ML14251A024: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 13: Line 13:
| document type = Letter
| document type = Letter
| page count = 35
| page count = 35
| project =
| stage = Other
}}
}}
=Text=
{{#Wiki_filter:AVIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261August 28, 201410 CFR 2.202EA-12-049Attention: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001Serial No.:NL&OS/MAE:Docket Nos.:License Nos.:14-394RO50-338/339NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSIONORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-12-0491
==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. 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), dated February 28, 2013 (Serial No. 12-162B)3. Virginia Electric and Power Company's Six-Month 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), dated February 27, 2014 (Serial No. 12-162E)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 wasimmediately effective and directed Dominion to develop, implement, and maintainguidance and strategies to maintain core cooling, containment, and spent fuel poolcooling capabilities in the event of a beyond-design-basis external event.Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a statusreport at six-month intervals following submittal of the OIP.The attachment to this letter provides the third six-month status report and an update ofmilestone accomplishments since the submittal of the prior six-month status report Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 2 of 3(Reference 3), including any changes to the compliance method, schedule, or need forrelief and the basis.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely,Mark D. SartainVice President -Nuclear EngineeringAttachment (1)Commitments made by this letter: No new Regulatory CommitmentsCOMMONWEALTH OF VIRGINIA)COUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and Commonwealthaforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Virginia Electric andPower Company. He has affirmed before me that he is duly authorized to execute and file the foregoingdocument in behalf of the Company, and that the statements in the document are true to the best of hisknowledge and belief.-77Acknowledged before me this2'-e'Uay Of 2014.My Commission Expires: -I -1 ' *(SEAL) '-.....VickiL- .. 11, 1 Notary PublicNOTARY PUBLICCommonwealth of VirginiaReg.
* 140542My Commissio Expires May 31, 2018 Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 3 of 3cc: Director of Office of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 13 H16M11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory Commission, Region IIRegional AdministratorMarquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257Dr. V. SreenivasNRC Project Manager North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738Ms. K. R. CottonNRC Project Manager SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorNorth Anna Power StationMr. J. E. Reasor, Jr.Old Dominion Electric CooperativeInnsbrook Corporate Center, Suite 3004201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049AttachmentSix-Month Status Report for the Implementation of Order EA-12-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsAugust 2014North Anna Power Station Units I and 2Virginia Electric and Power Company (Dominion)
Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 1 of 31Six-Month Status Report for the Implementation of Order EA-12-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsI IntroductionDominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverseand flexible strategies (FLEX) for North Anna Power Station (NAPS) in response to NRCOrder Number EA-12-049 (Reference 2). This attachment provides an update of milestoneaccomplishments and open items since submittal of the last status report (Reference 13),including any changes to the compliance method, schedule, or need for relief/relaxation andthe basis, if any.2 Milestone AccomplishmentsThe following milestones have been completed since the development of the OIP, and arecurrent as of July 31, 2014.* Submit Integrated Plan" Develop Strategies* Develop Modifications* Develop Training Plan" Purchase Equipment" Receive Equipment" Create Maintenance Procedures3 Milestone Schedule StatusThe following table provides an update to Attachment 2A of the OIP. The table provides theactivity status of each item, and whether the expected completion date has changed. Thedates are planning dates subject to change as design and implementation details aredeveloped.The revised milestone and associated target completion dates for 'Implement Modifications'do not impact the Order implementation dates for North Anna Units 1 and 2, but accuratelyreflect that the Unit 2 modifications will be implemented at the end of the upcoming refuelingoutage.Target Activity Revised TargetMilestone CompletionDate Status Completion DateSubmit Integrated Plan February 2013 CompleteDevelop Strategies October 2013 CompleteDevelop Modifications July 2014 Complete Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 2 of 31Target Activity Revised TargetMilestone Completion Status Completion DateDateImplement Modifications* April 2015* StartedDevelop Training Plan April 2014 CompleteImplement Training September 2014 StartedIssue FLEX Support Guidelines and September 2014 StartedAssociated Procedure RevisionsDevelop Strategies/Contract withNational SAFER Response Center August 2014 Started(NSRC)Purchase Equipment February 2014 CompleteReceive Equipment August 2014 CompleteValidation Walk-throughs orDemonstrations of FLEX Strategies August 2014 Started September 2014*and ProceduresCreate Maintenance Procedures* August 2014 CompleteUnit 1 Outage Implementation April 2015 StartedUnit 2 Outage Implementation October 2014 Started* Refer to Section 8, Supplemental Information, for an explanation of the change to thisMilestone.4 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at NAPS Units 1 and 2 as required by Order Number EA-12-049, datedMarch 12, 2012. The first and second Six-Month Status Report of the OIP for NAPS wereprovided by letters dated August 23, 2013 (Reference 11) and February 28, 2014 (Reference13), respectively. The following are changes to the compliance method information provided inthe NAPS OIP and subsequent updates, which continues to meet NEI 12-06 (Reference 3):a) Dominion no longer plans to pre-stage the 120/240 VAC DGs in the Unit 1 and Unit 2alleyways. The deployment strategy for the portable 120/240VAC diesel generators (DGs)used to re-power the vital bus circuits has been changed back to the original electrical re-powering strategy, described in Section F1.2 -PWR Portable Equipment Phase 2 of theOIP submitted on February 28, 2013 (Reference 1) with the exception that the DGs aresized for a single generator per unit.