RS-15-218, 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-12-049)

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-12-049)

ML15245A365
Person / Time
Site:	Ginna
Issue date:	08/28/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-218
Download: ML15245A365 (61)

Text

~Exe!.on Generation, Order No. EA-12-049 RS-15-218 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

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-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. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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 26, 2012

5. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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-1 2-049), dated February 28, 2013

6. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to 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 March 8, 2013

7. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), R. E. Ginna Nuclear Power Plant - Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2015 Page 2 Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) - February 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 February 27, 2014 (FLL 004)

9. Letter from M. G. Korsnick (CENG) 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)

10. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) - 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), dated February 20, 2015 (RS 061)

11. 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-1 2-049, (Mitigation Strategies) (TAC No. MF1 152), dated February 19, 2014

12. Letter from J. P. Boska (NRC) to J. E. Pacher (EGC), R. E. Ginna Nuclear Power Plant -

Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1152 and MF1147), dated June 18, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC), previously Constellation Energy Nuclear Group, LLC (Exelon, the licensee). 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 Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. References 5 and 6 provided the R. E. Ginna Nuclear Power Plant 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 7, 8, 9, and 10 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for R. E. Ginna Nuclear Power Plant. The purpose of this letter is to provide the fifth 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2015 Page 3 addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained Reference 11, and any NRC Audit Report open 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.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 8th day of August 2015.

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

Enclosure:

R. E. Ginna Nuclear Power Plant Fifth 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:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant Ms. Jessica A. Kratchman, NRR/JLD/JPSB, NRC Mr. Jeremy S. Bowen, NRRIJLD/JOMB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC

Enclosure R. E. Ginna Nuclear Power Plant Fifth 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 (57 pages)

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 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 enclosure provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and associated basis.

Since submittal of the last status report in February 2015 (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 February 2015 (Reference 4) and are current as of July 28, 2015.

The strategies/contract with the National SAFER Response Center has been developed.

The training plan has been developed.

The onsite and augmented staffing assessment considering functions related to Near-Term Task Force (NTTF) Recommendation 4.2 has been submitted to the NRC.

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.

Page 1 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Table 1 Status of Ginna FLEX OIP Milestones Target Activity Revised Target Milestone Completion Status Completion Date Date Commence Engineering and Design July 2013 Started September 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 Nvme 03 Cmlt uy215 National SAFER Response Center Submit 6-Month Status Report February 2014 Complete Complete Engineering and Design March 2014 Started September 2015*

Create Maintenance and Testing June 2014 Started October 2015 Procedures Submit 6-Month Status Report August 2014 Complete Procedure Changes Training Material Setm r204 taed epmbr015 Complete Spebr21 tre etme 05 Develop Training Plan November 2014 Complete 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 September 2015*

Demonstrations Provide onsite and augmented staffing assessment considering functionsMa205 Cmlt Jue015 related to Near-Term Task Force My21 opee Jn 05 (NTTF) Recommendation 4.2.

Implement Training June 2015 Started November 2015 Submit 6-Month Status Report Complete August 2015 with this submittal Complete Procurement of Equipment September 2015 Started Page 2 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 MiTarg Cmpetio Activity Revised Target MDetneCmltio Status Completion Date Full compliance with EA-12-049 isFal21Stre achievedFal25Stre Submit Completion Report December 2015 Not Started January 2016*

• Change since submittal of last six month status report.

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)

FLEX equipment connections will be protected against external hazards.

Ginna will locate all FLEX connections in seismically robust structures (SC-i or evaluated otherwise). In addition, any areas that plant operators will require access to deploy, or control the capability; will be located in, or on the exterior of, seismically robust structures. The following structures, which will be utilized during FLEX implementation, are Safety

Related, Seismic Category 1 Structures per UFSAR Table 3.2-1 (Reference 6):

Containment Auxiliary Building Control Building Intermediate Building Standby Auxiliary Feed Water Building Diesel Generator Building The following structures, which will be utilized during FLEX implementation, are non-safety related; however, they are considered seismically robust for the following reasons:

Turbine Building - per footnote "j" of UFSAR Table 3.2-1, the Turbine Building was analyzed during the SEP and it was determined that the building could meet Seismic Category 1 requirements without failure. Those portions of the building required to maintain its overall structural integrity are now considered Seismic Category 1.

Standby Auxiliary Feedwater Annex and Associated Concrete Pad - the concrete pad and associated enclosure building are designed using the safe-shutdown earthquake as a design input. The structure is designed to withstand SSE loads.

The event which causes flooding at Ginna is caused by extreme regional precipitation which has days of warning time associated with it (NEI 12-06 Table 6-1). The Ginna Battery Charger connections, RCS connections, and Auxiliary Feedwater Connections will be protected from the design basis flood.

Page 3 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Safety

~~External Poeues Sfuntyo Method Connection Hazard Poeues FucinProtection Drawings Core SAFW Pump One SAFW Pump

Seismic, ATT-5.5 Attachment Cooling Powered from SAFW (two available) can

Tornado, SAFW With Suction (P)

DIG supply its respective Flooding From DI Water SIG or both SIGs Storage During SBO Located in SAFW via a cross connect (Ref. 7)

Building/SAFW valve. Suction is Annex from the SAFW Dl Dwg. 33013-1 238 Storage Water Standby Aux Tank.

Feedwater P&ID (Ref. 8)

Core Diesel Driven FLEX Used to refill SAFW

Seismic, FSG-6 Alternate Cooling pump located in DI Water Storage Tornado SAFW DI Water (P)

SAFW Annex Tank. FLEX Pump (Protected Storage Tank and Hose Trailer are from, but not Makeup (Ref. 9)

Hoses stored in moved to west of available or Portable Trailers Screenhouse with needed Dwg. 33013-1238 suction for pump during Flood)

(Ref. 8)

+1 pump stored in "L" from Lake Ontario.

Building Discharge hoses are run up east side roadway to distribution manifold then from manifold to V-9782 (located in SAFW Annex). In addition, manifold allows branch lines to be laid into Auxiliary Building (AB) to fill SFP._

Page 4 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Safety Method Connection Externa Procedure(s)

Function Protection Drawings Core Diesel Driven FLEX Located in SAFW

Seismic, FSG-3 Alternate Low Cooling Pump located in Annex and connect Tornado Pressure Feedwater (A)

SAFW Annex along to SAFW cross (Protected (Ref. 10) with suction and connect line in from, but not discharge hoses.

SAFW Building.

available or Dwg. 33013-1 238 Suction is from needed (Ref. 8)

SAFW Dl Storage during Flood)

Water Tank or Lake Ontario.

Pump is moved into position outside SAFW Annex.

Suction hose is connected to fitting at V-9772 at base of tank. Discharge hose is run into SAFW Annex, through door 63 to V-9757 (to be installed) on discharge cross-tie line for SAFW Pumps.

RCS Alternate RCS Supplied from

Seismic, FSG-1 Long Term Makeup Injection from motor RWST with

Tornado, RCS Inventory (P) driven pump powered discharge to either Flood Control (Ref. 11) by SAFW DIG or both SI lines.

FSG-8 Alternate Located in SAFW Piping transitions RCS Injection Building from AB Basement/

(Ref. 12)~

Middle Level to SAFW Annex to Engineering Change SAFW Pump Room.

Notice ECP Valves I piping /

0001 69-CN-090 Power supply Alternate Charging located inside System (Ref. 13) protected structures.

Dwg. 3301 3-1 230 Alternate Charging

___ System (Ref. 44)

Page 5 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Safety

~~External Poeues SFuntio Method Connection Hazard Poeues Function_

Protection Drawings RCS Alternate RCS Connectable to the

Seismic, FSG-1 (Ref. 11)

Makeup Injection diesel driven alternate RCS Tornado (A) pump relocated from injection suction and (Protected FSG-8 (Ref. 12) the "L" Building to discharge lines from, but not east of the SAFW penetrating wall available or ECP-14-000169-CN-Building near door near door #99 to needed 090 (Ref. 13)

1. 99.

take suction from during Flood) the RWST and Dwg. 3301 3-1230 discharge to either (Ref. 44) or both SI lines.

SEP Diesel Driven FLEX FLEX Pump and Seismic FSG-1 1 Alternate Makeup pump located in Hose Trailer are (While the SEP Makeup and (F)

SAFW Annex moved to west of AB Cooling (Ref. 14)

Screenhouse with Operating Hoses stored in suction for pump Floor is not Dwg. 33013-1 248 Portable Trailers from Lake Ontario.

protected Auxiliary Cooling Discharge hose is from a Spent Fuel Pool

+1 pump stored in "L" run up east side

Tornado, Cooling P&ID Building roadway to access to the (Ref. 15) distribution SEP is still manifold. From expected to distribution manifold be available.)

hose can be run to (Protected the edge of SEP from, but not and tied down.

available or needed during Flood)

SEP Diesel Driven FLEX FLEX Pump and Seismic FSG-1 1 (Ref. 14)

Makeup pump located in Hose Trailer are (While the (A)

SAFW Annex moved to west of AB Dwg. 33013-1248 Screenhouse with Operating (Ref. 15)

Hoses stored in suction for pump Floor is not Portable Trailers from Lake Ontario.

protected Discharge hose is from a

+1 pump stored in "L" run up east side

Tornado, Building roadway to access to the distribution SEP is still manifold. From expected to distribution manifold be available.)

hose can be run to (Protected the Blitz fire nozzles from, but not located within 75 ft.

available or of SEP.

needed

___during Flood)

Page 6 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Safety

~~External Poeues SaeyMethod Connection Hazard Poeues Function Protection Drawings SFP Diesel Driven FLEX FLEX Pump and

Seismic, FSG-11 (Ref. 14)

Makeup pump Hose Trailer are Tornado (A)

Located in SAFW moved to west of (Protected Dwg. 33013-1248 Annex Screenhouse with from, but not (Ref. 15) suction for pump available or Hoses stored in from Lake Ontario.

needed Portable Trailers Discharge hose is during Flood) run up east side

+1 pump stored in "L" roadway to Building distribution manifold. From distribution manifold hose can be run to the flanged connection point at V-8662 in the SFP Cooling system located in the AB Basement.

Battery SAFW DIG is used to Fed from SAFW

Seismic, FSG-4 ELAP DC Chargers power Battery D/G through Flood Bus Load (P)

Chargers A & B ACPDPAF07.

Shed/Management through "protected Cable run from (Ref. 16) connection points" in Junction Box "A" to the SAFW Annex and Junction Box "B" all Dwg. 33013-3131 AB using installed located in SAFW 480 VAC Single Line junction boxes with Annex. Transition Diagram SAFW &

cables that are stored to "9 Box" in AB NFPA805 1000KW in the Waste Gas Middle level via Standby Diesel Compressor Room conduit (hard wired)

Generator Sets (AB Middle Level) to Waste Gas (Ref. 17)

Compressor Room.

Cable run from "9 Dwg. 33013-2539 Box" to MCC C and AC System Plant MCC D to feeder Load Distribution breakers for Battery One Line Wiring

__________Chargers A & B.

______Diagram (Ref. 18)

Page 7 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-049, ORDER MODIFYING LICENSES WITH REGARD TO REOUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Safety Externonetinalar Procedure(s)

Function MetodConecioniaar Drawings Battery Chargers (P)

SAFW DIG is used to power Battery Charger B through

protected connection points" in the SAFW Annex and AB using installed junction boxes with cables that are stored in the SAFW Annex and AB; and to power Battery Charger A through "protected connection points in Battery Room "A" using cables that are stored in the Waste Gas Compressor Room (AB Middle Level)

Fed from SAFW D/G through ACPDPAF07.

Cable run from Junction Box "A" to Junction Box "B" all located in SAFW Annex. Transition to "9 Box" in AB Middle level via conduit (hard wired) to Waste Gas Compressor Room.

Cable run from "9 Box" to MCC D to feeder breakers for

'B' Battery Chargers. In lieu of powering MCC C, cable is run from the SAFW Annex through Door 63 and 99 outside to TSC Hallway Door and down to Battery Room "A" with connection made directly to battery charger.

Tornado FSG-4 (Ref. 16)

Dwg. 3301 3-31 31 (Ref. 17)

Dwg. 3301 3-2539 (Ref. 18)

Battery Chargers (A) 100KW D/G relocated from "L" Building to outside the SAFW Annex overhead door is used to power Battery Chargers A &

B through "protected connection points" in the SAFW Annex and AB, using installed junction boxes with cables that are stored in the Northeast Sea Land.

Fed from 100 KW D/G by cable run from 100 KW D/G to Junction Box "B" located in SAFW Annex. Transition to "9 Box" in AB Middle level via conduit (hard wired) to Waste Gas Compressor Room.

Cable run from "9 Box" to MCC C and MCC 0 to feeder breakers for Battery Char qers A & B.

