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| issue date = 02/09/2017
| issue date = 02/09/2017
| title = Eighth 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 (EA-12-049), PLA-7570
| title = Eighth 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 (EA-12-049), PLA-7570
| author name = Rausch T S
| author name = Rausch T
| author affiliation = Susquehanna Nuclear, LLC, Talen Energy
| author affiliation = Susquehanna Nuclear, LLC, Talen Energy
| addressee name =  
| addressee name =  
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{{#Wiki_filter:Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.
{{#Wiki_filter:Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.
Upon separation of the Enclosure 2, this letter is decontrolled.
Upon separation of the Enclosure 2, this letter is decontrolled.
Timothy S. Rausch President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@TalenEnergy.com FIB 0 9 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 ENERGY 10 CFR2.202 SUSQUEHANNA STEAM ELECTRIC STATION EIGHTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MOD.IFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (NRC ORDER EA-12-049)
Timothy S. Rausch President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Boulevard     TALEN-~
PLA-7570 Docket No. 50-387 and No. 50-388  
Berwick, PA 18603               ENERGY FIB 0 9 2017                                                  Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@TalenEnergy.com U. S. Nuclear Regulatory Commission                                                               10 CFR2.202 Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION EIGHTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MOD.IFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (NRC ORDER EA-12-049)                                                               Docket No. 50-387 PLA-7570                                                                                              and No. 50-388