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 3 of 31b) Regarding the previously reported strategy for Modes 5 & 6, credit was taken for theRefueling Water Storage Tanks (RWSTs) to provide a borated water source for injectioninto the RCS. Although the RWSTs are not missile protected, credit as a borated watersource was based on the assumption that it was improbable that both tanks would bedestroyed by a single tornado. Subsequently, the strategy has been enhanced to addressthe scenario that both RWSTs are unavailable. The revised strategy includes the provisionto utilize clean water sources onsite (which are protected from a tornado), if both RWSTsare unavailable. If a clean water source is used, flow must be controlled in order to matchthe rate of water loss (due to boiling) so that dilution of the boron concentration in the RCSdoes not occur.c) Based on a study that included a chemical analysis of the various water sources onsite, thepreferred order of clean water sources for use in both the primary and secondary sides ofthe Nuclear Steam Supply System (NSSS) was revised.d) Dominion is pursuing an alternate means of compliance to NEI 12-06, Section 3.2.2,regarding additional "spare" cables and hoses. Typically, the hoses utilized to implement aFLEX strategy are not a single continuous hose, but are composed of individual sections ofa smaller length joined together to form a sufficient length. In the case of cables, multipleindividual lengths of cable are used to construct a circuit.Hoses and cables are passive devices, which are unlikely to fail provided they areappropriately inspected and maintained. The most likely cause of failure is mechanicaldamage during handling provided that the hoses and cables are stored in areas withsuitable environmental conditions. The hoses and cables for the FLEX strategies will bestored and maintained in accordance with manufacturers' recommendations including anyshelf life requirements. Initial inspections and periodic inspections or testing/replacementwill be incorporated into the site's maintenance and testing program and implemented inaccordance with Section 11.5 of NEI 12-06.The industry has proposed for NRC Staff consideration alternate methods of compliance tothe N+1 requirement applicable to hoses and cables, as stated in Section 3.2.2 of NEI 12-06. Dominion supports this industry proposal and has adopted the agreed upon method forhoses in that 10% of the total length and at least one of the longest single lengths for eachhose size has been purchased. With regard to cables, the 120/240VAC generators and the480VAC generators are backups to each other, therefore, only N sets of cables arerequired. Therefore, once NRC endorsement of this alternate approach is complete,Dominion will have achieved alternate compliance with the NEI 12-06 N+1 requirement forhoses.e) The structural integrity of the reactor Containment building will not be challenged due toincreasing Containment pressure during a BDB Extended Loss of AC Power (ELAP) event.Additionally, analysis has shown that any increase in temperature following an ELAP eventdoes not challenge the key parameter instrumentation in the Containment for at least 7days.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 4 of 31Multiple Containment cooling methods described in previous submittals are available asoptions for heat removal to maintain Containment temperature for equipment design limits.However, they are not required to be specifically designated as primary and alternatestrategies. Adequate time is available utilizing equipment from the NSRC to deploy thecooling methods described.f) The BDB and NSRC equipment details in OIP Table 1, PWR Portable Equipment Phase 2,and OIP Table 2, PWR Portable Equipment Phase 3, respectively, have changed. Updatesto the 'List Portable Equipment' and 'Performance Criteria' are included as well asassociated changes/deletions in footnotes. Changes to the number of components havebeen included for some of the support equipment categories, but no changes have beenmade to the quantities of any of the major FLEX components. Revised OIP Tables 1 and 2are attached.5 Need for Relief/Relaxation and Basis for the RelieflRelaxationDominion expects to comply with the order implementation date and no relief/relaxation isrequired at this time.6 Open ItemsThe NRC has established an audit process to allow the exchange of information between thelicensees and the NRC Staff (Reference 19). Between May 19, 2014 and May 22, 2014, NorthAnna Units 1 and 2 were the subject of an NRC onsite audit where the site specific aspects ofDominion's proposed FLEX Mitigating Strategies were reviewed. During this NRC onsite audit,the staff reviewed site specific documentation and upon completion of the audit, indicated thatfurther review of several items was not anticipated as Dominion proceeds towards compliancefor Orders EA-12-049 and EA-12-051. These items are identified in the following tables inSection 6. Note that the tables provided in Sections 6.4 and 6.5 are new and are the result ofthe ongoing audit process.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 5 of 316.1. Open Items from Overall Integrated PlanThe following table provides a summary of the status of Open Items (01) identified byDominion and documented in Attachment 2B of the NAPS Overall Integrated Plan submittedFebruary 28, 2013 and the status of each item.Overall Integrated Plan Open Items01 # Description StatusVerify response times listed in timeline and perform staffing Complete.assessment. (Reference 20)During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.Preliminary analyses have been performed to determine the time Complete.to steam generator overfill without operator action to reduce AFW2 flow, time to steam generator dryout without AFW flow, and time (Reference 4)to depletion of the useable volume of the ECST. The finaldurations will be provided when the analyses are completed.Preliminary analyses have been performed to determine the Complete.Class 1 E battery life based on implementation of load stripping (Reference 4)actions. The final battery life duration will be provided when theanalyses are completed. During the May 2014NRC Onsite Audit, theNRC Staff indicated that3 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 6 of 31Overall Integrated Plan Open Items01 # Description StatusThe Phase 3 coping strategy to maintain Containment integrity is Complete.under development. Methods to monitor and evaluate (Reference 13)Containment conditions and depressurize/cool Containment, ifnecessary, will be provided in a future update. During the May 2014NRC Onsite Audit, theNRC Staff indicated that4 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.Analyses will be performed to develop fluid components Complete.performance requirements and confirm fluid hydraulic-relatedstrategy objectives can be met. Hydraulic calculations forthe FLEX pumpsdeployed using theirassociated hose networkshave confirmed that thecore cooling/decay heatremoval, RCS inventory,and reactivity control(RCS Injection), and SFPmake-up strategies can5 be satisfactorilyaccomplished inresponse to anELAP/Loss of UltimateHeat Sink (LUHS) event.(References 6 and 7)Hydraulic calculationshave confirmed that theSW flows forContainment coolingoptions are adequate.(Reference 14).
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 7 of 31Overall Integrated Plan Open ItemsOI # [Description jStatusA study is in progress to determine the design features, sitelocation(s), and number of equipment storage facilities. The finaldesign for BDB equipment storage will be based on the guidancecontained in NEI 12-06, Section 11.3, Equipment Storage. Asupplement to this submittal will be provided with the results ofthe equipment storage study.Complete.6A single 10,000 sq. ft.Type 1 building is beingconstructed at NAPS forstorage of BDBequipment. The buildingis designed to meet theplant's design basis forthe Safe ShutdownEarthquake, high windhazards, snow, ice andcold conditions, and willbe located above theflood elevation from themost recent site floodinganalysis. The BDBStorage Building will besited in the OwnerControlled Area in theparking lot west ofWarehouse #5. Thisupdate provides thesupplemental informationreferred to in this openitem. (Reference 21)During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.FLEX Support Guidelines (FSGs) will be developed in Started.accordance with PWROG guidance. Existing procedures will berevised as necessary to implement FSGs. Scheduled completionI_ _ date: September 2014 Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 8 of 31Overall Integrated Plan Open Items01 # I Description StatusEPRI guidance documents will be used to develop periodictesting and preventative maintenance procedures for BDBequipment. Procedures will be developed to manageunavailability of equipment such that risk to mitigating strategycapability is minimized.Complete.