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Sixth 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)
	ML16050A046
Person / Time
Site:	Susquehanna
Issue date:	02/18/2016
From:	Rausch T; Susquehanna, Talen Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16050A045	List: ML16050A046;
References
	EA-12-049, PLA-7438
	Download: ML16050A046 (16)
	v • d • e

Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Upon separation of the Enclosure 2, this letter is decontrolled.

Timothy S. Rausch President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Boulevard TALEN~

FEB 18 2015 Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 ENERGY Timothy.Rausch@TalenEnergy.com U. S. Nuclear Regulatory Commission 10 CFR2.202 Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION SIXTH 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) Docket No. 50-387 PLA-7438 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 tvith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049), "dated Februmy 28, 2013

6. PPL Letter (PLA-7072), "Request for Implementation Date Relief in Response td March I 2, 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-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions,"

dated June 6, 20I 3

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 Beyond-Design-Basis External Events (Order Number EA-12-049), "dated August 26, 20I 3

9. PPL Letter (PLA-7 I 34), "Request for Relaxation from NRC Order EA-I 2-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,'" dated February 20, 2014

10. NRC Letterfrom 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 Jamta/)124, 20I4 (ADAMS# ML13339A764)

Enclosure 2 of the Attachment contains security-related information. Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information. When Enclosure 2 of the Attachment is separated, the remaindu of the Attachment and this cover letter are decontrolled.

Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Upon separation of the Enclosure 2, this letter is decontrolled.

Document Control Desk PLA-7438 II. PPL Letter (PLA-7I37), "Second Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049), "dated Februmy 28, 20I4 I2. NRC Letter from E. J. Leeds toT. S. Rausch, "Susquehanna Steam Electric Station Units I and 2- Relaxation of Certain Schedule Requirements for Order EA-I2-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated Aprili5, 20I4 (ML14065A028)

13. PPL Letter (PLA-7204), "Third Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated August 28, 2014 I4. PPL Letter (PLA-7295), "Fourth Six-Month Status Report in Response to March I2, 20I2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-I2-049), "dated FebntCll)' 25, 20I5 I5. PPL Letter (PLA-7377), "Fifth Six-Month Status Report in Response to March I2, 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, 20I5 The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna) Sixth 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 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. is a revision of the Mitigation Strategies Overall Integrated Plan that includes several updates. The information provided in Enclosure 2 is considered to contain information conceming physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Information" as defined in 10 CFR 2.390 (d)(1). Accordingly, Susquehanna requests that the infonnation provided in to the letter be withheld from public disclosure.

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to Susquehanna. Reference 1 was immediately effective and directs Susquehanna 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 extemal 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 Susquehanna's initial status report regarding Mitigation Strategies.

Reference 5 provided Susquehanna's initial Mitigation Strategies Overall Integrated Plan.

Enclosure 2 of the Attachment contains security related information. Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information. When Enclosure 2 of the Attachment is separated, the re.mainder of the Attachment and this cover letter are decontrolled.

t.

Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Upon separation of the Enclosure 2, this letter is decontrolled.

Document Control Desk PLA-7438 Reference 1 requires submission of status reports 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-13-109) impacts the Mitigation Strategy Overall Integrated Plan and implementation timeline. The NRC approved this relaxation in Reference 12. to this letter documents that Susquehanna Unit 2 has implemented all the necessary aspects of the Overall Implementation Plan in Enclosure 2 to this letter to be considered in compliance with the requirements of NRC Order EA-12-049, except for the NRC approved Request for Relaxation (Reference 12) regarding implementation of a Severe Accident Capable Hardened Containment Vent System per NRC Order EA 109.

This letter contains no new or revised regulatory commitments.

If you have any questions regarding this report, please contact Mr. Jason Jennings, Manager- Nuclear Regulatory Affairs, at (570) 542-3155.

I declare under penalty of pe1jury that the foregoing is tme and conect.

Executed on:

Sincerely, : Susquehanna Nuclear, LLC's Sixth 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 Extemal Events Enclosure 2 of the Attachment contains security related information. Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information. When Enclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.

Enclosure 2 of the Attachment contains Security-Related information and must be protected acco1*dingly.

Upon separation of the Enclosure 2, this letter is decontrolled.