==References:==
==References:==
: 1. NRC Order 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. NE! 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-tiesign-Basis-Ex-ternal Events (Order "dated October 29, 2012
: 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
* 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-13-109, "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 Beyond-Design-Basis External Events (Order Number EA-12-049), "dated August 26, 2013 9. PPL Letter (PLA-7134), "Request/or RelaxationfromNRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Basis External Events,'" dated February 20, 2014 10.
: 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
* 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)
: 3. NE! 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, "
Enclosure 2 of the Attachment contains security-related information.
Revision 0, dated August 2012
Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.
: 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-tiesign-Basis-Ex-ternal Events (Order Number.EA.~12~049), "dated October 29, 2012         *
When Enclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.
: 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 Beyond-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-13-109, "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 Beyond-Design-Basis External Events (Order Number EA-12-049), "dated August 26, 2013
: 9. PPL Letter (PLA-7134), "Request/or RelaxationfromNRC 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 StaffEvaluation 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 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 accordingly.
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-7570 11. PPL Letter (PLA-7137), "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), "dated February 28, 2014 12. NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 -Relaxation of Certain Schedule Requirements for Order EA-12-049  
Upon separation of the Enclosure 2, this letter is decontrolled.
'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated April 15, 2014 (ML14065A028)  
Document Control Desk PLA-7570
: 13. PPL Letter (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 14. PPL Letter (PLA-7295), "Fourth 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 February 25, 2015 15. Talen Letter (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 16. Talen Letter (PLA-7438), "Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies
: 11. PPL Letter (PLA-7137), "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), "dated February 28, 2014
* for Beyond-Design-Basis External Events (NRC Order EA-12-049), "dated February 18, 2016 17. Talen Letter (PLA-7513), "Seventh 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 19, 2016. The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna)
: 12. NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated April 15, 2014 (ML14065A028)
Eighth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference  
: 13. PPL Letter (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
: 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. Enclosure 2 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 concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive as defined in 10 CFR 2.390 ( d)(l ). Accordingly, Susquehanna requests that the information provided in Enclosure 2 to the letter be withheld from public disclosure.
: 14. PPL Letter (PLA-7295), "Fourth 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 February 25, 2015
On March 12, 2012, the Nuclear Regulatory Commission  
: 15. Talen Letter (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
("NRC'' or "Commission")
: 16. Talen Letter (PLA-7438), "Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies
issued an order (Reference  
* for Beyond-Design-Basis External Events (NRC Order EA-12-049), "dated February 18, 2016
: 1) to Susquehanna.
: 17. Talen Letter (PLA-7513), "Seventh 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 19, 2016.
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 external event. Specific requirements are outlined in Attachment 2 of Reference  
The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna)
: 1.
Eighth 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 concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Informa~ion" as defined in 10 CFR 2.390 (d)(l ). Accordingly, Susquehanna requests that the information provided in to the letter be withheld from public disclosure.
* Reference 1 required submission of an initial stafµs report 60 days following issuance of the final interim staff guidance (Reference  
On March 12, 2012, the Nuclear Regulatory Commission ("NRC'' or "Commission")
: 2) and an overall integrated plan pursuant to Enclosure 2 of the Attachment contains security related information.
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 external event. Specific requirements are outlined in Attachment 2 of Reference 1.
Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.
* Reference 1 required submission of an initial stafµs report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to 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.
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 accordingly.
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-7570 SectiOn IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference  
Upon separation of the Enclosure 2, this letter is decontrolled.
: 3) with clarifications and exceptions identified in Reference  
Document Control Desk PLA-7570 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.
: 2.
* Reference 4 provided Susquehanna's initial status report regarding Mitigation Strategies.
* Reference 4 provided Susquehanna's initial status report regarding Mitigation Strategies.
Reference 5 provided Susquehanna's initial Mitigation Strategies Overall Integrated Plan. Reference 1 requires submission of 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  
Reference 5 provided Susquehanna's initial Mitigation Strategies Overall Integrated Plan.
: 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.
Reference 1 requires submission of ~tatus reports at six-month intervals following submittal of the Overall Integrated Plan. Reference 3 provides direction regarding the content of the status reports.
The NRC approved this relaxation in Reference  
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 .
: 12. Enclosure 1 to this letter documents that Susquehanna Unit 1 and Susquehanna Unit 2 have 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  
Integrated Plan and implementation timeline. The NRC approved this relaxation in Reference 12. to this letter documents that Susquehanna Unit 1 and Susquehanna Unit 2 have implemented all the necessary aspects of the Overall Implementation Plan in 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-13-109.
: 12) regarding implementation of a Severe Accident Capable Hardened Containment Vent System per NRC Order EA-13-109.
This letter contains no new or revised regulatory commitments.
This letter contains no new or revised regulatory commitments.
If you have any questions regarding this report, please contact Mr. Jason Jennings, Nuclear Regulatory Affairs, at (570) 542-3155.
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 perjury that the foregoing is true and correct. Executed on:
I declare under penalty of perjury that the foregoing is true and correct.
* ___ *z. ___ ( 6\--+-l Sincerely,
Executed on: *_ _ _          *z.___(6\--+-ll~CJ~.---,
* Enclosure 2 of the Attachment contains security related information.
Sincerely,
Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.
* 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.
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 accordingly.
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-7570 Enclosure 1: Susquehanna Nuclear, LLC's Eighth Six Month Status Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 2: Susquehanna Nuclear' 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 2017) Security-Related Information  
Upon separation of the Enclosure 2, this letter is decontrolled.
-Withhold from Public Disclosure Under ,10 CFR 2.390 Copy: NRC Region I Ms. L. H. Micewski, 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.
Document Control Desk PLA-7570 : Susquehanna Nuclear, LLC's Eighth Six Month Status Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events : Susquehanna Nuclear' 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 2017) Security-Related Information - Withhold from Public Disclosure Under ,10 CFR 2.390 Copy: NRC Region I Ms. L. H. Micewski, NRC Sr. Resident Inspector
Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.
      .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.
When Enclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.
 