(Reference 22)8EPRI guidancedocuments have beenused, where available, todevelop the testing andpreventative maintenancestrategies for the sites.Fleet-wide templateshave been developed andinput into the individualsite maintenancestrategies. SpecificPeriodic Maintenance(PM) procedures basedon these strategies will beimplemented prior to therequired North Annacompliance date forOrder EA-12-049.A fleet-wide FLEXStrategy ProgramDocument has beendeveloped (Refer to OpenItem 9). The programincludes the requirementto manage unavailabilityof equipment such thatrisk to mitigating strategycapability is minimized. Afleet-wide procedure hasbeen developed tospecifically addressequipment unavailability.An overall program document will be developed to maintain theFLEX strategies and their bases and provide configuration controland change management for the FLEX Program.Complete.(Reference 23)9During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 and Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 9 of 31Overall Integrated Plan Open ItemsOI # Description StatusEA-1 2-051.The Dominion Nuclear Training Program will be revised to assure Complete.personnel proficiency in the mitigation of BDB events isdeveloped and maintained. These programs and controls will be Documentation of the Job10 developed and implemented in accordance with the Systematic Analysis performed forApproach to Training (SAT). new operational taskshas been provided via theongoing NRC auditprocess. (Reference 19)Complete the evaluation of TDAFW pump long term operation Complete.with < 290 psig inlet steam pressure.TDAFW pump operation11 and adequate AFW flowto the SGs at SGpressures < 290 psig hasbeen confirmed.(Reference 5)Plant modifications will be completed for permanent plant Started.changes required for implementation of FLEX strategies.12 Scheduled completiondate: See MilestoneSchedule above.Details of the ventilation strategy are under development and will Complete.13 conform to the guidance given in NEI 12-06. The details of thisstrategy will be provided at a later date. (Reference 13)Complete installation of N-9000 RCP seals in 2 of 3 RCPs in Started.each unit.14 Scheduled completiondate:April 2015 (Unit 1)Oct 2014 (Unit 2)Analyses will be performed to develop electrical components Complete.performance requirements and confirm electrical loading-relatedstrategy objectives can be met. Final calculationsconfirming the sizing andloading analysis of the120VAC, 480VAC, and4KV generators confirm15 the electrical loading-related strategyobjectives can be met arecomplete (References 16,17, & 18).During the May 2014NRC Onsite Audit, theNRC Staff indicated that Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 10 of 31Overall Integrated Plan Open Items01 # Description Statusfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.An evaluation of all BDB equipment fuel consumption and Complete.required re-fill strategies will be developed. (Reference 21)During the May 2014NRC Onsite Audit, theNRC Staff indicated that16 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.A lighting study will be performed to validate the adequacy of Complete.supplemental lighting and the adequacy and practicality of using (Reference 21)portable lighting to perform FLEX strategy actions.During the May 2014NRC Onsite Audit, theNRC Staff indicated that17 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.A comprehensive study of communication capabilities is being Complete.performed in accordance with the commitments made inDominion letter S/N 12-207F dated October 29, 2012 in response A study documenting theto Recommendation 9.3 of the 10 CFR 50.54(f) letter dated communications strategyMarch 12, 2012. The results of this study will identify the has been completed.communication means available or needed to implement The plan concludes thatcommand and control of the FLEX strategies at NAPS. FLEX strategies can be18 Validation of communications required to implement FLEX effectively implementedstrategies will be performed as part of Open Item No. 1. with a combination ofsound powered phones,satellite phones andhand-held radios.(Reference 10)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 11 of 31Overall Integrated Plan Open Items01 # Description StatusDuring the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051. +Preferred travel pathways will be determined using the guidancecontained in NEI 12-06. The pathways will attempt to avoidareas with trees, power lines, and other potential obstructionsand will consider the potential for soil liquefaction.19Complete.The soil liquefaction studyhas been completed(Reference 8), whichsupports the location ofthe storage building andthe haul routes. Theresults will be includedwith the final designpackage for the storagebuilding (Reference 9).During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.20 The equipment listed in Table 1 will be received on site. Complete.6.2. Open Items from the Interim Staff Evaluation (ISE)The following table provides a summary of the Open Items (01) from the NAPS Interim StaffEvaluation (Reference 12) and the current status of each item.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 12 of 31Interim Staff Evaluation Open Items01 # Description Status3.2.1.2.B Demonstration of the acceptability of the use the Flowserve This ISE 01 is beingN-9000 seals with the abeyance feature and validation of an addressed through theacceptable leakage rate for these seals. ongoing NRC auditprocess. (Generic)(Reference 19)3.2.1.8.A The Pressurized-Water Reactor Owners Group (PWROG) During the May 2014submitted to NRC a position paper, dated August 15, 2013 NRC Onsite Audit, the(ADAMS Accession No. ML13235A135 (non-public for NRC Staff indicatedproprietary reasons)), which provides test data regarding that further review ofboric acid mixing under single-phase natural circulation this item was notconditions and outlined applicability conditions intended to anticipated asensure that boric acid addition and mixing would occur under Dominion proceedsconditions similar to those for which boric acid mixing data is towards complianceavailable. During the audit process, the licensee informed the for Orders EA-12-049NRC staff that its boric acid mixing model is based on the and EA-12-051.PWROG method. Since the audit discussions, the NRC (References 19 and 21)endorsed the PWROG guidance with several clarifications inletter dated January 8, 2014. The licensee should addressthe clarifications in alignment with the NRC endorsementletter for the development of an adequate model fordetermining the mixing of boric acid in the reactor coolantsystem during natural circulation with the potential for two-_ _ phase flow conditions.6.3. Confirmatory Items from Interim Staff Evaluation (ISE)The following table provides a summary of the Confirmatory Items (CI) from the NAPS InterimStaff Evaluation (Reference 12) and the current status of each item.Interim Staff Evaluation Confirmatory ItemsCI # Description Status3.1.1. 1.A Storage & Protection of FLEX equipment -Confirm final During the May 2014design of FLEX storage structure conforms to NEI 12-06, NRC Onsite Audit, theSections 5.3.1, 6.2.3.1, 7.3.1, and 8.3.1 for storage NRC Staff indicatedconsiderations for the hazards applicable to North Anna. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 13 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.1.1.3.A Procedural Interface Considerations (Seismic) -Confirm FLEX During the May 2014support guideline to provide operators with direction on how to NRC Onsite Audit, theestablish alternate monitoring and control capabilities. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 24)3.1.1.4.A Off-Site Resources -Confirm RRC local staging area, This ISE Cl is beingevaluation of access routes, and method of transportation to addressed through thethe site. ongoing NRC auditprocess. (Reference 19)3.1.5.2.A In the Integrated Plan, the licensee did not address During the May 2014considerations for any manual actions required by plant NRC Onsite Audit, thepersonnel in high temperature conditions as recommended in NRC Staff indicatedNEI 12-06, Section 9.3.2. Discuss effects of high that further review oftemperatures on any manual action performed by plant this item was notpersonnel and any applicable contingencies and any related anticipated asprocedural changes or enhancements. Dominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)3.2.1.1 .A Confirm that the use of NOTRUMP code for the ELAP analysis This ISE Cl is beingof North Anna is limited to the flow conditions before reflux addressed through thecondensation initiates, including specification of an acceptable ongoing NRC auditdefinition for reflux condensation cooling, process.(Generic)(Reference 21)3.2.1.1.B Confirmation that the generic analysis in Section 5.2.1 of This ISE Cl is beingWCAP-17601-P is applicable or bounding with respect to addressed through theNorth Anna for an appropriate figure of merit for defining entry ongoing NRC auditinto the reflux condensation cooling mode. process.I __ (References 19 and 29)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 14 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.2.1.1.C Confirm the consistency of the margin imposed to prevent During the May 2014accumulator nitrogen injection with the cooldown terminus NRC Onsite Audit, theassumed in WCAP-1 7601-P. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 25)3.2.1.2.C Confirm that stresses resulting from a cooldown of the RCS During the May 2014will not result in the failure of seal materials. NRC Onsite Audit, theAs applicable, confirm that reestablishing cooling to the seals NRC Staff indicatedwill not result in increased leakage due to thermal shock. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(References 25 and 26)3.2.1.6.A Sequence of Events -Confirm that the final timeline has been This ISE Cl is beingtime validated after detailed designs are completed and addressed through theprocedures are developed. The results will be provided in a ongoing NRC auditfuture 6-month update. process.(Reference 19)3.2.1.8.B Complete calculations demonstrating adequate shutdown During the May 2014margin for North Anna in ELAP scenarios with and without NRC Onsite Audit, theseal leakage. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 15 of 31Interim Staff Evaluation Confirmatory 'ItemsCI # Description Status3.2.1.8.C Confirm that shutdown margin calculations will be verified to During the May 2014remain bounding for future operating cycles and clarify the NRC Onsite Audit, themethod that will be used to make this determination. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 19)3.2.1.9.A Confirm that the licensee provides sufficient BDB RCS During the May 2014Injections Pumps to conform to the spare capability (N+1) NRC Onsite Audit, theguidance of NEI 12-06, Section 3.2.2. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.1.9.B Confirm that calculations documenting the AFW supply, SFP During the May 2014makeup, and RCS inventory hydraulic analysis demonstrate NRC Onsite Audit, thethe pumps have adequate capacity for the strategies they NRC Staff indicatedsupport. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(References 6, 7, and14)3.2.2.A SFP venting -Confirm that opening of the roll-up doors would This ISE Cl is beingprovide an adequate ventilation path for the SFP area. addressed through theongoing NRC auditprocess. (Reference 19)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 16 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.2.3.A Containment -Confirm Containment analysis to determine During the May 2014any Containment temperature and pressure actions beyond NRC Onsite Audit, theseven days. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(References 13 and 21)3.2.4.2.A Ventilation -Equipment Cooling -Confirm development of the This ISE Cl is beingventilation strategy. addressed through theongoing NRC auditprocess. (References 13,19, and 21)3.2.4.2.B Confirm the adequacy of the battery room ventilation provided During the May 2014in the context of an ELAP. NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.4.4.A Verify the lighting study validates the adequacy of During the May 2014supplemental lighting and the adequacy and practicality of NRC Onsite Audit, theusing portable lighting to perform FLEX strategy actions. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.4.4.B Communications -Confirm the licensee's proposed This ISE CI is beingenhancements and interim measures to the site's addressed through thecommunications systems and that they have been ongoing NRC auditcompleted. process.I_ (References 10 and 19)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 17 of 31Interim Staff Evaluation Confirmatory ItemsCI # Description Status3.2.4.8.A Electrical Power Sources -Confirm load calculations for the This ISE Cl is beingphase 2 and 3 FLEX generators will support supplied loads, addressed through theongoing NRC auditprocess.(References 16, 17, 18,and 19)3.2.4.9.A Fuel Supplies -Confirm the adequacy of the fuel consumption During the May 2014evaluation. Confirm that the procedural guidance governing NRC Onsite Audit, there-fueling strategies addresses: (a) how the quality of the fuel NRC Staff indicatedoil and gasoline supplies will be controlled in order to ensure that further review ofproper diesel or gasoline-powered FLEX equipment operation, this item was not(b) available sources of gasoline and how those sources will anticipated asbe protected to ensure availability following a BDB event, and Dominion proceeds(c) if the onsite fuel capacity provides an indefinite supply of towards compliancefuel or if the RRC is capable of providing an indefinite, ongoing for Orders EA-12-049supply of fuel (both diesel and gasoline), and EA-12-051.(Reference 21)3.4.A Confirm the implementation of considerations 2 through 10 in This ISE CI is beingNEI 12-06, Section 12.2. addressed through theongoing NRC auditprocess.(Reference 19)6.4. Audit Question Reviewed During NAPS Onsite AuditVarious NAPS Audit Questions (AQs) were evaluated during the NAPS NRC Onsite Audit. Thefollowing AQs were evaluated and remained "Open".Audit Provide the direct current (dc) load profile with the required This AQ is beingQuestion loads for the mitigating strategies to maintain core cooling, addressed through the#43 containment, and spent fuel pool cooling, ongoing NRC auditprocess.