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| number = ML13242A013
| number = ML13242A013
| issue date = 08/23/2013
| issue date = 08/23/2013
| title = Surry, Units 1 and 2 - 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 No. EA-12-049)
| title = 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 No. EA-12-049)
| author name = Grecheck E S
| author name = Grecheck E
| author affiliation = Virginia Electric & Power Co (VEPCO)
| author affiliation = Virginia Electric & Power Co (VEPCO)
| addressee name =  
| addressee name =  
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261August 23, 201310 CFR 2.202EA-1 2-049Attention:
{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 23, 2013 10 CFR 2.202 EA-1 2-049 Attention: Document Control Desk                             Serial No.:   12-163D U.S. Nuclear Regulatory Commission                           NL&OS/MAE:   R2 Washington, D.C. 20555-0001                                 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 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)
Document Control Desk Serial No.: 12-163DU.S. Nuclear Regulatory Commission NL&OS/MAE:
R2Washington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-12-049)


==References:==
==References:==
: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events,dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, datedAugust 29, 20123. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 20124. Virginia Electric and Power Company's Initial Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),
: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
dated October 25, 201.2 (Serial No. 12-163A)5. Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),
: 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
dated February 28, 2013 (Serial No. 12-163B)6. Virginia Electric and Power Company's Supplement to Overall Integrated Plan inResponse to March 12, 2012 Commission Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (Order Number EA-12-049),
: 3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
dated April 30, 2013 (Serial No. 12-163C)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference  
: 4. Virginia Electric and Power Company's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 201.2 (Serial No. 12-163A)
: 1) to Virginia Electric and Power Company (Dominion).
: 5. Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-163B)
Reference 1 wasimmediately effective and directs Dominion to develop, implement, and maintainguidance and strategies to maintain or restore core cooling, containment, and spent fuelpool cooling capabilities in the event of a beyond-design-basis external event. Specificrequirements are outlined in Attachment 2 of Reference 1.13/4gA Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-049 Page 2 of 3Reference 1 required submission of an initial status report 60 days following issuance ofthe final interim staff guidance (Reference  
: 6. Virginia Electric and Power Company's Supplement to Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated April 30, 2013 (Serial No. 12-163C)
: 2) and an overall integrated plan pursuant toSection IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06,Revision 0 (Reference  
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 was immediately effective and directs Dominion to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, 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.
: 3) with clarifications and exceptions.
13/4gA
Reference 4 providedDominion's initial status report regarding mitigation strategies, and Reference 5provided Dominion's overall integrated plan. Reference 6 provided a supplement toDominion's 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 thecontent of the status reports.
 
The six-month status report (pursuant to Section IV,Condition C,2, of Reference  
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Page 2 of 3 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 endorsed industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions. Reference 4 provided Dominion's initial status report regarding mitigation strategies, and Reference 5 provided Dominion's overall integrated plan. Reference 6 provided a supplement to Dominion's overall integrated plan.
: 1) delineates the progress made in implementing therequirements of Reference 1 and is provided as an attachment to this letter. Theattached report also provides an update of milestone accomplishments since thesupplement to the overall integrated plan (Reference 6), including any changes to thecompliance method, schedule, or need for relief and the basis, if any.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.
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 six-month status report (pursuant to Section IV, Condition C,2, of Reference 1) delineates the progress made in implementing the requirements of Reference 1 and is provided as an attachment to this letter. The attached report also provides an update of milestone accomplishments since the supplement to the overall integrated plan (Reference 6), including any changes to the compliance method, schedule, or need for relief and the basis, if any.
Sincerely, Eugene S. GrecheckVice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIACOUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President Nuclear Engineering and Development of Virginia Electricand Power Company.
If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.
He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of hisknowledge and belief.rA CRAIG D SLYAcknowledged before me this 23 day of A,,wak 2013. CNotary Public-ýj I Commonwealth of VirginiaMy Commission Expires:"pc&.
Sincerely, Eugene S. Grecheck Vice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President Nuclear Engineering and Development of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.
3trL2A ZAN, Reg. # 7518653 , I-Expires December 31, 20NeaýPblic Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-049 Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Ms. K. R. Cotton GrossNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North AnnaU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 09 D211555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-049 Attachment Six Month Status Report for the Implementation of Order EA-1 2-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsSurry Power Station Units I and 2Virginia Electric and Power Company (Dominion)
rA Acknowledged before me this 23 day of A,,wak               2013.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-049 Attachment Page 1 of 18Six Month Status Report for the Implementation of Order EA-1 2-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference  
CRAIG DSLY CNotary Public
: 1) documenting thediverse and flexible strategies (FLEX) for Surry Power Station in response to NRCOrder Number EA-12-049 (Reference 2). This attachment provides an update ofmilestone accomplishments and open items since submittal of the OIP including anychanges to the compliance method, schedule, or need for relief/relaxation and thebasis, if any.2 Milestone Accomplishments The following milestone has been completed since the development of the OIP and iscurrent as of July 31, 2013.0 Submit OIP3 Milestone Schedule StatusThe following table provides an update to Attachment 2A of the OIP. It provides theactivity status of each item, and whether the expected completion date has changed.The dates are planning dates subject to change as design and implementation detailsare developed.
                                                    -ýj                     I     Commonwealth of Virginia My Commission Expires:"pc&.         3trL2A ZAN,                                   Reg. # 7518653           , I
The revised milestone targetModifications',
                                                                              -Expires             December 31, 20 NeaýPblic
and 'Unit 1implementation date.completion dates for 'Develop Strategies',  
 
'Implement Outage Implementation' do not impact the OrderTarget Activity Revised TargetMilestone Completion Status Completion Date DateSubmit Integrated Plan Feb 2013 CompleteDevelop Strategies July 2013 Started October 2013Develop Modifications Apr 2014 StartedImplement Modifications Sept 2014 Started May 2015Develop Training Plan Apr 2014 StartedImplement Training Aug 2014 Not Started Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 2 of 18Target Revised TargetMilestone Completion Activity Completion Date DateIssue FSGs* Sept 2014 Not StartedDevelop Strategies/
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Ms. K. R. Cotton Gross NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 D2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station
Contractwith Regional Response Center Apr 2014 Started(RRC)Purchase Equipment Feb 2014 StartedProcure Equipment*
 
Aug 2014 Not StartedValidation Walk-throughs orDemonstrations of FLEX Dec 2014 Not StartedStrategies and Procedures*
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Attachment Six Month Status Report for the Implementation of Order EA-1 2-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Surry Power Station Units I and 2 Virginia Electric and Power Company (Dominion)
Create Maintenance Procedures Aug 2014 Not StartedUnit 1 Outage Implementation Apr 2015 Not Started May 2015Unit 2 Outage Implementation Oct 2015 Not Started* Refer to Section 8 for an explanation of Milestone changes.4 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at Surry Power Station (Surry) Units 1 and 2 (Reference 1)as required by Order Number EA-12-049, dated March 12, 2012 (Reference 2). Thefollowing are changes to the compliance method information provided in the Surry OIP;however, the changes continue to meet NEI 12-06 (Reference 3):a) Details of the alternate connection strategy for Auxiliary Feedwater (AFW)injection, as described in Section B.2 -PWR Portable Equipment Phase 2 andshown on OIP Figure 3, have changed for Surry Units 1 and 2. The tie-inlocations at valve 1-FW-57 (Unit 1) and 2-FW-57 (Unit 2) will no longer be usedas the alternate AFW injection connections.
 
The re-located connections described below are more readily accessible and serve the same function in thealternate strategy.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Attachment Page 1 of 18 Six Month Status Report for the Implementation of Order EA-1 2-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1  Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverse and flexible strategies (FLEX) for Surry Power Station in response to NRC Order Number EA-12-049 (Reference 2). This attachment provides an update of milestone accomplishments and open items since submittal of the OIP including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
For Unit 1, the bonnet assembly of the AFW cross-connect isolation motor-operated valve (MOV) 1-FW-MOV-160B, located in the Unit 2 AFW PumpHouse, will be removed and a flanged temporary hose connection adapter will beinstalled on the valve to support connecting the BDB AFW pump to the Unit 1AFW cross-connect line. The location of 1-FW-MOV-160B allows for easy hoserouting and is within a safety related structure.
2   Milestone Accomplishments The following milestone has been completed since the development of the OIP and is current as of July 31, 2013.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 3 of 18For Unit 2, the bonnet assembly of the AFW cross-connect isolation MOV 2-FW-MOV-260B, located in the Unit 1 AFW Pump House, will be removed and aflanged temporary hose connection adapter will be installed on the valve tosupport connecting the BDB AFW pump to the Unit 2 AFW cross-connect line.The location of 2-FW-MOV-260B allows for easy hose routing and is within asafety related structure.
0   Submit OIP 3  Milestone Schedule Status The following table provides an update to Attachment 2A of the OIP. It provides the activity status of each item, and whether the expected completion date has changed.
A revised OIP Figure 3 is attached.
The dates are planning dates subject to change as design and implementation details are developed.
This figure represents the Unit 1configuration only but is typical for both units.b) Details of the strategy for the portable diesel generators (DGs) used to re-powerthe 120VAC vital bus circuits, as described in Section F1.2 -PWR PortableEquipment Phase 2, have changed for Surry Units 1 and 2. A single120/240VAC DG per unit will be sized to accommodate the necessary electrical loads for that unit and will power both BDB distribution panels for that unit. Thus,the deployment of two 120/240 VAC DGs per unit as shown in Figure 7 of thepreviously submitted OIP is no longer being pursued, and a revised Figure 7 isattached.
The revised milestone target completion dates for 'Develop Strategies', 'Implement Modifications', and 'Unit 1 Outage Implementation' do not impact the Order implementation date.
Figure 8 is not revised since the single 120/240VAC DG location is thesame as the two DGs for each unit as stated in the OIP. Figure 9 was a typicalschematic of the connections from one of two 120/240VAC DGs. A revisedFigure 9 showing the current connections for the 120/240VAC DG (Unit 1 only) isattached.
Target          Activity     Revised Target Milestone              Completion         Status         Completion Date                               Date Submit Integrated Plan               Feb 2013         Complete Develop Strategies                   July 2013         Started       October 2013 Develop Modifications                 Apr 2014         Started Implement Modifications             Sept 2014         Started         May 2015 Develop Training Plan                 Apr 2014         Started Implement Training                   Aug 2014       Not Started
A spare 120/240VAC DG will be purchased;  
 