Enclosure 1 to PLA-7570 Susquehanna Nuclear, LLC's Eighth 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-7570 Page 1of11 Susquehanna Nuclear, LLC's Eighth 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 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 Eighth Six Month Status Report provides an update of milestone accomplishments since submittal of the Seventh Six Month Status Report (Reference 8.17) 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 December 30, 2016.
Enclosure 1 to PLA-7570 Susquehanna Nuclear, LLC's Eighth 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
* Started installation of the Unit 2 Severe Accident Capable Hardened Containment Vent System. 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) was received in time to support implementation of the Mitigation Strategies.
Enclosure 1 to PLA-7570 Page 1of11 Susquehanna Nuclear, LLC's Eighth 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
The Open Item and Confirmatory Items identified in the ISE were 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.
: 1. Introduction Susquehanna Nuclear, LLC (Susquehanna) developed an Overall Integrated Plan (Reference 8.1) documenting the diverse and flexible strategies (FLEX),
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 Update 8 Update 9 Update 10 FLEX Strategy Evaluation Unit2 FLEX Strategy Evaluation Unit 1 Validation by Walk-throughs or Demonstration( s): Walk-throughs or Demonstrations Unit 2 Walk-throughs or Demonstrations Unit 1 Perform Staffing Analysis Modifications:
in response to Reference 8.2. This Eighth Six Month Status Report provides an update of milestone accomplishments since submittal of the Seventh Six Month Status Report (Reference 8.17) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
Target Completion Date October 2012 February 2013 September 2013 " August 2013 February 2014 August 2014 February 2015 August 2015 February 2016 August 2016 February 2017 August 2017 February 2018 April 2015 April 2016 April 2015 April 2016 October 2014 Activity Status Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete*
[NOTE: References cited in this enclosure are contained in Section 8.]
Not Started Not Started Complete Complete Complete Complete Complete Enclosure 1 to PLA-7570 Page 2of11 Revised Target Completion Date January 2014 May2015 May2015 Target Milestone Completion Date Modifications Evaluation June 2015 Unit 2 Design Engineering June 2014 -Issue Unit 2 Design Change Documents (for all Phases) Unit 2 Implementation April 2015 Outage Unit 1 Design Engineering June 2015 -Issue Unit 1 Design Change Documents (for all Phases) Unit 1 Implementation March 2016 Outage Storage: Storage Design May2014 Engineering Storage Implementation
: 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 December 30, 2016.
-April2015 Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:
* Started installation of the Unit 2 Severe Accident Capable Hardened Containment Vent System.
Procure On-Site April 2015 Equipment Contract with Vendor for March2013 National SAFER Response Center (NSRCs) established Develop Strategies with April2015 NSRC Activity Status Complete Complete (except HCVS, see Ref. 8.11) Complete Complete (except HCVS, see Ref. 8.11) Complete Complete Complete Complete Complete Complete Enclosure 1 to PLA-7570 Page 3of11 Revised Target Completion Date August 2015 May2015 August2015 May2015 May2015 Feb 2015 Target Milestone Completion Date Establish offsite staging May2015 location [Install Off-Site Delivery Station (if Necessary)]
: 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.
National SAFER Response December 2014 Centers in service for Susquehanna Procedures:
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) was 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 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.
BWROG issue Emergency February 2013 Procedure and Severe Accident Guidelines (EPGs/SAGs)
Rev. 3 Procedures Complete Unit April2015 2 FLEX Implementation (including FSGs and maintenance)
Procedures Complete Unit April 2016 1 FLEX Implementation (including FSGs and maintenance)
Training:
Develop Training Plan May2014 February 2016 Training Complete Unit2 FLEX April 2015 Implementation Unit 1 FLEX April2016 Implementation Activity Status Complete Complete Complete Complete (except HCVS, see Ref. 8.11) Complete (except HCVS, see Ref. 8.11) Complete Complete (except HCVS, see Ref. 8.11) Complete (except HCVS, see Ref. 8.11) Complete (except HCVS, see Ref. 8.11) Enclosure 1 to PLA-7570 Page 4of11 Revised Target Completion Date Feb 2015 May2015 April 2016 May2015 Target Milestone Completion Date Full Site FLEX April2016 Implementation (except HCVS) Unit 2 Severe Accident April 2017 Capable Hardened Containment Vent System Phase 1 Unit 1 Severe Accident April2018 Capable Hardened Containment Vent System Phase 1 Unit 1 Severe Accident April 2018 Capable Hardened Containment Vent System Phase 2 Unit 2 Severe Accident April 2019 Capable Hardened Containment Vent System Phase 2 August 2019 (after HCVS Submit Completion Report Order actions are complete per Ref 8.11)* Enclosure 1 to PLA-7570 Page 5of11 Revised Activity Target Status Completion Date Complete (except HCVS, see Ref. 8.11) Design Complete, Installation Started* Design Started*, Installation Not Started Design Started*, Implementation Not Started Design Started*, Implementation Not Started Not Started
* Revised since the six month update submitted August 19, 2016 (Reference 8 .1 7) 
: 4. Changes to Compliance Method Enclosure 1 to PLA-7570 Page 6of11 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===
Enclosure 1 to PLA-7570 Page 2of11 Revised Target Activity        Target Milestone            Completion Status      Completion Date Date Submit 60 Day Status Report  October 2012  Complete Submit Overall Integrated    February 2013  Complete Plan Expected receipt of draft SER  September    Complete      January 2014 from NRC (or ISE)                2013 Submit 6 Month Updates:            "
Susquehanna'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
Update 1                    August 2013  Complete Update 2                  February 2014  Complete Update 3                    August 2014  Complete Update 4                  February 2015  Complete Update 5                    August 2015  Complete Update 6                  February 2016  Complete Update 7                    August 2016  Complete Update 8                  February 2017 Complete*
Update 9                    August 2017  Not Started Update 10                  February 2018 Not Started FLEX Strategy Evaluation        April 2015  Complete      May2015 Unit2 FLEX Strategy Evaluation        April 2016  Complete Unit 1 Validation by Walk-throughs or Demonstration(s):
Walk-throughs or            April 2015  Complete        May2015 Demonstrations Unit 2 Walk-throughs or            April 2016  Complete Demonstrations Unit 1 Perform Staffing Analysis  October 2014  Complete Modifications:


===8.1 enClosure===
Enclosure 1 to PLA-7570 Page 3of11 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. 8.11)
Phases)
Unit 2 Implementation      April 2015    Complete        May2015 Outage Unit 1 Design Engineering  June 2015    Complete        August2015
  - Issue Unit 1 Design                (except HCVS, Change Documents (for all              see Ref. 8.11)
Phases)
Unit 1 Implementation    March 2016    Complete 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          April 2015    Complete        May2015 Equipment Contract with Vendor for  March2013      Complete National SAFER Response Center (NSRCs) established Develop Strategies with  April2015      Complete          Feb 2015 NSRC


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 byNRC Order EA-12-050.
Enclosure 1 to PLA-7570 Page 4of11 Revised Target Activity          Target Milestone            Completion Status        Completion Date Date Establish offsite staging    May2015        Complete location [Install Off-Site Delivery Station (if Necessary)]
Upon issuance ofNRC Qrder 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.
National SAFER Response    December 2014    Complete          Feb 2015 Centers in service for Susquehanna Procedures:
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.
BWROG issue Emergency      February 2013    Complete Procedure and Severe Accident Guidelines (EPGs/SAGs) Rev. 3 Procedures Complete Unit    April2015      Complete        May2015 2 FLEX Implementation                    (except HCVS, (including FSGs and                       see Ref. 8.11) maintenance)
Reference
Procedures Complete Unit    April 2016    Complete 1 FLEX Implementation                    (except HCVS, (including FSGs and                       see Ref. 8.11) maintenance)
Training:
Develop Training Plan        May2014        Complete February 2016    Complete        April 2016 Training Complete                        (except HCVS, see Ref. 8.11)
April 2015      Complete        May2015 Unit2 FLEX Implementation                          (except HCVS, see Ref. 8.11)
April2016      Complete Unit 1 FLEX Implementation                          (except HCVS, see Ref. 8.11)


===8.1 provided===
Enclosure 1 to PLA-7570 Page 5of11 Revised Target Activity          Target Milestone              Completion Status        Completion Date Date Full Site FLEX                April2016          Complete Implementation                                (except HCVS, (except HCVS)                                  see Ref. 8.11)
Susquehanna'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  
Unit 2 Severe Accident        April 2017          Design Capable Hardened                                  Complete, Containment Vent System                          Installation Phase 1                                           Started*
Unit 1 Severe Accident        April2018    Design Started*,
Capable Hardened                              Installation Not Containment Vent System                            Started Phase 1 Unit 1 Severe Accident        April 2018    Design Started*,
Capable Hardened                              Implementation Containment Vent System                          Not Started Phase 2 Unit 2 Severe Accident        April 2019    Design Started*,
Capable Hardened                             Implementation Containment Vent System                         Not Started Phase 2 August 2019        Not Started (after HCVS Submit Completion Report    Order actions are complete per Ref 8.11)*
* Revised since the six month update submitted August 19, 2016 (Reference 8.1 7)


