ML15057A227

Enclosure 1 to PLA-7295 PPL Susquehanna, Llc'S Fourth 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 Eve

ML15057A227
Person / Time
Site:	Susquehanna
Issue date:	02/25/2015
From:	Susquehanna
To:	Office of Nuclear Reactor Regulation
Shared Package
ML15057A224	List: ML15057A227 ML15057A228
References
EA-12-049, PLA-7295
Download: ML15057A227 (11)

Text

Enclosure 1 to PLA-7295 PPL Susquehanna, LLC's Fourth 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-7295 Page 1 of 10 PPL Susquehanna, LLC's Fourth 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 8.1) documenting the diverse and flexible strategies (FLEX), in response to Reference 8.2. This Fourth Six Month Status Report provides an update of milestone accomplishments since submittal of the Third Six Month Status Report (Reference 8.12) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

[NOTE: References cited in this enclosure are contained in Section 8.]

2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 8.1), and are current as of January 31, 2015.

• Open Items 10, 11, and 15 have been completed.

• The Phase 2 Staffing Assessment has been completed.

• Numerous milestones are in progress as listed on the Section 3, Milestone Schedule Status table, for example - construction of the FLEX equipment storage building, modification installation, and training.

3. Milestone Schedule Status The following table provides an update to Attachment 2, Milestone Schedule, of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the Order implementation date at this time. The Interim Staff Evaluation (IS E) from the NRC (Reference 8.9) has been received in time to support implementation of the Mitigation Strategies. The Open Item and Confirmatory Items identified in the ISE 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

Enclosure 1 to PLA-7295 Page 2 of 10 closed. The NRC's Audit Report will document the closure status of the Mitigation Strategies issues.

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 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started FLEX Strategy Evaluation April2015 Started Unit2 FLEX Strategy Evaluation April2016 Started Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April2015 Started Demonstrations Unit 2 Walk-throughs or April2016 Started Demonstrations Unit 1 Perform Staffing Analysis October 2014 Complete*

Modifications:

Modifications Evaluation June 2015 Started

Enclosure 1 to PLA-7295 Page 3 of 10 Revised Target Activity Target Milestone Completion Status Completion Date Date Unit 2 Design Engineering June 2014 Complete

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

Phases)

Unit 2 Implementation April2015 Not Started Outage Unit 1 Design Engineering June 2015 Complete

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

Phases)

Unit 1 Implementation April2016 Not Started Outage Storage:

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

Procure On-Site April2015 Started Equipment Contract with Vendor for March 2013 Complete National SAFER Response Center (NSRCs) established Develop Strategies with April2015 Started NSRC Establish offsite staging May2015 Complete*

location [Install Off-Site Delivery Station (if Necessary)]

Enclosure 1 to PLA-7295 Page 4 of10 Revised Target Activity Target Milestone Completion Status Completion Date Date National SAFER Response December 2014 Started April2015* ,

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 Started 2 FLEX Implementation (including FSGs and maintenance)

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

Training:

Develop Training Plan May2014 Complete Training Complete February 2016 Started Unit 2 FLEX April2015 Started Implementation Unit 1 FLEX April2016 Started Implementation Full Site FLEX April2016 Started Implementation Submit Completion Report August 2016 Not Started

• Revised since the six month update submitted August 28, 2014 (Reference 8.12)

Enclosure 1 to PLA-7295 Page 5 of 10

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 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 8.1 enclosure describes PPL's Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification is required to install a Hardened Containment Vent System.

Thus the PPL response to NRC Order EA-12-049 provided in Reference 8.1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

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

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference 8.8. This relaxation was granted in Reference 8.11.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with NRC Order EA-12-049, but needs relaxation of the implementation dates. The specific details have been submitted in a separate document (Reference 8.8).

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 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 8.1 enclosure describes the PPL Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened

Enclosure 1 to PLA-7295 Page 6 of 10 Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

Thus the PPL NRC Order EA-12-049 response provided in Reference 8.1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

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

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-1 09 is achieved.

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 8.8). This relaxation was granted in Reference 8.11.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of January 31, 2015 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 will document the closure status of the Mitigation Strategies issues.

Overall Integrated Plan Open Item Status

1. Phase 3 Shutdown Cooling Capability Complete

2. EOP changes required to support Started Mitigation Strategies.

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

4. FLEX Equipment Storage Complete

Enclosure 1 to PLA-7295 Page 7 oflO 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 1B.

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 of RCIC 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-7295 Page 8 of 10 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 28, 2014 (Reference 8.12)

7. Potential Draft Safety Evaluation Impacts None- PPL has received the ISE and will be closing 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 will document the closure status of the Mitigation Strategies Issues.

Enclosure 1 to PLA-7295 Page 9 of 10

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

8.1 PLA-69~ 1, "Overall Integrate~ Plan in Response to .March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2013.

8.2 NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.

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

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

8.4 NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External events," Revision 0, dated August 29, 2012.

8.5 PLA-7072, "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26,2013.

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

8.7 PLA-7071, "First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013.

8.8 PLA-7134, "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' dated February 20, 2014.

8.9 NRC Letter from J. S. Bowen toT. S. Rausch, "Susquehanna Steam Electric Station, Units 1 And 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January 24, 2014 (ADAMS# ML13339A764).

Enclosure 1 to PLA-7295 Page 10 of 10 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 toT. 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 April15, 2014.

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.