SBK-L-14153, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
| ML14246A193 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/26/2014 |
| From: | Dean Curtland NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, SBK-L-14153 | |
| Download: ML14246A193 (18) | |
Text
NExTera ENERGY P August 26, 2014 SBK-L-14153 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, LLC's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
References:
- 1. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A736)
- 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 (ML12229A174)
- 3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12242A378)
- 4. NextEra Energy Seabrook, LLC 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 Numnber EA- 12-049), dated October 26, 2012 (ML12311A013)
- 5. NextEra Energy Seabrook, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA- 12-049), dated February 26, 2013 (ML13063A438)
- 6. NextEra Energy Seabrook, LLC First Six-Month Status Report in Response to March 12, 2012 Conmmission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), dated August 28, 2013 (ML13247A178)
- 7. NextEra Energy Seabrook, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), dated February 27, 2014 (ML14064A188)
NextEra Energy Seabrook, LLC, P0O. Box 300, Lafayette Road, Seabrook, NH 03874 t I
U.S. Nuclear Regulatory Commission SBK-L-14153/Page 2 On March 12, 2012, the Nuclear Regulatory Comnission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra Energy Seabrook). Reference 1 was immediately effective and directs NextEra Energy Seabrook 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 NextEra Energy Seabrook initial status report regarding mitigation strategies. Reference 5 provided the NextEra Energy Seabrook overall integrated plan.
Reference I requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first 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. Reference 7 provided the second six-month status update. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1.
The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
This letter contains no new regulatory commitments.
If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August 2 , 2014.
Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President
U.S. Nuclear Regulatory Commission SBK-L-14153/Page 3 cc: NRC Region I Administrator J.G. Lamb, NRC Project Manager, ProJect Directorate 1-2 NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratchmann, NRR/JLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
Enclosure to SBK-L-14153 NextEra Energy Seabrook, LLC's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
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NextEra Energy Seabrook, LLC's Third 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 NextEra Energy Seabrook, LLC (Seabrook) developed and submitted an Overall Integrated Plan (Reference 1) in response to NRC Order EA-12-049. The Integrated Plan describes Seabrook's proposed diverse and flexible coping strategies (FLEX). This status report provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation, if any.
2 Milestone Accomplishments The following milestone has been completed since the submittal of the Overall Integrated Plan:
" Submit first 6 month status report
- Submit second 6 month status report
- Submit third 6 month status report 3 Milestone Schedule Status The following provides an update to Attaclunent 2 of the Seabrook Overall Integrated Plan (Reference 1). The table includes the current status of each item and whether the expected completion date has changed. As noted in the original station submittal these dates are planning dates which are subject to change as design and implementation details are developed.
The following milestone target completion dates have been adjusted or added:
In the submittal of the Overall Integrated Plan in February 2013, Seabrook included Westinghouse SHIELD low leakage RCP seals in all 4 RCPs as a backup strategy against significant RCS leakage to Containment. Seabrook intends to replace all 4 RCP seals with the SHIELD seal technology in October 2015 during refueling outage 17. Revised milestone target completion dates do not currently impact Seabrook's full compliance date.
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Target Revised Milestone Completion Activity Status Target Date Completion Date Submit Overall Integrated February 2013 Complete N/A Implementation Plan Submit 6 Month Updates:
Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Not Started N/A Update 5 Aug 2015 Not Started N/A Prepare engineering change packages for December 2014 Missile barrier N/A SEPS missile barrier and RCP low design and RCP leakage seals (if necessary) low leakage seals design both in development Prepare bid for construction of SEPS March 2015 In Progress N/A missile barrier Install RCP shutdown seals in four pumps April 2014 Contract for October 2015 in refueling outage # 17 RCP low leakage seals awarded Construct SEPS missile barrier December 2014 Not Started April 2015 Revise / develop procedures based upon December 2014 Working N/A approved strategies and engineering implementation packages Develop required training for station staff December 2014 Not Started N/A based upon draft procedure changes and engineering change packages.