: however, as stated in theOIP, the 480VAC DG is considered the alternate re-powering source forinstrumentation.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 2 of 18 Target                          Revised Target Milestone                    Completion         Activity       Completion Date                                 Date Issue FSGs*                               Sept 2014       Not Started Develop Strategies/ Contract with Regional Response Center             Apr 2014           Started (RRC)
c) Details of the modification to the steam generator (SG) power-operated reliefvalves (PORVs),
Purchase Equipment                         Feb 2014           Started Procure Equipment*                         Aug 2014         Not Started Validation Walk-throughs or Demonstrations of FLEX                     Dec 2014         Not Started Strategies and Procedures*
as described in Section B.1 -PWR Installed Equipment Phase 1, have changed for Surry Units 1 and 2. Although the overall strategyhas not been altered, the details of the modification have been revised to providea more suitable option that will continue to allow for local manual operation of theSG PORVs. Instead of a modification to add hand wheels to the valves, the SGPORVs will be modified to add a protected backup air bottle system which will beinstalled in the Main Steam Valve House (MSVH) AFW pump room. Localmanual operation of the SG PORVs using the protected backup air bottle systemwill continue to allow control of RCS cooldown to support the reactor core coolingand decay heat removal Phase 1 strategy.
Create Maintenance Procedures             Aug 2014         Not Started Unit 1 Outage Implementation               Apr 2015         Not Started         May 2015 Unit 2 Outage Implementation               Oct 2015         Not Started
d) Changes to the timing of the RCS Injection strategy have been made. Thestrategy for RCS injection for inventory and reactivity control has been movedfrom a Phase 3 activity to a Phase 2 activity.
* Refer to Section 8 for an explanation of Milestone changes.
The details and descriptions provided in Section C.3 of the OIP for RCS injection for the Phase 3 activitycontinue to be the same for the Phase 2 strategy for RCS injection, including thetime at which natural circulation capability is lost, i.e., approximately 33 hours Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 4 of 18based on WCAP-17601 (Reference  
4 Changes to Compliance Method By letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at Surry Power Station (Surry) Units 1 and 2 (Reference 1) as required by Order Number EA-12-049, dated March 12, 2012 (Reference 2). The following are changes to the compliance method information provided in the Surry OIP; however, the changes continue to meet NEI 12-06 (Reference 3):
: 5) and ETE-NAF-2012-0150 (Reference 9).For conservatism and margin to account for uncertainty within the calculations and unanticipated deployment issues, a time of 16 hours has been chosen,which provides significant margin (by a factor of 2) prior to loss of naturalcirculation and the start of reflux boiling.e) The quantities of BDB equipment stated in OIP Table 1, PWR PortableEquipment Phase 2, and OIP Table 2, PWR Portable Equipment Phase 3, havechanged.
a) Details of the alternate connection strategy for Auxiliary Feedwater (AFW) injection, as described in Section B.2 - PWR Portable Equipment Phase 2 and shown on OIP Figure 3, have changed for Surry Units 1 and 2. The tie-in locations at valve 1-FW-57 (Unit 1) and 2-FW-57 (Unit 2) will no longer be used as the alternate AFW injection connections.               The re-located connections described below are more readily accessible and serve the same function in the alternate strategy.
Per Footnote 1 to Table 1, the quantities were based on theassumption that two storage buildings would be available to store BDBequipment pending completion of the study to determine the details of the BDBStorage Building(s).
For Unit 1, the bonnet assembly of the AFW cross-connect isolation motor-operated valve (MOV) 1-FW-MOV-160B, located in the Unit 2 AFW Pump House, will be removed and a flanged temporary hose connection adapter will be installed on the valve to support connecting the BDB AFW pump to the Unit 1 AFW cross-connect line. The location of 1-FW-MOV-160B allows for easy hose routing and is within a safety related structure.
Open Item No. 6 has been completed, and the decision tohave one storage building is documented in Section 6 of this update. A revisedTable 1 is attached.
 
As discussed in the previous item d), Surry will purchase and store BDB RCSInjection pumps for use in the Phase 2 RCS Inventory strategy.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 3 of 18 For Unit 2, the bonnet assembly of the AFW cross-connect isolation MOV 2-FW-MOV-260B, located in the Unit 1 AFW Pump House, will be removed and a flanged temporary hose connection adapter will be installed on the valve to support connecting the BDB AFW pump to the Unit 2 AFW cross-connect line.
These pumpsare being added to the revised Table 1 for Phase 2 equipment.
The location of 2-FW-MOV-260B allows for easy hose routing and is within a safety related structure.
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation relief/relaxation has been identified at this time.6 Open Items from Overall Integrated PlanThe following table provides a summary of the openAttachment 2B of the OIP and the status of each item.date and no requireditems documented inOverall Integrated Plan Open Item01 # Description StatusVerify response times listed in timeline and perform staffing Not started.1 assessment.
A revised OIP Figure 3 is attached.             This figure represents the Unit 1 configuration only but is typical for both units.
Scheduled completion date: December 2014Preliminary analyses have been performed to determine the Complete.
b) Details of the strategy for the portable diesel generators (DGs) used to re-power the 120VAC vital bus circuits, as described in Section F1.2 - PWR Portable Equipment Phase 2, have changed for Surry Units 1 and 2. A single 120/240VAC DG per unit will be sized to accommodate the necessary electrical loads for that unit and will power both BDB distribution panels for that unit. Thus, the deployment of two 120/240 VAC DGs per unit as shown in Figure 7 of the previously submitted OIP is no longer being pursued, and a revised Figure 7 is attached. Figure 8 is not revised since the single 120/240VAC DG location is the same as the two DGs for each unit as stated in the OIP. Figure 9 was a typical schematic of the connections from one of two 120/240VAC DGs. A revised Figure 9 showing the current connections for the 120/240VAC DG (Unit 1 only) is attached. A spare 120/240VAC DG will be purchased; however, as stated in the OIP, the 480VAC DG is considered the alternate re-powering source for instrumentation.
2 Class 1 E battery life based on implementation of load (Reference 4)stripping actions.
c) Details of the modification to the steam generator (SG) power-operated relief valves (PORVs), as described in Section B.1 - PWR Installed Equipment Phase 1, have changed for Surry Units 1 and 2. Although the overall strategy has not been altered, the details of the modification have been revised to provide a more suitable option that will continue to allow for local manual operation of the SG PORVs. Instead of a modification to add hand wheels to the valves, the SG PORVs will be modified to add a protected backup air bottle system which will be installed in the Main Steam Valve House (MSVH) AFW pump room. Local manual operation of the SG PORVs using the protected backup air bottle system will continue to allow control of RCS cooldown to support the reactor core cooling and decay heat removal Phase 1 strategy.
The final battery life duration will beprovided when the analyses are completed.
d) Changes to the timing of the RCS Injection strategy have been made. The strategy for RCS injection for inventory and reactivity control has been moved from a Phase 3 activity to a Phase 2 activity. The details and descriptions provided in Section C.3 of the OIP for RCS injection for the Phase 3 activity continue to be the same for the Phase 2 strategy for RCS injection, including the time at which natural circulation capability is lost, i.e., approximately 33 hours
Preliminary analyses have been performed to determine the Complete.
 
