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 (NRC Order EA-12-049)

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 (NRC Order EA-12-049)

ML13240A214
Person / Time
Site:	Susquehanna
Issue date:	08/26/2013
From:	Rausch T Susquehanna
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, PLA-7071
Download: ML13240A214 (12)

Text

Timothy S. Rausch PPL Susquehanna, LLC Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 AUG 2 6 2013 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 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 (NRC ORDER EA-12-049) Docket No. 50-387 PLA-7071 and No. 50-388

References:

1. NRC Order EA 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 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. PLA-6923, PPL Susquehanna's 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 049),

dated October 29, 2012

5. PLA-6981, 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), dated February 28, 2013

6. PLA-7072, PPL Susquehanna's 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 049), dated August 2013

7. NRC Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Sever Accident Conditions, dated June 6, 2013 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

Document Control Desk PLA-7071 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 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 purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

The Request for Relief contained in Reference 6 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. A summary level description of requested relief is provided below.

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 5 provided PPL's response to 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 5 enclosure describes the 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 (HCVS).

Thus the PPL NRC Order EA-12-049 response provided in Reference 5 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Document Control Desk PLA-7071 Upon issuance of NRC Order EA-13-109 (Reference 7), 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 5 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance to NRC Order EA-13-109 is achieved.

Relief from the NRC Order EA-12-049 IV.A.2 requirements is therefore required.

PPL will be in compliance with the aspects of the Reference 5 Mitigation Strategies for Unit 1 and Unit 2 that do not rely upon a Hardened Containment Vent System per the original schedule, unless otherwise described.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. John L. Tripoli at 570-542-3100.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:  :'6 [-L<.c I, l ~

Sincerely,

Enclosure:

PPL Susquehanna, LLC' s First 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 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 to PLA-7071 PPL Susquehanna, LLC's First 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 to PLA-7071 Page 1 of 8 PPL Susquehanna, LLC's First 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 PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan (Reference 1)

[NOTE: References cited in this enclosure are contained in Section 8.], documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

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 July 31, 2013.

• Contract with Vendor for Regional Response Center (RRCs) established.

• Numerous other milestones have been started as listed on the Section 3, Milestone Schedule Status.

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. A new item regarding

'Validation' has been added at the request of the NRC.

Validation:

Walk-throughs or Demonstration(s)

• Walk-throughs or demonstrations encompassing all FLEX equipment points of connection/tie-in for Phase 2 and 3 will be completed prior to startup from the implementation outages.

The revised milestone target completion dates do not impact the Order implementation date at this time. The draft SERs from the NRC need to be received in time to support implementation of the Mitigation Strategies.

Enclosure to PLA-7071 Page 2 of 8 Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Expected receipt of draft SERs September 2013 Not Started March 2014 from NRC Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Not Started Update 3 August 2014 Not Started Update4 February 2015 Not Started Update 5 August 2015 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started FLEX Strategy Evaluation April2015 Started Unit 2 FLEX Strategy Evaluation April2016 Started Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April2015 Not Started Demonstrations Unit 2 Walk-throughs or April2016 Not Started Demonstrations Unit 1 Perform Staffing Analysis October 2014 Not Started Modifications:

Modifications Evaluation June 2015 Started Unit 2 Design Engineering- June 2014 Started Issue Unit 2 Design Change Documents (for all Phases)

Enclosure to PLA-7071 Page 3 of 8 Revised Target Activity Target Milestone Completion Status Completion Date Date Unit 2 Implementation April2015 Not Started Outage Unit 1 Design Engineering- June 2015 Started Issue Unit 1 Design Change Documents (for all Phases)

Unit 1 Implementation April2016 Not Started Outage Storage:

Storage Design Engineering May 2014 Started Storage Implementation - April2015 Not Started Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site Equipment April2015 Started Contract with Vendor for March 2013 Complete Regional Response Center (RRCs) established Develop Strategies with RRC April2015 Started Establish offsite staging May 2015 Not Started location [Install Off-Site Delivery Station (if Necessary)]

Regional Response Center in December 2014 Started service Procedures:

BWROG Emergency February 2013 Complete Procedure and Severe Accident Guidelines (EPGs/SAGs) Rev. 3

Enclosure to PLA-7071 Page 4 of 8 Revised Target Activity Target Milestone Completion Status Completion Date Date Procedures Complete Unit 2 April2015 Started FLEX Implementation (including FSGs and maintenance)

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

Training:

Develop Training Plan May 2014 Started Training Complete February 2016 Not Started Unit 2 FLEX Implementation April2015 Not Started Unit 1 FLEX Implementation April2016 Not Started Full Site FLEX April2016 Not Started Implementation Submit Completion Report August 2016 Not Started

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 1 provided the 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 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 (HCVS).

Enclosure to PLA-7071 Page 5 of 8 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.

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 to NRC Order EA-13-109 is achieved.

Relief from the NRC Order EA-12-049 IV .A.2 requirements is required and has been requested (Reference 5).

PPL will be in compliance with the aspects of the Reference 1 Unit 1 and Unit 2 Mitigation Strategies that do not rely upon a Hardened Containment Vent System unless otherwise described.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with NRC Order EA-12-049, but needs implementation date relief. This section provides a summary of the needed relief/relaxation only. The specific details will be submitted in a separate document (Reference 5).

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 (HCVS) 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.

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.

Enclosure to PLA-7071 Page 6 of 8 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 I and 2 will not be achieved until compliance to NRC Order EA-13-109 is achieved.

Relief from the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 5).

PPL will be in compliance with the aspects of the Reference I Unit I and Unit 2 Mitigation Strategies that do not rely upon a Hardened Containment Vent System unless otherwise described.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item (current as of July 31, 2013).

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, Started GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment lB.

6. Determine appropriate use of RCIC or Started 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.

9. Establish method of venting the Refuel Started Floor.

Enclosure to PLA-7071 Page 7 of 8 Overall Integrated Plan Open Item Status

10. Evaluate means to assure continued long Started term gas supply for ADS/SRVs.

11. Evaluate means to transfer diesel fuel oil Started from storage tanks to the tow-along fuel tankers.

12. Evaluate the effects of injecting Spray Started 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 longer.

13. The calculation EC-030-1006, Rev 14, Started 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-030-1 006, Rev 14, have not been performed.

14. The calculation EC-SBOR-0504, Rev 6, Started 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 Started will be determined during the procurement process for the 480V AC generators.

Draft Safety Evaluation Open Item Status None

7. Potential Draft Safety Evaluation Impacts None- PPL has not received a Draft Safety Evaluation at this time.

Enclosure to PLA-7071 Page 8 of 8

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

1. PLA-6981, PPL Susquehanna, LLC'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 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. PLA-7072, PPL Susquehanna's 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 2013.

6. NRC Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Sever Accident Conditions, dated June 6, 2013.