PLA-7137, Second Six-Month Status 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

Second Six-Month Status 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

ML14062A061
Person / Time
Site:	Susquehanna
Issue date:	02/28/2014
From:	Rausch T Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14063A523	List: PLA-7137, Second Six-Month Status 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
References
EA-12-049, PLA-7137
Download: ML14062A061 (12)

Text

Timothy S. Rausch Senior Vice President

& Chief Nuclear Officer FEB 2 8 2014 PPL Susquehanna, LLC 769 Salem Boulevard Berwick, P A 18603 Tel. 570.542.3345 Fax 570.542.1504 tsrausch@pplweb

.com U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION 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 (NRC ORDER EA-12-049)

PLA-7137 Docket No. 50-387 and No. 50-388

References:

1. 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 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. PPL Letter (PLA-6923), "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 29, 2012 5. PPL Letter (PLA-6981), "Overall Integrated Plan in Response to March 12 , 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2013 6. PPL Letter (PLA-7072), "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049), " dated August 26 , 2013 7. NRC Order EA-13-1 09, " Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, " dated June 6, 2013 8. PPL Letter (PLA-7071), " First Six Month Status Report in Response to March 12 , 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049), "dated August 26 , 2013 9. PPL Letter (PLA-7134), "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'" dated February 20, 2014 10. NRC Letter from J. S. Bowen to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 And 2-Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889), " dated January 24 , 2014 (ADAMS# ML13339A764)

The purpose of this letter is to provide PPL Susquehanna, LLC's (PPL) 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. Enclosure 1 provides Document Control Desk PLA-7137 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. Enclosure 2 is a revision of the Mitigation Strategies Overall Integrated Plan. This revision documents the change from 480 V AC generators to 4160 V AC generators in Phase 2 and several other updates. Enclosure 2 contains security-related information to be withheld from public disclosure under 10 CFR 2.390. On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to PPL Susquehanna, LLC (PPL). Reference 1 was immediately effective and directs PPL to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment cooling, 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 PPL' s initial status report regarding Mitigation Strategies.

Reference 5 provided PPL's initial Mitigation Strategies 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. The Request for Relaxation contained in Reference 9 supersedes the Request for Relief made in Reference

6. The Request for Relaxation is based on NRC mandated changes to the Hardened Containment Vent System implementation dates that impact the Mitigation Strategy Overall Integrated Plan. Specifically, the change in implementation dates for the Hardened Containment Vent Order (NRC Order EA-12-050 was rescinded and superseded by NRC Order EA-13-1 09) impacts the Mitigation Strategy Overall Integrated Plan and implementation timeline.

This letter contains no new or revised regulatory commitments.

If you have any questions regarding this report, please contact Mr. John L. Tripoli at 570-542-3100. Document Control Desk PLA-7137 I declare under penalty of peijury that the foregoing is true and correct. Executed on: \ \ Sffic(7<<2 T. S. Rausch Enclosure 1: PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 2: PPL Susquehanna'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), (February 2014) Security-Rela ted InformationWithhold from Public Disclosure Under 10 CFR 2.390. Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP Enclosure 1 to PLA-7137 PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 1 to PLA-7137 Page 1 of8 PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events 1. Introduction PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan (Reference

1) documenting the diverse and flexible strategies (FLEX), in response to Reference

2. This Second Six Month Status Report provides an update of milestone accomplishments since submittal of the First Six Month Status Report (Reference

7) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. [NOTE: References cited in this enclosure are contained in Section 8.] 2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of January 31, 2014.

• Open Items 5, 6, 12 and 14 have been completed.

• Numerous milestones have been started as listed on the Section 3, Milestone Schedule Status table, for example -Phase 2 Staffing Analysis, construction of the equipment storage building, selection of staging areas for Phase 3, modification installation, and training.

3. Milestone Schedule Status The following table provides an update to Attachment 2, Milestone Schedule, 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.

The revised milestone target completion dates do not impact the Order implementation date at this time. The ISE from the NRC (Reference

9) has been received in time to support implementation of the Mitigation Strategies.

The Open Item and Confirmatory Items identified in the ISE will be addressed by the Regulatory Audit Process.

Milestone Submit 60 Day Status Report Submit Overall Integrated Plan Expected receipt of draft SER from NRC (or ISE) Submit 6 Month Updates: Update 1 Update 2 Update 3 Update 4 Update 5 Update 6 Update 7 FLEX Strategy Evaluation Unit2 FLEX Strategy Evaluation Unit 1 Validation by Walk-tbroughs or Demonstration( s ): Walk-throughs or Demonstrations Unit 2 Walk-throughs or Demonstrations Unit 1 Perform Staffing Analysis Modifications:

Modifications Evaluation Target Completion Date October 2012 February 2013 September 2013 August 2013 February 2014 August 2014 February 2015 August 2015 February 2016 August 2016 April2015 April2016 April2015 April2016 October 2014 June 2015 Enclosure 1 to PLA-7137 Page 2 of8 Revised Activity Target Status Completion Date Complete Complete Complete*

January 2014 Complete Complete*

Not Started Not Started Not Started Not Started Not Started Started Started Not Started Not Started Started* Started Milestone Unit 2 Design Engineering

-Issue Unit 2 Design Change Documents (for all Phases) Unit 2 Implementation Outage Unit 1 Design Engineering