time to steam generator overfill without operator action to (Reference 4)reduce AFW flow, time to steam generator dryout withoutAFW flow, and time to depletion of the useable volume of theECST and ECMT. The final durations will be provided whenthe analyses are completed.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 4 of 18 based on WCAP-17601 (Reference 5) and ETE-NAF-2012-0150 (Reference 9).
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 5 of 18Overall Integrated Plan Open Item01 # Description StatusThe Phase 3 coping strategy to maintain containment integrity Started.is under development.
For conservatism and margin to account for uncertainty within the calculations and unanticipated deployment issues, a time of 16 hours has been chosen, which provides significant margin (by a factor of 2) prior to loss of natural circulation and the start of reflux boiling.
Methods to monitor and evaluate Scheduled completion 4 containment conditions and depressurize/cool containment, if date is revised fromnecessary, will be provided in a future update. December 2013 toOctober 2013 **Analyses will be performed to develop fluid components Started.5 performance requirements and confirm fluid hydraulic-related Scheduled completion strategy objectives can be met. date: September 2013A study is in progress to determine the design features, sitelocation(s),
e) The quantities of BDB equipment stated in OIP Table 1, PWR Portable Equipment Phase 2, and OIP Table 2, PWR Portable Equipment Phase 3, have changed. Per Footnote 1 to Table 1, the quantities were based on the assumption that two storage buildings would be available to store BDB equipment pending completion of the study to determine the details of the BDB Storage Building(s). Open Item No. 6 has been completed, and the decision to have one storage building is documented in Section 6 of this update. A revised Table 1 is attached.
and number of equipment storage facilities.
As discussed in the previous item d), Surry will purchase and store BDB RCS Injection pumps for use in the Phase 2 RCS Inventory strategy. These pumps are being added to the revised Table 1 for Phase 2 equipment.
Thefinal design for BDB equipment storage will be based on theguidance contained in NEI 12-06, Section 11.3, Equipment Storage.
5   Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date and no required relief/relaxation has been identified at this time.
A supplement to this submittal will be provided withthe results of the equipment storage study.6Complete.
6 Open Items from Overall Integrated Plan The following table provides a summary of the open                        items documented        in B of the OIP and the status of each item.
A single 10,000 sq. ft.Type 1 building will beconstructed at Surry forstorage of BDBequipment.
Overall Integrated Plan Open Item 01 #                               Description                                       Status Verify response times listed in timeline and perform staffing       Not started.
Thebuilding will be designedto meet the plant'sdesign basis for theSafe ShutdownEarthquake, high windhazards, snow, ice andcold conditions, and willbe located above theflood elevation from themost recent site floodinganalysis.
1     assessment.                                                         Scheduled completion date: December 2014 Preliminary analyses have been performed to determine the           Complete.
The BDBStorage Building will besited just east of thesouth employee parkinglot, inside the OwnerControlled Area. Thelocation lies in an areabetween the SurryNuclear Information Center and the intakecanal. This updateprovides thesupplemental information referred to inthis open item.FLEX Support Guidelines (FSGs) will be developed in Started.7 accordance with PWROG guidance.
2     Class 1 E battery life based on implementation of load             (Reference 4) stripping actions. The final battery life duration will be provided when the analyses are completed.
Existing procedures will Scheduled completion be revised as necessary to implement FSGs. date: September 2014 Six Month StatusSerial No. 12-163DDocket Nos. 50-280/281 Report Order EA-12-049 Attachment Page 6 of 18Overall Integrated Plan Open Item01 # Description StatusEPRI guidance documents will be used to develop periodic Not started.testing and preventative maintenance procedures for BDB Scheduled completion 8 equipment.
Preliminary analyses have been performed to determine the           Complete.
Procedures will be developed to manage date: December 2014unavailability of equipment such that risk to mitigating strategycapability is minimized.
time to steam generator overfill without operator action to         (Reference 4) reduce AFW flow, time to steam generator dryout without AFW flow, and time to depletion of the useable volume of the ECST and ECMT. The final durations will be provided when the analyses are completed.
An overall program document will be developed to maintain Started.the FLEX strategies and their bases and to provide Scheduled completion configuration control and change management for the FLEX date: December 2014Program.The Dominion Nuclear Training Program will be revised to Started.assure personnel proficiency in the mitigation of BDB events Scheduled completion 10 is developed and maintained.
 
These programs and controls date: December 2014will be developed and implemented in accordance with theSystematic Approach to Training (SAT).Plant modifications will be completed for permanent plant Started.changes required for implementation of FLEX strategies.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 5 of 18 Overall Integrated Plan Open Item 01 #                           Description                                       Status The Phase 3 coping strategy to maintain containment integrity     Started.
Scheduled completion date: See Milestone Schedule.
is under development. Methods to monitor and evaluate             Scheduled completion 4   containment conditions and depressurize/cool containment, if     date is revised from necessary, will be provided in a future update.                   December 2013 to October 2013 **
The following actions will be completed to qualify the ECMT Started.as a source of water to the TDAFW pump in response to an Scheduled completion ELAP/LUHS event: (1) Upgrade the piping system from the date is revised from12 ECMT to the TDAFW pump suction to Seismic Category I, (2) December 2013 to MayModify the TDAFW pump discharge piping to install local AFW 2015 **flowrate indication, and (3) Confirm adequate TDAFW pumpNPSH with flow from the ECMT through the idle AFW boosterpumps **Complete the evaluation of TDAFW pump long term operation Complete.
Analyses will be performed to develop fluid components           Started.
with < 290 psig inlet steam pressure.
5   performance requirements and confirm fluid hydraulic-related     Scheduled completion strategy objectives can be met.                                 date: September 2013 A study is in progress to determine the design features, site    Complete.
TDAFW pump operation and adequate AFW flow13 to the SGs at SGpressures
location(s), and number of equipment storage facilities. The    A single 10,000 sq. ft.
< 290 psighas been confirmed.
final design for BDB equipment storage will be based on the      Type 1 building will be guidance contained in NEI 12-06, Section 11.3, Equipment         constructed at Surry for Storage. A supplement to this submittal will be provided with    storage of BDB the results of the equipment storage study.                     equipment. The building will be designed to meet the plant's design basis for the Safe Shutdown Earthquake, high wind hazards, snow, ice and cold conditions, and will be located above the flood elevation from the 6                                                                    most recent site flooding analysis. The BDB Storage Building will be sited just east of the south employee parking lot, inside the Owner Controlled Area. The location lies in an area between the Surry Nuclear Information Center and the intake canal. This update provides the supplemental information referred to in this open item.
(Reference 6)Details of the ventilation strategy are under development and Started.14 will conform to the guidance given in NEI 12-06. The details Scheduled completion of this strategy will be provided at a later date. date: September 2013Analyses will be performed to develop electrical components Complete.
FLEX Support Guidelines (FSGs) will be developed in             Started.
15 performance requirements and confirm electrical loading-The 120/240VAC DGsrelated strategy objectives can be met. have each been sized ata rating of 25KW. A Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-1 2-049Attachment Page 7 of 18Overall Integrated Plan Open Item01 # Description Statussingle DG will besufficient to handle thenecessary loads for asingle unit. A total ofthree (3) 120/240VAC DGs will be stored in theBDB Storage Buildingfor deployment asneeded. The 480VACDGs have each beensized at a rating of200KW. The two (2)480VAC DGs will bestored in the BDBStorage Building fordeployment as needed.(Reference 8)An evaluation of all BDB equipment fuel consumption and Not started.16 required re-fill strategies will be developed including any Scheduled completion gasoline required for small miscellaneous equipment.
7   accordance with PWROG guidance. Existing procedures will         Scheduled completion be revised as necessary to implement FSGs.                       date: September 2014
date: June 2014A lighting study will be performed to validate the adequacy of Started.17 supplemental lighting and the adequacy and practicality of Scheduled completion using portable lighting to perform FLEX strategy  
 
