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#REDIRECT [[L-13-243, Firstenergy Nuclear Operating Company'S, 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 No]]
| number = ML13238A260
| issue date = 08/26/2013
| title = Firstenergy Nuclear Operating Company'S, 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 No
| author name = Sena P P
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name =
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000334, 05000346, 05000412, 05000440
| license number = DPR-066, NPF-003, NPF-058, NPF-073
| contact person =
| case reference number = EA-12-049, L-13-243, TAC MF0841, TAC MF0842, TAC MF0961, TAC MF0962
| document type = Letter, Status Report
| page count = 13
| project = TAC:MF0841, TAC:MF0842, TAC:MF0961, TAC:MF0962
| stage = Other
}}
 
=Text=
{{#Wiki_filter:FENOC i"ffi 76 South Main Street Akron. Ohio 44308 Peter P. Sena lll President and Chief Nuclear Officer August 26,2013 L-13-243 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202 SUBJEQT: Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 FirstEnerov NucleAr Qperatinq Company's (FENOC's)
First Six-Month Status Report in Response to March 12. 2012 Commission Order Modifying Licenses with Reqard to Requirements for Mitiqation Strateqies for Beyond-Design-Basis External Eventl(Order Number EA-12-019) ffAC Nos. MF0841, MF0842. MF0961, and MF0962)On March 12,2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference
: 1) to FENOC. Reference 1 was immediately effective and directs FENOC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuef 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 lV, Condition C. Reference2 endorses industry guidance document Nuclear Energy Institute (NEl) 12-06, Revision 0 (Reference
: 3) with clarifications and exceptions identified in Reference
: 2. Reference 4 provided the FENOC initial status report regarding mitigation strategies.
Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP).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. The purpose of this letter is to provide the first six-month Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-13-243 Page 2 status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference
: 1. The attached reports for BVPS, DBNPS, and PNPP (Attachments 1,2, and 3, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.This letter contains no new regulatory commitments.
lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August ab ,2013.Respectfu lly subm itted,/* /,tz_Peter P. Sena, lll Attachments:
: 1. Beaver Valley Power Station First Six-Month Status Report for the lmplementation of Order EA-1 2-A49, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Davis-Besse Nuclear Power Station First Six-Month Status Report for the f mplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Perry Nuclear Power Plant First Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
 
==References:==
: 1. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012 NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-449, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29,2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) lmplementation Guide, Revision 0, dated August2012 FirstEnergy Nuclear Operating Company's (FENOC's)
Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard 2.3.2.3.4.
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-13-243 Page 3 to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 26,2012 5. FirstEnergy Nuclear Operating Company's (FENOC's)
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 27,2013 cc: Director, Office of Nuclear Reactor Regulation (NRR)NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS)NRC Resident Inspector (DBNPS)NRC Resident Inspector (PNPP)NRC Project Manager (BVPS)NRC Project Manager (DBNPS)NRC Project Manager (PNPP)Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments)
Site BRP/DEP Representative (without Attachments)
Utility Radiological Safety Board (without Attachments)
Attachment 1 L-13-243 Beaver Valley Power Station First Six-Month Status Report for the lmplementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 4 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Beaver Valley Power Station, Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Referen ce 2. This attachment provides an update of milestone accomplishments since submittal of the OlP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.2 MilestoneAccomplishments The following milestone(s) have been completed since the submittal of the OIP (Reference 1). This update is current as of July 19, 2013.. Completed review of the FLEX strategies following the submittal.
FLEX strategies are unchanged, and a vendor has been selected to perform the detailed design engineering for the plant modifications.. Submitted the Phase 1 staffing study (Reference
: 3) performed using the guidance in Nuclear Energy Institute (NEl) 12-01, Guideline for Assessrng Beyond Design Basis Accidenf Response Sfaffing and Communications Capabilities.
o Planned plant modifications have been targeted to the appropriate refueling outage and/or on-line work period.o The Pressurized Water Reactors Owners Group (PWROG) has issued the generic FLEX Support Guidelines.