Seismic (Protected from, but not available or needed during Flood)

FSG-4 (Ref. 16)

Dwg. 33013-3131 (Ref. 17)

Dwg. 33013-2539 (Ref. 18)

Page 8 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Safety Method Connection Externa Procedure(s)

FucinProtection Drawings Battery 100 KW DIG Fed from 100 KW Tornado FSG-4 (Ref. 16)

Chargers relocated from "L" D/G by cables run (Protected (A)

Building to the east from 100 KW D/G to from, but not Dwg. 33013-3131 outside entrance to portable FLEX available or (Ref. 17) the TSC is used to Junction box and needed power Battery then lay out cables during Flood)

Dwg. 33013-2539 Chargers A & B from the Junction (Ref. 18) through "protected Box to the selected connection points" in battery charger(s) in the Battery Rooms, the associated using cables that are Battery Room.

stored in the Northeast Sea Land.

b) Regarding deployment of portable equipment during flooding:

ER-SC.2, "High Water (Flood) Plan," (Reference 19) identifies two severity levels that exist with respect to external flooding: Level 1 and Level 2. The symptoms or triggers that initiate a Level 1 flooding condition are as follows: (1) 5 inches of rain over a 24-hour period forecasted in the next 3 days; (2) Shift Manager discretion. The symptoms that initiate a Level 2 flooding condition are as follows: (1) Forecasted rainfall of 10 inches or more within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (2) Lake level rises to a level of 252 ft., as noted in the discharge canal and a continued rise is observed or expected; (3) Flooding of Deer Creek reaches access road bridge handrail; (4) Wave action causes water splashing over discharge canal wall OR pushes water over the armor stone; (5) Flooding of the Screen House or Turbine Building Basement; (6) Shift Manager discretion.

Per ER-SC.2, during a Level 1 flooding condition, personnel are dispatched to place FLEX dewatering pumps in the following areas: Auxiliary Building/RHR Subbasement; inside engineered barriers in the Turbine Building Basement near Emergency D/G Rooms; and inside engineered barriers in the Turbine Building Basement near the Battery Rooms.

Additionally, in accordance with ER-SC.2, personnel are to stage a 100KW portable FLEX D/G (KBD01A) on the Turbine Building Operating Floor as a source of power for the FLEX dewatering pumps.

It should be noted that these are contingency actions and are not credited as FLEX strategies. Credited FLEX equipment consists of the doors and seals of the Battery Rooms, Air Handling Room, and the Diesel Generator Rooms. No flooding of the Auxiliary Building is anticipated during the Probable Maximum Flood.

As previously stated, KBD01A is used as a source of power for the FLEX dewatering pumps. Details related to fuel consumption of KBD01A are documented in DA-ME 003, "Fukushima Fuel Consumption Analysis," (Reference 20). Table 2 of this analysis concludes that it would take approximately 12.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for KBD01A to deplete its fuel Page 9 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 tank (conservatively assuming an initial fuel oil level of 55% at the beginning of the event). According to DA-ME-15-006, "Fukushima Timeline Analysis," (Reference 21) the flooding event only has a persistence of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; as a result, a sufficient amount of fuel oil exists within KBDO1A to operate throughout the duration of the flood.

Should refueling be required, STP-O-40.2, "Diesel Driven FLEX Generator Periodic/Annual Load Bank Test," Attachment 4, (Reference 22) provides guidance for refueling KBD01A utilizing two FLEX Fuel Tank Trailers.

Each fuel tank trailer contains 990 gallons of diesel fuel. For added conservatism, these tanks were not credited for use in DA-ME-14-003.

Per ER-SC.2, during a Level 1 flooding condition, personnel are dispatched to fill the Diesel Fuel Truck and Fuel Trailers with Diesel Fuel and Stage at high ground onsite.

As a result, approximately 1,980 gallons of non-utilized diesel fuel would be available for refueling KBD01A if required.

With respect to core cooling, the SAFW pumps are credited FLEX components, as outlined in DA-ME-15-006.

Consequently, ER-SC.2 Steps 6.2.8 and 6.3.8, require Operations to evaluate if city water should be aligned to the SAFW pumps during Level 1 and Level 2 flooding conditions.

It should be noted that the SAFW Dl Water Storage Tank is the credited source of water for the SAFW pumps. Similarly, the SAFW pumps are credited for core cooling during a tornado event. The installation of ECP-14-000749, "SAFW AB Cross Tie (Fukushima)," (Reference 23) will ensure the capability to provide flow to both Steam Generators from either SAFW pump.

c) Connection points for portable equipment remain viable for flooded conditions as specified in NEI 12-06, Section 6.2.3.2, Consideration 5. With respect to core cooling, the SAFW pumps are credited FLEX components (DA-ME-15-006, Reference 21). Prior to flooding conditions an operator will be staged in the SAFW Building to operate the SAFWV Pump as needed. It should be noted that the credited source of water during a beyond design basis external flooding event is the SAFW Dl Water Storage Tank (TCD05). Neither the DI Water Storage Tank nor the SAFW Pumps are impacted by an external flood. In the event that both SAFW Pumps and both Fukushima/NFPA Diesel Generators (KDG08 and KDG09) fail, a portable FLEX pump could be installed to provide flow directly to the Steam Generators. This is considered an N+I scenario and as a result is not time critical.

Therefore, an adequate amount of time would have elapsed following the event such that floodwaters would have receded and debris would be removed prior to installing a portable FLEX pump.

There is no adverse change to the alternate Residual Heat Removal (RHR) strategy during an external flooding scenario. All equipment utilized for alternate RHR is located in the Auxiliary Building Subbasement, which is not impacted by an external flood.

Similarly, the connection points and equipment deployment areas to supply Lake Ontario water to an RHR Heat Exchanger are not impacted by an external flooding event.

Considering floodwaters recede within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event and NSRC equipment does not arrive for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the event, adequate time would be available to remove Page 10 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 debris from equipment deployment areas and connection points prior to equipment arrival and installment.

There are no adverse impacts to secondary water inventory strategies as a result of flooding. The DI Water Storage Tank which is utilized for the first portion of the event has approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of inventory. Due to the fact that floodwaters will recede within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event, adequate time remains to align the ultimate heat sink for infinite makeup capability using one of three portable FLEX pumps.

Per DA-ME-15-006, all equipment responsible for RCS makeup and the associated connection points are protected during a beyond design basis external flooding event.

To maintain Containment integrity during ELAP conditions, long term cooling will be established using NSRC equipment.

This equipment shall provide flow to the Containment Recirculation Fan Coolers (CRFCs) through Service Water (SW) connection points located in the Intermediate Building Basement.

While the Intermediate Building Basement is subject to flooding, Containment cooling is not needed for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, which is well past the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> flood duration.

Spent Fuel Pool (SFP) makeup will be accomplished using a portable FLEX pump with water supplied from Lake Ontario. Two connection points for SFP makeup exist: at the pool (provided that radiation levels are within limits) and in the basement of the Auxiliary Building. Since SFP makeup is not required until at least 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> after the event and floodwaters recede within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event, neither of these connection points are impacted by external flooding conditions.

The FSGs do not necessarily differentiate between connection points (i.e., FLEX Tornado Connection Point versus FLEX Flooding Connection Point).

There are redundant connection points that can be utilized for multiple beyond design basis scenarios. Both protected and accessible connection points exist for all beyond design basis external events.

d) FLEX equipment can operate under extreme hot and cold temperatures.

Flex Pumps (Three) and the Flex 100 KW Diesel Generator are all equipped with engine block heaters and battery tenders.

Two Pump units and the 100 KW D/G are stored in a commercial structure with the 3rd Flex Pump stored in a robust structure (SAFW Annex) that is protected from floods, tornados, and earthquakes.

The SAFW Annex is temperature controlled as well.

For the 100 KW D/G the design temperature specifications for the control unit indicate a range of minus 40°F to 158°F with an Engine Derate indicated for ambient temperatures greater than 122°F. This temperature range bounds those experienced at Ginna.

Page 11 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 For the Flex Pump engine there is no max ambient temperature indicated in the specifications. Only if the operating (coolant) temperature indicates greater than 234°F is it recommended that load be reduced on the engine.

For cold weather concerns a block heater is recommended for temperatures down to 0°F, which is currently used.

e) WCAP-1 7601, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," (Reference 24) was reviewed and the guidance utilized to assist with development of the QIP.

WCAP-17601 Section 3.1 'Westinghouse' provides 10 recommendations for consideration in developing the FLEX mitigation strategies.

Ginna's positions on these recommendations are as follows:

The recommendation to minimize RCP seal leakage rates is applicable to Ginna.

The ELAP mitigation strategy will utilize the ECA-0.0, "Loss of All AC Power,"

(Reference 25) guidance to direct a cooldown of the RCS early in the event to reduce RCP seal leakage. Symmetric RCS cooldown will be performed utilizing both steam generators for RCP seal package temperature considerations.

The recommendation to develop inventory coping times beyond the reference case by installing low leakage RCP seals was evaluated by Ginna, but will not be implemented due to the 10 CFR Part 21 issue that was identified by Westinghouse for their low leakage seals. As documented in WCAP-17601 Section 5.3.1.6, Ginna has the added benefit of coping time with its Model 93 RCPs (ME-343, "Equipment Specification for New Westinghouse Model 93 Reactor Coolant Pump Internals,"

Reference 26) due to the leak donor locations being significantly elevated with respect to the Model 93A RCPs.

Regarding the WCAP-17601 high level list of instrumentation for the RCS, in order to confirm / maintain adequate core cooling, Ginna is crediting instrumentation that has been previously evaluated as acceptable for coping with seismic, flooding, tornados, and loss of AC power events and are part of Ginna's current licensing basis. These instruments are described in the OIP and meet the NEI 12-06 guidance for PWR instrumentation in Section 3.2.1.10.

These instruments support the key actions identified in plant procedures and/or guidance. This approach was accepted in the R. E. Ginna Nuclear Power Plant -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Reference 27), Section 3.2.1.5, Monitoring Instrumentation and Controls. FSG-7, "Loss of Vital Instrumentation or Control Power," (Reference 28) provides actions to establish alternate monitoring and control capabilities.

The recommendation for maintaining a subcritical condition in the reactor core is applicable to Ginna.

FLEX specific cycle generated curves will not be used for maintaining subcritical conditions. To supplement the existing cycle specific curves, bounding actions to maintain subcritical conditions will be implemented in procedures.

CALC-2014-0002, "Cycle 38 Reactor Engineering Calculations,"

(Reference 29) adds a new Section 8.23 and Attachment 11 for FLEX Boration Strategies.

Depending on the scenario evaluated, a 40% or 15% uncertainty was Page 12 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 applied to bound the calculation for elevated boron concentrations that may be applicable to future core designs.

Since makeup to the ROS will be required to maintain adequate inventory for natural circulation cooling, expectations are that the borated makeup strategy will provide adequate shutdown margin (Keff less than 0.99) for the realistic conditions and assumptions cited in WCAP-17601.

For additional information see the response to audit question 3.2.1.8.A.

The recommendation to supply 40 gpm of RCS makeup at 1500 psia is applicable to Ginna. A modification is in progress to provide makeup capability of 75 gpm at 1500 psig.

Makeup will be initiated prior to the transition from two-phase natural circulation to ref lux boiling and with sufficient time to maintain shutdown margin with an hour margin for natural circulation conditions. For additional information see the response to ISE Confirmatory Item 3.2.1.8.A.

As stated under recommendation 2 above, the recommendation to install low leakage seals was evaluated by Ginna but will not be implemented due to the 10 CFR Part 21 issue that was identified for the Westinghouse low leakage seal design.

The recommendation to consider the prioritization of pre-staging a FLEX strategy for alternate feedwater additions, when time and resources permit, is applicable to Ginna. The primary FLEX strategy for alternate feedwater additions relies upon a SAFW pump powered by the SAFW DIG, which is an approved alternative in the R.

E. Ginna Nuclear Power Plant -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Reference 27). In addition, the alternate strategy for feedwater addition relies upon one portable diesel driven FLEX pump and associated hoses stored in the new SAF'W Annex (robust structure) capable of feeding the steam generators. Deployment will involve hooking up the suction and discharge hoses to the new condensate storage tank and AFW lines respectively, which are in close proximity to the portable diesel driven pump, and then perform the valve alignment, start the pump, and begin feeding. To prevent S/G overfill when the TDAFW pump is available, ECA-0.0 (Reference 25) directs the operators to monitor intact S/G levels and when narrow range level is GREATER THAN 7% [25% adverse CNMT] and to control AFW by throttling TDAFW flow control valves, or by throttling TDAFW pump discharge MOV-3996, or by locally throttling TDAFW flow control valves, or by starting and stopping the TDAFW pump.

The recommendation to have a low pressure portable feedwater system capable of feeding the steam generators is applicable to Ginna.

Ginna's flow and pressure requirements differ from the generic numbers provided in the recommendation, but it is noted that the recommended requirements may vary from one plant to another.

The flow and pressure applicable to Ginna, which is stated in the Overall Integrated Plan, is 215 gpm and 260 psig.