: actions, date: June 2014A communications study will be performed in accordance with Started.the statements made in response to Recommendation 9.3 of Scheduled completion 18 the 10 CFR 50.54(f) letter dated March 12, 2012 in Dominion date: Consistent withletter S/N 12-208F dated October 29, 2012. ** Recommendation 9.3implementation dates.Preferred travel pathways will be determined using the Not started.guidance contained in NEI 12-06. The pathways will attempt Scheduled completion 19 to avoid areas with trees, power lines, and other potential date: June 2014obstructions and will consider the potential for soilliquefaction.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 6 of 18 Overall Integrated Plan Open Item 01 #                             Description                                       Status EPRI guidance documents will be used to develop periodic           Not started.
The equipment listed in Table 1 will be procured.  
testing and preventative maintenance procedures for BDB             Scheduled completion 8 equipment. Procedures will be developed to manage                   date: December 2014 unavailability of equipment such that risk to mitigating strategy capability is minimized.
** Not started.Scheduled completion 20 date is revised fromJune 2014 to August2014 **** Refer to Section 8 for an explanation of changes to Open Items.
An overall program document will be developed to maintain           Started.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 8 of 187 Potential Draft Safety Evaluation ImpactsThere are no potential impacts to the Draft Safety Evaluation identified at this time.8 Supplemental Information This supplemental information provides details of changes identified in the statusupdates above and addresses the following topics: a) Open Item No. 4, b) Open ItemNo. 12, c) Open Item No. 18, d) Open Item No. 20, e) Milestone  
the FLEX strategies and their bases and to provide                 Scheduled completion configuration control and change management for the FLEX           date: December 2014 Program.
'Issue FSGs',f) Milestone  
The Dominion Nuclear Training Program will be revised to           Started.
'Procure Equipment',
assure personnel proficiency in the mitigation of BDB events       Scheduled completion 10 is developed and maintained. These programs and controls           date: December 2014 will be developed and implemented in accordance with the Systematic Approach to Training (SAT).
and g) the addition of Milestone "Validation Walk-throughs or Demonstration of FLEX Strategies and Procedures."
Plant modifications will be completed for permanent plant           Started.
a) Surry, Open Item 4: The Open Item completion date is revised to October 2013to be consistent with the revised completion date for the Milestone "DevelopStrategies."
changes required for implementation of FLEX strategies.             Scheduled completion date: See Milestone Schedule.
b) Surry, Open Item 12: The updated completion date allows for the requiredmodifications to be implemented and accurately reflects the updated milestone schedule activity for 'Implement Modifications'.
The following actions will be completed to qualify the ECMT         Started.
The revision to the wording forpart (3) of this Open Item more accurately reflects the planned activities todetermine and validate that adequate TDAFW pump NPSH from the ECMTthrough the idle AFW booster pumps is available to qualify the ECMT as asource of water to the TDAFW pump in response to an ELAP/LUHS event. Therevised Open Item 12, part (3) and revised completion schedule are as follows:Open Item 12, part (3): Confirm adequate TDAFW pump NPSH from theECMT through the idle AFW booster pump using conservative analysis.
as a source of water to the TDAFW pump in response to an           Scheduled completion ELAP/LUHS event: (1) Upgrade the piping system from the             date is revised from 12  ECMT to the TDAFW pump suction to Seismic Category I, (2) December 2013 to May Modify the TDAFW pump discharge piping to install local AFW 2015 **
Completion Schedule:
flowrate indication, and (3) Confirm adequate TDAFW pump NPSH with flow from the ECMT through the idle AFW booster pumps **
May 2015c) Surry, Open Item 18: The revision to the wording more accurately reflects theplanned activities to determine and validate that adequate communications areavailable to implement FLEX strategies in all phases of the response to anELAP/LUHS event. The revised Open Item 18 is as follows:A comprehensive study of communication capabilities is being performed inaccordance with the statements made in Dominion letter S/N 12-205F datedOctober 29, 2012 in response to Recommendation 9.3 of the 10 CFR 50.54(f)letter dated March 12, 2012. The results of this study will identify thecommunication means available or needed to implement command andcontrol of the FLEX strategies at Surry. Validation of communications required to implement FLEX strategies will be performed as part of Open ItemNo. 1.
Complete the evaluation of TDAFW pump long term operation           Complete.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 9 of 18d) Surry, Open Item 20: The revision to the wording more accurately reflects theequipment that will be purchased and delivered to the site. The updatedcompletion schedule accurately reflects the Milestone schedule.
with < 290 psig inlet steam pressure.                               TDAFW pump operation and adequate AFW flow 13                                                                      to the SGs at SG pressures < 290 psig has been confirmed.
The revisedOpen Item and revised completion schedule are as follows:Open Item 20: The equipment listed in Table 1 will be received on site.Completion Schedule:
(Reference 6)
August 2014e) Surry Milestone  
Details of the ventilation strategy are under development and       Started.
'Issue FSGs': The revision to the wording more accurately reflects the actual scope of the tasks as they occur. The revised Milestone Taskis as follows:Milestone Task: Issue FSGs and Associated Procedure Revisions f) Surry Milestone  
14 will conform to the guidance given in NEI 12-06. The details       Scheduled completion of this strategy will be provided at a later date.                 date: September 2013 Analyses will be performed to develop electrical components         Complete.
'Procure Equipment':
15 performance requirements and confirm electrical loading-           The 120/240VAC DGs related strategy objectives can be met.                             have each been sized at a rating of 25KW. A
The revision to the wording moreaccurately reflects the actual tasks as they occur in sequence.
 
The revisedmilestone task is the successor to 'Purchase Equipment'.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-1 2-049 Attachment Page 7 of 18 Overall Integrated Plan Open Item 01 #                               Description                                     Status single DG will be sufficient to handle the necessary loads for a single unit. A total of three (3) 120/240VAC DGs will be stored in the BDB Storage Building for deployment as needed. The 480VAC DGs have each been sized at a rating of 200KW. The two (2) 480VAC DGs will be stored in the BDB Storage Building for deployment as needed.
The revised Milestone Task is as follows:Milestone Task: Receive Equipment g) Surry Milestone  
(Reference 8)
'Validation Walk-throughs or Demonstration of FLEXStrategies and Procedures':
An evaluation of all BDB equipment fuel consumption and           Not started.
This milestone was added for consistency withtemplate and industry formats.
16     required re-fill strategies will be developed including any       Scheduled completion gasoline required for small miscellaneous equipment.               date: June 2014 A lighting study will be performed to validate the adequacy of     Started.
It corresponds to the activity previously identified in Open Item No. 1. The scheduled milestone date is the same as the open itemcompletion date. By this date, sufficient FLEX equipment will be available toperform the walk-throughs and procedures will be in a near final form and will relyon the walk-throughs for validation prior to final issuance.
17     supplemental lighting and the adequacy and practicality of         Scheduled completion using portable lighting to perform FLEX strategy actions,         date: June 2014 A communications study will be performed in accordance with       Started.
9 References The following references support the updates to the Overall Integrated Plan described inthis enclosure.
the statements made in response to Recommendation 9.3 of           Scheduled completion 18     the 10 CFR 50.54(f) letter dated March 12, 2012 in Dominion       date: Consistent with letter S/N 12-208F dated October 29, 2012. **                     Recommendation 9.3 implementation dates.
: 1. "Dominion'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),"
Preferred travel pathways will be determined using the             Not started.
Serial No.12-163B, dated February 28, 2013.2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements 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.
guidance contained in NEI 12-06. The pathways will attempt         Scheduled completion 19     to avoid areas with trees, power lines, and other potential       date: June 2014 obstructions and will consider the potential for soil liquefaction.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 10 of 184. Dominion letter, "Supplement to Overall Integrated Plan in Response to March 21,2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis Events (Order Number EA-12-049),"
The equipment listed in Table 1 will be procured.   **           Not started.
Serial No. 12-163C, dated April 30, 2013.5. WCAP-17601, "Reactor Coolant System Response to the Extended Loss of ACPower Event for Westinghouse, Combustion Engineering and Babcock & WilcoxNSSS Designs",
Scheduled completion 20                                                                       date is revised from June 2014 to August 2014 **
August 2012.6. Dominion Calculation ME-0969, "Evaluation of the TDAFW Pump Performance atLow Steam Generator Pressures,"
  ** Refer to Section 8 for an explanation of changes to Open Items.
August 2013.7. Engineering Technical Evaluation, ETE-CPR-2012-0011, "Beyond Design Basis -FLEX Strategy Overall Integrated Plan Basis Document,"
 
Revision 1, August 2013.8. Dominion Calculation EE-0864, "Surry Power Station Beyond Design Basis -FLEXElectrical 480VAC and 120VAC System Loading Analysis,"
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 8 of 18 7  Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
Revision 0, April 2013.9. Engineering Technical Evaluation, ETE-NAF-2012-0150, "Evaluation of CoreCooling Coping for Extended Loss of AC Power (ELAP) and Proposed Input forDominion's Response to NRC Order EA-12-049 for Dominion Fleet," Revision 0,January 2013.
8   Supplemental Information This supplemental information provides details of changes identified in the status updates above and addresses the following topics: a) Open Item No. 4, b) Open Item No. 12, c) Open Item No. 18, d) Open Item No. 20, e) Milestone 'Issue FSGs',
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 11 of 18Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/
f) Milestone 'Procure Equipment', and g) the addition of Milestone "Validation Walk-throughs or Demonstration of FLEX Strategies and Procedures."
flexibility)
a) Surry, Open Item 4: The Open Item completion date is revised to October 2013 to be consistent with the revised completion date for the Milestone "Develop Strategies."
Diverse Uses Performance Maintenance CriteriaMaintenance
b) Surry, Open Item 12: The updated completion date allows for the required modifications to be implemented and accurately reflects the updated milestone schedule activity for 'Implement Modifications'. The revision to the wording for part (3) of this Open Item more accurately reflects the planned activities to determine and validate that adequate TDAFW pump NPSH from the ECMT through the idle AFW booster pumps is available to qualify the ECMT as a source of water to the TDAFW pump in response to an ELAP/LUHS event. The revised Open Item 12, part (3) and revised completion schedule are as follows:
/Containment Preventive List Portable Equipment Core SFP Instrumentation Accessibility
Open Item 12, part (3): Confirm adequate TDAFW pump NPSH from the ECMT through the idle AFW booster pump using conservative analysis.
[Open Item 4] Maintenance requirements BDB High Capacity Will follow EPRIdiesel-driven pump (2) X X 1200 gpm4  templateand assoc. hoses andfittings requirements Will follow EPRIBDB AFW pump (3) and X 300 gpm4 templateassoc. hoses and fillings grequirements BDB RCS Injection pump Will follow EPRI(2) and assoc. hoses and X 40 gpm templatefittings requirements 120/240V AC generators (3)3 and associated Will follow EPRIcables, connectors and X 20 kW templateswitchgear requirements 120/240V AC generators (8)2 and associated Will follow EPRIcables, connectors and X 5-6.5 kW templateswitchgear (to power requirements support equipment)
Completion Schedule: May 2015 c) Surry, Open Item 18: The revision to the wording more accurately reflects the planned activities to determine and validate that adequate communications are available to implement FLEX strategies in all phases of the response to an ELAP/LUHS event. The revised Open Item 18 is as follows:
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 12 of 18Table I -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/
A comprehensive study of communication capabilities is being performed in accordance with the statements made in Dominion letter S/N 12-205F dated October 29, 2012 in response to Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012. The results of this study will identify the communication means available or needed to implement command and control of the FLEX strategies at Surry. Validation of communications required to implement FLEX strategies will be performed as part of Open Item No. 1.
flexibility)
 