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Target Revised Milestone Completion Activity Status Target Date Completion Date Procure SEPS / portable equipment December 2014 Design N/A refueling trailer modification in progress Submit 4 th 6-month status report to NRC February 2015 Not Started N/A Develop PMs for refueling trailer March 2015 Not Started N/A Store refueling trailer in Service Water June 2015 Working N/A Pump house Off-site resources implementation site - June 2015 Working N/A RRC operational fall 2015 5th and final 6-month status report to August 2015 Not Started N/A NRC Conduct walkthroughs / demonstrations August 2015 Working N/A of portable equipment connection points Implement training for station staff September Not Started N/A 2015 Install four RCP shutdown seals in October 2015 Working N/A Refueling Outage #17 Final implementation - Order full November Not Started N/A compliance letter to NRC 2015 4 Changes to Compliance Method Seabrook has received feedback in the form of NRC audit questions and subsequent teleconferences with NRC Staff reviewers. The NRC's Interim Staff Evaluation (ISE) was also received. As details are developed, additional information will be uploaded to ePortal for NRC staff review as part of the audit process.
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5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Seabrook currently expects to comply with the order implementation date and no relief/relaxation is required at this time. Should the NRC staff /ISE require significant changes to the strategies defined in the Overall Integrated Plan, it may be necessary for Seabrook to request relief/relaxation at some time in the future.
6 Open Items from Overall Integrated Plan and NRC Interim Staff Evaluation /TER The following Table provides a summary of the Pending Items documented in the Overall Integrated Plan:
Overall Integrated Plan Pending Actions Status 1 Revise ECA-0.0 to include a step to determine if an In Progress extended loss of offsite power event is in progress.
This determination will delineate future procedural strategies and transitions.
2 Revise ECA-0.0, Attachment 'A' to include a Table In Progress of loads for an extended loss of offsite power event or create a new Attachment with this information.
A seismic evaluation will be conducted on the Complete, no credit will be taken for connections that penetrate the upper half of the CST the non-seismic volume in the CST to determine if Seabrook can take credit for the entire tank volume for Phase 1 & 2 event coping.
4 Revise ECA-0.0 or ES-0. 1 to add a step to manually Not Started shutdown the motor-driven EFW pump if the TDEFW pump is running satisfactorily.
5 Add an Attachment to ES-0.2, ES-0.3 and ES-0.4 Not Started that provides a Table of electrical loads for responding to an extended loss of offsite power event.
6 Develop a SEPS genset refueling strategy from 1) an In Progress offsite supplier outside a 25 mile radius from the station (primary strategy), and 2) the EDG fuel oil storage tanks using a refueling trailer stored in the SW Pumphouse (backup strategy). This strategy will_
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Overall Integrated Plan Pending Actions Status include provisions for refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event that only a single SEPS is functional.
7 Revise ES-0.2, ES-0.3, and ES-0.4 to include a step Not Started for implementation of a SEPS genset refueling strategy.
8 Develop a FSG for refueling SEPS from the EDG In Progress fuel oil storage tanks using a portable refueling trailer. Utilize the information contained in existing procedure OS 1061.02, 'Receipt of SEPS Fuel Oil',
for development of the FSG.
9 Revise ES-0.2, ES-0.3, and ES-0.4 to include Not Started direction for connecting the backup diesel-driven air compressor to the Service Air system to restore Instrument Air system pressure.
10 Develop required Preventive Maintenance actions In Progress and Surveillance test procedures for the refueling trailer to be procured and stored in the Service Water Pumphouse.
11 Revise OS 1246.01, 'Loss of Offsite Power - Plant Not Started Shutdown', to address a reactor de-fueled condition
('Mode 7'). In that case restoration of spent fuel pool cooling is paramount as opposed to restoration of RHR cooling.
12 Conduct an Engineering Evaluation to determine if In Progress the existing hurricane enclosures for the SEPS gensets provide adequate missile protection. If protection is not adequate, develop a design change (EC) to add missile protection for the SEPS gensets.
13 Evaluate the 'seismic robustness' of SEPS and Complete determine if enhancements are needed with respect to the new Ground Motion Response Spectrum (GMRS) data for the site. This data will not be available until the seismic hazard re-evaluation is conducted in accordance Recommendation 2.1 of the RFI letter.
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Overall Integrated Plan Pending Actions Status 14 Once the site flooding re-evaluation is completed in Not Started accordance with Recommendation 2.1 of the RFI letter, determine if additional flood protection is necessary for SEPS.
15 Formalize the Engineering assessment of ELAP load In Progress capacity for a single SEPS genset and modify procedural guidance in the applicable EOPs and AOPs, as necessary.
16 Evaluate the impact of missile protection barriers In Progress that may be installed to protect the SEPS gensets on the capability to implement the snow removal plan and revise the plan as necessary.