The pressure value is based on the ECA-0.0 Appendix A (Reference 25) direction to cooldown the RCS when establishing low pressure S/G feed by reducing steam generator pressure to 260 psig; and the flow value is based on the design flow for a SAFW pump, which meets decay heat removal requirements. As stated under recommendation 1 above, symmetric RCS Page 13 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 cooldown will be performed utilizing both steam generators for RCP seal package temperature considerations.

The recommendation to evaluate the strategy for accumulator makeup capability and isolation / venting to prevent gas injection is applicable to Ginna. See the response to ISE Confirmatory Item 3.2.1.A. Boration requirements have been determined and are discussed under recommendation 4 above, in response to ISE Confirmatory Item 3.2.1.8.A, and will be implemented in procedures ECA-0.0 (Reference 25) and FSG -

1, "Long Term RCS Inventory Control," (Reference 11).

The recommendation to consider the prioritization of staging portable equipment that may be required to isolate/vent the accumulators when certain cooldown maneuvers are necessitated is applicable to Ginna. This will be addressed in the response to ISE Confirmatory Item 3.2.1.B.

f)

Analyses of multiple plant areas have been completed to evaluate the effects of loss of heating ventilating and air conditioning (HVAC) during an ELAP event. RWA-1 433-001, "Ginna Standby Auxiliary Feedwater Room Heat-Up Analysis",

(Reference 30) documents the SAFW Building and SAFW Annex temperature response for HELBs, Appendix R cases, and Fukushima/FLEX cases. The calculation includes assessment of temperatures of key components within the SAFW building.

SAFW ventilation is established under ATT-5.5, "Attachment SAFW with Suction from DI Water Storage Tank During SBO" (Reference 7). SAFW pumps depend on ambient cooling such that ventilation is adequate to ensure temperatures are acceptable.

The new permanent RCS Injection pump in the SAFW Building will depend on ambient cooling. The selected pump motor has Type H insulation such that it is qualified for well beyond predicted room temperatures for thousands of hours.

ECP-1 3-000975-01 5-7B-01, "Design Change Technical Evaluation," (Reference 31) documented acceptable SAFW Annex DIG air system flow resistance to satisfy radiator flow requirements.

RWA-1433-001 modeled ventilation for the Annex D/G.

Case 6 simulated FLEX conditions.

The analysis outputs were provided as maximum temperatures for different room elevations.

Annex D/G temperature constraints are satisfied by comparison of ECP-13-000975-015-7B-01 requirements against RWA-1433-001 predictions. One temperature of potential interest is the engine air intake. ECP 000975-015-7B-01 documents the engine will derate if the air intake temperature exceeds 122°F. The GOTHIC analysis identifies a max air temperature of 123°F below 10 ft. elevation (air intakes are at approximately 7 foot elevation). The engine air intake temperature is expected to be significantly less than the max prediction of 123°F given the location of the engine air intakes in the room air flow. The engine air intakes are upstream of the engine and face the incoming outside air such that the engine intake air is not expected to be heated significantly.

Specific FLEX analyses of Battery Room ventilation needs were not performed.

Ventilation for the Battery Rooms is established under FSG-4 (Reference 16).

Small Page 14 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 portable heating/cooling units for the Battery Rooms are expected to be sized and procured prior to the 2015 Ginna Refueling Outage.

Also see response to ISE Confirmatory Item 3.2.4.2.A.

g) Electrical isolations and interactions are addressed as follows: The FLEX Generators (Fixed and Portable) will initially be connected to a dead bus and will be isolated from the bus. Other sources of power to that bus will be verified to be unavailable and de-energized. This will preclude the possibility that the other potential power sources will also attempt to repower the same equipment.

Overcurrent protection and electrical isolation is evaluated for the fixed FLEX generators installed per electrical design change package ECP-12-000459, "DDSAFW Project Electrical Design and Installation,"

(Reference 32).

Procedure FSG-4 (Reference 16) provides necessary actions to prolong essential equipment and control power long enough to deploy and use FLEX equipment for plant recovery.

See Figure 1 attached: 480 VAC Single Line Diagram BDBEE Flow Path.

Exelon proposes the following alternative approaches to NEI 12-06 Revision 0 (Reference 5) and provides the basis for the alternative approach:

a) Exelon proposes an alternate approach to NEI 12-06 for having an auto start feature for the new 1 MW FLEX D/G in the SAFW Annex, which automatically energizes its associated bus.

Proposed Alternative:

In this alternate approach, upon loss of normal yard 12.47 KV power to the SAFW Building loads and D/G auxiliary load equipment (i.e., block heaters, engine battery, chargers, etc.) an automatic transfer switch (ATS) will automatically initiate a command to start the 1 MW FLEX D/G and, once stable, swap the source power from the normal yard power to the SAFW switchgear power and take on the loads connected to new panel ACPDPAF04 and, through it, to a new 120/208V Power Transformer (PXAF02) to supply new power panel ACPDPAF05.

Basis for the alternative approach:

The existing normal power to the SAFW pump motors is 480 VAC, 3-phase, 60 Hz power from safety-related Bus 14 and Bus 16. With implementation of modification ECP 000459, "DDSAFW Project Electrical Design and Installation," (Reference 32), upon loss of normal bus power, the operators are able to manually transfer the power source to the SAFW pump motors from their normal power source to the 1 MW FLEX D/G via Class 1 E manual transfer switches 43/PSF01 A and 43/PSF01 B (Figure 1). ECP-1 2-000459 Page 15 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 supplies the 1 MW FLEX DIG Non-Safety Related Emergency source of power to these switches. For use in emergencies, the Operators will start the D/G manually if it has not started prior to this time due to the loss of normal yard 12.47 KV power.

With the generator bus voltage achieving a nominal 480V within 10 seconds, the operator can then manually start the SAFW pumps and other FLEX loads. The newly installed D/G and electrical distribution system is completely independent, and physically separated from the plant electrical distribution system except at the connection to the Manual Transfer Switches. When normal yard power recovers, the automatic transfer switch is inhibited from transferring back to normal yard power until operator action is taken.

Use of the 1 MW FLEX D/G to power the SAFW pumps as a FLEX strategy was previously accepted as an alternative approach to NEI 12-06 (ML14007A704, Reference 27).

While the D/G auto start feature was not identified prior to the ISE review, the auto start feature does not automatically power the SAF'W pumps and other FLEX loads. The auto start feature is used to repower the 1 MW FLEX D/G auxiliary load equipment to maintain generator readiness for a BDBEE.

Providing power to mitigation equipment from the 1 MW FLEX D/G must be performed manually as previously described. Exelon requests NRC Staff review and approval of this auto start feature as an acceptable alternative to the NEI 12-06 guidance.

b) Exelon proposes an alternate approach to NEI 12-06 for protection of FLEX equipment as stated in Section 5.3.1 (seismic,) Section 7.3.1 (severe storms with high winds), and Section 8.3.1 (impact of snow, ice and extreme cold).

Proposed Alternative:

This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building. For all hazards scoped in for the site, the FLEX equipment will be stored in a configuration such that no one external event can reasonably fail the site FLEX capability (N).

Basis for the alternative approach:

To ensure that no one external event will reasonably fail the site FLEX capability (N),

Exelon will ensure that N equipment is protected in the robust building. To accomplish this, Exelon will develop procedures to address the unavailability allowance as stated in NEI 12-06 Section 11.5.3., (see Maintenance and Testing section below for further details).

This section allows for a 90-day period of unavailability.

If a piece of FLEX equipment stored in the robust building were to become or found to be unavailable, Exelon will impose a shorter allowed outage time of 45 days. For portable equipment that is expected to be unavailable for more than 45 days, actions will be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of this determination to restore the site FLEX capability (N) in the robust storage location and implement compensatory measures (e.g., move the +1 piece of equipment into the robust building) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> where the total unavailability time is not to exceed 45 days.

Once the site FLEX capability (N) is restored in the robust Page 16 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 storage location, Exeion will enter the 90-day allowed out of service time for the unavailable piece of equipment with an entry date and time from the discovery date and time.

MAINTENANCE AND TESTING

• The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SEP should be managed such that risk to mitigating strategy capability is minimized.

o The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

o The required FLEX equipment may be unavailable for 90 days provided that the site FLEX capability (N) is met. If the site FLEX (N) capability is met but not protected for all of the site's applicable hazards, then the allowed unavailability is reduced to 45 days.

o The duration of FLEX equipment unavailability, discussed above, does not constitute a loss of reasonable protection from a diverse storage location protection strategy perspective.

o If FLEX equipment or connections become unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

o If FLEX equipment or connections to permanent plant equipment required for FLEX strategies are unavailable for greater than 45/90 days, restore the FLEX capability or implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) prior to exceedance of the 45/90 days.

For NEI 12-06 Section 5.3.1, seismic hazard, Exelon will also incorporate these actions:

Large portable FLEX equipment such as pumps and power supplies should be secured as appropriate to protect them during a seismic event (i.e., Safe Shutdown Earthquake (SSE) level).

Stored equipment and structures will be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

For NEI 12-06 Section 7.3.1, severe storms with high winds, Exelon will also incorporate this action:

For a 2-unit site, (N+I) of on-site FLEX equipment are required. The plant screens in per Sections 5 through 9 for seismic, flooding, wind (both tornado and hurricane),

snow, ice and extreme cold, and high temperatures.

o To meet Section 7.3.1.1.a, either of the following are acceptable:

Page 17 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 o

All required sets (N+I) in a structure(s) that meets the plant's design basis for high wind hazards, or o

(N) sets in a structure(s) that meets the plant's design basis for high wind hazards and (+1) set stored in a location not protected for a high wind hazard.

For NEI 12-06 Section 8.3.1, impact of snow, ice and extreme cold, Exelon will also incorporate this action:

SStorage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The equipment should be maintained at a temperature within a range to ensure its likely function when called upon.

For example, by storage in a heated enclosure or by direct heating (e.g., jacket water, battery, engine block heater, etc.).

Exelon will meet all of the requirements in NEI 12-06 Section 6.2.3.1 for external flood hazard and Section 9.3.1 for impact of high temperatures.

c) Exelon proposes an alternative approach to the N+I requirement applicable to hoses and cables as stated in Section 3.2.2 of NEI 12-06. NEI 12-06, Section 3.2.2 specifically states that a site will have FLEX equipment to meet the needs of each unit on a site plus one additional spare. This is commonly known as N+I where N is the number of units at a given site. The relevant text from NEI 12-06 is as follows: "In order to assure reliability and availability of the FLEX equipment required to meet these capabilities, the site should have sufficient equipment to address all functions at all units on-site, plus one additional spare, i.e., an N+I capability, where "N" is the number of units on-site. Thus, a two-unit site would nominally have at least three portable pumps, three sets of portable ac/dc power supplies, three sets of hoses & cables, etc."

NEI 12-06, Section 11.3.3 states: "FLEX mitigation equipment should be stored in a location or locations informed by evaluations performed per Sections 5 through 9 such that no one external event can reasonably fail the site FLEX capability (N)."

Typically the hoses utilized to implement a FLEX strategy are not a single continuous hose but are composed of individual sections of a smaller length joined together to form a sufficient length.

In the case of cables, multiple individual lengths are used to construct a circuit such as in the case of 3-phase power.

Proposed Alternative:

NEI 12-06 currently requires N+I sets of hoses and cables. As an alternative, the spare quantity of hose and cable is adequate if it meets either of the two methods described below:

Method 1 : Provide additional hose or cable equivalent to 10% of the total length of each type/size of hose or cable necessary for the "N" capability. For each type/size of hose or Page 18 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 cable needed for the "N" capability, at least 1 spare of the longest single section/length must be provided.

Example 1-1: An installation requiring 5,000 ft. of 5 in. diameter fire hose consisting of 100 50 ft. sections would require 500 ft. of 5 in. diameter spare fire hose (i.e., ten 50 ft. sections).

Example 1-2: A pump requires a single 20 ft. suction hose of 4 in. diameter, its discharge is connected to a flanged hard pipe connection. One spare 4 in. diameter 20 ft. suction hose would be required.

Example 1-3:

An electrical strategy requires 350 ft. cable runs of 4/0 cable to support 480 volt loads.

The cable runs are made up of 50 ft. sections coupled together. Eight cable runs (2 cables runs per phase and 2 cable runs for the neutral) totaling 2800 ft. of cable (56 sections) are required.

A minimum of 280 ft. spare cable would be required or 6 spare 50 ft. sections.

Example 1-4:

An electrical strategy requires 100 ft. of 4/0 cable (4 cables, 100 ft.

each) to support one set of 4 kv loads and 50 ft. of 4/0 (4 cables, 50 ft. each) to support another section of 4 kv loads. The total length of 4/0 cable is 600 ft. (100 ft.

x 4 plus 50 ft. x 4). One spare 100' 4/0 cable would be required representing the longest single section/length.

Method 2: Provide spare cabling and hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy.

Example 2 A FLEX strategy for a two unit site requires 8 runs each of 500 ft. of 5 in. diameter hose (4000 ft. per unit). The total length of 5 in. diameter hose required for the site is 8000 ft. with the longest run of 500 ft.

