ML14059A078

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

ML14059A078
Person / Time
Site:	Palisades
Issue date:	02/28/2014
From:	Vitale A J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, PNP 2014-011
Download: ML14059A078 (12)

Text

Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 PNP 2014-011 Tel 269 7642000 Anthony J. Vitale Site Vice President February 28, 2014 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

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

Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events, dated March 12, 2012 (ADAMS Accession No. 12054A736)

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 8eyond-Design-8asis External Events, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML 12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML 12242A378)

4. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2012-091, Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated October 25,2012 (ADAMS Accession No. ML 12300A065

5. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-010, Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated February 28,2013 PNP 2014-011 Page 2 of 2 6. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, Palisades Nuclear Plant 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

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference

1) to Entergy Nuclear Operations, Inc. (ENO). Reference 1 was immediately effective and directs ENO 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. 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 NEI12-06, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference

2. Reference 4 provided the Palisades Nuclear Plant (PNP) initial status report regarding mitigation strategies.

Reference 5 provided the PNP overall integrated plan. Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first six-month status report. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The attachment provides an update of milestone accomplishments, including any changes to the compliance method, schedule, or need for relief and the basis, if any. This letter contains no new commitments and no revised commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28 , 2013. Sincerely, ajv/jse

Attachment:

Palisades Nuclear Plant Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) cc: Office Director, NRR, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC ATTACHMENT Palisades Nuclear Plant Second Six-Month Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) 1 Introduction Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an overall integrated plan (Reference 1), which documented the diverse and flexible strategies (FLEX), in response to Reference

2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. 2 Milestone Accomplishments The following milestone(s) have been completed since July 31, 2013, and are current as of January 31,2014.

• First Six-Month Status Report -August 2013

• Second Six-Month Status Report -Complete with submission of this document in February 2014

• FLEX Strategy Evaluation

-January 2014 3 Milestone Schedule Status The following provides an update to Attachment 2 of the overall integrated plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

• Perform Staffing Analysis The Perform Staffing Analysis milestone completion date has been changed to April 2014. This new milestone target completion date does not impact the Order implementation date.

• Modifications Evaluation The Modifications Evaluation milestone target completion date has been changed to April 2014. This new milestone target completion date does not impact the Order implementation date. Page 1 of 10 Target Revised Target Milestone Completion Activity Status Completion Date* Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Six-Month Status Updates Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Jan 2014 Complete Perform Staffing Analysis Dec 2013 Started Apr 2014 Modifications Modifications Evaluation Jan 2014 Started Apr 2014 Engineering and Implementation N-1 Walkdown Feb 2014 Started Design Engineering May 2014 Started I mplementation Outage Oct 2015 Not Started On-site FLEX Equipment Purchase and Procure Jun 2014 Started Off-site FLEX Equipment Develop Strategies with RRC Jan 2015 Started Install Off-Site Delivery Station (If Oct 2015 Not Started Necessary)

Procedures Pressurized Water Reactor Owners Group (PWROG) issues Nuclear Jun 2013 Complete Steam Supply System (NSSS)-Specific Guidelines Create PNP FLEX FSG Mar 2015 Not Started Create Maintenance Procedures Mar 2015 Not Started Training Develop Training Plan Jun 2015 Not Started Training Complete Sept 2015 Not Started Validation I Demonstration Oct 2015 Not Started Submit Completion Report Oct 2015 Not Started "Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports Page 2 of 10 4 Changes to Compliance Method The following changes are being incorporated to the FLEX strategy for PNP. 1. Overall Integrated Plan (OIP) page 9, item 3 (and other locations of OIP) states the battery life will be four hours. The four hour battery capacity was determined to provide insufficient margin for transition to Phase 2. Based on analysis and planning for a deeper load shed, the installed battery capacity will be extended to eight hours (see Open Item 016). Therefore, the time at which a portable FLEX generator is required to be deployed and operational has been extended from hour 4 to hour 8 based on battery capacity.

2. OIP page 10, item 9 (and other locations of DIP) stated that LC-19 will be repowered from the portable FLEX generator.

This remains the primary strategy to provide power to battery chargers.

However, Load Center 20 will also be modified similar to Load Center 19 to provide diverse connection locations to the battery chargers.

3. OIP page 11, item 10 (and other locations of OIP) stated that a FLEX portable transfer pump will be used to refill the CST. The Phase 2 core cooling strategy has changed such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided by the FLEX portable transfer pump directly to the main feed water (MFW) system piping or the auxiliary feed water (AFW) system piping via hose connections, thereby bypassing the CST. 4. OIP page 11, item 10 (and other locations of OIP) requires commencement of deployment of a portable FLEX pump two hours after the event such that it can be operational four hours after the event. This was based on the limited protected inventory of the condensate storage tank (CST) and the primary system makeup storage tank (T-81). Additional inventory in the CST and T-81 will now be protected (see Open Item 013) which increases the volume available for Phase 1 of the beyond-design-basis external event (BDBEE). Therefore, the time at which the FLEX pump is required to be deployed and operational has been delayed from hour 4 to hour 8 based on CST and T-81 protected inventory.