Diverse Uses Performance Maintenance CriteriaMaintenance
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 9 of 18 d) Surry, Open Item 20: The revision to the wording more accurately reflects the equipment that will be purchased and delivered to the site. The updated completion schedule accurately reflects the Milestone schedule. The revised Open Item and revised completion schedule are as follows:
/Containment Preventive List Portable Equipment Core [ontem SFP Instrumentation Accessibility Mainte[Open Item 4] Maintenance requirements 480V AC generators (2)3and associated cables,connectors and Will follow EPRIswitchgear (to re-power X 200 kW templatebattery chargers, requirements inverters, and VitalBuses)Portable boric acid Will follow EPRIbatching tank (2) X templaterequirements Will follow EPRILight plants (4) 2 X templaterequirements Will follow EPRIFront end loader (1)2 X templaterequirements Will follow EPRITow vehicles (2) 2 X templaterequirements Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 13 of 18Table I -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/flexibility)
Open Item 20: The equipment listed in Table 1 will be received on site.
Diverse Uses Performance Maintenance CriteraMaintenance
Completion Schedule: August 2014 e) Surry Milestone 'Issue FSGs': The revision to the wording more accurately reflects the actual scope of the tasks as they occur. The revised Milestone Task is as follows:
/Containment Preventive List Portable Equipment Core SFP Instrumentation Accessibility
Milestone Task: Issue FSGs and Associated Procedure Revisions f) Surry Milestone 'Procure Equipment': The revision to the wording more accurately reflects the actual tasks as they occur in sequence. The revised milestone task is the successor to 'Purchase Equipment'. The revised Milestone Task is as follows:
[Open Item 4] Maintenance requirements Hose trailer or utility Will follow EPRIvehicle (2) 2 X templaterequirements Will follow EPRIFans / blowers (10)2 X templaterequirements Will follow EPRIAir compressors (6) 2 X templaterequirements Fuel carts with transfer Will follow EPRIpumps (2) 2 X templaterequirements Communications Will follow EPRIequipment 5 X templaterequirements Misc. debris removal Will follow EPRIequipment (2 sets) 2 X templaterequirements Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 14 of 18Table I -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/
Milestone Task: Receive Equipment g) Surry Milestone 'Validation Walk-throughs or Demonstration of FLEX Strategies and Procedures': This milestone was added for consistency with template and industry formats. It corresponds to the activity previously identified in Open Item No. 1. The scheduled milestone date is the same as the open item completion date. By this date, sufficient FLEX equipment will be available to perform the walk-throughs and procedures will be in a near final form and will rely on the walk-throughs for validation prior to final issuance.
flexibility)
9   References The following references support the updates to the Overall Integrated Plan described in this enclosure.
Diverse Uses Performance Maintenance CriteriaMaintenance
: 1. "Dominion'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)," Serial No.
/Containment Preventive List Portable Equipment Core [ontem SFP Instrumentation Accessibility Mainte[Open Item 4] Maintenance requirements Misc. Support Equipment Will follow EPRI(2 sets) 2 X templaterequirements Cables for 4160 VACgenerator connections (4 X Xsets)NOTES:1. This table is based on one BDB Storage Building.
12-163B, dated February 28, 2013.
: 2. Support equipment.
: 2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"
Not required to meet N+1.3. 480V AC generators are an alternate strategy to the 120/240V AC generators.
dated March 12, 2012.
Therefore, only N is required.
: 3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.
: 4. Preliminary performance criteria.
 
Final performance criteria will be determined by the hydraulic analyses performed in accordance with the design process [Open Item 5].5. Equipment purchased in response to the results of the study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letterdated March 12, 2012.
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 10 of 18
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 15 of 18Table 2 -PWR Portable Equipment Phase 3Use and (potential/
: 4. Dominion letter, "Supplement to Overall Integrated Plan in Response to March 21, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events (Order Number EA-12-049),"
flexibility)
Serial No. 12-163C, dated April 30, 2013.
Diverse Uses Performance Criteria NotesList portable Core Containment SFP Instrumentation Accessibility equipment  
: 5. WCAP-17601, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs", August 2012.
[Open Item 2]4kV generators' (2)and associated cables, connectors and switchgear NOTE:1. Preliminary performance criteria.
: 6. Dominion Calculation ME-0969, "Evaluation of the TDAFW Pump Performance at Low Steam Generator Pressures," August 2013.
Final performance criteria will be determined by the electrical loading analyses performed in accordance with the design process.
: 7. Engineering Technical Evaluation, ETE-CPR-2012-0011, "Beyond Design Basis -
RRC equipment will meet the required performance criteria.
FLEX Strategy Overall Integrated Plan Basis Document," Revision 1, August 2013.
Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 16 of 18L. FROMI-CN-TK-2
: 8. Dominion Calculation EE-0864, "Surry Power Station Beyond Design Basis - FLEX Electrical 480VAC and 120VAC System Loading Analysis," Revision 0, April 2013.
-62 pnFW63If623 L.. I-FW-32SSTEAM GENERATOR I-RC-E-tA STEAM GENERATOR I-RC-E-IB STEAM GENERATOR I-RC-E-IC CS PUMP ROOM JLEGENDsC D ] BO MODIFICATION PRIMARY BOB AFW CONNECTIONS FROM UNIT 2AFW PUMPSTO UNIT 2 STEAMGENERATORS TO STEAM GENERATOR I-RC-E-IA TO STEAM GENERATOR I-RC-E-IC TO STEAM GENERATOR I-RC-E-1I FROM UNIT IAFW PUMPSALTERNATE BOB AFW CONNECTION FIGURE 3 (AUGUST 2013 UPDATE)CORE COOLING AND DECAY HEAT REMOVALPRIMARY AND ALTERNATE MECHANICAL CONNECTIONS SURRY POWER STATION Serial No. 12-163DDocket Nos. 50-281/281 Six Month Status Report Order EA-12-049 Page 17 of 18-- -- --- --- --- ----- --- -I ~ ------------
: 9. Engineering Technical Evaluation, ETE-NAF-2012-0150, "Evaluation of Core Cooling Coping for Extended Loss of AC Power (ELAP) and Proposed Input for Dominion's Response to NRC Order EA-12-049 for Dominion Fleet," Revision 0, January 2013.
41101 )IJ Io~)oooo)oo)  
 
