ML14251A231

Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Nrc Order EA-12-049) PLA-7204

ML14251A231
Person / Time
Site:	Susquehanna
Issue date:	08/27/2014
From:	Rausch T PPL Bell Bend
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, PLA-7204
Download: ML14251A231 (13)

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. I Timothy S. Rausch PPL Susquehanna, LLC 0 Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard 0 Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 tsrausch@pplweb.com AUG 22014 PPT U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION 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) Docket No. 50-387 PLA-7204 and No. 50-388

References:

1. NRC OrderEA-12-049, "Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events," dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-O1, "Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events, " Revision 0, dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, datedAugust 2012

4. PPL Letter (PLA-6923), "InitialStatus Report in Response to March 12, 2012 Commission OrderModifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA-12-049), " dated October 29, 2012

5. PPL Letter (PLA-6981), "Overall Integrated Plan in Response to March 12, 2012 Commission OrderModifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-Basis External Events (NRC Order EA-12-049), " dated February28, 2013

6. PPL Letter (PLA-7072), "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond-Design-BasisExternal Events (NRC OrderEA-12-049),"

dated August 26, 2013

7. NRC Order EA-13-109, "Order to Modifv, 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 Requirementsfor Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," datedAugust 26, 2013

9. PPL Letter (PLA-7134), "Request for Relaxation front NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'" dated February20, 2014

10. NRC Letterfrom J. S. Bowen to T. S. Rausch, "SusquehannaSteam Electric Station, Units I and 2 -Interim Staff Evaluation Relating To Overall IntegratedPlan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January24, 2014 (ADAMS # ML13339A764)

Enclosure 2 of the Attachment contains proprietary information. Withhold from public disclosure under 10CFR2.390(d)(1), as other than Safeguards Information, and designated as Security Sensitive Information. When Ip&p 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-7204

11. PPL Letter (PLA-7137), "Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategies for Beyond-Design-Basis External Events (NRC OrderEA-12-049), " dated February 28, 2014

12. NRC Letterfroom E. J. Leeds to T. S. Rausch, "SusquehannaSteam Electric Station Units 1 and 2 - Relaxation of Certain Schedule Requirements for OrderEA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirementsfor Mitigation Strategiesfor Beyond Design Basis External Events. "' dated April 15, 2014 The purpose of this letter is to provide PPL Susquehanna, LLC's (PPL) third 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 Information" as defined in 10 CFR 2.390 (d)(1). Accordingly, PPL requests that the information provided in Enclosure 2 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 PPL. Reference 1 was immediately effective and directs PPL to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided PPL's initial status report regarding Mitigation Strategies.

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

Reference 1 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan. Reference 3 provides direction regarding the content of the status reports.

The Request for Relaxation contained in Reference 9 supersedes the Request for Relief made in Reference 6. The Request for Relaxation is based on NRC mandated changes to the Hardened Containment Vent System implementation dates that impact the Mitigation Strategy Overall Integrated Plan. Specifically, the change in implementation dates for the Hardened Containment Vent Order (NRC Order EA-12-050 was rescinded and superseded by NRC Order EA-13-109) impacts the Mitigation Strategy Overall Enclosure 2 of the Attachment contains proprietary information. Withhold from public disclosure under 10CFR2.390(d)(1), 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-7204 Integrated Plan and implementation timeline. The NRC approved this relaxation in Reference 12.

This letter contains no new or revised regulatory commitments.

If you have any questions regarding this report, please contact Mr. John L. Tripoli, Manager - Nuclear Regulatory Affairs, at (570) 542-3100.

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

Executed on: ý-Iaý 11+

Sincerely, T. S. Rausch : PPL Susquehanna, LLC's Third 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 : PPL Susquehanna's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), (August 2014) Security-Related Information -

Withhold from Public Disclosure Under 10 CFR 2.390 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP Enclosure 2 of the Attachment contains proprietary information. Withhold from public disclosure under 10CFR2.390(d)(1), 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-7204 PPL Susquehanna, LLC's Third 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-7204 Page 1 of 9 PPL Susquehanna, LLC's Third Six Month Status Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan (Reference 1) documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This Third Six Month Status Report provides an update of milestone accomplishments since submittal of the First Six Month Status Report (Reference 7) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

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

2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2014.