Using this method, 500 ft. of 5 in. diameter spare hose would be required.

For either alternative method, both the N sets of hoses or cables and the spare set of hoses or cables would all be kept in a location that meets the reasonable protection requirements for the site.

Basis for the alternative approach:

The NRC has endorsed (ML15125A442, Reference 33) the NEI position paper (ML15126A135, Reference 34) for the above stated alternate approach.

If using Method 2, per the endorsement letter, Exelon will ensure that the FLEX pumps and portable generators are confirmed to have sufficient capability to meet flow and electrical requirements when a longer spare hose/cable is substituted for a shorter length. Exelon acknowledges the NRC staff has not reviewed and is not endorsing the specific examples included in the NEI endorsement request dated May 1, 2015.

If necessary, Exelon will provide additional justification regarding the acceptability of various cable and hose lengths with respect to voltage drops, and fluid flow resistance, rather than merely relying on the additional, longest length cable/hose as implied by Example 1-4 in the subject letter.

Page 19 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Hoses and cabies are passive devices unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided that the hoses and cables are stored in areas with suitable environmental conditions (e.g., cables stored in a dry condition and not subject to chemical or petroleum products). The hoses and cables for the FLEX strategies will be stored and maintained in accordance with manufacturers' recommendations including any shelf life requirements. Initial inspections and periodic inspections or testing will be incorporated in the site's maintenance and testing program implemented in accordance with Section 11.5 of NEI 12-06.

Therefore, the probability of a failure occurring during storage is minimal, resulting in the only likely failure occurring during implementation.

Mechanical damage will likely occur in a single section versus a complete set of hose or cable. Therefore, the N+I alternative addresses the longest individual section/length of hose or cable.

Providing either a spare cable or hose of a length of 10% of the total length necessary for the "N" capability or alternatively providing spare cabling or hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy is sufficient to ensure a strategy can be implemented.

Mechanical damage during implementation can be compensated for by having enough spares to replace any damaged sections with margin. It is reasonable to expect that an entire set of hoses or cables would not be damaged provided they have been reasonably protected.

d) Exelon proposes an alternate approach to NEI 12-06 for having primary and alternate injection points to the S/Gs for the portable FLEX SIG injection pump, as specified by NEI 12-06, Section 3.2.2 and Table D-1.

Proposed Alternative:

This alternate approach will be to have one connection point for the portable FLEX S/G injection pump. The portable FLEX S/G injection pump is located in the SAFW Building Annex and will be staged outside of this building if used. There is one connection point for the portable FLEX S/G injection pump discharge hose, which is inside the SAFW Building.

An alternate injection point is not planned due to the multiple and diverse methods of delivering water to the S/Gs using the SAFW pumps powered by the SAFW DIG using the previously accepted alternative approach (ML14007A704, Reference 27) to NEI 12-06.

Basis for the alternative approach:

Ginna has multiple and diverse methods to deliver water to the SIGs from a SAFW pump powered by the SAFW DIG. Only one of the two SAFW pumps is needed for performing the heat removal function.

Either SAFW pump is capable of being powered by the SAFW DIG and can be aligned to feed both S/Gs through their discharge headers and one of two normally isolated cross connections between their discharge headers (See Page 20 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Figure 2 attached: FLEX SAFW System Pumps and Connections).

One cross connection is located in the SAFW Building and the other cross connection is located in the Auxiliary Building.

The multiple and diverse methods of delivering water to the S/Gs using a SAFW pump or a portable FLEX S/G injection pump meets the intent of NEI 12-06 Section 3.2.2 and Table D-I. Exelon requests NRC Staff review and approval of this alternative approach as an acceptable alternative to the NEI 12-06 guidance.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation R. E. Ginna Station 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 5: Develop and implement a FLEX method / procedure to refill the new SAFW CST prior to losing suction.

This item is complete.

FSG-6, "Alternate SAFW DI water Storage Tank Makeup,"

(Reference 9) provides a method of refilling the SAFW DI Water Storage Tank by taking suction from the Lake Ontario and discharging through a fill connection at the tank. This will allow SAFW Pumps to continue operation.

Open Item 10:

Develop site specific playbook for delivery of portable FLEX equipment from the NSRC to the site.

This item is complete.

The site specific playbook for delivery of portable FLEX equipment from the NSRC to the site has been developed and approved.

Open Item 12:" Develop and implement procedures to close Safety Injection (SI)

Accumulator injection valves or vent the SI Accumulators prior to nitrogen injection into the RCS.

This item is complete. See response to ISE Confirmatory Item 3.2.1.A.

Page 21 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Open Item 17:

Perform an analysis to demonstrate adequate manpower, 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.

This item is complete.

The Phase 2 Staffing Study (Reference 35) concluded that GINNA Station has adequate resources / staffing to locally operate ARVs in the Intermediate Building Cold Side (IB) in the event of an ELAP. ECA-0.O "Loss of All AC Power" (Reference 25) provides actions to open doors in the lB that provide a "chimney effect" in order to stabilize and then lower surrounding area temperatures in the vicinity of the ARVs. RWA-1316-001, "FLEX Intermediate Building GOTHIC Heat Up Analysis,"

(Reference 36) supports this.

ECP-14-000727, "Intermediate Building Block Wall Reinforcement," (Reference 37) is in progress that will reinforce / protect the lB walls from a Tornado I Missile event thereby maintaining the lB in a condition that the ARVs will remain accessible following an event.

Communications upgrades are being performed in accordance with "9.3 Communications".

This includes a portable radio repeater, satellite phones and a rapid case. Operators of the ARVs will exit the lB to communicate with the control room and reenter to operate the ARVs as needed.

FSG-5, "Initial Assessment and FLEX Equipment Staging", (Reference 38) will contain lighting strategies such that lighting will be available for Operators as follows:

Personal flashlights stored empty, in a protected cabinet Batteries to supply personal flashlights, in same protected cabinet as above Portable flood lights w/ power cords, stored in a protected cabinet Head lamps stored empty, in a protected cabinet Batteries to supply head lamps, in the same protected cabinet as above FSG-5 provides guidance on alternate HVAC (portable fans I doors to open).

Open Item 19: Perform an analysis or implement a design change to qualify SIG Pressure instrumentation for a Tornado Missile event.

This item is complete. One train of SIG pressure instrumentation will be qualified for a tornado missile event. Attachments A & B of FSG-7, "Loss of Vital Instrumentation or Control Power," (Reference 28) attempt to restore MCB readings of S/Gs A & B. If the SIG pressure instrumentation was damaged, use of FSG-7 Attachment P would direct an operator to take local readings of that parameter from a protected location in the Intermediate Building.

Also, FSG-7 Attachments I, J, M & N provide a means of obtaining RCS Thot and TCoId temperatures, if needed, to allow a symmetric cooldown to be effected.

Page 22 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Open Item 22: Develop and implement procedures to refill the new CST from an alternate water source prior to depleting the usable volume (approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the event).

This item is complete.

FSG-6 "Alternate SAFW DI Water Storage Tank Makeup" (Reference 9) provides guidance for filling the tank using a FLEX pump taking suction from Lake Ontario, Condenser Hotwell (if available) or the Outside Condensate Storage Tank (if available).

Open Item 25:

Implement a design change to install a new isolation valve 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.

This item is complete. ECP-14-000749 (Reference 23) will implement the SAFW cross connect modification in the Auxiliary Building to ensure that flow can be provided downstream of the damaged piping (from the tornado).

It will install a valve to ensure that back flow to the upstream damaged piping cannot occur.

ECP-13-000483, "DDSAFW Project SAFW Piping Tie-in Design and Installation," (Reference 39) will install a single FLEX connection to the SAFW cross-tie line in the SAFW Pump Room (V-9757).

These two ECPs together allow for the discharge of the FLEX pump to provide flow to both SIGs.

Open Item 26: Implement a strategy to provide a sustainable source of nitrogen and/or air to the Power Operated Relief Valves (PORVs) to protect RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops filled.

This item is complete. Ginna does not plan to provide a long term source of nitrogen and/or air to the PORVs for mode 4/5 loops filled BDBEE event. A PORV can be cycled 50 times given 300 psig N2 accumulator pressure per DA-NS-92-014, "RCS Overpressurization Protection System Nitrogen Accumulator Tanks TRC03A & B Low-Pressure Limit," (Reference 40) analysis.

However, the Nitrogen accumulators are maintained at greater than 725 psig per Alarm Response Procedure, AR-AA-15, "N2 Accum B Lo Press 725 psi," (Reference 41). At the normal accumulator tank pressure, 360 cycles are available for a single PORV. The UFSAR (Reference 6) indicates 40 cycles in 10 minutes is typical and this is consistent with 86-1234820, "Low Temperature Overpressure Analyses Summary Report" (Reference 42).

This results in about 90 minutes of PORV cycle time for a single PORV. ([360 I 40] x 10mmn = 90 min) Two PORVs are expected to be available and SAFW is expected to be aligned in approximately half an hour.

Consequently, adequate nitrogen is available to allow continued PORV function until well after SAFW heat transfer is established.

Page 23 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Open Item 27: Develop and implement procedures to provide guidance for water solid SIG cooldown using FLEX equipment.

This item is deleted.

This is no longer in scope for a coping strategy.

Current procedure ER-FIRE.3 "Alternate Shutdown for Aux Building Basement/Mezzanine Fire,"

(Reference 43) provides guidance for performing a water solid cooldown under a Fire Scenario.

b)

Maintain RCS Inventory Control /Long Term Subcriticality Open Item 33:

Implement a design change to connect a new pre-staged high pressure charging pump and FLEX diesel driven portable charging pump to the RWST.

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 1500 psi, with discharge piping connected to the Safety Injection System.

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 1500 psi.

These items are complete.

RCS make-up will be achieved through a new Alternate RCS Injection System, with injection into the cold leg via the Safety Injection (SI)

System. An Alternate RCS Injection System (33013-1230, "Alternate Charging System,"

P&ID, Reference 44) has been designed and will be installed prior to the Fall 2015 refueling outage, with final system tie-ins being made during the outage. The overall design strategy is to draw on the RWST and pump the borated water, using a high pressure positive displacement pump located in the SAFW Building, into the cold leg of the RCS, via the SI lines.

The Alternate RCS Injection FLEX pump suction piping will be tied into the RWST recirculation pump suction line that takes suction off the bottom of the tank (el. 237' 8").

The 3" Alternate RCS Injection FLEX pump suction piping will be run through the Auxiliary Building to buried lines between the Auxiliary Building and the SAFW Annex, to the Alternate RCS Injection pump in the SAFW Building. The Alternate RCS Injection FLEX pump will be mounted on an 8" concrete pad. The positive displacement pump will be powered by the 1 MW diesel generator housed in the SAFW Annex. It will provide a flow of 75 gpm at 1500 psig, through a 2" pump discharge line that parallels the suction line into the Auxiliary Building basement, west of the RWST, and into the Safety Injection "A" and "B" header.

The entire system will be manually operated and controlled, making it impervious to Auxiliary Building fires or floods.

Page 24 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Since the Alternate RCS Injection System interfaces with the Safety Injection pump discharge headers, safety related isolation valves are being installed to provide a boundary.

Each Alternate RCS Injection branch line feeding into the SI "A" and "B" headers will be equipped with a safety related normally closed ball valve. The common line feeding the two branch lines will also have a safety related normally closed ball valve to provide double isolation for each header.

These valves are classified as Containment Isolation Valves (CIVs). Additionally, a check valve in the common line has been added to ensure that contaminated water does not migrate through the Auxiliary Building to the SAFW Building or SAFW Annex, which are not Radiologically Controlled Areas (RCA).

Since the Alternate RCS Injection FLEX pump is a positive displacement pump, a flow of 75 gpm from the pump is constant.

A regulating valve on the pump skid ensures downstream pressure does not exceed the valve setting. Downstream pressure above the setting will cause a portion of the flow to be bypassed back to the pump suction. The regulating valve setting of 1575 psig ensures that the required flow of 75 gpm can be fed into the reactor pressurized to 1500 psig. Additionally, a relief valve on the pump skid is set at 1775 to 1875 psig to ensure that the pressure remains well below the pressure/temperature rating of the downstream piping.

A trailer-mounted diesel driven Alternate RCS Injection FLEX pump is being provided as a redundant pump to the permanently mounted pump.

Hose connections, at valves 9056 and 9072 on P&ID 33013-1230 (Reference 44), provide the ability to connect the trailer mounted pump to the hard-piped Alternate RCS Injection System.

Open Item 36: Develop and implement procedures to initiate RCS boration prior to commencing RCS cooldown to provide margin to prevent re-criticality.

This item is complete.

ECA-0.0, "Loss of All AC Power," (Reference 25) has the Operators monitor the Reactor for Subcriticality as a continuous action step that is performed immediately after Steam Generator depressurization (RCS cooldown) is commenced.

If unable to verify subcriticality using Nuclear Instrumentation and an ELAP is in progress, then FSG-1, "Long Term RCS Inventory Control," (Reference 11) can be performed.