)~~ ~ZL---.0.... .0 ....0~ .... ._._._....
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 11 of 18 Table 1 - PWR Portable Equipment Phase 21 [Open Item 20]
A l0 ------.-.~~~L{J&#xfd; P-1 'I I- 4 ~ -~ ,60 F ---------I----- -------------6 Z-- ---- --------- ---------- --- ---KEYsFIGURE 7 (AUGUST 2013 UPDATE)BDB FLEX STRATEGY ELECTRICAL CONNECTIONS ONE LINE DIAGRAMSURRY POWER STATION Serial No. 12-163DDocket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 18 of 18LIGHTING PAELNORMAL FEEDNOTE: UNIT 2 SIMILARKEY,MCR -MAIN CONTROL ROOMESGR -EMERGENTY SWGR ROOMCD- BO MODIFICATION FIGURE 9 (AUGUST 2013 UPDATE)120/240 VAC GENERATOR ELECTRICAL CONNECTIONS SURRY POWER STATION}}
Use and (potential/ flexibility) Diverse Uses                           Performance         Maintenance Criteria Maintenance /
Containment                                                                       Preventive List Portable Equipment Core                           SFP       Instrumentation Accessibility
[Open Item 4]                                                                       Maintenance requirements BDB High Capacity                                                                                                     Will follow EPRI diesel-driven pump (2)     X                               X                                       1200 gpm 4        template and assoc. hoses and fittings                                                                                                              requirements Will follow EPRI BDB AFW pump (3) and       X                                                                       300 gpm4         template assoc. hoses and fillings                                                                                 grequirements BDB RCS Injection pump                                                                                               Will follow EPRI (2) and assoc. hoses and   X                                                                         40 gpm         template fittings                                                                                                              requirements 120/240V AC generators (3)3 and associated                                                                                                   Will follow EPRI cables, connectors and                                                   X                             20 kW         template switchgear                                                                                                            requirements 120/240V AC generators (8)2 and associated                                                                                                   Will follow EPRI cables, connectors and                                                                 X             5-6.5 kW       template switchgear (to power                                                                                                 requirements support equipment)
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 12 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]
Use and (potential/ flexibility) Diverse Uses                           Performance       Maintenance Criteria Maintenance /
Containment                                                                     Preventive List PortableEquipment Core   [ontem                 SFP     Instrumentation Accessibility                     Mainte
[Open Item 4]                                                                   Maintenance requirements 480V AC generators (2)3 and associated cables, connectors and                                                                                                   Will follow EPRI switchgear (to re-power                                               X                           200 kW       template battery chargers,                                                                                               requirements inverters, and Vital Buses)
Portable boric acid                                                                                             Will follow EPRI batching tank (2)         X                                                                                     template requirements Will follow EPRI Light plants (4) 2                                                                   X                           template requirements Will follow EPRI Front end loader (1)2                                                               X                           template requirements Will follow EPRI Tow vehicles (2) 2                                                                   X                           template requirements
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 13 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]
Use and (potential/flexibility)Diverse Uses                           Performance       Maintenance Critera Maintenance /
Containment                                                                   Preventive List Portable Equipment Core                         SFP     Instrumentation Accessibility
[Open Item 4]                                                                 Maintenance requirements Hose trailer or utility                                                                                       Will follow EPRI vehicle (2) 2                                                                       X                         template requirements Will follow EPRI Fans / blowers (10)2                                                               X                         template requirements Will follow EPRI Air compressors (6) 2                                                               X                         template requirements Fuel carts with transfer                                                                                       Will follow EPRI pumps (2) 2                                                                         X                         template requirements Communications                                                                                                 Will follow EPRI equipment 5                                                                         X                         template requirements Misc. debris removal                                                                                           Will follow EPRI equipment (2 sets) 2                                                               X                         template requirements
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 14 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]
Use and (potential/ flexibility) Diverse Uses                               Performance       Maintenance Criteria Maintenance /
Containment                                                                         Preventive List Portable Equipment     Core   [ontem               SFP     Instrumentation   Accessibility                       Mainte
[Open Item 4]                                                                       Maintenance requirements Misc. Support Equipment                                                                                                   Will follow EPRI (2 sets) 2                                                                                   X                           template requirements Cables for 4160 VAC generator connections (4                                                   X               X sets)
NOTES:
: 1. This table is based on one BDB Storage Building.
: 2. Support equipment. Not required to meet N+1.
: 3. 480V AC generators are an alternate strategy to the 120/240V AC generators. Therefore, only N is required.
: 4. Preliminary performance criteria. Final performance criteria will be determined by the hydraulic analyses performed in accordance with the design process [Open Item 5].
: 5. Equipment purchased in response to the results of the study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 15 of 18 Table 2 - PWR Portable Equipment Phase 3 Use and (potential/ flexibility) Diverse Uses                           PerformanceCriteria        Notes List portable       Core     Containment       SFP     Instrumentation   Accessibility equipment                   [Open Item 2]
4kV generators' (2) and associated cables, connectors and switchgear NOTE:
: 1. Preliminary performance criteria. Final performance criteria will be determined by the electrical loading analyses performed in accordance with the design process. RRC equipment will meet the required performance criteria.
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 16 of 18 L.             FROM I-CN-TK-2
                                        -62   pnFW63I f623      L.. I-FW-32S STEAM GENERATOR I-RC-E-tA STEAM GENERATOR I-RC-E-IB STEAM GENERATOR I-RC-E-IC CS PUMP ROOM       J LEGENDs PRIMARY BOB AFW CONNECTIONS                 C    D        BO]    MODIFICATION FROM UNIT 2 AFW PUMPS                                                      TO UNIT 2 STEAM GENERATORS TO STEAM GENERATOR I-RC-E-IA TO STEAM GENERATOR I-RC-E-IC TO STEAM GENERATOR I-RC-E-1I FROM UNIT I AFW PUMPS ALTERNATE BOB AFW   CONNECTION FIGURE 3 (AUGUST 2013 UPDATE)
CORE COOLING AND DECAY HEAT REMOVAL PRIMARY AND ALTERNATE MECHANICAL CONNECTIONS SURRY POWER STATION
 
Serial No. 12-163D Docket Nos. 50-281/281 Six Month Status Report Order EA-12-049 Page 17 of 18
      -------- --- -------                                                             - -- ~  - -I -----------
41101       Io~)oooo)oo)       )IJ                                                                              )~
                                                                              ~   ~ZL 0....           .. . 0       . ......
                                                ._._._....           0~
A l0                                 ------.-
                                                        .~~~L{J&#xfd;         4    ~                -        ~          , P-1 'II-60     I    F                           -- --- - ---
        - - - - - - - - - - - - - -6         Z-- - ---   - - - - - - - ---       - - - - - ----               - -- - --
KEYs FIGURE 7 (AUGUST 2013 UPDATE)
BDB FLEX STRATEGY ELECTRICAL CONNECTIONS ONE LINE DIAGRAM SURRY POWER STATION
 
Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 18 of 18 LIGHTING NORMAL  PAEL FEED NOTE: UNIT 2 SIMILAR KEY, MCR - MAIN CONTROL ROOM ESGR - EMERGENTYSWGR ROOM CD-     BO MODIFICATION FIGURE 9 (AUGUST 2013 UPDATE) 120/240 VAC GENERATOR ELECTRICAL CONNECTIONS SURRY POWER STATION}}

Latest revision as of 02:02, 6 February 2020

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 No. EA-12-049)
ML13242A013
Person / Time
Site: Surry  Dominion icon.png
Issue date: 08/23/2013
From: Grecheck E
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, 12-163D
Download: ML13242A013 (22)


Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 23, 2013 10 CFR 2.202 EA-1 2-049 Attention: Document Control Desk Serial No.: 12-163D U.S. Nuclear Regulatory Commission NL&OS/MAE: R2 Washington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 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)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
4. Virginia Electric and Power Company's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 201.2 (Serial No. 12-163A)
5. Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-163B)
6. Virginia Electric and Power Company's Supplement to Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated April 30, 2013 (Serial No. 12-163C)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 was immediately effective and directs Dominion to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, 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.

13/4gA

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Page 2 of 3 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 endorsed industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions. Reference 4 provided Dominion's initial status report regarding mitigation strategies, and Reference 5 provided Dominion's overall integrated plan. Reference 6 provided a supplement to Dominion's 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 six-month status report (pursuant to Section IV, Condition C,2, of Reference 1) delineates the progress made in implementing the requirements of Reference 1 and is provided as an attachment to this letter. The attached report also provides an update of milestone accomplishments since the supplement to the overall integrated plan (Reference 6), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Eugene S. Grecheck Vice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President Nuclear Engineering and Development of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

rA Acknowledged before me this 23 day of A,,wak 2013.

CRAIG DSLY CNotary Public

-ýj I Commonwealth of Virginia My Commission Expires:"pc&. 3trL2A ZAN, Reg. # 7518653 , I

-Expires December 31, 20 NeaýPblic

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Ms. K. R. Cotton Gross NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 D2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Attachment Six Month Status Report for the Implementation of Order EA-1 2-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Surry Power Station Units I and 2 Virginia Electric and Power Company (Dominion)

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report - Order EA-12-049 Attachment Page 1 of 18 Six Month Status Report for the Implementation of Order EA-1 2-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverse and flexible strategies (FLEX) for Surry Power Station in response to NRC Order Number EA-12-049 (Reference 2). This attachment provides an update of milestone accomplishments and open items since submittal of the OIP including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone has been completed since the development of the OIP and is current as of July 31, 2013.

0 Submit OIP 3 Milestone Schedule Status The following table provides an update to Attachment 2A of the OIP. 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 for 'Develop Strategies', 'Implement Modifications', and 'Unit 1 Outage Implementation' do not impact the Order implementation date.

Target Activity Revised Target Milestone Completion Status Completion Date Date Submit Integrated Plan Feb 2013 Complete Develop Strategies July 2013 Started October 2013 Develop Modifications Apr 2014 Started Implement Modifications Sept 2014 Started May 2015 Develop Training Plan Apr 2014 Started Implement Training Aug 2014 Not Started

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 2 of 18 Target Revised Target Milestone Completion Activity Completion Date Date Issue FSGs* Sept 2014 Not Started Develop Strategies/ Contract with Regional Response Center Apr 2014 Started (RRC)

Purchase Equipment Feb 2014 Started Procure Equipment* Aug 2014 Not Started Validation Walk-throughs or Demonstrations of FLEX Dec 2014 Not Started Strategies and Procedures*

Create Maintenance Procedures Aug 2014 Not Started Unit 1 Outage Implementation Apr 2015 Not Started May 2015 Unit 2 Outage Implementation Oct 2015 Not Started

  • Refer to Section 8 for an explanation of Milestone changes.

4 Changes to Compliance Method By letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at Surry Power Station (Surry) Units 1 and 2 (Reference 1) as required by Order Number EA-12-049, dated March 12, 2012 (Reference 2). The following are changes to the compliance method information provided in the Surry OIP; however, the changes continue to meet NEI 12-06 (Reference 3):

a) Details of the alternate connection strategy for Auxiliary Feedwater (AFW) injection, as described in Section B.2 - PWR Portable Equipment Phase 2 and shown on OIP Figure 3, have changed for Surry Units 1 and 2. The tie-in locations at valve 1-FW-57 (Unit 1) and 2-FW-57 (Unit 2) will no longer be used as the alternate AFW injection connections. The re-located connections described below are more readily accessible and serve the same function in the alternate strategy.

For Unit 1, the bonnet assembly of the AFW cross-connect isolation motor-operated valve (MOV) 1-FW-MOV-160B, located in the Unit 2 AFW Pump House, will be removed and a flanged temporary hose connection adapter will be installed on the valve to support connecting the BDB AFW pump to the Unit 1 AFW cross-connect line. The location of 1-FW-MOV-160B allows for easy hose routing and is within a safety related structure.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 3 of 18 For Unit 2, the bonnet assembly of the AFW cross-connect isolation MOV 2-FW-MOV-260B, located in the Unit 1 AFW Pump House, will be removed and a flanged temporary hose connection adapter will be installed on the valve to support connecting the BDB AFW pump to the Unit 2 AFW cross-connect line.