" Open Items 1, 4, 7, 8, 9, 13 and 14 have been completed.

Numerous milestones have been started and are in progress as listed on the Section 3, Milestone Schedule Status table, for example - Phase 2 Staffing Analysis, construction of the 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 (ISE) from the NRC (Reference 9) has been received in time to support implementation of the Mitigation Strategies. The Open Item and Confirmatory Items identified in the ISE will be addressed by the Regulatory Audit Process.

Enclosure 1 to PLA-7204 Page 2 of 9 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 Not Started Update 5 August 2015 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started FLEX Strategy Evaluation April 2015 Started Unit 2 FLEX Strategy Evaluation April 2016 Started Unit 1 Validation by Walk-throughs or Demonstration(s):

Walk-throughs or April 2015 Not Started Demonstrations Unit 2 Walk-throughs or April 2016 Not Started Demonstrations Unit 1 Perform Staffing Analysis October 2014 Started Modifications:

Modifications Evaluation June 2015 Started

Enclosure 1 to PLA-7204 Page 3 of 9 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 April 2015 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 April 2016 Not Started Outage Storage:

Storage Design May 2014 Complete*

Engineering Storage Implementation - April 2015 Started Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site April 2015 Started Equipment Contract with Vendor for March 2013 Complete National SAFER Response Center (NSRCs) established Develop Strategies with April 2015 Started NSRC Establish offsite staging May 2015 Started location [Install Off-Site Delivery Station (if Necessary)]

Enclosure 1 to PLA-7204 Page 4 of 9 Revised Target Activity Target Milestone Completion Status Completion Date Date National SAFER Response December 2014 Started* January Centers in service 2015*

Procedures:

BWROG issue Emergency February 2013 Complete Procedure and Severe Accident Guidelines (EPGs/SAGs) Rev. 3 Procedures Complete Unit April 2015 Started 2 FLEX Implementation (including FSGs and maintenance)

Procedures Complete Unit April 2016 Started 1 FLEX Implementation (including FSGs and maintenance)

Training:

Develop Training Plan May 2014 Complete Training Complete February 2016 Started*

Unit 2 FLEX April 2015 Started*

Implementation Unit 1 FLEX April 2016 Started*

Implementation Full Site FLEX April 2016 Started*

Implementation Submit Completion Report August 2016 Not Started

• Revised since the six month update submitted February 28, 2014 (Reference 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.

Enclosure 1 to PLA-7204 Page 5 of 9 Reference 1 provided PPL's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions.

The Reference 1 enclosure describes PPL's Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification is required to install a Hardened Containment Vent System.

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

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

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for PPL Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference 8. This relaxation was granted in Reference 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).

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

Reference 1 provided PPL's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will also affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions.

The Reference 1 enclosure describes the PPL Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

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

Enclosure 1 to PLA-7204 Page 6 of 9 Upon issuance of NRC Order EA-13-109, the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050.

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

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 8). This relaxation was granted in Reference 11.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of July 31, 2014 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.

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*

5. Review GEH Report NEDC 33771P, Complete GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment 11B.

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

Enclosure 1 to PLA-7204 Page 7 of 9 Overall Integrated Plan Open Item Status

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 Started term gas supply for ADS/SRVs.

11. Evaluate means to transfer diesel fuel oil Started 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.

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 />.

Enclosure 1 to PLA-7204 Page 8 of 9 Overall Integrated Plan Open Item Status

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

• Revised since the six month update submitted February 28, 2014 (Reference 10)

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.

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

1. PPL Letter (PLA-698 1), "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2013.

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

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

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

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

Revision 0, dated August 29, 2012.

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

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

7. PPL Letter (PLA-707 1), "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.

Enclosure 1 to PLA-7204 Page 9 of 9

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

9. NRC Letter from J. S. Bowen 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).

10. 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.

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.