3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The following milestones are being added as part of this update.Validation:
o Walk-throughs or Demonstrations:
February-2015 Attachment 1 L-13-243 Page 2 of 4 The revised milestone target completion dates do not impact the order implementation date.Milestone Target Completion Date Activity Status (as of 711$131 Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Complete 6 Month NRC Status Updates 08t28t15 Started Update 1 08t28t13 Started Update 2 02t28114 Not Started Update 3 08t28114 Not Started Update 4 02t27 t15 Not Started Update 5 08t28t15 Not Started Complete FLEX Strateqv Review March-2O13 Complete Validation N/A Not Started Februarv-2415 Wal k-th rouqh s or De monstrations N/A Not Started February-2015 Gomplete Staffing Analysis November-2015 Started November-2014 Submit NEI 12-01 Phase 1 Staffinq Studv April-2013 Complete Submit NEI 12-01 Phase 2 Staffinq Studv November-2015 Not Started November-2Q14 Gomplete Plant Modifications November-2015 Started Tarqet plant modifications April-2013 Complete Unit 1 Modifications complete Mav-2015 Started Complete 1 R22 outaqe madificafions November-2013 Started Complete on-l i ne mod ifications February-2415 Started Complete 1 R23 outaqe modifications Mav-2015 Started Unit 2 Modifications comolete November-2015 Started Complete 2R17 outaqe modifications Mav-2014 Started Com plete on-line modifications Auoust-2015 Started Complete 2R1 I outaqe modificafions November-2015 Started FLEX Storaqe Gomplete March-2O15 Not Started Complete Buildins Desisn December-2013 Not Started Commence Construction June-2014 Not Started Complete Construction March-2O15 Not Started River (UHS) Access Gomplete October-2014 Not Started Fence & Gate frtlodification Desiqn Auoust-2013 Not Started February-2014 New Fence & Gate Construction Auqust-2014 Not Started Securitv Barrier Pipe Penetrations Desiqn January-2014 Not Started Security Barrier Pipe Penetration Construction October-2014 Not Started On-site FLEX Equipment June-2014 Not Started December-2014 Confirm FLEX Eauipment Requirements April-2013 Started November-2013 FLEX Equinment Ordered Mav-2013 Not Started December-2013 FLEX Equipment Delivered Mav-2014 Not Started December-2014 Off-site FLEX Equipment April-2015 Not Started Develon Strateqies with RRC November-2013 Not Started June-201 4 Phase 3 Srfe Access Strate,gies in Place October-2014 Not Started Complete Near Sffe Sfagrng Location (as needed)March-2015 Not Started April-2015 Attachment 1 L-13-243 Page 3 of 4 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.6 Open ltems from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the draft safety evaluation (SE) and the status of each item.Draft Safetv Evaluation Open ltem Status N/A N/A Milestone Target Gompletion Date Activity Status (as of 71191131 Revised Target Completion Date Procedures Complete December-2014 Started PWROG issues NSSS-sp ecific quidelines June-2013 Complete/ssue Beaver Vallev FSG June-2014 Not Started/ssue M ainten ance Proced u res December-2014 Not Started Training Complete April-2015 Started Develop Traininq PIan September-2014 Started lmplement Traininq October-2014 Not Started April-2015 Submit Completion Report November-2015 Not Started Overall Inteqrated Plan Open ltem Status Ol 1 . Finalize the location of the FLEX storage building.
The deployment routes, distances, and times provided in this report are bounded for the currently proposed locations but will be updated as necessary.
Not Started Ol 2. Perform containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.
Not Started Ol 3. Modify the RWST at each unit to protect it from tornado missiles or identify a borated source that is protected from tornados and can be utilized to provide core cooling when steam generators are not available.
Not Started Attachment 1 L-13-243 Page 4 of 4 7 Potential Draft Safety Evaluation lmpacts There are no potential impacts to the draft safety evaluation identified at this time.I References The following references support the updates to the OIP described in this attachment.