17 Determine if a quantity of diesel fuel will be In Progress provided from the Regional Response Centers along with requested Phase 3 portable equipment. If not, establish a contract with a fuel supplier outside a 25 mile radius from the plant to provide fuel within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of a BDBEE.
18 Develop a FSG for staging and deployment of Phase In Progress 3 equipment from the RRCs into the Protected Area.
19 Develop a FSG for connecting the 2MW generators In Progress from the RRC to 4.16 KV Emergency Busses E5 and E6.
20 Develop a FSG for refueling the RRC generators or In Progress incorporate this action into the SEPS refueling FSG.
21 Implement low leakage RCP seals on all four RCPs All four seals are planned to be as a backup strategy to minimize RCS leakage into replaced with the low leakage seal Containment. design in October 2015.
22 Based on PWROG guidance, determine if new FSGs Complete, new FSGs are being are required that incorporate the existing guidance developed for Steam Generator and provided in SAG-I, 'Inject to the SGs', and SAG-3, RCS injection in the event the SEPS
'Inject to the RCS' or whether transition points to are unavailable.
these two SAMGs should be added to the applicable EOPs.
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Overall Integrated Plan Pending Actions Status 23 Develop a method for obtaining local readings for In Progress the 12 critical parameters identified on page 12 of 60 of the Integrated Plan and include in site procedures as appropriate.
7 Interim Staff Evaluation Open/Confirmatory Item Status Open/Confirmatory Item Status 1.2.4.8.A Verify that the enclosure for the SEPS The current SEPS environmental enclosures DGs and switchgear SEP-SWG-1 provides are non-safety related structures but are sufficient protection of the equipment from designed for a sustained wind loading of seismic events and wind driven missiles. 120 mph which exceeds the UFSAR value of 110 mph. The two SEPS genset enclosures, switchgear enclosure and associated transformers will be further protected from both tornado and hurricane missiles by a steel frame structure attached to the existing Seismic Class I cooling tower building with steel grating panels and designed for seismic loading.
The missile shield will also be designed for a 110 mph sustained wind load. The missile shield will provide protection from the full spectrum of UFSAR missiles, but will be based on a tornado wind speed of 200 mph and hurricane gust of 180 mph.
These wind speed values differ from the UFSAR design, but are consistent with the current guidance found in the applicable Regulatory Guides for maximum wind gusts. Specifically, a tornado wind speed of 200 mph is shown in R.G. 1.76 Figure 1 for Region II. The peak hurricane wind gust for the Seabrook location shown on Figure 3 of R.G. 1.221 is 180mph. The corresponding missile velocities will be calculated consistent with the UFSAR missile spectrum.
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The SEPS exhaust pipes will be seismically mounted and protected from missiles until they exit the missile shield. At this point a blowout disk or open connection will be installed to protect against over pressure if evaluation shows potential for excessive backpressure from postulated crimping of the piping above the shield.
The SEPS was installed originally as a non-seismic non-nuclear safety system. SEPS engines will be upgraded to meet the new EPRI GMRS for seismic. This is based on a seismic fragility analysis performed in 2012, which concluded that additional hold down bolts will be required for the engines and associated accessories, but modification of the gensets themselves was not required. To meet the augmented/expedited approach evaluation methodology, the SEPS hold down bolts will be designed to meet a bounding spectrum of the new EPRI GMRS and the existing SSE. Seismic design for the missile shield will be to the new GMRS, but additionally will remain functional for the SSE.
3.1.1.1 .A Protection of FLEX equipment from One B5b pump (PDDP) will continue to be seismic and high wind hazards - Confima that the stored in its current structure located in the PDDPs and hose trailers will be adequately "A" parking lot outside the protected area.
protected from seismic and high wind hazards. The associated hose and fittings are provided on a separate trailer stored in the same structure. This structure provides weather protection including high and low temperature conditions and is above the design basis flood elevation. Modification consisting of tie down anchors will be added to protect the shelter from high winds and seismic.
The second PDDP pump with associated hose and fittings and one new RCS high pressure makeup pump (PDDHP) with associated hose and fittings will be stored at least 1200 feet away, in a perpendicular orientation to the typical hurricane path, from the first PDDP (or a distance Page 9 of 15
evaluated based on area historical tornado size). A second new RCS high pressure makeup pump with associated hose and fittings will be stored at least 1200 feet away from first PDDHP. This ensures a PDDP pump, and a PDDHP pump will remain available during a tornado scenario.