(Reference 19)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 18 of 316.5. Additional Items Reviewed During NAPS Onsite AuditThe following table provides a list of the additional Safety Evaluationidentified and evaluated during the NAPS NRC Onsite Audit and the(SE) Review itemsstatus of each item.Safety Feb 2014 Update Section 4a. Portable 120/240VAC DG will During the May 2014Evaluation now be pre-staged. NRC Onsite Audit, theReview NRC Staff indicatedItem #1 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(See Section 4a.)Safety SW reservoir and lake are credited as indefinite source of During the May 2014Evaluation water. SW has a finite volume of water. Therefore, if the SW NRC Onsite Audit, theReview reservoir is used as a source for make-up flow, the SW NRC Staff indicatedItem #2 reservoir will eventually need make-up water from the lake. that further review ofThe licensee is not clear in stating whether the dam forming this item was notthe lake is seismically qualified or if a viable suction source anticipated ascan be maintained at the lake following a loss of the dam. Dominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 27)Safety 1. (RCS Venting) The generic analysis in WCAP-17601-P During the May 2014Evaluation strictly addressed ELAP coping time without consideration of NRC Onsite Audit, theReview the actions directed by a site's mitigating strategies. WCAP- NRC Staff indicatedItem #3 17792-P extends these analytical results through explicit that further review ofconsideration of mitigating strategies involving RCS makeup this item was notand boration. In support of the RCS makeup and boration anticipated asstrategies proposed therein, a generic recommendation is Dominion proceedsmade that PWRs vent the RCS while makeup is being towards complianceprovided. Please provide the following information in regard to for Orders EA-12-049this topic: a. Will the mitigating strategy include venting of the and EA-12-051.RCS? b. If so, please provide the following information: i. The (References 21 and 28)vent path to be used and the means for its opening andclosure. ii. The criteria for opening the vent path. iii. Thecriteria for closing the vent path. iv. Clarification as to whetherthe vent path could experience two-phase or single-phaseliquid flow during an ELAP. If two-phase or liquid flow is apossibility, please clarify whether the vent path is designed toensure isolation capability after relieving two-phase or liquidflow. If relief of two-phase or liquid flow is to be avoided,please discuss the availability of instrumentation or othermeans that would ensure that the vent path is isolated prior to Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 19 of 31departing from single-phase steam flow. vi. If a pressurizerPORV is to be used for RCS venting, please clarify whetherthe associated block valve would be available (or the timelineby which it could be repowered) in the case that the PORVwere to stick open. If applicable, please further explain whyopening the pressurizer PORV is justified under ELAPconditions if the associated block valve would not be available.vii. If a pressurizer PORV is to be used for RCS venting,please clarify whether FLEX RCS makeup pumps and FLEXsteam generator makeup pumps will both be available prior toopening the PORV. If they will not both be available, pleaseprovide justification. c. If RCS venting will not be used, pleaseprovide the following information: i. The expected RCStemperature and pressure after the necessary quantity ofborated makeup has been added to an unvented RCS. ii.Adequate justification that the potential impacts of unventedmakeup will not adversely affect the proposed mitigatingstrategy (e.g., FLEX pump discharge pressures will not bechallenged, plant will not reach water solid condition, adequateboric acid can be injected, increased RCS leakage will notadversely affect the integrated plan timeline, etc.).SafetyEvaluationReviewItem #42. (Westinghouse Standard RCP Seals: NSAL-14-1) OnFebruary 10, 2014, Westinghouse issued Nuclear SafetyAdvisory Letter (NSAL)-14-1, which informed licensees ofplants with standard Westinghouse RCP seals that 21 gpmmay not be a conservative leakage rate for ELAP analysis.This value had been previously used in the ELAP analysisreferenced by many Westinghouse PWRs, including thegeneric reference analysis in WCAP-17601-P. Therefore,please clarify whether the assumption of 21 gpm of sealleakage per RCP (at 550 degrees F, 2250 psia) remains validin light of the issues identified in NSAL-14-1. In so doing,please identify the specifics of the seal leak off line design and#1 seal faceplate material relative to the categories in NSAL-14-1 and identify the corresponding presumed leakage ratefrom NSAL-14-1 that is deemed applicable.This SE Review Item isbeing addressed throughthe ongoing NRC auditprocess.(Reference 19)
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 20 of 31SafetyEvaluationReviewItem #54. (RVLIS Measurement Principle) Please clarify whether thereactor vessel level instrumentation system (RVLIS) indicationprovides a measure of collapsed level that can be used withFigures 3.3-1 through 3.3-3 of WCAP-17792-P. If the RVLISsystem does not provide an indication of collapsed level, thenplease clarify how the required timing for RCS makeup will bedetermined and provide justification.During the May 2014NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)4 tSafetyEvaluationReviewItem #6(Timeline to reflux cooling) Please clarify whether proceduralguidance for the timing of providing makeup to the reactorcoolant system is based on analysis in WCAP-17792-P, pages3-10 through 3-16. If so, please further provide adequatejustification for basing the timing of primary makeup on theassumption that reactor coolant pump seal leakage rates thatare less than the maximum expected value under ELAPconditions will not increase.During the May 2014NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)Safety Please provide adequate basis that calculations performed During the May 2014Evaluation with the NOTRUMP code (e.g., those in WCAP-17601-P, NRC Onsite Audit, theReview WCAP-1 7792-P) are adequate to demonstrate that criteria NRC Staff indicatedItem #7 associated with the analysis of an ELAP event (e.g., that further review ofavoidance of reflux cooling, promotion of boric acid mixing) are this item was notsatisfied. NRC staff confirmatory analysis suggests that the anticipated asneed for implementing certain mitigating strategies for Dominion proceedsproviding core cooling and adequate shutdown margin may towards complianceoccur sooner than predicted in NOTRUMP simulations. for Orders EA-12-049and EA-12-051.(Reference 21)Safety Please provide adequate basis that, when considering mixing This SE Review Item isEvaluation time, there is sufficient flow capacity to support borated being addressed throughReview makeup to both units from a single RCS makeup pump taking the ongoing NRC auditItem #8 suction from a portable batching tank. process.(Reference 19)Safety Please provide a clearly labeled sketch or marked-up plant This SE Review Item isEvaluation drawing of the plan view of the SFP area, depicting the SFP being addressed throughReview inside dimensions, the planned locations/placement of the the ongoing NRC auditItem #9 primary and back-up SFP level sensor, and the proposed process.routing of the cables that will extend from these sensors (Reference 19)toward the location of the read-out/display device.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 21 of 31Safety Human factors questions addressed during walkdowns of plant During the May 2014Evaluation equipment as well as in discussion with personnel. NRC Onsite Audit, theReview NRC Staff indicatedItem #10 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 19)Safety Unprotected water sources in Modes 5 & 6 This SE Review Item isEvaluation being addressed throughReview the ongoing NRC auditItem #11 process.(See Section 4b andReferences 19 and 21)Safety Provide details on maintenance and testing and Storage of This SE Review Item isEvaluation 120v/480v pre-staged cables. being addressed throughReview the ongoing NRC auditItem #12 process.(Reference 19)Safety Provide discussion on evaluation of diesel powered equipment This SE Review Item isEvaluation exhaust regarding habitability of other areas, being addressed throughReview the ongoing NRC auditItem #13 process.(Reference 19)Safety When do we plan to deploy hoses in SFP prior to bulk boiling During the May 2014Evaluation to minimize exposure. NRC Onsite Audit, theReview NRC Staff indicatedItem #14 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)Safety Walk-through of building access procedures, to include any This SE Review Item isEvaluation unique access control devices being addressed throughReview the ongoing NRC auditItem #15 process.(Reference 19)
Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 22 of 317 Potential Safety Evaluation ImpactsSection 6.5 provides a list of the additional Safety Evaluation (SE) Review items identified andevaluated during the NAPS NRC Onsite Audit and the status of each item.Additionally, Dominion is participating in the ongoing industry effort to develop guidance for theFinal Integrated Plan that will support NRC preparation of the Safety Evaluation documentingNAPS's compliance with Order EA-12-049. The format of the Final Integrated Plan isconsistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davismemorandum (ML14161A643)(Reference 15).8 Supplemental InformationThis supplemental information provides details of the changes identified in the status updatesabove and addresses a) Open Item 14, b) the Milestone Task 'Implement Modifications,' c) theMilestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies andProcedures' and d) the Milestone Task 'Create Maintenance Procedures' as follows:a) NAPS, Open Item 14: The revision to the status wording more accurately reflects thestatus for each North Anna Unit. The split completion schedule reflects the currentoutage schedules.b) NAPS, Milestone Task 'Implement Modifications': The revision separates Units 1and 2 to more accurately reflect the actual tasks as they will occur for each NAPS Unit.The updated completion schedules accurately reflect the current outage schedules.The revised Milestone Tasks and Completion Schedules are as follows:Milestone Task: Implement Unit 1 ModificationsCompletion Schedule: April 2015Milestone Task: Implement Unit 2 ModificationsCompletion Schedule: October 2014c) NAPS, Milestone Task 'Validation Walk-throuqhs or Demonstrations of FLEXStrategies and Procedures': The revision to the scheduled milestone targetcompletion date is needed to allow for completion of the walk-throughs, which are inprogress.d) NAPS, Milestone Task 'Create Maintenance Procedures': The Milestone is to berestated as 'Develop Maintenance Strategies." This change is to revise the currentmilestone to reflect the intended activity which was to develop the maintenancestrategies based on industry and vendor supplied information. As per the responseprovided above for Open Item 8, the restated task has been completed. The designchange implementing the FLEX Mitigating Strategies Program identifies themaintenance strategies required for the FLEX implementation and requires that PeriodicMaintenance (PM) procedures be developed. Submittal of requests for creation ofthese PMs is in accordance with the Design Control Program and will be tracked. ThePMs will be prioritized such that the near-term requirements, (e.g., 30 day walkdowninspections) are in-place prior to FLEX Mitigating Strategy implementation date. The Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 23 of 31PMs for the longer term requirements will be implemented prior to their firstperformance interval.9 ReferencesThe following references support the updates to the OIP described in this attachment and areavailable in ADAMS or have been provided to the staff for their review.1. "Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," datedFebruary 28, 2013 (Serial No. 12-162B).2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"Revision 0, dated August 2012.4. "Supplement to Overall Integrated Plan in Response to March 21, 2012 CommissionOrder Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis Events (Order Number EA-12-049)," dated April 30, 2013 (SerialNo. 12-162C).5. Dominion Calculation ME-0968, "Evaluation of the TDAFW Pump Performance at LowSteam Generator Pressures," August 2013.6. Dominion Calculation ME-0965, "Evaluate the BDB High Head Injection pump for BeyondDesign Basis (BDB) at the primary and alternative supply locations in Modes 1-4, and theBDB AFW Pump in Modes 5 and 6," Revision 0.7. Dominion Calculation ME-0966, "Beyond Design Basis (BDB) -BDB High Capacity Pumpand BDB AFW Pump Hydraulic Analysis for Spent Fuel Pool Makeup and AFW Injectionat NAPS Units 1 and 2," Revision 0.8. Geotechnical Engineering Report, "BDB FLEX Storage Building," North Anna PowerStation, Louisa, VA, Schnabel Reference #13613081, October 3, 2013, Addendum 1.9. Design Change NA-1 3-00016, "BDB Storage Building/ North Anna Power Station/ Units 1& 2."10. ETE-CPR-2013-0003, "Beyond Design Basis Communications Strategy/Plan," Rev. 111. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 23, 2013 (Serial No. 12-162D).12."North Anna Power Station, Units 1 and 2 -Interim Staff Evaluation Relating to OverallIntegrated Plan in Response to Order EA-12-049 (Mitigating Strategies)," dated January29, 2014.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 24 of 3113. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2014 (Serial No. 12-162E).14. Dominion Calculation ME-12126, "FLEX Beyond Design Basis (BDB) Service Water (SW)Containment Integrity Strategy Hydraulic Analysis," Rev 0.15. Memorandum from Jack R. Davis, JLD, Office of NRR, to Stewart N. Bailey, Sheena A,Whaley, and Jeremy S. Bowen, "Supplemental Staff Guidance for the Safety Evaluationsfor Order EA-12-049 on Mitigation Strategies for Beyond-Design-Basis External Eventsand Order EA-12-051 on Spent Fuel Pool Instrumentation," dated July 1, 2014(ML14161A643).16. Dominion Calculation EE-0863, "NAPS BDB FLEX Electrical 480 and 120 VAC SystemLoading Analysis," Rev. 1 (Unit 1).17. Dominion Calculation EE-0865, "NAPS BDB FLEX Electrical 480 and 120 VAC SystemLoading Analysis," Rev. 0 (Unit 2).18.Dominion Calculation EE-0871, "NAPS BDB FLEX Electrical 4160VAC System LoadingAnalysis," Rev. 0.19. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate to All OperatingReactor Licensees and Holders of Construction Permits, "Nuclear RegulatoryCommission Audits of Licensee Responses to Mitigating Strategies Order EA-12-049,"dated August 28, 2013 (ML13234A503).20. Dominion Letter to NRS titled "North Ann Power Station Units 1 and 2, March 12, 2012Information Request, Phase 2 Staffing Assessment Report," dated May 7, 2014 (SN:14-199)21. ETE-CPR-2012-0012, Rev. 4, "Beyond Design Basis -FLEX Strategy Overall IntegratedPlan Basis Document."22.Procedure CM-AA-BDB-102, "Beyond Design Basis FLEX Equipment UnavailabilityTracking."23. Procedure CM-AA-BDB-10, Beyond Design Basis FLEX Program.24. FSG-7, "Loss of Vital Instrumentation or Control Power."25. Procedure ECA-0.0, "Station Blackout."26. FlowServe document, "White Paper on the Response for the N-Seal Reactor CoolantPump (RCP) Seal Package to Extend Loss of AC Power (ELAP)," Rev. 0 dated February11, 2014 (Proprietary)27. North Anna Power Station Updated Final Safety Analysis Report (UFSAR), Section3.8.3.1.28. FSG-8, "Alternate RCS Boration."29. ETE-CPR-2012-0150, Rev. 1, Add. 0, "Core Cooling Evaluation for Dominion Fleet andPrepared Input for Response to Order EA-1 2-049."