Document Control Desk PLA-7438 : 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 2016) Security- Related Infmmation-Withhold from Public Disclosure Under 10 CFR 2.390 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Ms. T. Hood, NRC Project Manager Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. M . Shields, PA DEP/BRP Enclosure 2 of the Attachment contains security related information. Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information. When Enclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.

Enclosure 1 to PLA-7438 Susquehanna Nuclear, LLC's Sixth 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-7438 Page 1 of 11 Susquehanna Nuclear, LLC's Sixth 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

1. Introduction Susquehanna Nuclear, LLC (Susquehanna) developed an Overall Integrated Plan (Reference 8.1) documenting the diverse and flexible strategies (FLEX),

in response to Reference 8.2. This Sixth Six Month Status Report provides an update of milestone accomplishments since submittal of the Fifth Six Month Status Repoti (Reference 8.14) 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 8.1), and are current as of January 31, 2016.

The Modifications Evaluation (Unit 1 Scope) was completed and Unit 1 Design Engineering documents have been issued.

The remaining Unit 1 milestones are in progress as listed on the Section 3, Milestone Schedule Status table, for example- modification installation, procedures, 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 Interim Staff Evaluation (ISE) from the NRC (Reference 8.9) has been received in time to support implementation of the Mitigation Strategies. The Open Item and Confirmatory Items identified in the ISE were addressed by the Regulatory Audit Process. The NRC perfonned the Mitigation Strategies and Spent Fuel Pool Level lnstmmentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Repoti documented the closure status of the Mitigation Strategies ISSUeS.

Enclosure 1 to PLA-7438 Page 2 of 11 Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Febmary 2013 Complete Plan Expected receipt of draft SER September Complete January 2014 from NRC (or ISE) 2013 Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 Febmary 2014 Complete Update 3 August 2014 Complete Update 4 Febmary 2015 Complete Update 5 August 2015 Complete Update 6 Febmary 2016 Complete*

Update 7 August 2016 Not Statted Update 8 Febmary 2017 Not Statied Update 9 August 2017 Not Statted Update 10 Febmary 2018 Not Started FLEX Strategy Evaluation April2015 Complete May 2015 Unit2 FLEX Strategy Evaluation April2016 Started Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April2015 Complete May2015 Demonstrations Unit 2 Walk-throughs or April2016 Statied Demonstrations Unit 1 Perform Staffing Analysis October 2014 Complete Modifications:

Enclosure 1 to PLA-7438 Page 3 of 11 Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications Evaluation June 2015 Complete* August 2015 Unit 2 Design Engineering June 2014 Complete

- Issue Unit 2 Design (except HCVS, Change Documents (for all see Ref. 11)

Phases)

Unit 2 Implementation April2015 Complete May 2015 Outage Unit 1 Design Engineering June 2015 Complete* August 2015

- Issue Unit 1 Design (except HCVS, Change Documents (for all see Ref. 11)

Phases)

Unit 1 Implementation March 2016 Not Started Outage Storage:

Storage Design May2014 Complete Engineering Storage Implementation - April2015 Complete May2015 Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site April2015 Complete May2015 Equipment Contract with Vendor for March 2013 Complete National SAFER Response Center (NSRCs) established Develop Strategies with April2015 Complete Feb 2015 NSRC

Enclosure 1 to PLA-7438 Page 4 of 11 Revised Target Activity Target Milestone Completion Status Completion Date Date Establish offsite staging May 2015 Complete location [Install Off-Site Delivery Station (if Necessary)]

National SAFER Response December 20 14 Complete Feb 2015 Centers in service for Susquehanna Procedures:

BWROG issue Emergency February 2013 Complete Procedure and Severe Accident Guidelines (EPGs/SAGs) Rev. 3 Procedures Complete Unit April2015 Complete May2015 2 FLEX Implementation (including FSGs and maintenance)

Procedures Complete Unit April2016 Started 1 FLEX Implementation (including FSGs and maintenance)

Training:

Develop Training Plan May2014 Complete February 2016 Stalied Complete for Training Complete Unit 2 and Common, Unit 1 planned for Feb 2016 Unit2 FLEX April2015 Complete May2015 Implementation Unit 1 FLEX April2016 Stalied Implementation

Enclosure 1 to PLA-7438 Page 5 of 11 Revised Target Activity Target Milestone Completion Status Completion Date Date Full Site FLEX April2016 Stmted Implementation (except HCVS)

August 2019 Not Started (after HCVS Submit Completion Report Order actions are complete perRef8.11)*

Revised since the six month update submitted August 26, 2015 (Reference 8.14)

Enclosure 1 to PLA-7438 Page 6 ofll

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.