The location of 2-FW-MOV-260B allows for easy hose routing and is within a safety related structure.

A revised OIP Figure 3 is attached. This figure represents the Unit 1 configuration only but is typical for both units.

b) Details of the strategy for the portable diesel generators (DGs) used to re-power the 120VAC vital bus circuits, as described in Section F1.2 - PWR Portable Equipment Phase 2, have changed for Surry Units 1 and 2. A single 120/240VAC DG per unit will be sized to accommodate the necessary electrical loads for that unit and will power both BDB distribution panels for that unit. Thus, the deployment of two 120/240 VAC DGs per unit as shown in Figure 7 of the previously submitted OIP is no longer being pursued, and a revised Figure 7 is attached. Figure 8 is not revised since the single 120/240VAC DG location is the same as the two DGs for each unit as stated in the OIP. Figure 9 was a typical schematic of the connections from one of two 120/240VAC DGs. A revised Figure 9 showing the current connections for the 120/240VAC DG (Unit 1 only) is attached. A spare 120/240VAC DG will be purchased; however, as stated in the OIP, the 480VAC DG is considered the alternate re-powering source for instrumentation.

c) Details of the modification to the steam generator (SG) power-operated relief valves (PORVs), as described in Section B.1 - PWR Installed Equipment Phase 1, have changed for Surry Units 1 and 2. Although the overall strategy has not been altered, the details of the modification have been revised to provide a more suitable option that will continue to allow for local manual operation of the SG PORVs. Instead of a modification to add hand wheels to the valves, the SG PORVs will be modified to add a protected backup air bottle system which will be installed in the Main Steam Valve House (MSVH) AFW pump room. Local manual operation of the SG PORVs using the protected backup air bottle system will continue to allow control of RCS cooldown to support the reactor core cooling and decay heat removal Phase 1 strategy.

d) Changes to the timing of the RCS Injection strategy have been made. The strategy for RCS injection for inventory and reactivity control has been moved from a Phase 3 activity to a Phase 2 activity. The details and descriptions provided in Section C.3 of the OIP for RCS injection for the Phase 3 activity continue to be the same for the Phase 2 strategy for RCS injection, including the time at which natural circulation capability is lost, i.e., approximately 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 4 of 18 based on WCAP-17601 (Reference 5) and ETE-NAF-2012-0150 (Reference 9).

For conservatism and margin to account for uncertainty within the calculations and unanticipated deployment issues, a time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> has been chosen, which provides significant margin (by a factor of 2) prior to loss of natural circulation and the start of reflux boiling.

e) The quantities of BDB equipment stated in OIP Table 1, PWR Portable Equipment Phase 2, and OIP Table 2, PWR Portable Equipment Phase 3, have changed. Per Footnote 1 to Table 1, the quantities were based on the assumption that two storage buildings would be available to store BDB equipment pending completion of the study to determine the details of the BDB Storage Building(s). Open Item No. 6 has been completed, and the decision to have one storage building is documented in Section 6 of this update. A revised Table 1 is attached.

As discussed in the previous item d), Surry will purchase and store BDB RCS Injection pumps for use in the Phase 2 RCS Inventory strategy. These pumps are being added to the revised Table 1 for Phase 2 equipment.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date and no required relief/relaxation has been identified at this time.

6 Open Items from Overall Integrated Plan The following table provides a summary of the open items documented in B of the OIP and the status of each item.

Overall Integrated Plan Open Item 01 # Description Status Verify response times listed in timeline and perform staffing Not started.

1 assessment. Scheduled completion date: December 2014 Preliminary analyses have been performed to determine the Complete.

2 Class 1 E battery life based on implementation of load (Reference 4) stripping actions. The final battery life duration will be provided when the analyses are completed.

Preliminary analyses have been performed to determine the Complete.

time to steam generator overfill without operator action to (Reference 4) reduce AFW flow, time to steam generator dryout without AFW flow, and time to depletion of the useable volume of the ECST and ECMT. The final durations will be provided when the analyses are completed.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 5 of 18 Overall Integrated Plan Open Item 01 # Description Status The Phase 3 coping strategy to maintain containment integrity Started.

is under development. Methods to monitor and evaluate Scheduled completion 4 containment conditions and depressurize/cool containment, if date is revised from necessary, will be provided in a future update. December 2013 to October 2013 **

Analyses will be performed to develop fluid components Started.

5 performance requirements and confirm fluid hydraulic-related Scheduled completion strategy objectives can be met. date: September 2013 A study is in progress to determine the design features, site Complete.

location(s), and number of equipment storage facilities. The A single 10,000 sq. ft.

final design for BDB equipment storage will be based on the Type 1 building will be guidance contained in NEI 12-06, Section 11.3, Equipment constructed at Surry for Storage. A supplement to this submittal will be provided with storage of BDB the results of the equipment storage study. equipment. The building will be designed to meet the plant's design basis for the Safe Shutdown Earthquake, high wind hazards, snow, ice and cold conditions, and will be located above the flood elevation from the 6 most recent site flooding analysis. The BDB Storage Building will be sited just east of the south employee parking lot, inside the Owner Controlled Area. The location lies in an area between the Surry Nuclear Information Center and the intake canal. This update provides the supplemental information referred to in this open item.

FLEX Support Guidelines (FSGs) will be developed in Started.

7 accordance with PWROG guidance. Existing procedures will Scheduled completion be revised as necessary to implement FSGs. date: September 2014

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 6 of 18 Overall Integrated Plan Open Item 01 # Description Status EPRI guidance documents will be used to develop periodic Not started.

testing and preventative maintenance procedures for BDB Scheduled completion 8 equipment. Procedures will be developed to manage date: December 2014 unavailability of equipment such that risk to mitigating strategy capability is minimized.

An overall program document will be developed to maintain Started.

the FLEX strategies and their bases and to provide Scheduled completion configuration control and change management for the FLEX date: December 2014 Program.

The Dominion Nuclear Training Program will be revised to Started.

assure personnel proficiency in the mitigation of BDB events Scheduled completion 10 is developed and maintained. These programs and controls date: December 2014 will be developed and implemented in accordance with the Systematic Approach to Training (SAT).

Plant modifications will be completed for permanent plant Started.

changes required for implementation of FLEX strategies. Scheduled completion date: See Milestone Schedule.

The following actions will be completed to qualify the ECMT Started.

as a source of water to the TDAFW pump in response to an Scheduled completion ELAP/LUHS event: (1) Upgrade the piping system from the date is revised from 12 ECMT to the TDAFW pump suction to Seismic Category I, (2) December 2013 to May Modify the TDAFW pump discharge piping to install local AFW 2015 **

flowrate indication, and (3) Confirm adequate TDAFW pump NPSH with flow from the ECMT through the idle AFW booster pumps **

Complete the evaluation of TDAFW pump long term operation Complete.

with < 290 psig inlet steam pressure. TDAFW pump operation and adequate AFW flow 13 to the SGs at SG pressures < 290 psig has been confirmed.

(Reference 6)

Details of the ventilation strategy are under development and Started.

14 will conform to the guidance given in NEI 12-06. The details Scheduled completion of this strategy will be provided at a later date. date: September 2013 Analyses will be performed to develop electrical components Complete.

15 performance requirements and confirm electrical loading- The 120/240VAC DGs related strategy objectives can be met. have each been sized at a rating of 25KW. A

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-1 2-049 Attachment Page 7 of 18 Overall Integrated Plan Open Item 01 # Description Status single DG will be sufficient to handle the necessary loads for a single unit. A total of three (3) 120/240VAC DGs will be stored in the BDB Storage Building for deployment as needed. The 480VAC DGs have each been sized at a rating of 200KW. The two (2) 480VAC DGs will be stored in the BDB Storage Building for deployment as needed.

(Reference 8)

An evaluation of all BDB equipment fuel consumption and Not started.

16 required re-fill strategies will be developed including any Scheduled completion gasoline required for small miscellaneous equipment. date: June 2014 A lighting study will be performed to validate the adequacy of Started.

17 supplemental lighting and the adequacy and practicality of Scheduled completion using portable lighting to perform FLEX strategy actions, date: June 2014 A communications study will be performed in accordance with Started.

the statements made in response to Recommendation 9.3 of Scheduled completion 18 the 10 CFR 50.54(f) letter dated March 12, 2012 in Dominion date: Consistent with letter S/N 12-208F dated October 29, 2012. ** Recommendation 9.3 implementation dates.

Preferred travel pathways will be determined using the Not started.

guidance contained in NEI 12-06. The pathways will attempt Scheduled completion 19 to avoid areas with trees, power lines, and other potential date: June 2014 obstructions and will consider the potential for soil liquefaction.

The equipment listed in Table 1 will be procured. ** Not started.