===8.1 enclosure===
Enclosure 1 to PLA-7570 Page 6of11
: 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 byNRC Order EA-12-050.
Upon issuance ofNRC Qrder 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 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


describes the Susquehanna Mitigation Strategies*
Enclosure 1 to PLA-7570 Page 7of11 Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.
that is based on venting the containment using the Hardened Containment Enclosure 1 to PLA-7570 Page 7of11 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 byNRC Order EA-12-050.
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 byNRC Order EA-12-050.
Upon issuance ofNRC 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.
Upon issuance ofNRC 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.
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 .
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 December 30, 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. BOP changes required to support Complete Mitigation Strategies.  
achieved.
: 3. Develop S SES "Response Plan" for use Complete of the National SAFER Response Centers (NSRC). 4. FLEX Equipment Storage Complete Overall Integrated Plan Open Item. 5. Review GEH Report NEDC 33771P, GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment lB. 6. Determine appropriate use of RCIC or FLEX pump mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3. 7. Evaluate the impact ofRCIC pump seal failures.
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.
EC-050-1034, Rev. 0 approved 12/13/2013  
: 6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of December 30, 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.
: 8. Evaluate potential RCIC pump modifications.  
Overall Integrated Plan Open Item                         Status
: 9. Establish method of venting the Refuel Floor. EC-012-6122, Rev 0 approved on 4/29/2014.  
: 1. Phase 3 Shutdown Cooling Capability                       Complete
: 10. Evaluate means to assure continued long term gas supply for ADS/SRVs.  
: 2. BOP changes required to support                           Complete Mitigation Strategies.
: 11. Evaluate means to transfer diesel fuel oil from storage tanks to the diesel fueled equipment.  
: 3. Develop S SES "Response Plan" for use                     Complete of the National SAFER Response Centers (NSRC).
: 12. Evaluate the effects of injecting Spray Pond water (UHS) to the RPV over a long period of time of 72 hours or longer. 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.
: 4. FLEX Equipment Storage                                     Complete
However, final review and approval of the calculation EC-030-1006, Rev 14, have not been performed.
 
The calculation has now been reviewed and approved.
Enclosure 1 to PLA-7570 Page 8of11 Overall Integrated Plan Open Item.         Status
Enclosure 1 to PLA-7570 Page 8of11 Status Complete Complete Complete Complete Complete ' Complete Complete Complete Complete Overall Integrated Plan Open Item 14. The calculation EC-SBOR-0504, Rev 6, Reactor Building Heatup Analysis during Station Blackout was performed.
: 5. Review GEH Report NEDC 33771P,             Complete GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment lB.
However, final review and approval of the calculation EC-SBOR-0504, Rev 6 have not been performed.
: 6. Determine appropriate use of RCIC or       Complete FLEX pump mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3.
Revision 7 of this calculation was approved on 3/20/2014.
: 7. Evaluate the impact ofRCIC pump seal       Complete failures. EC-050-1034, Rev. 0 approved 12/13/2013
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 hours. 15. Fuel consumption and refuel intervals will be determined during the procurement process for the 4160V AC generators.
: 8. Evaluate potential RCIC pump               Complete modifications.
Enclosure 1 to PLA-7570 Page 9of11 Status Complete Complete *Revised since the six month update submitted August 19, 2016 (Reference 8.17) 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 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.
: 9. Establish method of venting the Refuel     Complete Floor. EC-012-6122, Rev 0 approved on 4/29/2014.
: 8. References Enclosure 1 to PLA-7570 Page 10of11 The following references support the updates to the Overall Integrated Plan described in this enclosure:
: 10. Evaluate means to assure continued long   Complete term gas supply for ADS/SRVs.
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 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).
: 11. Evaluate means to transfer diesel fuel oil Complete from storage tanks to the diesel fueled equipment.
Enclosure 1 to PLA-7570 Page 11of11 8.10 PLA-7137, "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)," dated February 28, 2014. 8.11 NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 -Relaxation of Certain Schedule Requirements for Order EA-12-049  
: 12. Evaluate the effects of injecting Spray   Complete Pond water (UHS) to the RPV over a long period of time of 72 hours or longer.
'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"'
: 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-030-1006, Rev 14, have not been performed. The calculation has now been reviewed and approved.
dated April 15, 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 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 February 25, 2015.
Enclosure 1 to PLA-7570 Page 9of11 Overall Integrated Plan Open Item                         Status
* 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 External Events (NRC Order EA-12--049)," dated August 26, 2015. 8.15 NRC Letter from John D. Hughey to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 -Repol,"t for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April 13, 2015 (ML15089A123).
: 14. The calculation EC-SBOR-0504, Rev 6,                     Complete Reactor Building Heatup Analysis during Station Blackout was performed.
8.16 PLA-7438, "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)," dated February 18, 2016. 8.17 PLA-7513, "Seventh 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 19, 2016 .}}
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 hours.
: 15. Fuel consumption and refuel intervals                   Complete will be determined during the procurement process for the 4160VAC generators.
*Revised since the six month update submitted August 19, 2016 (Reference 8.17)
: 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 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.
 