FirstEnergy Nuclear Operating Company's (FENOC's)
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 27,2013.NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(0 Regarding Recommendations 2.1 ,2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated April 29,2013.1.2.3.
Attachment 2 L-13-243 Davis-Besse Nuclear Power Station First Six-Month Status Report for the lmplementation of Order EA-1 2-A49, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 3 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference2.
This attachment provides an update of milestone accomplishments since submittal of the OlP, 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 the submittal of the OIP (Reference 1). This update is current as of July 19, 2013.. Planned plant modifications have been targeted to the appropriate refueling outage and/or on-line work period.3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The following milestones are being added as part of this update.Validation:. Walk-throughs or Demonstrations:
April-2016 The revised milestone target completion dates do not impact the order implementation date.
Attachment 2 L-13-243 Page 2 of 3 Milestone Target Gompletion Date Activity Status (as of 71191131 Revised Target Gompletion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Complete 6 Month NRC Status Updates 02t28t16 Started Update 1 08128113 Started Update 2 02t28114 Not Started Update 3 08128t14 Not Started Update 4 02t27 t15 Not Started Update 5 08t28115 Not Started Update 6 02t28t16 Not Started Validation N/A Not Started April-2016 Walk-th rough s or De monstrations N/A Not Started April-2016 Complete Staffinq Analvsis November-2015 Not Started October-2015 Submit NEI 12-01 Phase 2 Staffino Sfudv November-2015 Not Started October-2415 Complete Plant Modifications April-2016 Started Tarset plant modifications Mav-2013 Complete Mod ifications com plete April-2016 Started Complete 1 Rl I outaqe modifications June-2014 Complete*Complete on-line modifications Februarv-2016 Started Complete 1 R19 outaqe modifications April-2016 Started Com plete Com m u n ication s Modifications April-2016 Started Complete SFP Level lndication Modificafrons April-2016 Started FLEX Storage Complete April-2016 Not Started Complete Buildinq Desiqn December-2014 Not Started Commence Construction June-2O15 Not Started Complete Construction April-2016 Not Started On-site FLEX Equipment April-2016 Started Confirm FLEX Equipment Reouirements January-2014 Started FLEX Equipment Ordered January-2015 Not Started FLEX Equipment Delivered April-2016 Not Started Off-site FLEX Equipment April-2016 Not Started Develop Strateqies with RRC June-2014 Not Started Phase 3 S,fe Access Strateqies in Place April-2016 Not Started Complete Near Sife Sfaging Location (as needed)April-2016 Not Started Procedures Complete April-2016 Started PWROG issues NSSS-sp ecific quidelines June-2013 Started Auqust-2013
/ssue Davis-Besse FLEX Strategy Guidelines June-2014 Not Started June-2015/ssue Maintenance Procedures April-2016 Not Started Training Complete April-2016 Not Started Develop Traininq Plan September-2015 Not Started Implement Traininq April-2016 Not Started Submit Completion Report April-2016 Not Started* Modifications are targeted for 1R19 and on-line; none targeted for 1 R18.
Attachment 2 L-13-243 Page 3 of 3 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.6 Open ltems from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the draft safety evaluation (SE) and the status of each item.Draft Safety Evaluation Open ltem Status N/A N/A 7 Potential Draft Safety Evaluation lmpacts There are no potential impacts to the draft safety evaluation identified at this time.8 References The following references support the updates to the OIP described in this attachment.
: 1. FirstEnergy Nuclear Operating Company's (FENOC's)
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 27,2013.2. 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.Overall Inteqrated Plan Open ltem Status Ol 1. Finalize locations for FLEX storage buildings.
Deployment routes, distances and times contained in the submittal are bounded for the currently proposed locations but will be updated as necessary.
Started Ol 2. Finalize the strategy for providing a protected source of borated water to support FLEX strateqies.
Started Ol 3. Determine if a mobile boration unit and/or water purification unit is required to support the FLEX strategies.