Additionally, the strategy of refilling the CST has changed such that the CST refill will not be used. Instead inventory for feeding the steam generators will be provided directly to the main feed water (MFW) system piping or the auxiliary feed water (AFW) system piping via hose connections, thereby bypassing the CST (see Open Item 017). 5. OIP page 11, item 14 (and other locations of OIP) credits the battery room exhaust fans for removal of hydrogen from the battery rooms. It has been determined that the battery room exhaust fans are not robust and cannot be credited.

Therefore a new strategy developed for control of hydrogen will employ the use of portable fans for ventilation in battery rooms. Also see Open Item 018. 6. OIP page 11, item 15 (and other locations of DIP) credits the volume control tank (VCT) and safety injection refueling water tank (SIRWT) as borated sources of water for primary coolant system (PCS) inventory and reactivity control. However, it has been determined that the VCT and SIRWT are not robust for all applicable external hazards. Therefore the VCT and SIRWT are no longer the credited sources of borated water. Concentrated boric acid storage tanks (T-53A and T-53B) will now be credited as the borated water sources for these functions early in Phase 2. Later in Page 3 of 10 Phase 2 (> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), the boric acid batching tank (T-77) will be used to batch required borated water inventory.

Also see Open Item 0116. 7. 01 P page 12, item 16 states that spent fuel pool (SFP) equipment (hoses and monitor nozzles) will be deployed at hour 18 to prevent SFP level from dropping below the level of 15 feet above the fuel at hour 20.93. Under worst case conditions it is estimated that boiling could occur beginning at approximately 5.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore operators would be required to enter the SFP area under potentially onerous conditions.

It was determined that in order to protect personnel from the need to enter the SFP area after it is already boiling that actions should be taken for deployment of SFP cooling equipment (hoses and monitor nozzles) prior to the start of boiling. The action will now be taken at approximately five hours after event initiation and prior to SFP boiling in order to mitigate potential habitability concerns after boiling. 8. OIP page 12, item 21 (and other locations of OIP) credit a mobile water purification unit (and/or other large regional response center (RRC) equipment) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event. This timing was determined to be unlikely and unsupported by the RRC for large equipment such as purification units, 4160 V diesel generators, and boration units. Therefore the purification units will not be credited until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the event. 9. OIP page 18, in the section for PWR Installed Equipment Phase 1, it is stated that the turbine driven auxiliary feedwater (TDAFW) pump is not credited for seismic events because the turbine driver is not seismically qualified.

The TDAFW system (including the turbine driver) has now been qualified as seismically robust and is credited for all external events. See Open Item 015 in this report for additional information.

10. OIP page 19, under Steam Generators Available for Cooling (Modes 1-4), states that a modification will be required to provide for remote manual operation of the ADVs to begin cooling down the plant at hour 2. The modification selected, and which will allow for the remote manual operation of the ADVs, is the installation of backup nitrogen bottles to last through Phase 1 and connection point for an air compressor to be connected for Phase 2. 11. OIP page 19, under Key Reactor parameters (and other locations of OIP) the level indications for tank T-81 and SIRWT are credited.

Because the CST and T-81 are cross-tied, it has been determined that the level indication for the CST is sufficient to indicate the available inventory in both tanks. Therefore level indication for T-81 is redundant and is not required.

SIRWT level indication is not required because the tank is no longer credited.

12. OIP page 62 (and other locations of OIP) states use of multiple FLEX generators.

PNP has determined that it is preferable to use only one FLEX generator in the PNP strategy.

This FLEX generator will be sufficiently sized to carry all the loads that are planned for use in the FLEX strategy.

13. During analysis of site seismic capabilities it was determined that PNP is susceptible to soil liquefaction.

Therefore new storage locations are being developed and Attachment 3 of OIP will be updated for storage, staging and routing. Also see Open Item 011. Page 4 of 10 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation ENO 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 Staff Evaluation The following tables provide a summary and status of any open items documented in the overall integrated plan and any open items or confirmatory items documented in Interim Staff Evaluation (ISE). A fourth table includes a listing of audit questions and the status of each item. Overall Integrated Plan Open Item 011. Perform analysis on Palisades' susceptibility to soil liquefaction and potential consequences on the FLEX implementation plan. 012. Develop Phase 3 deployment strategy with correspondence with the RRC. 013. Evaluate the need to missile protect primary system makeup storage tank (T-81) and other external tanks. 014. Select the location of FLEX equipment storage facility.