See the response to ISE Confirmatory Item 3.2.1.8.A for additional information.

Open Item 38: Ensure the NSRC can supply a mobile boration unit.

This item is complete. The NSRC can supply a Mobile Boration Unit that consists of a 1000-gallon tank capable of heating a boric acid solution of up to 7750 ppm to 130°F in less than four hours. The Unit includes agitator, heaters and controls, hoses and power Page 25 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 supplies. Ginna will also be receiving a Reverse Osmosis Water Purification Unit from the NSRC. The intent is to utilize the output of the NSRC supplied water purification unit to supply the Mobil Boration Unit.

c)

Maintain Core Cooling & Heat Removal (SIGs Not Available) (Modes 5 & 6)

Open Item 40: Perform an analysis to determine the transition point from gravity fill of the refueling cavity to when forced makeup is required.

This item is complete.

DA-ME-1 5-006, "Fukushima Timeline Analysis," Attachment 2, RWST Gravity Drain Assessment, (Reference 21) determined the transition point from gravity fill of the refueling cavity to when forced makeup is required.

Open Item 43:

Develop and implement procedures to makeup to the refueling cavity from the new CST, UHS, or RWST to maintain refueling cavity level and boron concentration.

This item is complete.

FSG-1 4, "Shutdown RCS Makeup" (Reference 45) will provide guidance for maintaining Refueling Cavity level using SAFW DI Water Storage Tank, Lake Ontario, or the RWST.

d)

Maintain Spent Fuel Pool Cooling Open Item 54: Implement a strategy to provide for a protected makeup connection to the Spent Fuel Pool (SFP) cooling piping to provide makeup to the SFP that exceeds SFP boil-off and provide a means to supply SFP makeup without accessing the SFP walkway.

This item is complete.

FSG-1 1, "Alternate SEP Makeup and Cooling," (Reference 14) provides direction to fill the SFP at a flanged connection point at V-8662. This valve is located in the Auxiliary Building Basement and allows for a fill path at other than the SEP walkway. Access would be through the East Stairwell and across the Auxiliary Building Basement. FSG-5, "Initial Assessment and FLEX Equipment Staging," (Reference 38) initiates action to provide vent paths for the Spent Fuel Pool Area.

This includes opening doors in the Auxiliary Building, Auxiliary Building Tornado dampers, Fuel Cask Handling Building doors and providing portable air mover.

This procedure is implemented prior to SEP boiling.

Open Item 55: Provide the necessary connecting hoses and/or equipment to work with existing pumps and water sources for filling the SFP.

This item is complete.

FSG-1 1 (Reference 14) provides direction to maintain level in the Spent Fuel Pool using FLEX pumps / hoses / valves and manifolds.

Page 26 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Open Item 56:

Implement new FSG-11, Alternate SFP Makeup and Cooling, to provide multiple strategies for establishing a diverse means of SFP 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 />.

This item is complete. Procedure FSG-11 (Reference 14) provides multiple strategies for establishing a diverse means of SEP makeup. The primary SEP makeup strategy will be accomplished using a medium pressure portable FLEX pump with water supply from Lake Ontario. A medium pressure portable FLEX pump will be moved from its storage location into location near the northwest corner of the Screen House. Non-collapsible suction hose will be directed into Lake Ontario and discharge hose routed to the edge of the SEP and tied down. Sufficient flow will be established to recover and maintain SEP level.

If Lake Ontario is not accessible, the medium pressure portable FLEX pump can be located at the SAFW DI Water Storage Tank and take suction from the SAFW Dl Water Storage Tank. If necessary, an alternate makeup flow path to the SEP can be establish by spraying the SEP with Blitz fire nozzles located within 75 feet of the SEP.

FSG-1 1 provides direction to fill the SEP at a flanged connection point at V-8662. This valve is located in the Auxiliary Building Basement and allows for a fill path at other than the SEP walkway. Access would be through the East Stairwell and across the Auxiliary Building Basement.

e)

Safety Function Support Open Item 60: Implement a strategy to supply the battery chargers from the 1 MW D/G using existing plant equipment connection points.

Open Item 61: Implement a strategy to supply the battery chargers from a 100 kW D/G using existing plant equipment connection points.

These items are complete.

The primary strategy will be to power one or more of the protected battery chargers for the 125 VDC batteries from the 1 MW SAFW DIG to ensure vital instrumentation remains powered. Temporary cables will be run from the 1 MW SAFW D/G connections in the SAFW Annex to a portable distribution panel and/or to a distribution panel in the Waste Gas Compressor (WGC) Room. From the portable distribution panel cable can be routed to one battery charger on each train. From the distribution panel in the WGC Room cable can be routed to breakers on MOO C and MOO 0 to power one battery charger for each train. There are two battery chargers available to each of the station batteries, both with a capacity of 200 amps at 132 Volts DC and requiring up to 58 amps at 480 Volts AC.

Page 27 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 The alternate strategy will be implemented in the event that the 1 MW SAFW DIG cannot be used to provide power to the battery chargers. A FLEX 100 KW FLEX D/G capable of delivering 150 amps at 480 Volts 3-phase will be connected to one or more of the protected battery chargers for the 125 VDC batteries to ensure vital instrumentation remains powered.

This alternate strategy will use two methods similar to the 1 MW SAFW D/G. To power the distribution panel in the WGC Room, the 100 KW FLEX D/G will be transported to outside the SAFW Annex overhead door. Temporary cables will be routed from the 100 KW FLEX D/G to a junction box in the SAFW Annex to feed the distribution panel in the WGC Room and from the distribution panel in the WGC Room to battery charger breakers for each train on MOO C and MOO D. To power the portable distribution panel the 100 KW FLEX D/G will be transported to the TSO area.

Temporary cables will be routed from the 100 KW FLEX D/G to the portable distribution panel and from the portable distribution panel to one battery charger on each train.

Open Item 62: Provide the necessary connecting hoses and/or equipment to work with existing pumps and water sources for filling the SFP.

This item is complete. See response to ISE Oonfirmatory Item 3.2.4.2,A.

Open Item 63: Perform an analysis to evaluate the Battery Room low temperature for an ELAP event, assuming -160F air temperature to determine if, and when, Battery Room heating is required.

This item is complete. Ginna's design basis vital station battery sizing calculation DA-EE-97-069, "Sizing of Vital Batteries A and B," (Reference 46) utilizes a minimum Battery Room ambient temperature of 55°F. This temperature was utilized for both the station blackout analysis (4-hour coping period) as well as the SI sequence analysis.

Ginna has also performed a special case analysis to verify the capacity of the station batteries for an extended 8-hour SBO (ELAP) under DA-EE-2001-028, "Vital Battery 8-Hour Oapacity" (Reference 47).

A more realistic minimum Battery Room ambient temperature of 65°F is used for this analysis. Elevated temperatures are not considered in these analyses as they actually improve battery performance by lowering the internal resistance of the battery as well as speeding up the internal chemical reactions.

As discussed in section 7.5.3.1 of DA-EE-97-069, the 55°F ambient temperature is conservative and would not be seen in the Battery Rooms.

DA-ME-99-033, "Vital Battery Temperatures During Station Blackout Event," (Reference 48) has demonstrated that the Battery Room temperatures will not drop below 65°F during an 8-hour station blackout scenario (ELAP). Therefore, a 65°F minimum ambient temperature was used in the extended SBO analysis.

The DA-ME-99-033 calculation uses a set of very conservative assumptions (e.g., inverter heat loads not credited, which would add several degrees to the rooms). Using the 55°F (65°F for the extended SBO analysis) ambient temperature in the battery sizing calculations provides conservative margin in Page 28 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 the analysis.

Therefore, the station battery is shown, through the existing design analyses, to be able to perform its function for the duration of an ELAP event.

Open Item 64: Implement a strategy for accessing the UHS for all BDBEEs and to meet required deployment times. This must also address how debris in the UHS or other raw water sources will be filtered / strained and how the resulting debris will effect core cooling.

This item is complete. The DDSAFW Dl Water Storage Tank provides --24 hours of feed water for the SIGs (DA-ME-14-020, "Deionized Water Tank Inventory Requirements," Reference 49). This tank is protected from all events (seismic, tornado and flood), and will be used as a heat sink until the ultimate heat sink is available.

Emergency Operating Procedure ATT-5.5, "Attachment SAFW with Suction from DI Water Storage Tank During SBO," (Reference 7) starts the SAFW pumps and is accomplished within 37 minutes of event initiation.

FSG-3, "Alternate Low Pressure Feedwater," (Reference 10) FSG-6, "Alternate SAFW DI Water Storage Tank Makeup,"

(Reference 9) and FSG-12, "Alternate CNMT Cooling," (Reference 50) all have steps directing use of Lake Ontario (UHS).

FSG-1 1, Alternate SEP Makeup and Cooling,"

(Reference 14) directs using Lake Ontario for Spent Fuel Pool makeup or spray and is directed by ECA-0.0, "Loss of All AC Power" (Reference 25).

In the area of the discharge canal there are multiple options to place a hose into the discharge canal to provide makeup to the DDSAFW DI Water Storage Tank or S/Gs if the preferred area (by the grating) is blocked.

FLEX suction hoses have a strainer installed on the end of the hose. Each strainer has

-3.7 X the surface area of the non-collapsible suction hose.

Strainer perforation diameter is 3/8". There are 19 holes per row and 50 rows around the diameter of the strainer, giving a surface area of ~105 in2.

Non-collapsible suction hoses are 6" diameter giving a surface area of 28 in2. There are two suction strainers available. In the unlikely event that one becomes clogged there would be a brief interruption to shut down the pump, swap strainers, and restart the pump.

Monitoring of pump flow and pressure would indicate a possible clogged suction strainer. FSG-5, "Initial Assessment and FLEX Equipment Staging," (Reference 38) directs staging of debris removal equipment. FLEX pumps with flexible suction hoses can be maneuvered to access Lake Ontario water at various places on the discharge canal.

The water chemistry of Lake Ontario has minimal effect on long term heat transfer in the Steam Generators (NWT 167, Use of Lake Ontario Water in Steam Generators During Hot Shutdown attached to June 23, 1981 letter to NRC, Reference 51).

Lake Ontario water is used to feed S/Gs when condensate grade water is not available per ER-AFW.1, "Alternate Water Supply to the AFW Pumps," (Reference 52). By letter dated June 17, 1999 (Reference 53), the staff concluded that the licensee's approach (i.e., use of Condensate Storage Tanks and then Lake Ontario) demonstrates that it can achieve Page 29 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 and maintain hot shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a seismic event.

By letter dated September 29, 1981 (Reference 69), the staff issued a letter to Ginna regarding Systematic Evaluation Program (SEP) Topics in which the staff concluded that the licensee should provide procedures that should caution operators on the long-term use of service water to feed the SIGs. The condenser Hotwell has ~-30,000 gallons of DI water available and can be gravity filled from the Condensate Storage Tanks.

The NSRC can provide a portable filtering/demineralizer system to provide filtered or condensate grade water from Lake Ontario or other onsite sources such as the yard fire loop.

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 54), show that the persistence of the flood is approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. The onsite water sources are sufficient to supply water for this timeframe.

Open Item 70:

Develop and implement procedures to establish battery room 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.

This item is complete. Station batteries are expected to last 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during an ELAP (Reference 47). Monitoring of battery voltage is directed in ECA-0.0 (Reference 25) with a re-direction to FSG-4, "ELAP DC Bus Load Shed/Management," (Reference 16) at 108.6 DC volts. Steps in FSG-4 start normal Battery Room ventilation (DC powered vent fans) after establishing temporary power to the station battery chargers.

FSG-4 also directs establishing temporary Battery Room ventilation if required.

FSG-5 (Reference 38) directs establishing Battery Room ventilation.

Guidance for Battery Room ventilation is also provided in Alarm Response AR-C-13, "Battery Rooms Loss of Ventilation" (Reference 55).

Gothic Analysis DA-EE-99-068, "Vital Battery Room Hydrogen Analysis," (Reference 56) indicates 2% H2 is not exceeded until 73.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> without any ventilation.

Page 30 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 f)

ISE Confirmatory items ISE Confirmatory Item 3.1.1.A: Confirm that the licensee addresses the results of the seismic and flooding re-evaluations pursuant to the NRC's 50.54(f) letter of March 12, 2012.

This item is complete.

The Seismic Hazard and Screening Report (Reference 57) concludes that the SSE envelopes the GMRS from 1-10 Hz and that the GMRS is slightly higher than the SSE above 10 Hz.

Ginna will perform a high frequency confirmation in accordance with the NRC prioritization process.

The Flood Hazard Reevaluation Report (Reference 54) concludes that local intense precipitation, probable maximum flooding in streams and rivers, and select combined-effect flood combinations were not bounded by the design basis flood hazard.

Therefore, Ginna plans to prepare a full Integrated Assessment of flooding.

ISE Confirmatory Item 3.1.1.1.A: Protection, seismic - confirm that 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.