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 25 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance IList Portable PreventiveEquipment Core Containment SEP Instrumentation Accessibility MaintenanceRequirementsBDB HighCapacity diesel- Will follow EPRIdriven pump (2)6 X X X 1200 gpm @ templateand assoc. hoses 150 psid requirementsand fittingsBDB AFW pump 300 gpm @ Will follow EPRI(3) and assoc. X templatehoses and fittings 500 psid requirementsBDB RCS Injection Will follow EPRIpump (2)5 and 45 gpm @ Wilateassoc. hoses and X 3000 psid templatefittings requirements120/240VACgenerators (3) 3 Will follow EPRIand associated X 40 kW templatecables, connectors requirementsand switchgear Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 26 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential! Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibilit MaintenanceRequirements120/240VACgenerators (8)2and associated Will follow EPRIcables, connectors X 5-6.5 kW templateand switchgear (to requirementspower supportequipment)480VACgenerators (2)3and associatedcables, connectors Will follow EPRIand switchgear (to X X 350 kW templatere-power battery requirementschargers,inverters, and VitalBuses)Portable boric acid Will follow EPRIbatching tank (2) X 1000 gal templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 27 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential/ Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable Core Containment SFP Instrumentation Accessiblit PreventiveEquipment MaintenanceRequirementsWill follow EPRILight plants (2)2 X templaterequirementsFront end loader Will follow EPRI(1) 2 X templaterequirementsWill follow EPRITow vehicles (2) 2 X X X X templaterequirementsHose trailer (2) Will follow EPRIand Utility vehicle X X X X template(1)2 requirementsFans / blowers Will follow EPRI(10)2 X templaterequirementsAir compressors Will follow EPRI(6)2 X X templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 28 of 31Table I -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibility MaintenanceRequirementsFuel truck (1) with Will follow EPRI1,100 gal. tank X X X X X templateand pumps requirementsFuel carts with Will follow EPRItransfer pumps (2) X X X X X template2 requirementsCommunications Will follow EPRIequipmenti4 X X X X X templaterequirementsMisc. debris Will follow EPRIremoval X templateequipment 2 requirementsMisc. SWill follow EPRIEquipment 2 X templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 29 of 31Table I -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibilit MaintenanceRequirementsNOTES:1. This table is based on one BDB Storage Building.2. Support equipment. Not required to meet N+1.3. 480VAC generators are an alternate strategy to the 120/240VAC generators. Therefore, only N is required.4. Quantities are identified in ETE-CPR-2013-0003 that was developed in response to the results of thecommunications study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.5. One BDB RCS Injection pump can be shared between units if necessary. A BDB RCS Injection pump from theRRC will be deployed from the RRC by 28 hours, if required, to replace an inoperable on-site BDB RCSInjection pump.6. One BDB High Capacity pump is needed to implement the FLEX core and SFP cooling strategies. This pumpis stored in the Type 1 BDB Storage Building and protected from hazards. The 50.54(hh)(2) high capacitypump is credited to meet the N+1 requirement as a backup to the BDB High Capacity pump. This pump isstored onsite in a location other than the BDB Storage Building.
Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 30 of 31Table 2 -PWR Portable Equipment Phase 3Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance NotesList Quantity Quantity Power Core Cont. Access Instrumentation. RCS PreventativePortable Req'd Provided Cooling Cooling/ Inventory MaintenanceEquipment /Unit I Unit Integrity RequiredMedium Jet PerformedVoltage 2 3 Turb. X X X 4.16 KV 1 MW by RRC (1)GeneratorsLow Jet PerformedVoltage 0 1 Turb X X X 480VAC 1100 KW by RRC (2)Generators T bRCHighPressure 1 Diesel 3000# 60 GPM (2)Injection by RRCPumpS/G RPV PerformedMakeup 0 1 Diesel X X 500# 500 GPM by RRC (2)PumpLowPressure 2500 PerformedMedium Diesel X X 300# GPM by RRC (2)Flow PumpLowPressure / 5000 PerformedHigh Flow Diesel X X 150# GPM by RRC (3)Pump _.__ _ ..._"Lighting 0 1 Diesel X 40,000 Lu Performed (4)Towers by RRC Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 31 of 31Table 2 -PWR Portable Equipment Phase 3Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance NotesList Quantity Quantity Power Core Cont. Access Instrumentation. RCS PreventativePortable Req'd Provided Cooling Cooling/ Inventory MaintenanceEquipment /Unit I Unit Integrity RequiredDiesel Fuel 0 AR N/A X X X X X 500 Gal Performed (2)Transfer by RRCMobile Performed (2)Water 0 2 Diesel X X 150 GPMTretmntby RRC (5)Treatment ., .. .MobileBoration 0 1 N/A X 1000 Gal Performed (2)Skid*. .by RRCSkid , Note 1 -RRC 4KV generator supplied in support of Phase 3 for Core Cooling, Containment Cooling, and Instrumentation FLEX Strategies. (Includes adistribution panel and sufficient cables for connection to site 4kV buses.)Note 2 -RRC Generic Equipment -Not required for FLEX Strategy -Provided as Defense-in-Depth.Note 3 -RRC Low Pressure / High Flow pump supplied in support of Phase 3 for Core Cooling and Containment Cooling FLEX Strategies.Note 4 -RRC components provided for low light response plans.Note 5 -Usage dependent on Westinghouse Water Quality Study results.}}

Revision as of 19:06, 26 June 2018

North Anna, 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)
ML14251A024
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/28/2014
From: Sartain M D
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
14-394, EA-12-049
Download: ML14251A024 (35)


Text

AVIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261August 28, 201410 CFR 2.202EA-12-049Attention: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001Serial No.:NL&OS/MAE:Docket Nos.:License Nos.:14-394RO50-338/339NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSIONORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-12-0491

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. 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), dated February 28, 2013 (Serial No. 12-162B)3. Virginia Electric and Power Company's Six-Month 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), dated February 27, 2014 (Serial No. 12-162E)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 wasimmediately effective and directed Dominion to develop, implement, and maintainguidance and strategies to maintain core cooling, containment, and spent fuel poolcooling capabilities in the event of a beyond-design-basis external event.Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a statusreport at six-month intervals following submittal of the OIP.The attachment to this letter provides the third six-month status report and an update ofmilestone accomplishments since the submittal of the prior six-month status report Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 2 of 3(Reference 3), including any changes to the compliance method, schedule, or need forrelief and the basis.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely,Mark D. SartainVice President -Nuclear EngineeringAttachment (1)Commitments made by this letter: No new Regulatory CommitmentsCOMMONWEALTH OF VIRGINIA)COUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and Commonwealthaforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Virginia Electric andPower Company. He has affirmed before me that he is duly authorized to execute and file the foregoingdocument in behalf of the Company, and that the statements in the document are true to the best of hisknowledge and belief.-77Acknowledged before me this2'-e'Uay Of 2014.My Commission Expires: -I -1 ' *(SEAL) '-.....VickiL- .. 11, 1 Notary PublicNOTARY PUBLICCommonwealth of VirginiaReg.
