spent Fuel Pool Level Indication Modifications for Fukushima response,"

Revision 0

20. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.
21. Letter from J. S. Bowen (NRC) to M. G. Korsnick (CENG), "R. E. Ginna Nuclear Power Plant

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049 (Mitigation Strategies) (TAC No. MF1152)," dated February 19, 2014 (ML14007A704).

Page 21 of 21

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