This item is complete. It is planned to have FLEX portable equipment secured in the event of an earthquake and protected from seismic interactions. This will be completed prior to the end of the Fall 2015 refueling outage.

ISE Confirmatory Item 3.1.1.3.A:

Procedural Interfaces - seismic - 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.

This item is complete.

FSG-7, "Loss of Vital Instrumentation or Control Power,"

(Reference 28) will provide Operators the ability to obtain system parameters should the power to the instruments be lost or wiring damage that precludes the instrument from being read in the Control Room. The Operator will be able to obtain a reading in the Control Room (wiring intact) or at the Containment Penetration (field wiring not intact).

ISE Confirmatory Item 3.1.4.2.A:

Snow, ice and extreme cold - 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 fraziU ice, is assessed and resolved.

Page 31 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 This item is complete.

Frazil ice at Ginna has historically occurred at the Intake Structure.

The intake structure is not credited for FLEX.

Frazil ice at the suction of hoses dropped into the discharge canal for FLEX or SAFER pumps is reasonabiy expected to not be a concern requiring special equipment for the following reasons:

Frazil ice blockage has been managed effectively at Ginna by accelerating and decelerating the water going through the intake structure by changing level in the Screenhouse. This agitation has historically been effective at disrupting the frazil ice and re-establishing normal flow rates. For FLEX pumps, the length of hose dropped into the discharge canal is short enough to allow operators to physically agitate the hose to disrupt frazil ice if it were to occur. Alternatively the drafting pumps have variable speed engines and discharge valves that could be used to accelerate/decelerate flow similar to the intake structure strategy.

• Frazil ice has occurred at Ginna during late night hours.

Operators would be cognizant of the potential for frazil ice during extreme cold conditions and cognizant of the potential vulnerability during late night hours. Margin is available in the FLEX response times and integrated flows/heat removal associated with FLEX/SAFER pumps to accommodate brief periods of flow degradation from FLEX/SAFER pumps for frazil ice management.

Potential icing over of the discharge canal could be effectively managed by on-site personnel using available equipment.

If the ice is thin then it could be broken using readily available lengths of piping or boards. Options for accessing the discharge canal if the ice is thick include but are not limited to use of the debris remover to break up the ice, accessing the water in the Screenhouse bays, or accessing the water in the discharge tunnels via removal of manways.

FSG-5, "Initial Assessment and FLEX Equipment Staging," (Reference 38) provides a precaution that if potential freezing conditions exist, strategies for use and protection of vulnerable FLEX equipment should be evaluated. Attachment C will provide additional strategies for extreme weather conditions. Strategies for protection include creating a continuous flow path such that freezing of vulnerable FLEX equipment (i.e., hose, pumps, etc.) will not occur.

In addition, pumps and associated hosing can be drained when not in use to prevent freezing.

ISE Confirmatory Item 3.2.1.A:

Confirm resolution of open item to develop and implement procedures to close SI accumulator injection valves or vent the SI accumulators prior to nitrogen injection into the RCS.

This item is complete.

ECA-O.O, Loss of All AC Power," Appendix A (Reference 25) directs operators to Depressurize Intact S/Gs to 260 psig when establishing low pressure S/G feed and then Perform FSG-10, "Passive RCS Injection Isolation,"

Page 32 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 (Reference 58) to isolate or vent the SI Accumulators, thereby preventing N2 injection to the RCS.

However, this setpoint will be revised to comply with current guidance.

(Passport AR #01704249-77, Reference 59). Ginna follows the advice in PA-PSC-0965, "PWROG Core Cooling Position Paper," (Reference 60).

ISE Confirmatory Item 3.2.1.1.A:

Confirm completion of timelines 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.

This item is complete. SIG Dryout: Analysis RWA-1323-003 (Reference 61) states that SIG dryout occurs as early as 43 mai after initiation of ELAP.

DA-ME-1 5-006, "Fukushima Timeline Analysis," (Reference 21) has SAFW flow established to the SIGs by 37 mmi into the event.

ROS Inventory: Per RWA-1323-003, two-phase natural circulation becomes less than one-phase circulation at 15.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

DA-ME-1 5-006 has the Alternate RCS Injection pump providing RCS makeup no later than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after initiation.

RCS Boration: To comply with NRC endorsement of the boron mixing generic concern, ECA-0.0, "Loss of all AC Power," (Reference 25) directs charging at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Setpoint ID J.23; WOG Footnote ID V.08) into the event, per FSG-1, "Long Term RCS Inventory Control," (Reference 11) to ensure subcriticality is maintained. However, it is likely that charging will commence earlier per FSG-1 based on RVLIS and/or Pressurizer levels.

Therefore, the boration time requirement is bounded by the requirement to maintain RCS inventory.

ISE Confirmatory Item 3.2.1.2.A:

RCP seals - Confirm that, if RCP 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.

This item is complete.

Low leakage RCP seals will not be installed.

Westinghouse Model 93 RCPs are installed at Ginna.

ISE Confirmatory Item 3.2.1.8.A: The licensee informed the NRC 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.

This item is complete. The shutdown margin calculation is CALC-2014-0002, "Cycle 38 Reactor Engineering Calculations," (Reference 29) which analyzes for the most limiting Page 33 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 conditions (xenon free, largest cooldown, both zero and max seal leakage).

RE-103, "Control of Reload Core Design," (Reference 62) ensures that adequate shutdown margin checks are performed for future operating cycles.

For the boration strategy:

• A newly installed (and electrically isolated) Alternate RCS Injection Pump powered from the new SAFW DIG, taking suction from the RWST (300,000 gallons) and discharging to the RCS, will be used to provide borated makeup to the RCS. This charging pump is located in the SAFW Building (SAFWB).

This arrangement will include a discharge line routed through a protected portion of the Auxiliary Building to newly installed Safety Injection (SI) line connections on both trains.

The new charging pump will be manually aligned as required. The alternate FLEX strategy is to use a diesel driven portable Alternate RCS Injection 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 gpm from the RWST into the RCS at 1500 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 /> (RWA-1 323-003, Ginna RELAP5 ELAP Analysis for Mode 1, Reference 61) from the start of the event and that two-phase loop flow will be less than single-phase loop flow at approximately 15.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> from the start of the event (RWA-1 323-003). To comply with NRC endorsement of the boron mixing generic concern, ECA-0.0, "Loss of all AC Power," (Reference 25) directs charging at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> into the event (Setpoint ID J.23; WOG Footnote ID V.08 -

this setpoint is subject to change upon further review but will be bounded by the need to make up RCS inventory) per FSG-1, "Long Term RCS Inventory Control,"

(Reference 11) to ensure subcriticality is maintained.

However, it is likely that charging will commence earlier per FSG-1 based on RVLIS and/or Pressurizer levels.

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.

Additional information was provided in the August 2014 Six-Month Status Report (Reference 63).

ISE Confirmatory Item 3.2.3.A:

Containment analysis - Confirm completion of containment analysis and incorporation of results into mitigation strategies, Page 34 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 This item is complete. Ginna's containment analysis is documented in RWA-l1403-001, "GOTHIC FLEX Containment Analysis" (Reference 64).

This analysis uses GOTHIC 8.0, has cases for Modes 1 and 5, and was benchmnarked against previous LOCA analyses.

ISE Confirmatory Item 3.2.4.2.A:

Ventilation - Confirm completion of GOTHIC calculations and incorporation of results into mitigation strategies.

This item is complete.

GOTHIC calculations were performed as follows and results incorporated into mitigation strategies:

RWA-1316-001, "FLEX Intermediate Building GOTHIC Heat Up Analysis."

(Reference 36) This includes TDAFW pump and SRV/SV areas, which are located in the Intermediate Building.

RWA-1 403-001, "GOTHIC FLEX Containment Analysis." (Reference 64)

RWA-1433-001, "Ginna Standby Auxiliary Feedwater Room Heat-Up Analysis."

(Reference 30)

CALC-2014-0006, "Auxiliary Building Environmental Conditions During ELAP."

(Reference 65)

ELAP specific Battery Room/Relay Room/Control Room analyses were not performed. Ginna plans to size and procure portable HVAC for these areas prior to Ginna's 2015 Refueling Outage.

ISE Confirmatory Item 3.2.4.4.A:

Emergency lighting - Confirm development of lighting strategies.

This item is complete.

As described in UFSAR (Reference 6), Section 9.5.3, Lighting Systems: Fixed emergency lighting units are provided in safety-related areas and other areas which contain fire hazards to facilitate emergency operations, manual fire-fighting, and access to and egress from each designated fire area. The lighting units are 8-hour rated [but are not seismically qualified]. In. addition to the fixed lighting systems, portable battery-powered handlights are provided.

Ginna safe shutdown panels are located in several areas of the plant. The lighting at the safe shutdown areas has been determined to be sufficient to perform all required safe shutdown tasks. This determination was made by a lighting survey conducted in conjunction with 10 CFR 50, Appendix R, compliance efforts. The Control Room 125-V dc emergency lighting system comes on for loss of ac power [does not load shed by FLEX].

The Control Room emergency lighting fixtures are fed from either the A or B station batteries. In the event of loss of either battery there is a transfer switch in the Control Room by which the operators can manually switch the emergency lighting feed from one train to the other. Should loss of either battery occur in the emergency lighting mode, an 8-hour-rated emergency light fixture located near the transfer switch will remain functional to provide sufficient lighting to perform the transfer. The 125-V dc power supply up to the point of termination at the emergency lighting fixtures is Class 1E and Seismic Category I. The emergency lighting Page 35 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 fixtures are standard. A prototype fixture has been seismically tested in accordance with IEEE 344-1975 to ensure continued operation of the fixtures in the event of an earthquake. In addition, an analysis of the seismically reinforced suspended ceiling has been performed to ensure that the ceiling, including the normal and emergency lighting fixtures, does not create a hazard to Control Room personnel or safety-related equipment during a seismic event.

Lighting in the SAFW Annex Building will be automatically powered from the SAFW DIG when in operation.

Initial lighting in the SAFW Building Room will be from 8-hour Appendix R battery powered lighting, with portable flood lights being available to be deployed.

The door to the SAFW Annex can be opened to help with lighting in the SAFW feed room.

FSG-5, "Initial Assessment and FLEX Equipment Staging," (Reference 38) will contain lighting strategies such that lighting will be available as follows:

Personal flashlights stored empty, in a protected cabinet Batteries to supply personal flashlights, in same protected cabinet as above Portable flood lights w/ power cords, stored in a protected cabinet Head lamps stored empty, in a protected cabinet Batteries to supply head lamps, in the same protected cabinet as above ISE Confirmatory Item 3.2.4.4.B:

Communications

-Confirm completion of upgrades.

This item is complete. Installation for the Flex Satellite Communication System will be performed under Work Order C92852633, "Fukushima -

NTTF 9.3 Communication -

Install Satellite Phones" (Reference 66). This Modification has been developed under ECP-1 4-000756, "Installation of FLEX Satellite Communications system to provide FLEX and NARs phone service to Control Room and TSC" (Reference 67).

This project includes the installation of a satellite network that will provide a secondary path for the EMNet and NTTF Recommendation 9.3: Communications phones. This network is to provide essential communications in the Main Control Room (MCR) and in the Technical Support Center (TSC) during an extended loss of ac power due to a BDBEE.

A permanently installed emergency power source for the secondary satellite network will be installed and made available at a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following a loss of ac power.

Satellite network connectivity will be provided for three (3) Voice-Over Internet Protocol (VOIP) phones for FLEX communication along with one (1) laptop in the MCR. Satellite connectivity for one (1) EMNet NARS desktop PC and six (6) VOIP phones for FLEX communication are provided for the TSC. The satellite dish antenna may not survive an event; therefore, there is a portable satellite dish in protected storage.

A separately available Rapid Case with its own portable satellite dish (in case the installed satellite dish does not survive the event) and network will be available and Page 36 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 powered by its own portable generator.

This system can operate standalone or can interface with the fixed system described above.

FSG-5 (Reference 38) will contain a communications plan. Onsite communications will use station radios in talk-around mode, will deploy a portable radio repeater for better radio reception, and will use bull horns. Irridium satellite phones are already in the MCR.

Chargers for radio batteries will be powered from small 3.3 KW diesel generators.

ISE Confirmatory Item 3.2.4.5.A: Protected Area Access - Confirm that strategies are in place to allow access to protected areas as needed to execute mitigation strategies.

This item is complete. On-Shift Operations personnel carry security door access keys, that in the situation that the card reader system becomes disabled, will have unrestricted access to plant areas required for mitigating actions of a BDBEE.

There is currently no planned movement or deployment of equipment that specifically requires electrical power, such that consideration for a power supply strategy is required.

Any such movement of gates, doors, fences, etc. will and can be performed by manual action.

Page 37 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 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 Reference 70) 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 (DIG) 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 Complete (This OIP new SAFW CST prior to losing suction.

Update 8/201 5)

Page 38 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

6. Develop and implement a program and/or procedure to keep FLEX Started (8/201 5) equipment deployment pathways clear or with identifiled actions to clear the pathways.