Started Attachment 3 L-13-243 Perry Nuclear Power Plant First Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 3 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overalt Integrated Plan (OlP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Referen ce 2. This attachment provides an update of milestone accomplishments since submittal of the OlP, 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 the submittal of the OIP (Reference 1). This update is current as of July 19, 2013.Completed review of the FLEX strategies following the submittal.
FLEX strategies are unchanged, and a vendor has been selected to perform the detailed design engineering for the plant modifications.
Planned plant modifications have been targeted to the appropriate refueling outage and/or on-line work period.3 Milestone Schedule Status The following provides an update to Attachment 2of the OlP. lt provides the activity status of each item and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
The following milestones are being added as part of this update.Validation:. Walk-throughs or Demonstrations:
March-2O15 The following milestones replace previous modification milestones.
Complete Plant Modifications:
o Target plant modifications o Complete on-line modifications o Complete 1R15 outage modifications Attachment 3 L-13-243 Page 2 of 3 The revised milestone target completion dates do not impact the order implementation date.Milestone Target Completion Date Activity Status (as of 71191131 Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02t28113 Complete 6 Month Status Updates 02t27 t15 Started Update 1 08t01t13 Started Update 2 02128t14 Not Started Update 3 08128114 Not Started Update 4 02t27 t15 Not Started FLEX Strategy Review Mav-2013 Complete Validation N/A Not Started March-2O15 Walk-th rouqh s or Demonstration s N/A Not Started March-2015 Complete Staffing Analysis*January-2014 Not Started October-2014 Complete Plant Modifications April-2015 Started March-2015 Tarqet plant modifications Mav-2013 Complete Complete on-line modifications December-2014 Started Complete 1 Rl 5 outaqe modifications February-2015 Started March-2O15 FLEX Storaqe January-2015 Not Started Complete Unit 2 Aux Building for storage and Use January-2015 Not Started Conveft Unit 2 diesel Building for storage and Use January-2015 Not Started Lake (UHS) Access November-2014 Started Reqrade road to barqe slip area October-2014 Not Started Fence & Gate Construction modifications October-2014 Not Started Securitv Barrier Pipe Penetrations Design January-2014 Started February-2014 Security Barrier Pipe Penetration Construction November-2014 Not Started On-site FLEX Equipment January-2015 Not Started October-2014 Ordered Auqust-2013 Not Started November-2013 Delivered Januarv -2015 Not Started October-2014 Off-site FLEX Equipment March-2015 Not Started Develop Stratesies with RRC December-2013 Not Started June-2014 Complete Near Slfe Sfagrng Location (as needed)March-2015 Not Started Phase 3 SrTe Access Strateqies in Place November-2014 Not Started Procedures March-2O15 Started Implement EPG/SAG Rev 3 Guidance Auqust-2014 Started Create Perry FSG Mav-2014 Not Started lmplement Perrv FSG March-2015 Not Started Cre ate M ai nten ance Proced ures July-2014 Not Started Trainins March-2015 Started Develop EOP Traininq Plan January-2014 Started Implement EOP Traininq July-2014 Not Started March-Z015 Develop SAMG Trainin,s Plan January-2014 Not Started Attachment 3 L-13-243 Page 3 of 3*Changed milestone from Perform Staffing Analysis to Complete Staffing Analysis.4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.6 Open ltems from Overall Integrated Plan and Draft Safety Evaluation None.7 Potential Draft Safety Evaluation lmpacts There are no potential impacts to the draft safety evaluation identified at this time.8 References The following references support the updates to the OIP described in this attachment.
: 1. FirstEnergy Nuclear Operating Company's (FENOC's)
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 27,2013.2. 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.Milestone Target Completion Date Activity Status (as of 7llgll3l Revised Target Gompletion Date lmplement SAMG Traininq January-2015 Not Started March-2015 Develop FLEX Traininq Plan Auoust-2014 Not Started I mplement FLEX Training November-2014 Not Started March-2015 Submit Gompletion Report March-2015 Not Started}}

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