Scheduled completion 20 date is revised from June 2014 to August 2014 **

    • Refer to Section 8 for an explanation of changes to Open Items.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 8 of 18 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 Supplemental Information This supplemental information provides details of changes identified in the status updates above and addresses the following topics: a) Open Item No. 4, b) Open Item No. 12, c) Open Item No. 18, d) Open Item No. 20, e) Milestone 'Issue FSGs',

f) Milestone 'Procure Equipment', and g) the addition of Milestone "Validation Walk-throughs or Demonstration of FLEX Strategies and Procedures."

a) Surry, Open Item 4: The Open Item completion date is revised to October 2013 to be consistent with the revised completion date for the Milestone "Develop Strategies."

b) Surry, Open Item 12: The updated completion date allows for the required modifications to be implemented and accurately reflects the updated milestone schedule activity for 'Implement Modifications'. The revision to the wording for part (3) of this Open Item more accurately reflects the planned activities to determine and validate that adequate TDAFW pump NPSH from the ECMT through the idle AFW booster pumps is available to qualify the ECMT as a source of water to the TDAFW pump in response to an ELAP/LUHS event. The revised Open Item 12, part (3) and revised completion schedule are as follows:

Open Item 12, part (3): Confirm adequate TDAFW pump NPSH from the ECMT through the idle AFW booster pump using conservative analysis.

Completion Schedule: May 2015 c) Surry, Open Item 18: The revision to the wording more accurately reflects the planned activities to determine and validate that adequate communications are available to implement FLEX strategies in all phases of the response to an ELAP/LUHS event. The revised Open Item 18 is as follows:

A comprehensive study of communication capabilities is being performed in accordance with the statements made in Dominion letter S/N 12-205F dated October 29, 2012 in response to Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012. The results of this study will identify the communication means available or needed to implement command and control of the FLEX strategies at Surry. Validation of communications required to implement FLEX strategies will be performed as part of Open Item No. 1.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 9 of 18 d) Surry, Open Item 20: The revision to the wording more accurately reflects the equipment that will be purchased and delivered to the site. The updated completion schedule accurately reflects the Milestone schedule. The revised Open Item and revised completion schedule are as follows:

Open Item 20: The equipment listed in Table 1 will be received on site.

Completion Schedule: August 2014 e) Surry Milestone 'Issue FSGs': The revision to the wording more accurately reflects the actual scope of the tasks as they occur. The revised Milestone Task is as follows:

Milestone Task: Issue FSGs and Associated Procedure Revisions f) Surry Milestone 'Procure Equipment': The revision to the wording more accurately reflects the actual tasks as they occur in sequence. The revised milestone task is the successor to 'Purchase Equipment'. The revised Milestone Task is as follows:

Milestone Task: Receive Equipment g) Surry Milestone 'Validation Walk-throughs or Demonstration of FLEX Strategies and Procedures': This milestone was added for consistency with template and industry formats. It corresponds to the activity previously identified in Open Item No. 1. The scheduled milestone date is the same as the open item completion date. By this date, sufficient FLEX equipment will be available to perform the walk-throughs and procedures will be in a near final form and will rely on the walk-throughs for validation prior to final issuance.

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

1. "Dominion'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)," Serial No.

12-163B, dated February 28, 2013.

2. NRC Order Number 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.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 10 of 18

4. Dominion letter, "Supplement to Overall Integrated Plan in Response to March 21, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events (Order Number EA-12-049),"

Serial No. 12-163C, dated April 30, 2013.

5. WCAP-17601, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs", August 2012.
6. Dominion Calculation ME-0969, "Evaluation of the TDAFW Pump Performance at Low Steam Generator Pressures," August 2013.
7. Engineering Technical Evaluation, ETE-CPR-2012-0011, "Beyond Design Basis -

FLEX Strategy Overall Integrated Plan Basis Document," Revision 1, August 2013.

8. Dominion Calculation EE-0864, "Surry Power Station Beyond Design Basis - FLEX Electrical 480VAC and 120VAC System Loading Analysis," Revision 0, April 2013.
9. Engineering Technical Evaluation, ETE-NAF-2012-0150, "Evaluation of Core Cooling Coping for Extended Loss of AC Power (ELAP) and Proposed Input for Dominion's Response to NRC Order EA-12-049 for Dominion Fleet," Revision 0, January 2013.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 11 of 18 Table 1 - PWR Portable Equipment Phase 21 [Open Item 20]

Use and (potential/ flexibility) Diverse Uses Performance Maintenance Criteria Maintenance /

Containment Preventive List Portable Equipment Core SFP Instrumentation Accessibility

[Open Item 4] Maintenance requirements BDB High Capacity Will follow EPRI diesel-driven pump (2) X X 1200 gpm 4 template and assoc. hoses and fittings requirements Will follow EPRI BDB AFW pump (3) and X 300 gpm4 template assoc. hoses and fillings grequirements BDB RCS Injection pump Will follow EPRI (2) and assoc. hoses and X 40 gpm template fittings requirements 120/240V AC generators (3)3 and associated Will follow EPRI cables, connectors and X 20 kW template switchgear requirements 120/240V AC generators (8)2 and associated Will follow EPRI cables, connectors and X 5-6.5 kW template switchgear (to power requirements support equipment)

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 12 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]

Use and (potential/ flexibility) Diverse Uses Performance Maintenance Criteria Maintenance /

Containment Preventive List PortableEquipment Core [ontem SFP Instrumentation Accessibility Mainte

[Open Item 4] Maintenance requirements 480V AC generators (2)3 and associated cables, connectors and Will follow EPRI switchgear (to re-power X 200 kW template battery chargers, requirements inverters, and Vital Buses)

Portable boric acid Will follow EPRI batching tank (2) X template requirements Will follow EPRI Light plants (4) 2 X template requirements Will follow EPRI Front end loader (1)2 X template requirements Will follow EPRI Tow vehicles (2) 2 X template requirements

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 13 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]

Use and (potential/flexibility)Diverse Uses Performance Maintenance Critera Maintenance /

Containment Preventive List Portable Equipment Core SFP Instrumentation Accessibility

[Open Item 4] Maintenance requirements Hose trailer or utility Will follow EPRI vehicle (2) 2 X template requirements Will follow EPRI Fans / blowers (10)2 X template requirements Will follow EPRI Air compressors (6) 2 X template requirements Fuel carts with transfer Will follow EPRI pumps (2) 2 X template requirements Communications Will follow EPRI equipment 5 X template requirements Misc. debris removal Will follow EPRI equipment (2 sets) 2 X template requirements

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 14 of 18 Table I - PWR Portable Equipment Phase 21 [Open Item 20]

Use and (potential/ flexibility) Diverse Uses Performance Maintenance Criteria Maintenance /

Containment Preventive List Portable Equipment Core [ontem SFP Instrumentation Accessibility Mainte

[Open Item 4] Maintenance requirements Misc. Support Equipment Will follow EPRI (2 sets) 2 X template requirements Cables for 4160 VAC generator connections (4 X X sets)

NOTES:

1. This table is based on one BDB Storage Building.
2. Support equipment. Not required to meet N+1.
3. 480V AC generators are an alternate strategy to the 120/240V AC generators. Therefore, only N is required.
4. Preliminary performance criteria. Final performance criteria will be determined by the hydraulic analyses performed in accordance with the design process [Open Item 5].
5. Equipment purchased in response to the results of the study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 15 of 18 Table 2 - PWR Portable Equipment Phase 3 Use and (potential/ flexibility) Diverse Uses PerformanceCriteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment [Open Item 2]

4kV generators' (2) and associated cables, connectors and switchgear NOTE:

1. Preliminary performance criteria. Final performance criteria will be determined by the electrical loading analyses performed in accordance with the design process. RRC equipment will meet the required performance criteria.

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 16 of 18 L. FROM I-CN-TK-2

-62 pnFW63I f623 L.. I-FW-32S STEAM GENERATOR I-RC-E-tA STEAM GENERATOR I-RC-E-IB STEAM GENERATOR I-RC-E-IC CS PUMP ROOM J LEGENDs PRIMARY BOB AFW CONNECTIONS C D BO] MODIFICATION FROM UNIT 2 AFW PUMPS TO UNIT 2 STEAM GENERATORS TO STEAM GENERATOR I-RC-E-IA TO STEAM GENERATOR I-RC-E-IC TO STEAM GENERATOR I-RC-E-1I FROM UNIT I AFW PUMPS ALTERNATE BOB AFW CONNECTION FIGURE 3 (AUGUST 2013 UPDATE)

CORE COOLING AND DECAY HEAT REMOVAL PRIMARY AND ALTERNATE MECHANICAL CONNECTIONS SURRY POWER STATION

Serial No. 12-163D Docket Nos. 50-281/281 Six Month Status Report Order EA-12-049 Page 17 of 18


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KEYs FIGURE 7 (AUGUST 2013 UPDATE)

BDB FLEX STRATEGY ELECTRICAL CONNECTIONS ONE LINE DIAGRAM SURRY POWER STATION

Serial No. 12-163D Docket Nos. 50-280/281 Six Month Status Report Order EA-12-049 Attachment Page 18 of 18 LIGHTING NORMAL PAEL FEED NOTE: UNIT 2 SIMILAR KEY, MCR - MAIN CONTROL ROOM ESGR - EMERGENTYSWGR ROOM CD- BO MODIFICATION FIGURE 9 (AUGUST 2013 UPDATE) 120/240 VAC GENERATOR ELECTRICAL CONNECTIONS SURRY POWER STATION