7. Determine schedule for when NSRCs will be fully operational.

Complete (See the 8/2013 OIP Update Reference 71 )

8. Define criteria for the local NSRC staging area by June 2013.

Complete (See the 2/2014 OIP Update Reference 70)

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 Reference 63)

10. Develop site specific playbook for delivery of portable FLEX Complete (This OIP equipment from the NSRC to the site.

Update 8/201 5)

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)

Complete (This QIP Accumulator injection valves or vent the SI Accumulators prior to Update 8/2015) nitrogen injection into the ROS.

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 QIP Update) and then feed is lost to that one S/G. This is to account for the reduction in water available for heat removal.

14. Implement the design change to install the 1 MW SAFW D/G, 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 (See the Pump powered by the new SAFW D/G and taking suction on the 2/2015 OIP Update new 160,000 CST. Revise procedures to direct Operators to Reference 4) 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.

Page 39 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

16. Implement a design change to protect a SIG Atmospheric Relief Started (2/201 5)

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

17. Perform an analysis to demonstrate adequate manpower, Complete (This OIP communications capability, and habitability for local operation of Update 8/2015) the SIG 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 (See the ensure that the new CST maintains a minimum usable volume at 2/2015 OIP Update all times.

Reference 4)

19. Perform an analysis or implement a design change to qualify S/G Complete (This OIP Pressure instrumentation for a Tornado Missile event.

Update 8/2015)

20. Identify instrumentation and develop procedures to take field Complete (See the readings of necessary parameters, including (Pressure Indicator) 2/2015 QIP Update PI-430 and (Level Indicator) LI-427.

Reference 4)

21. Implement a strategy to connect a portable air compressor at a Deleted (See the location!/configuration to support ARV operation.

2/2015 OIP Update Reference 4)

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).

Reference 70)

Complete (This OIP Update 8/201 5)

23. Implement a design change as part of the installation of the new Complete (See the CST to install a mechanical connection that will allow the tank to be 2/2015 OIP Update refilled from a portable diesel driven pump.

Reference 4)

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 Complete (This OIP upstream of the FLEX connection to S/G B in case a tornado Update 8/2015) missile impacts a section of unprotected piping between the SAFW Building and the connection point.

Page 40 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

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 QIP Update RCS Integrity during a BDBEE while in Mode 4 or Mode 5, loops Reference 70) filled.

Complete (This OIP Update 8/201 5)

27. Develop and implement procedures to provide guidance for water Deleted (This OIP solid S/G cooldown using FLEX equipment.

Update 8/201 5)

28. Ensure NSRC can supply D/Gs capable of powering vital bus Complete (See the loads.

2/2014 QIP Update Reference 70)

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 QIP Update Reference 63)

Started (2/2015)

30. Ensure NSRC can supply a water processing unit.

Complete (See the 8/2014 OIP Update Reference 63)

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.

Ref erence70)

32. Perform an analysis to validate that a FLEX Boric Acid Storage Deleted (See the Tank (EBAST) 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 Reference 70) 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°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.

Reference 63)

Complete (This OIP Update 8/201 5)

34. Implement a strategy to batch mix boron in the FBAST.

Deleted (See the 8/2014 OIP Update Ref erence63)

35. Implement a design change to install a pump capable of pumping Revised (See the 75 gallons per minute (gpm) of borated water from the RWST into 2/2015 OIP Update the RCS at 1500 pounds per square inch (psi), with discharge Reference 4) piping connected to the Safety Injection System.

Complete (This OIP Update 8/201 5)

Page 41 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

36. Develop and implement procedures to initiate RCS boration prior to Complete (This OIP commencing RCS cooldown to provide margin to prevent re-Update 8/2015) criticality.

37. Implement a design change to connect a portable diesel engine Revised (See the driven high pressure pump to the RWST and the Safety Injection 2/2015 OIP Update System, which is capable of pumping 75 gpm of borated water Reference 4) from the RWST to the RCS at 1500 psi.

Complete (This OIP Update 8/2015)

38. Ensure the NSRC can supply a mobile boration unit.

Revised (See the 8/2014 OIP Update Reference 63)

Complete (This OIP Update 8/201 5)

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 Complete (This OIP fill of the refueling cavity to when forced makeup is required.

Update 8/2015)

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 ROS 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.

Page 42 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

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.

Reference 63)

Complete (This QIP Update 8/201 5)

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.

Reference 70)

45. Evaluate the viability of feed and bleed for available SIGs 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 ref lux condensation and its potential effects on reactor shutdown margin.

46. Implement a design change to establish provisions for refilling the Deleted (See the EBAST with borated water.

8/2014 OIP Update Ref erence63)

47. Implement a strategy to provide a connection point for Instrument Revised (See the Air to Containment.

2/2014 OIP Update Reference 70)

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.

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 QIP Update determine the mitigating strategies necessary to ensure the Reference70) instrumentation and controls in containment which are relied upon Satd(/04 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 Reference 71)

Complete (See the 2/2015 OIP Update)

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.

Page 43 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

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.

Reference 63)

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 Reference 70)

SFP makeup without accessing the SFP walkway.

Complete (This OIP Update 8/201 5)

55. Provide the necessary connecting hoses and/or equipment to work Complete (This OIP with existing pumps and water sources for filling the SFP.

Update 8/2015)

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 />.

Reference 63)

Complete (This OIP Update 8/2015)

57. Perform an analysis to determine if a vent pathway from the SFP is Complete (See the needed for steam and condensate to minimize the potential for 2/2015 OIP Update steam to cause access and equipment problems in the Auxiliary Reference 4)

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 Reference 70)

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 Reference 63)

Exchanger to remove heat from the SFP cooling system with Revised (See the the Standby SFP Recirculation Pump; or 8/2014 OIP Update provide water to SFP Heat Exchanger A to remove heat from Reference 63) the SFP Cooling System with the Standby SFP Recirculation Pump or SFP Pump A.

60. Implement a strategy to supply the battery chargers from the 1 MW Revised (See the D/G using existing plant equipment connection points.

8/2014 OIP Update Reference 63)

Complete (This OIP Update 8/201 5)

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 Reference 63)

Complete (This OIP Update 8/201 5)

Page 44 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

62. Perform GOTHIC calculations consistent with NUMARC 87-00, Complete (This OIP Guidelines and Technical Bases for NUMARC Initiatives Update 8/2015)

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 ARVI/(Safety Valve (SV) areas Auxiliary Building, Refueling Water Storage Tank (RWST) area Battery Rooms, Relay Room, and Control Room Standby Auxiliary Feedwater Building

63. Perform an analysis to evaluate the Battery Room low temperature Complete (This CIP for an ELAP event, assuming -160F air temperature to determine if, Update 8/201 5) 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 /

Reference 70) strained and how the resulting debris will effect core cooling.

Complete (This QIP Update 8/201 5)

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.

Reference 70)

Started (2/2014)

66. Perform an analysis to provide a basis that the Offsite D/G 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 (2/201 4)

Operator actions after a BDBEE.

69. Develop a strategy to protect onsite consumables for use after a Deleted (See the BDBEE.

2/2015 OIP Update Reference 4)

70. Develop and implement procedures to establish battery room Complete (This OIP 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 Update 8/2015) unacceptable hydrogen concentration limit of 2%, once the GOTHIC analysis has been completed as discussed in Phase 2.

Page 45 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Ginna OIP Open Items Status

71. Table 3 lists Phase 3 Response Equipment I Commodities that are being considered for pre-staging at an offsite location. These include:

Radiation Protection Equipment Commodities - Food, Potable Water Diesel Fuel Heavy Equipment -Transportation, Debris Removal Boric Acid Portable Lighting Portable Toilets Deleted (See the 2/2014 OIP Update Ref erence70)

72. Install wide range SEP level instrumentation in accordance with Complete (See the NRC Order EA-12-051.

2/2015 OIP Update Reference 4)

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 (2/201 4) evaluated for suitability in the mitigation strategies Page 46 of 57

ENCLOSURE R, E. GINNA NUCLEAR POWER PLANT FIFTH 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 Table 3 provides a summary of the open and confirmatory items documented in the Ginna Interim Staff Evaluation (ISE) (Reference 27) and the open or pending items listed in the FLEX/SFPI audit report (Reference 68), and the status of each item.

Table 3 Status of Interim Safety Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status None ISE Confirmatory Items and Status Open or Pending FLEXISFPI Audit Items

1. ISE Confirmatory Item 3.1.1.A - Confirm that the licensee Complete (This addresses the results of the seismic and flooding re-evaluations QIP Update pursuant to the NRC's 50.54(f) letter of March 12, 2012.

8/201 5))

2. ISE Confirmatory Item 3.1.1.1.A-Protection, seismic - confirm that Complete (This large portable FLEX equipment such as pumps and power supplies OIP Update would be secured as appropriate to protect them during a seismic 8/201 5) 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.

3. ISE Confirmatory Item 3.1.1.3.A - Procedural Interfaces - seismic -

Complete (This confirm that a reference source for the plant operators is provided OIP Update that provides approaches to obtaining necessary instrument readings 8/2015) to support the implementation of the coping strategies.

4. ISE Confirmatory Item 3.1.4.2.A - Snow, ice and extreme cold -

Complete (This confirm that potential loss of access to the UHS and flow path due to QIP Update extreme low temperatures, e.g., due to ice blockage or formation of 8/2015) frazil ice, is assessed and resolved.

5. ISE Confirmatory Item 3.2.1.A - Confirm resolution of open item to Complete (This develop and implement procedures to close SI accumulator injection OIP Update valves or vent the SI accumulators prior to nitrogen injection into the 8/2015)

RCS.

Page 47 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 ISE Confirmatory Items and Status Open or Pending FLEX/SFPI Audit Items

6.

ISE Confirmatory Item 3.2.1.B - Consider the prioritization of Started (2/2015) staging portable equipment that may be required to isolate/vent the accumulators when certain cooldown maneuvers are necessary. The licensee's plan was to enter containment and locally close the accumulator isolation valves. The NRC staff asked for an alternate plan in case the containment building had an adverse environment.

The staff requests that the licensee make available for audit their plan to isolate or vent the RCS cold leg accumulators to avoid injecting nitrogen into the RCS.

7. ISE Confirmatory Item 3.2.1.1.A - Confirm completion of timelines Complete (This used in conjunction with the thermal hydraulic analysis to document OIP Update the duration of each phase for each critical function, and the basis for 8/2015) the duration.

8. ISE Confirmatory Item 3.2.1.2.A - RCP seals - Confirm that, if RCP Complete (This seals are changed to non-Westinghouse seals, the acceptability of QIP Update the use of non-Westinghouse seals is addressed, and the RCP seal 8/2015) leakage rates for use in the ELAP analysis are provided with acceptable justification.

9. ISE Confirmatory Item 3.2.1.2.B - Confirm that the RCP seal 0-Started (8/2014) rings will maintain their integrity at the temperature conditions experienced during the ELAP event, and that the RCP seal leakage rate used in the ELAP analysis is adequate and acceptable. The staff requests that the licensee make available for audit a list of where the B type 0-rings are located and an evaluation of the impact of high temperatures on those 0-rings.

10. ISE Confirmatory Item 3.2.1.8.A - The licensee informed the NRC Complete (This staff of its intent to abide by the generic approach described in the OIP Update PWROG August 15, 2013 position paper related to modeling the 8/201 5) 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.

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.

Page 48 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 ISE Confirmatory Items and Status Open or Pending FLEXISFPI Audit Items

12. ISE Confirmatory Item 3,2.3,A-Containment analysis - Confirm Complete (This completion of containment analysis and incorporation of results into QIP Update mitigation strategies.

8/2015)

13. ISE Confirmatory Item 3.2.4.2.A - Ventilation - Confirm completion Complete (This of GOTHIC calculations and incorporation of results into mitigation OIP Update strategies.

8/2015)

14. ISE Confirmatory Item 3.2.4.4.A-Emergency lighting - Confirm Complete (This development of lighting strategies.

OIP Update 8/2015)

15. ISE Confirmatory Item 3.2.4.4.B - Communications - Confirm Complete (This completion of upgrades.

OIP Update 8/2015)

16. ISE Confirmatory Item 3.2.4.5.A - Protected Area Access - Confirm Complete (This that strategies are in place to allow access to protected areas as OI P Update needed to execute mitigation strategies.

8/2015)

17. ISE Confirmatory Item 3.2.4.8.A - Confirm that the final electrical Started (This OIP design has the necessary electrical isolations and protections. The Update 8/201 5)

NRC staff determined that the auto start feature of the 1 MW FLEX SeScin4o DG in the SAFW Annex, which automatically energizes the bus, is an ti nlsr alternative to NEI 12-06, as is the use of a permanently installed FLEX DG. The staff accepted the permanent DG in the ISE review, but was unaware of the auto start feature at that time. Also, the staff needs to evaluate the connection points for the 41 60V FLEX DG from the NSRC. The staff requests that the licensee make available for audit the reasons why an auto start and load feature could be an acceptable alternative to NEI 12-06, and provide a list of connection points for the 4160V FLEX DG.