Enclosure 1 to PLA-7570 Page 10of11
: 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 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).
 
Enclosure 1 to PLA-7570 Page 11of11 8.10       PLA-7137, "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)," dated February 28, 2014.
8.11       NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"' dated April 15, 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 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 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-De~ign-Basis External Events (NRC Order EA-12--049)," dated August 26, 2015.
8.15       NRC Letter from John D. Hughey to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 - Repol,"t for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April 13, 2015 (ML15089A123).
8.16       PLA-7438, "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)," dated February 18, 2016.
8.17       PLA-7513, "Seventh 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 19, 2016 .
      ~: ...}}

Latest revision as of 19:30, 4 February 2020

Eighth 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 (EA-12-049), PLA-7570
ML17045A608
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 02/09/2017
From: Rausch T
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17046A006 List:
References
EA-12-049, PLA-7570
Download: ML17045A608 (16)
v • d • e


Text

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-~

Berwick, PA 18603 ENERGY FIB 0 9 2017 Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@TalenEnergy.com U. S. Nuclear Regulatory Commission 10 CFR2.202 Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION EIGHTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MOD.IFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (NRC ORDER EA-12-049) Docket No. 50-387 PLA-7570 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. NE! 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-tiesign-Basis-Ex-ternal 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 Beyond-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-13-109, "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 Beyond-Design-Basis External Events (Order Number EA-12-049), "dated August 26, 2013
9. PPL Letter (PLA-7134), "Request/or RelaxationfromNRC 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 StaffEvaluation 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 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 accordingly.

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

Document Control Desk PLA-7570

11. PPL Letter (PLA-7137), "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), "dated February 28, 2014
12. NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated April 15, 2014 (ML14065A028)
13. PPL Letter (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
14. PPL Letter (PLA-7295), "Fourth 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 February 25, 2015
15. Talen Letter (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
16. Talen Letter (PLA-7438), "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), "dated February 18, 2016
17. Talen Letter (PLA-7513), "Seventh 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 19, 2016.

The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna)

Eighth 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 concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Informa~ion" as defined in 10 CFR 2.390 (d)(l ). Accordingly, Susquehanna requests that the information 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 external event. Specific requirements are outlined in Attachment 2 of Reference 1.

  • Reference 1 required submission of an initial stafµs report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to 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 accordingly.

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

Document Control Desk PLA-7570 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.

Reference 1 requires submission of ~tatus 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 1 and Susquehanna Unit 2 have implemented all the necessary aspects of the Overall Implementation Plan in 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-13-109.

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 perjury that the foregoing is true and correct.

Executed on: *_ _ _ *z.___(6\--+-ll~CJ~.---,

Sincerely,

  • 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 accordingly.

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

Document Control Desk PLA-7570 : Susquehanna Nuclear, LLC's Eighth Six Month Status Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events : Susquehanna Nuclear' 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 2017) Security-Related Information - Withhold from Public Disclosure Under ,10 CFR 2.390 Copy: NRC Region I Ms. L. H. Micewski, 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-7570 Susquehanna Nuclear, LLC's Eighth 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-7570 Page 1of11 Susquehanna Nuclear, LLC's Eighth 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 Eighth Six Month Status Report provides an update of milestone accomplishments since submittal of the Seventh Six Month Status Report (Reference 8.17) 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 December 30, 2016.
  • Started installation of the Unit 2 Severe Accident Capable Hardened Containment Vent System.
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) was 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 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.