Reference 8.1 provided Susquehanna's response to the NRC Order EA 049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions.

The Reference 8.1 enclosure describes Susquehanna'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 Susquehanna response to NRC Order EA-12-049 provided in Reference 8.1 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 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 8.1 for Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference 8.8. This relaxation was granted in Reference 8 .11.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation Susquehanna 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 8.8).

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 8.1 provided Susquehanna's response to the NRC Order EA 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 8.1 enclosure describes the Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened Containment

Enclosure 1 to PLA-7438 Page 7 ofll Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

Thus Susquehanna's NRC Order EA-12-049 response provided in Reference 8.1 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 8.1 for 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 8.8). This relaxation was granted in Reference 8 .11.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of January 31, 2016 of the open items documented in the Overall Integrated Plan and ISE. The Open Item and Confirmatory Items identified in the ISE will be addressed by the Regulatory Audit Process. The NRC performed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies issues.

Overall Integrated Plan Open Item Status

1. Phase 3 Shutdown Cooling Capability Complete

2. EOP changes required to support Complete Mitigation Strategies.

3. Develop SSES "Response Plan" for use Complete of the National SAFER Response Centers (NSRC).

4. FLEX Equipment Storage Complete

Enclosure 1 to PLA-7438 Page 8 of 11 Overall Integrated Plan Open Item Status

5. Review GEH Report NEDC 33771P, Complete GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment lB .

6. Dete1mine 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 Complete failures. EC-050-1 034, Rev. 0 approved 12/13/2013

8. Evaluate potential RCIC pump Complete modifications.

9. Establish method of venting the Refuel Complete Floor. EC-0 12-6122, Rev 0 approved on 4/29/2014.

10. Evaluate means to assure continued long Complete te1m gas supply for ADS/SRVs.

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

12. Evaluate the effects of injecting Spray Complete Pond water (UHS) to the RPV over a long period of time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or longer.

13. The calculation EC-030-1006, Rev 14, Complete Control Structure Temperature Response to a Station Blackout or Fire Induced Loss of Control Structure HVAC was performed. However, final review and approval of the calculation EC-030-1 006, Rev 14, have not been performed. The calculation has now been reviewed and approved.

Enclosure 1 to PLA-7438 Page 9 of 11 Overall Integrated Plan Open Item Status

14. The calculation EC-SBOR-0504, Rev 6, Complete 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. Revision 7 of this calculation was approved on 3/20/2014. Appendix 0 was added to identify and evaluate mitigating measures that could be implemented to enhance Switchgear and Load Center Room cooling, as needed, for time > 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

15. Fuel consumption and refuel intervals Complete will be dete1mined during the procurement process for the 4160VAC generators.

Revised since the six month update submitted August 26, 20 15 (Reference 8.14)

7. Potential Draft Safety Evaluation Impacts None- Susquehanna received the ISE and closed the Open Item and Confirmatory Items via the audit process. The NRC perfmmed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies ISSUeS.

Enclosure 1 to PLA-7438 Page 10 of 11

8. References The following references support the updates to the Overall Integrated Plan described in this enclosure:

8.1 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.

8.2 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.

8.3 NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, dated August, 2012.

8.4 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.

8.5 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.

8.6 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.

8.7 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.

8.8 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.

8.9 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).

Enclosure 1 to PLA-7438 Page 11 of 11 8.10 PLA-7137, "Second Six-Month Status Repmi 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, 2014.

8.11 NRC Letter from E. J. Leeds toT. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 -Relaxation of Certain Schedule Requirements for Order EA 049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"' dated April15, 2014 (ML14065A028).

8.12 PLA-7204, "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 (NRC Order EA-12-049)," dated August 28, 2014.

8.13 PLA-7295, "Fourth Six-Month Status Repmi 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 25, 2015.

8.14 PLA-7377, "Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2015.

8.15 NRC Letter from John D. Hughey toT. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 -Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA 049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April13, 2015 (ML15089A123).