Status Started Preliminary borings were performed on site and soi/liquefaction susceptibility was identified.

Based on this information a set of FLEX equipment will be stored inside the protected area (PA) for the seismic event. The other set of FLEX equipment will be stored outside of the PA and be protected against the tornado event. Both locations will be protected from all other BDBEEs. Additional planning is under way to address other impacts to equipment storage and deployment.

See also Change to Compliance Method Item 13. Started Started The CST volume alone is insufficient to provide the required inventory, when considering available on site resources for SG makeup during Phase 1. Additional inventory is required and can be provided by tank T-81. T-81 will be verified/credited as robust for all applicable external events. As required, modifications will be implemented to protect both the CST and primary system makeup tank for all applicable external events. See also Change to Compliance Method Item 4. Started Refer to 011. One set of equipment will be stored in Sea-Land containers inside the PA for the Seismic event. An additional set(s) of equipment will be stored outside the PA in a structure(s) providing an appropriate level of protection for the tornado event. Both sets will be protected against the other applicable (screened-in)

BDBEE external hazards. Page 5 of 10 Overall Integrated Plan Open Item Status 015. Perform seismic evaluation of turbine-Started driven auxiliary feedwater pump (TDAFWP) Seismic evaluation documents the seismic driver K-8. qualification of the pump and associated components.

The TDAFW pump is qualified with the exception of an outlier related to a check for bolt tightness.

Bolt tightness on the pump is being performed under WO# 372138 and documented under EC 46465. See also Change to Compliance Method Item 9. 016. Evaluate strategies to extend battery Started coping time. The battery load shedding strategy is currently being revised to extend the battery coping time through shedding loads in addition to those identified in the station blackout procedure.

Preliminary results indicate a coping time of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the installed batteries accompanying the expected deep load shed list. See also Change to Compliance Method Item 1. 017. Evaluate sources of non-borated water Complete/Closed in addition to condensate storage tank (T-2) After depletion of T-2 and T-81 , makeup to and T-81. the SGs will be from a portable pump with the credited suction source being Lake Michigan.

Modifications to credit sources of non-borated water for sources other than T-2 and T-81 were determined to not be required.

018. Palisades Probabilistic Risk Assessment Complete/Closed (PRA) to provide justification why battery Palisades PRA provided multiple evaluations room ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. for battery room hydrogen generation.

It was determined that supplemental ventilation is required approximately

1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s

after charging begins for removal of hydrogen.

Ventilation is not required for Phase 2 temperature control. This supplemental ventilation has been included in the Palisades strategy.

See also Change to Compliance Method Item 5. 019. Evaluate the effects of FLEX on security Started procedures.

The security plan/program will be updated to correspond to FLEX procedures.

0110. Evaluate requirements of mobile Complete/Closed purification unit from RRC. It was determined that the 250 gpm RRC demineralized water treatment unit is preferred over the 100 gpm RRC reverse osmosis unit in order to support SG makeup and provide makeup to the RRC mobile Page 6 of 10 Overall Integrated Plan Open Item Status boration unit. 0111. Evaluate requirements of mobile Complete/Closed boration unit from RRC. The required flow rate of borated water for PNP is a maximum of 58.3 gpm. 0112. Evaluate methods of venting the fuel Complete/Closed handling building.

The strategy for venting the fuel handling building will be to open an existing double leaf door/hatch on the roof of the building.

0113. Evaluate the use of high-efficiency LED Complete/Closed lighting.

The use of high-efficiency LED lighting has been evaluated for its impact to battery coping time and control room heat loads. LED lighting would have minimal impact and is not required or recommended.

0114. Perform evaluation to determine if Complete/Closed additional parameters will need to be In addition to NE112-06, PWROG FLEX monitored during FLEX activities.

guidance was reviewed for key parameter monitoring.

The NE112-06 and PWROG guidance regarding recommended instrumentation has been incorporated into . the FLEX strategy and the power supply for these instruments evaluated.

All the credited instruments are powered by battery/DC buses and available throughout the event. 0115. Perform analysis to ensure survivability Started of containment.

Containment analysis has been completed using the Modular Accident Analysis Program (MAAP) and is being reviewed for owner's acceptance.

Preliminary results of this analysis show containment design parameters will not be exceeded for the at-power scenario (Le., event initiating in Mode 1). For the most conservative shutdown scenario (Le., Mode 5 reduced inventory), preliminary results of the analysis show that actions will be required to prevent exceeding the design limits of containment.