-Issue Unit 1 Design Change Documents (for all Phases) Unit 1 Implementation Outage Storage: Storage Design Engineering Storage Implementation

-Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site Equipment Contract with Vendor for Regional Response Center (RRCs) established Develop Strategies with RRC Establish offsite staging location [Install Off-Site Delivery Station (if Necessary)]

Target Completion Date June 2014 April2015 June 2015 April2016 May2014 April2015 April2015 March2013 April2015 May2015 Activity Status Started Enclosure 1 to PLA-7137 Page 3 of8 Revised Target Completion Date Not Started Started Not Started Started Started* Started Complete Started Started Milestone Regional Response Center . . m serv1ce Procedures:

BWROG Emergency Procedure and Severe Accident Guidelines (EPGs/SAGs)

Rev. 3 Procedures Complete Unit 2 FLEX Implementation (including FSGs and maintenance)

Procedures Complete Unit 1 FLEX Implementation (including FSGs and maintenance)

Training:

Develop Training Plan Training Complete Unit2 FLEX Implementation Unit 1 FLEX Implementation Full Site FLEX Implementation Submit Completion Report Target Completion Date December 2014 February 2013 April2015 April2016 May2014 February 2016 April2015 April2016 April2016 August 2016 Activity Status Started* Complete Started Started Started Started* Started* Started* Started* Enclosure 1 to PLA-7137 Page 4 of8 Revised Target Completion Date January 20 1 5* Not Started

• Revised since the six month update submitted August 26, 2013 (Reference

7) 4. Changes to Compliance Method NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

Enclosure 1 to PLA-713 7 Page 5 of8 Reference 1 provided PPL's response to the NRC Order EA-12-049.

The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA 050 will affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions. The Reference 1 enclosure describes PPL' s Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification is required to install a Hardened Containment Vent System. Thus the PPL response to NRC Order EA-12-049 provided in Reference 1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Upon issuance of NRC Order EA-13-109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050.

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference

8. 5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with NRC Order EA-12-049, but needs relaxation of the implementation dates. The specific details have been submitted in a separate document (Reference 8). NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

Reference 1 provided PPL's response to the NRC Order EA-12-049.

The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will also affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions. The Reference 1 enclosure describes the PPL Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

Thus the PPL NRC Order EA-12-049 response provided in Reference 1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Enclosure 1 to PLA-7137 Page 6 of8 Upon issuance of NRC Order EA-13-109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050.

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved.

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 8). 6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of January 31, 2014 of the open items documented in the Overall Integrated Plan and Interim Staff Evaluation (ISE). The Open Item and Confirmatory Items identified in the ISE will be addressed by the Regulatory Audit Process. Overall Integrated Plan Open Item Status 1. Phase 3 Shutdown Cooling Capability Started 2. EOP changes required to support Started Mitigation Strategies.

3. Develop SSES "playbook" for use of the Started Regional Response Center (RRC). 4. FLEX Equipment Storage Started 5. Review GEH Report NEDC 33771P, Complete*

GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment 1 B. 6. Determine appropriate use ofRCIC or Complete*

FLEX pump mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3. 7. Evaluate the impact of RCIC pump Seal Started Failures.

8. Evaluate potential RCIC pump Started modifications.

Overall Integrated Plan Open Item 9. Establish method of venting the Refuel Floor. 10. Evaluate means to assure continued long term gas supply for ADS/SRVs.

11. Evaluate means to transfer diesel fuel oil from storage tanks to the diesel fueled equipment.

12. Evaluate the effects of injecting Spray Pond water (UHS) to the RPV over a long period of time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or long er. 13. The calculation EC-030-1006, Rev 14, Control Structure Temperature Response to a Station Blackout or Fire Induced Loss Of Control Structure HV AC was performed.

However, final review and approval of the calculation EC-03 0-1006, Rev 14, have not been performed.

14. The calculation EC-SBOR-0504, Rev 6, Reactor Building Heatup Analysis During Station Blackout was performed.

However, final review and approval of the calculation EC-SBOR-0504, Rev 6 have not been performed.

15. Fuel consumption and refuel intervals will be determined during the procurement process for the 4160V AC generators.

Enclosure 1 to PLA-7137 Page 7 of8 Status Started Started Started Complete*

Started Complete*

Started

• Revised since the six month update submitted August 26, 2013 (Reference

7) 7. Potential Draft Safety Evaluation Impacts None-PPL just received the Interim Staff Evaluation and will be closing the Open Item and Confirmatory Items in the future.

8. References Enclosure 1 to PLA-7137 Page 8 of8 The following references support the updates to the Overall Integrated Plan described in this enclosure:

1. PPL Letter (PLA-6981), "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 (NRC Order EA-12-049)," dated February 28, 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. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August, 2012. 4. 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. 5. PPL Letter (PLA-7072), "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Basis External Events (NRC Order EA-12-049)," dated August 26, 2013. 6. NRC Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013. 7. PPL Letter (PLA-7071), "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 26, 2013. 8. PPL Letter (PLA-7134), "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'" dated February 20, 2014 9. NRC Letter from J. S. Bowen toT. S. Rausch, "Susquehanna Steam Electric Station, Units 1 And 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January 24, 2014 (ADAMS# ML13339A764)