18. ISE Confirmatory Item 3.3.1.A - Confirm sufficient quantities of Started (8/2014)

FLEX equipment to meet N+1, and identify their storage locations.

The staff requests that the licensee make available for audit the location where each piece of FLEX equipment will be stored and the associated protection from external events at these storage locations.

Page 49 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 ISE Confirmatory Items and Status Open or Pending FLEX/SFPI Audit Items

19. Audit Item Reference AQ 1-B - Provide information to demonstrate Complete (This conformance to the storage guidance of NEI 12-06 for FLEX CIP Update equipment, especially Section 7.3.1, or justify an alternative to NEI 8/201 5) 12-06. The licensee's plan is to store N+1 equipment in a commercial SeScin4o building which is not fully robust. The staff requests that the licensee ti nlsr make available for audit a justification for using an alternative to the guidance of NEI 12-06. This configuration is a design that is used at most Exelon plants. The NRC staff previously discussed this with Exelon following the NRC FLEX audit at Byron Station. The NRC is pursuing a resolution with the licensee.

20. Audit Item Reference SE 1-E - The final validation and verification Started (8/2015) and timeline checks of procedures and operator actions during an ELAP need to be performed when procedures are completed. The staff is especially concerned with the timeline for initiating feedwater to the SGs. The staff requests that the licensee make available for audit the validation and verification of the procedures and timeline that shows the actions for an ELAP can be completed as planned.

21. Audit Item Reference SE 7-E - In planning operator actions for Started (8/2015)

ELAP, the licensee relies on an analysis of plant response using the modeling code RELAP5/MOD3.3. The NRC staff needs to evaluate the results obtained by the licensee. No input is needed at this time.

The NRC staff will evaluate the licensee's results.

22. Audit Item Reference SE 11-E - Discuss all areas where local Started (8/2015) manual actions are performed and evaluate the ability to perform these tasks based on local conditions such as heat, cold, humidity, radiation, lighting, and communications. The NRC staff requests that the licensee make available for audit a list of all local manual actions and evaluate if the conditions allow for the task to be accomplished in accordance with the event timeline.

23. Audit Item Reference SE 12-E - Discuss strategies involving RCS Started (8/201 5) makeup and boration to verify shutdown margin is maintained and methods of venting the RCS to permit injection flow. The NRC staff requests that the licensee make available for audit an evaluation of shutdown margin and the ability to inject borated water into the RCS without taking the pressurizer solid.

Page 50 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 ISE Confirmatory Items and Status Open or Pending FLEX/SFPI Audit Items

24. Audit Item Reference SE 13-E - Provide justification for the ability of Started (8/2015) the RCP seals to limit the leakage from the RCS during ELAP conditions to the leakage values assumed in the plant analyses. The staff acknowledges that this is applicable to all pressurized-water reactors with standard Westinghouse RCP seals. The staff has pursued this with the Pressurized-Water Reactor Owners Group without reaching a resolution. The NRC staff requests that the licensee make available for audit an evaluation of compensatory margins in the analysis that could compensate in the event that RCP seal leakage is greater than assumed in the analysis.

25. Audit Item Reference SE 14-E - Determine if all components in the Started (8/2015)

RCP seal leakoff line that function to limit seal leakage flow are capable of withstanding the pressure predicted during an ELAP event, or evaluate the new leakage flow that would result from a failure of the seal leakoff line. No input is needed at this time. The NRC staff will evaluate the licensee's response.

26. Audit Item Reference SE 16-E - Provide the plan for maintenance Complete (This and testing of FLEX equipment which conforms to the guidance of OIP Update NEI 12-06, Section 11.5. The NRC staff understands that Exelon is 8/2015) preparing a corporate response to this issue. Please provide the SeScin4o corporate response, and any specific maintenance and testing this Enclosure requirements for your specific FLEX equipment.

27. Audit Item Reference SE 17-E - RCS injection does not have Started (8/201 5) primary and alternate injection points as specified by NEI 12-06, Section 3.2.2 and Table D-I. The NRC staff requests that the licensee make available for audit a strategy for RCS injection that conforms to NEI 12-06, or provides justification for an alternative to NEI 12-06.

28. Audit Item Reference SE 18-E - The portable FLEX SG injection Complete (This pump does not have primary and alternate injection points to the SGs OIP Update as specified by NEI 12-06, Section 3.2.2 and Table D-I. The NRC 8/201 5) staff requests that the licensee make available for audit a strategy for SeScin4o SG injection that conforms to NEI 12-06, or provides justification for ti nlsr an alternative to NEI 12-06.

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

Page 51 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 8

References The following references support the updates to the DIP 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-1 3-007).

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-13-01 5).

4. Letter from M. G. Korsnick (EGC) to Document Control Desk (NRC), "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)," dated February 20, 2015 (RS-15-061).

5.

NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," dated August 2012.

6.

UFSAR, "Updated Final Safety Analysis Report," Revision 25

7. ATT-5.5, "Attachment SAFW with Suction from DI Water Storage Tank during SBO,"

Revision 00000

8. Dwg-33013-1238, "Standby Aux Feedwater P&ID," Revision 034

9. FSG-6, "Alternate SAFW DI Water Storage Tank Makeup," DRAFT 7/10/2015

10. FSG-3, "Alternate Low Pressure Feedwater," DRAFT 7/23/2015

11. FSG-1, "Long Term RCS Inventory Control," DRAFT 7/24/2015

12. FSG-8, "Alternate RCS Injection," DRAFT 7/24/2015

13. ECP-14-000169-CN-090, "Alternate Charging System," Revision 0000

14. FSG-1 1, "Alternate SFP Makeup and Cooling," DRAFT 7/10/2015

15. 33013-1248, "Auxiliary Cooling Spent Fuel Pool Cooling P&ID," Revision 041

16. FSG-4, "ELAP DC Bus Load Shed/Management," DRAFT 7/13/2015

17. 33013-31 31, "480 VAC Single Line Diagram SAFW & NFPA805 1000KW Standby Diesel Generator Sets," Revision 003

18. 33013-2539, "AC System Plant Load Distribution One Line Wiring Diagram," Revision 028

19. ER-SC.2, "High Water (Flood) Plan," Revision 01001 Page 52 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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

20. DA-ME-14-003, "Fukushima Fuel Consumption Analysis," Revision 1

21. DA-ME-15-006, "Fukushima Timeline Analysis," Revision 0

22. STP-O-40.2, "Diesel Driven FLEX Generator Periodic/Annual Load Bank Test,"

Revision 00000

23. ECP-14-000749, "SAFW AB Cross Tie (Fukushima)," Revision 0000

24. WCAP-17601, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs,"

Revision 1

25. ECA-0.0, "Loss of All AC Power," DRAFT 7/10/2015

26. ME-343, "Equipment Specification for New Westinghouse Model 93 Reactor Coolant Pump Internals," Revision 001

27. 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. MF1 152)," dated February 19, 2014 (ML14007A704).

28. FSG-7, "Loss of Vital Instrumentation or Control Power," DRAFT 7/23/2015

29. CALC-2014-0002, "Cycle 38 Reactor Engineering Calculations," Revision 5/7/2014

30. RWA-1 433-001, "Ginna Standby Auxiliary Feedwater Room Heat-Up Analysis", Revision 0

31. ECP-1 3-000975-01 5-7B-01, "Design Change Technical Evaluation," Revision 0005

32. ECP-12-000459, "DDSAFW Project Electrical Design and Installation," Reference 0000

33. Letter from Jack R. Davis (NRC) to Joseph E. Pollock (NEI) "Endorsement of NEI Alternate Approach for Spare Hoses and Cables," dated May 18, 2015 (ML15125A442)

34. Letter from Nicholas Pappas (N El) to Jack R. Davis (NRC), "Alternative Approach to NEI 12-06 Guidance for Hoses and Cables," dated May 1,2015 (ML15126A135)

35. Letter from James Barstow (EGC) to Document Control Desk (NRC), "Response to March 12, 2012 Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations ot the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5,

Recommendation 9.3, Emergency Preparedness -

Staffing, Requested Information Items 1, 2, and 6 -

Phase 2 Staffing Assessment," dated June 8, 2015

36. RWA-1 316-001, "FLEX Intermediate Building GOTHIC Heat Up Analysis," Revision 0

37. ECP-1 4-000727, "Intermediate Building Block Wall Reinforcement," Revision 0000

38. FSG-5, "Initial Assessment and FLEX Equipment Staging", DRAFT 7/23/2015

39. ECP-13-000483, "DDSAFW Project SAFW Piping Tie-in Design and Installation,"

Revision 0000 Page 53 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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

40. DA-NS-92-014, "RCS Overpressurization Protection System Nitrogen Accumulator Tanks TRC03A & B Low-Pressure Limit," Revision 000

41. AR-AA-1 5, "N2 Accum B] Lo Press 725 psi," Revision 01001

42. 86-1234820, "Low Temperature Overpressure Analyses Summary Report" Revision 003

43. ER-FIRE.3 "Alternate Shutdown for Aux Building Basement/Mezzanine Fire,"

Revision 03500

44. 33013-1230, 'Alternate Charging System," P&ID, Revision 000

45. FSG-14, "Shutdown ROS Makeup," DRAFT 7/24/2015

46. DA-EE-97-069, "Sizing of Vital Batteries A and B," Revision 006

47. DA-EE-2001-028, "Vital Battery 8-Hour Capacity," Revision 001

48. DA-ME-99-033, "Vital Battery Temperatures During Station Blackout Event," Revision 000

49. DA-ME-1 4-020, "Deionized Water Tank Inventory Requirements," Revision 000

50. FSG-12, "Alternate CNMT Cooling," DRAFT 7/27/2015

51. Letter from John E. Maier (Rochester Gas and Electric Corporation) to Directory of Nuclear Reactor Regulation (USNRC), "SEP Topics V-10.B, V-11.A, V-11.B, VI-7.C.1, VII-3, and VIII-2, R. E. Ginna Nuclear Power Plant," dated June 23, 1981

52. ER-AFW.1, "Alternate Water Supply to the AFW Pumps," Revision 03700

53. Letter from Guy S. Vissing (NRC) to Dr. Robert C. Mecredy (Rochester Gas and Electric Corporation), Plant-Specific Safety Evaluation Report for USI A-46 Program Implementation at the R. E. Ginna Nuclear Power Plant (TAC No. M69449), dated June 17, 1999

54. Letter from M. G. Korsnick (EGC) to Document Control Desk (NRC),"Flood Hazard Reevaluation Report Pursuant to 10 CFR 50.54(f) Regarding the Fukushima Near-Term Task Force Recommendation 2.1: Flooding," dated March 11, 2015 (ML15072A008)

55. AR-C-13, "Battery Rooms Loss of Ventilation," Revision 00801

56. DA-EE-99-068, "Vital B]attery Room Hydrogen Analysis," Revision 003

57. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), "Seismic Hazard and Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 31, 2014 (ML14099A196)

58. FSG-10, "Passive RCS Injection Isolation," DRAFT 7/13/2015

59. Passport AR #01704249-77, "Ensure setpoint upgrade for ERG Rev 2+ include revised setpoints H.7 and H.8 based on DW-06-01 4," due 10/30/2015

60. PA-PSC-0965, "PWROG Core Cooling Position Paper," Revision 0

61. RWA-1 323-003, "Ginna RELAP5 ELAP Analysis for Mode 1," Revision 0 Page 54 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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

62. RE-i103, "Control of Reload Core Design," Revision 00304

63. Letter from M. G. Korsnick (EGC) 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)

64. RWA-1 403-001, "GOTHIC FLEX Containment Analysis," Revision 0

65. CALC-2014-0006, "Auxiliary Building Environmental Conditions during ELAP," Revision 0

66. Work Order C92852633, "Fukushima - NTTF 9.3 Communication - Install Satellite Phones"

67. ECP-14-000756, "Installation of FLEX Satellite Communications system to provide FLEX and NARs phone service to Control Room and TSC," Revision 0000

68. Letter from J. P. Boska (NRC) to J. E. Pacher (Exelon Generation Company, LLC), "R. E.

Ginna Nuclear Power Plant -

Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF1 152 and MF1 147)," dated June 18, 2015

69. Letter from D. M. Crutchfield (NRC) to J. E. Maier (Rochester Gas & Electric Corporation),

"Ginna - SEP Topics V-i10.B, RHR System Reliability, V-i11.B, RHR Interlock Requirements, and VII-3, Systems Required for Safe Shutdown (Safe Shutdown Systems Report)," dated September 29, 1981

70. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) - February 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-i2-049), dated February 27, 2014 (FLL-14-004)

71. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), R. E. Ginna Nuclear Power Plant - 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 27, 2013 Page 55 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 Figure 1 : 480 VAC Single Line Diagram BDBEE Flow Path Page 56 of 57

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT FIFTH 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 ill Figure 2: FLEX SAFW System Pumps and Connections Page 57 of 57