Enclosure 1 to PLA-7570 Page 2of11 Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 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 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Complete Update 7 August 2016 Complete Update 8 February 2017 Complete*

Update 9 August 2017 Not Started Update 10 February 2018 Not Started FLEX Strategy Evaluation April 2015 Complete May2015 Unit2 FLEX Strategy Evaluation April 2016 Complete Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April 2015 Complete May2015 Demonstrations Unit 2 Walk-throughs or April 2016 Complete Demonstrations Unit 1 Perform Staffing Analysis October 2014 Complete Modifications:

Enclosure 1 to PLA-7570 Page 3of11 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. 8.11)

Phases)

Unit 2 Implementation April 2015 Complete May2015 Outage Unit 1 Design Engineering June 2015 Complete August2015

- Issue Unit 1 Design (except HCVS, Change Documents (for all see Ref. 8.11)

Phases)

Unit 1 Implementation March 2016 Complete 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 April 2015 Complete May2015 Equipment Contract with Vendor for March2013 Complete National SAFER Response Center (NSRCs) established Develop Strategies with April2015 Complete Feb 2015 NSRC

Enclosure 1 to PLA-7570 Page 4of11 Revised Target Activity Target Milestone Completion Status Completion Date Date Establish offsite staging May2015 Complete location [Install Off-Site Delivery Station (if Necessary)]

National SAFER Response December 2014 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 (except HCVS, (including FSGs and see Ref. 8.11) maintenance)

Procedures Complete Unit April 2016 Complete 1 FLEX Implementation (except HCVS, (including FSGs and see Ref. 8.11) maintenance)

Training:

Develop Training Plan May2014 Complete February 2016 Complete April 2016 Training Complete (except HCVS, see Ref. 8.11)

April 2015 Complete May2015 Unit2 FLEX Implementation (except HCVS, see Ref. 8.11)

April2016 Complete Unit 1 FLEX Implementation (except HCVS, see Ref. 8.11)

Enclosure 1 to PLA-7570 Page 5of11 Revised Target Activity Target Milestone Completion Status Completion Date Date Full Site FLEX April2016 Complete Implementation (except HCVS, (except HCVS) see Ref. 8.11)

Unit 2 Severe Accident April 2017 Design Capable Hardened Complete, Containment Vent System Installation Phase 1 Started*

Unit 1 Severe Accident April2018 Design Started*,

Capable Hardened Installation Not Containment Vent System Started Phase 1 Unit 1 Severe Accident April 2018 Design Started*,

Capable Hardened Implementation Containment Vent System Not Started Phase 2 Unit 2 Severe Accident April 2019 Design Started*,

Capable Hardened Implementation Containment Vent System Not Started Phase 2 August 2019 Not Started (after HCVS Submit Completion Report Order actions are complete per Ref 8.11)*

  • Revised since the six month update submitted August 19, 2016 (Reference 8.1 7)

Enclosure 1 to PLA-7570 Page 6of11

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 byNRC Order EA-12-050.

Upon issuance ofNRC Qrder 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 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-7570 Page 7of11 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 byNRC Order EA-12-050.

Upon issuance ofNRC 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 December 30, 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. BOP changes required to support Complete Mitigation Strategies.
3. Develop S SES "Response Plan" for use Complete of the National SAFER Response Centers (NSRC).
4. FLEX Equipment Storage Complete

Enclosure 1 to PLA-7570 Page 8of11 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. Determine appropriate use of RCIC or Complete FLEX pump mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3.
7. Evaluate the impact ofRCIC pump seal Complete failures. EC-050-1034, Rev. 0 approved 12/13/2013
8. Evaluate potential RCIC pump Complete modifications.
9. Establish method of venting the Refuel Complete Floor. EC-012-6122, Rev 0 approved on 4/29/2014.
10. Evaluate means to assure continued long Complete term 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 <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, 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-030-1006, Rev 14, have not been performed. The calculation has now been reviewed and approved.

Enclosure 1 to PLA-7570 Page 9of11 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

15. Fuel consumption and refuel intervals Complete will be determined during the procurement process for the 4160VAC generators.
  • Revised since the six month update submitted August 19, 2016 (Reference 8.17)
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 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.

Enclosure 1 to PLA-7570 Page 10of11

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 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).

Enclosure 1 to PLA-7570 Page 11of11 8.10 PLA-7137, "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)," dated February 28, 2014.

8.11 NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"' dated April 15, 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 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 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-De~ign-Basis External Events (NRC Order EA-12--049)," dated August 26, 2015.

8.15 NRC Letter from John D. Hughey to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 - Repol,"t for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April 13, 2015 (ML15089A123).

8.16 PLA-7438, "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)," dated February 18, 2016.

8.17 PLA-7513, "Seventh 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 19, 2016 .

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