0116. Evaluate borated water sources in Complete/Closed addition to safety injection refueling water All additional sources of borated water were tank (SIRWT). evaluated for use following a BDBEE. The concentrated boric acid storage tanks (T-53A and T -53 B) are the credited source of borated water. These tanks are analyzed to provide sufficient borated water for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, borated water will be batched as necessary for inventory control using the boric acid batching tank T-77. See also Change to Compliance Page 7 of 10 Overall Integrated Plan Open Item Status Method Item 6. 0117. Entergy, for the Palisades site, will Complete negotiate and execute a contract with Strategic Alliance for FLEX Emergency Response (SAFER) that will meet the requirements of NEI 12-06, Section 12. 0118. Evaluate a location to install a tee in Complete/Closed the service water system to allow the ultimate Several locations in the service water system heat sink (UHS) FLEX pump to provide were evaluated.

A pipe elbow downstream of cooling. service water system (SWS) pump P-7C was identified as the best location for connecting a pipe tee to allow flow from the RRC UHS pump. 0119. Evaluate the use of lake water to cool Started the steam generators during an extended An analysis has been completed and is being loss of ac power (ELAP). reviewed for owner's acceptance that determines the impacts on the steam generators when using lake water as the makeup source. 0120. Evaluate time until primary coolant Complete/Closed system (PCS) makeup is necessary in Modes An evaluation was performed that 5&6. documented the time until PCS makeup is required in shutdown modes. The time when makeup is required varies greatly depending on the status of the PCS when the event occurs (Le., PCS level, pressure, and temperature).

The most limiting scenario was found to be such that PCS makeup could be required as early as one hour after the event if the PCS is vented and at reduced inventory.

High risk evolutions such as vented PCS and reduced inventory will be managed by outage risk planning and contingency actions such as pre-staging equipment as discussed in the NRC endorsed white paper on Shutdown / Refueling Modes. 0121. Evaluate connection to ensure cooling Complete/Closed water can be provided for containment air Cooling water flow to the containment air fans. fans is through the service water system addressed in the status update to 01 18. Connection of the RRC supplied FLEX UHS pump to the SWS will provide the necessary means/connection for cooling water flow to the containment air coolers. 0122. Evaluate the robustness of the Complete/Closed charging pumps. The charging pumps have been evaluated as robust for seismic events. The pumps are Page 8 of 10 Overall Integrated Plan Open Item Status located inside the auxiliary building and protected against all other external hazards. Interim Staff Evaluation Open Items Status The U.S. Nuclear Regulatory Commission (NRC) has N/A not issued an Interim Staff Evaluation for Palisades; therefore, there are no open items for the Interim Staff Evaluation identified at this time Interim Staff Evaluation Confirmatory Items Status The NRC has not issued an Interim Staff Evaluation for NIIA Palisades; therefore, there are no confirmatory items from the Interim Staff Evaluation identified at this time Audit Question Open Items Status Completion or Target Date PAL-002 Closed PAL-003 Closed PAL-004 Closed PAL-007 In progress Aug 2014 PAL-008 In progress Aug 2014 PAL-011 In progress Aug 2014 PAL-012 In progress Aug 2014 PAL-013 In progress Aug 2014 .. PAL-014 In progress Aug 2014 PAL-015 Closed PAL-016 In progress Aug 2014 PAL-017 In progress Oct 2015 PAL-018 In progress Aug 2014 PAL-019 In progress Aug 2014 PAL-020 Closed PAL-021 In progress Aug 2014 PAL-022 Complete e-Portal updated PAL-023 In progress Aug 2014 PAL-024 Closed PAL-025 In progress Aug 2014 PAL-026 In progress Aug 2014 PAL-027 In progress Aug 2014 PAL-028 In progress Aug 2014 PAL-030 In progress Aug 2014 PAL-033 In progress Aug 2014 PAL-035 In progress Aug 2014 PAL-036 In progress Oct 2015 PAL-037 In progress Aug 2014 PAL-039 Closed PAL-040 In progress Oct 2015 PAL-041 Closed PAL-043 In progress Aug 2014 Page 9 of 10 Audit Question Open Items Status Completion or Target Date PAL-044 In progress Aug 2014 PAL-04S In progress Aug 2014 PAL-046 In progress Aug 2014 PAL-04? In progress Aug 2014 PAL-048 In progress Aug 2014 PAL-049 In progress Aug 2014 PAL-OSO In progress Aug 2014 PAL-OS 1 In progress Aug 2014 PAL-OS3 In progress Aug 2014 PAL-OS4 In progress Aug 2014 PAL-OSS Closed PAL-OS? In progress Aug 2014 PAL-OS? In progress Aug 2014 7 Potential Interim Staff Evaluation Impacts The NRC has not yet issued an interim staff evaluation for PNP; therefore, there are no potential impacts to the interim staff evaluation identified at this time. S References The following references support the updates to the Overall Integrated Plan described in this attachment.

1. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-010, Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2013 2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No. ML 120S4A?36).

3. Entergy Nuclear Operation, Inc. (ENO) letter to NRC, PNP 2013-064, Palisades Nuclear Plant 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. Page 10 of 10