Missile protection will be accomplished based on the separation distance between the two pumps and redundancy (only one PDDP pump or PDDHP pump is used for the backup strategy). Storage will be on concrete pads away from any seismic II/I concerns at an elevation above the design basis flood and not susceptible to Local Intense Precipitation (LIP) concerns. The pumps will be tied down to the pad for wind protection and seismic movement.
Basic environmental protection will be provided by an enclosure that will be rated for 110 mph sustained winds but will not be a seismic I/I hazard for the pumps (e.g. a wind rated fabric structure or seismic building).
3.1.1.2.A Confirm that at least one connection The tie in points for the PDDPs will be to point for each use of a PDDP is protected from a seismically qualified piping and free of any seismic event (includes access to the connection II/I concerns that could prevent access point and areas the operators have to access to needed to deploy or operate the pump.
deploy or control the PDDP).
3.1.1.2.B Confirmn that a tow vehicle for FLEX Multiple tow vehicles will be identified and equipment movement is reasonably protected from stored and procedurally controlled above a seismic event, flooding event, and high wind the flood level, away from adverse seismic event. interaction and secured against the 110 mph sustained design basis wind load.
3.1.1.3.A Procedural interface for seismic hazards FSGs are being developed to provide this
-Confirm that operators have procedural guidance guidance.
and references for the methods of obtaining local readings for critical parameters to support the implementation of the coping strategy, consistent with the guidelines in Section 3.2.1.10 of NEI 12-06.
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3.1.1.4.A Off-Site Resources - Confirm the The local staging area will be in the location of the local staging area for the RRC General Office Building parking area just equipment, and that access routes to the site, the off the South access road. This location is method of transportation, and the drop off area away from seismic interaction concerns and have been properly evaluated for all applicable above the flood elevation.
hazards.
i 3.1.5 High temperature - Confirm that the effects High temperature has been included in the of high temperature have been considered in the design and storage of FLEX equipment.
procurement, protection, and deployment of FLEX The SEPS generators and switchgear are equipment. located in environmental structures. At least one PDDP is located in a structure that protects against high temperature.
Equipment designed to IEEE standards of 104 degrees F bound postulated high temperature conditions at the site.
i 3.2.1.7.A Confirm that portable FLEX equipment Portable FLEX equipment (including the is included in the licensee's program to maintain SEPS gensets) will be maintained in equipment available for deployment in shutdown shutdown and refueling modes.
and refueling modes.
i 3.2.1.9.A Use of portable pumps - Confirm that The PDDP is capable of injection into the appropriate procedural guidance is provided for SGs after manual depressurization using the operation of the PDDPs for SG and RCS injection atmospheric dump valves. The injection as part of the FLEX strategies. path is into the main feedwater header to existing 2" drain lines located between the Feedwater Isolation Valves (FWIVs) and the main feedwater check valves. The existing guidance in the Station's Severe Accident Guidelines (SAG's) to depressurize the SG's and provide feedwater will be incorporated into the FSGs.
The PDDP is capable of makeup to a depressurized SG. Per the vendor curve for the PDDP, the pump is capable of producing 225 psig TDH at a flow rate of 1000 gpm. Per the pump curves, both pumps can produce significantly greater than 1,000 gpm flow before they approach their runout limits.
The 275 psig upper pressure limit used is a restriction based on the pressure rating of the temporary hoses and the capability of Page 11 of 15
the PDDP's. The SAG will be modified for use as an FSG.
Currently the Station's Severe Accident Guidelines (SAG's), provide procedural direction for use of the PDDP as an RCS makeup source, temporarily connecting either a high pressure suction source (defined as between 150 and 275 psig) or a low pressure suction source (defined as
<150 psig) to the suction side of either a Charging or a Safety Injection pump.
Seabrook is enhancing the FLEX strategy by including two Portable Diesel Driven High Pressure Makeup pumps (PDDHPs) that are capable of injection into the RCS.
Procedural guidance to connect and inject into the charging pump discharge header at either the A charging pump or B charging pump 4" discharge piping located in the charging pump rooms1 will be incorporated into the FSGs. The FSGs will use the new PDDHP, connecting the suction side of the pump to the Refueling Water Storage Tank (RWST) at an existing blank flanged connection in the PAB. The procedure will include steps to use the Reactor Makeup Water (RMW) tank, Boric Acid tanks, or Fire Water Main as alternate suction sources. The SAGs will be modified to use the new PDDHP as well.
i 3.2.1.9.B Confirm availability of the fire main to The PDDP suction can be aligned to the fire provide a suction source for the PDDP for all of main piping. The fire main will remain the hazards applicable to Seabrook. available for all hazards except for a seismic event. The source of water for the fire main at the fire pumps and tanks is not Seismic Class I and not protected from all hazards. Water inventory from this source that is protected from all hazards is therefore limited to the seismically qualified portions of the fire protection system. In the event of a seismic event, the FSGs will isolate this section of seismic fire main piping from the non-seismic portions 1 Preliminary, final location provided per EOC contract Page 12 of 15
to preserve the integrity of the seismic FP header.
There is also a 6" cross-connect line (via FP-V761 and FP-V970) from the Service Water header to the FP header that can be used to supply additional water to FP in the event that the FP tanks and non-seismic FP piping is lost.
In addition to the Fire Protection system, the Refueling Water Storage Tank is located within a Seismic Class I building and protected from all hazards. A suction path for the PDDP s and RCS makeup pumps will be developed as part of the Flex procedures to utilize this borated water source. Additional water sources include the Reactor Makeup Water Storage (RMW)
Tank & Boric Acid Tanks, the Detain Water Storage Tanks and the Condensate Storage Tank. The FSGs for operation of the PDDP s and the RCS makeup pump will list the available connections and will prioritize the selection of available suction sources.
i 3.2.2.A Confirm that the PDDPs and hose trailers The FLEX guidelines will not utilize the are incorporated into the FLEX guidelines for PDDPs for this purpose. The SFP is makeup and spray to the SFP. located below grade. The strategy for SFP makeup will use gravity drain from the RWST which is located inside a Class I structure protected from all hazards.
3.2.4.4.A Confirm that adequate portable lighting Portable lighting will not be needed if is available for operator use during an ELAP either SEPS genset is available. Portable event. battery powered lighting will be available for use during the ELAP event in the event both SEPS are inoperable.
3.2.4.4.B The NRC staff has reviewed the Upgrades have been completed.
licensee communications assessment (ADAMS Accession Nos. ML 12311A34 and ML13060A048) and has determined that the assessment and planned upgrades are reasonable (ADAMS Accession No. ML13102A254).
Confirm that the upgrades have been completed.
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3.2.4.7.A Confirm the source of water to be used The nearby brackish Brown's River is the for makeup to the service water cooling basin source of water.
tower by the portable diesel-driven cooling tower makeup pump.
3.2.4.8.B Confirm that any SEPS missile barrier The barrier will be designed to facilitate modifications do not interfere with the ability to snow removal from the intake system area.
remove snow from the SEPS DGs air intake system.
3.2.4.9.A Confirm that the refueling strategy for The SEPS refueling plan in the original OIP SEPS has been changed to require refueling to uses a small tank (500 gallons) mounted on begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event, a trailer to transfer diesel fuel from the EDG storage tanks to the SEPS within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. However, in the event that only one SEPS is available post ELAP, refueling will be required after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Accordingly the refueling requirement for SEPS has been revised to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The trailer and associated hoses will be stored in the Class I SW pump house. The refueling strategy will provide the 178 gal per hour needed to refuel the SEPS engines with in the required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.3.1 .A Confirm that the PDDPs will be included The PDDPs will be incorporated into the in the maintenance and testing (M&T) program in maintenance and testing program consistent conformance with the Electric Power Research with EPRI guidance.
Institute report on M&T.
3.3.2.A Confirm that the configuration control of Configuration control for the FSGs will FLEX strategies conforms to the guidance of conform to the guidance of Section 11.8 of Section 11.8 of NEI 12-06. NEI 12-06.
3.4.A Offsite resources - Confirm that NEI 12-06, The staffing analysis will confirm that NEI-Section 12.2 guidelines 2 through 10, regarding 12-06, Section 12.2 guidelines 2 through minimum capabilities for offsite resources, have 10, regarding minimum capabilities for been adequately addressed. offsite resources, have been adequately addressed.
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8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.
- 1. NextEra Energy Seabrook LLC - SBK-L-13038 - Overall Integrated Plan in Response to March 12, 2012 Conmmission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 26, 2013.
- 2. NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.
- 3. NextEra Energy Seabrook, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA- 12-049), dated August 28, 2013