  • 140542My Commissio Expires May 31, 2018 Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 3 of 3cc: Director of Office of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 13 H16M11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory Commission, Region IIRegional AdministratorMarquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257Dr. V. SreenivasNRC Project Manager North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738Ms. K. R. CottonNRC Project Manager SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorNorth Anna Power StationMr. J. E. Reasor, Jr.Old Dominion Electric CooperativeInnsbrook Corporate Center, Suite 3004201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049AttachmentSix-Month Status Report for the Implementation of Order EA-12-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsAugust 2014North Anna Power Station Units I and 2Virginia Electric and Power Company (Dominion)

Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 1 of 31Six-Month Status Report for the Implementation of Order EA-12-049Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsI IntroductionDominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the diverseand flexible strategies (FLEX) for North Anna Power Station (NAPS) in response to NRCOrder Number EA-12-049 (Reference 2). This attachment provides an update of milestoneaccomplishments and open items since submittal of the last status report (Reference 13),including any changes to the compliance method, schedule, or need for relief/relaxation andthe basis, if any.2 Milestone AccomplishmentsThe following milestones have been completed since the development of the OIP, and arecurrent as of July 31, 2014.* Submit Integrated Plan" Develop Strategies* Develop Modifications* Develop Training Plan" Purchase Equipment" Receive Equipment" Create Maintenance Procedures3 Milestone Schedule StatusThe following table provides an update to Attachment 2A of the OIP. The table provides theactivity status of each item, and whether the expected completion date has changed. Thedates are planning dates subject to change as design and implementation details aredeveloped.The revised milestone and associated target completion dates for 'Implement Modifications'do not impact the Order implementation dates for North Anna Units 1 and 2, but accuratelyreflect that the Unit 2 modifications will be implemented at the end of the upcoming refuelingoutage.Target Activity Revised TargetMilestone CompletionDate Status Completion DateSubmit Integrated Plan February 2013 CompleteDevelop Strategies October 2013 CompleteDevelop Modifications July 2014 Complete Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 2 of 31Target Activity Revised TargetMilestone Completion Status Completion DateDateImplement Modifications* April 2015* StartedDevelop Training Plan April 2014 CompleteImplement Training September 2014 StartedIssue FLEX Support Guidelines and September 2014 StartedAssociated Procedure RevisionsDevelop Strategies/Contract withNational SAFER Response Center August 2014 Started(NSRC)Purchase Equipment February 2014 CompleteReceive Equipment August 2014 CompleteValidation Walk-throughs orDemonstrations of FLEX Strategies August 2014 Started September 2014*and ProceduresCreate Maintenance Procedures* August 2014 CompleteUnit 1 Outage Implementation April 2015 StartedUnit 2 Outage Implementation October 2014 Started* Refer to Section 8, Supplemental Information, for an explanation of the change to thisMilestone.4 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at NAPS Units 1 and 2 as required by Order Number EA-12-049, datedMarch 12, 2012. The first and second Six-Month Status Report of the OIP for NAPS wereprovided by letters dated August 23, 2013 (Reference 11) and February 28, 2014 (Reference13), respectively. The following are changes to the compliance method information provided inthe NAPS OIP and subsequent updates, which continues to meet NEI 12-06 (Reference 3):a) Dominion no longer plans to pre-stage the 120/240 VAC DGs in the Unit 1 and Unit 2alleyways. The deployment strategy for the portable 120/240VAC diesel generators (DGs)used to re-power the vital bus circuits has been changed back to the original electrical re-powering strategy, described in Section F1.2 -PWR Portable Equipment Phase 2 of theOIP submitted on February 28, 2013 (Reference 1) with the exception that the DGs aresized for a single generator per unit.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 3 of 31b) Regarding the previously reported strategy for Modes 5 & 6, credit was taken for theRefueling Water Storage Tanks (RWSTs) to provide a borated water source for injectioninto the RCS. Although the RWSTs are not missile protected, credit as a borated watersource was based on the assumption that it was improbable that both tanks would bedestroyed by a single tornado. Subsequently, the strategy has been enhanced to addressthe scenario that both RWSTs are unavailable. The revised strategy includes the provisionto utilize clean water sources onsite (which are protected from a tornado), if both RWSTsare unavailable. If a clean water source is used, flow must be controlled in order to matchthe rate of water loss (due to boiling) so that dilution of the boron concentration in the RCSdoes not occur.c) Based on a study that included a chemical analysis of the various water sources onsite, thepreferred order of clean water sources for use in both the primary and secondary sides ofthe Nuclear Steam Supply System (NSSS) was revised.d) Dominion is pursuing an alternate means of compliance to NEI 12-06, Section 3.2.2,regarding additional "spare" cables and hoses. Typically, the hoses utilized to implement aFLEX strategy are not a single continuous hose, but are composed of individual sections ofa smaller length joined together to form a sufficient length. In the case of cables, multipleindividual lengths of cable are used to construct a circuit.Hoses and cables are passive devices, which are unlikely to fail provided they areappropriately inspected and maintained. The most likely cause of failure is mechanicaldamage during handling provided that the hoses and cables are stored in areas withsuitable environmental conditions. The hoses and cables for the FLEX strategies will bestored and maintained in accordance with manufacturers' recommendations including anyshelf life requirements. Initial inspections and periodic inspections or testing/replacementwill be incorporated into the site's maintenance and testing program and implemented inaccordance with Section 11.5 of NEI 12-06.The industry has proposed for NRC Staff consideration alternate methods of compliance tothe N+1 requirement applicable to hoses and cables, as stated in Section 3.2.2 of NEI 12-06. Dominion supports this industry proposal and has adopted the agreed upon method forhoses in that 10% of the total length and at least one of the longest single lengths for eachhose size has been purchased. With regard to cables, the 120/240VAC generators and the480VAC generators are backups to each other, therefore, only N sets of cables arerequired. Therefore, once NRC endorsement of this alternate approach is complete,Dominion will have achieved alternate compliance with the NEI 12-06 N+1 requirement forhoses.e) The structural integrity of the reactor Containment building will not be challenged due toincreasing Containment pressure during a BDB Extended Loss of AC Power (ELAP) event.Additionally, analysis has shown that any increase in temperature following an ELAP eventdoes not challenge the key parameter instrumentation in the Containment for at least 7days.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 4 of 31Multiple Containment cooling methods described in previous submittals are available asoptions for heat removal to maintain Containment temperature for equipment design limits.However, they are not required to be specifically designated as primary and alternatestrategies. Adequate time is available utilizing equipment from the NSRC to deploy thecooling methods described.f) The BDB and NSRC equipment details in OIP Table 1, PWR Portable Equipment Phase 2,and OIP Table 2, PWR Portable Equipment Phase 3, respectively, have changed. Updatesto the 'List Portable Equipment' and 'Performance Criteria' are included as well asassociated changes/deletions in footnotes. Changes to the number of components havebeen included for some of the support equipment categories, but no changes have beenmade to the quantities of any of the major FLEX components. Revised OIP Tables 1 and 2are attached.5 Need for Relief/Relaxation and Basis for the RelieflRelaxationDominion expects to comply with the order implementation date and no relief/relaxation isrequired at this time.6 Open ItemsThe NRC has established an audit process to allow the exchange of information between thelicensees and the NRC Staff (Reference 19). Between May 19, 2014 and May 22, 2014, NorthAnna Units 1 and 2 were the subject of an NRC onsite audit where the site specific aspects ofDominion's proposed FLEX Mitigating Strategies were reviewed. During this NRC onsite audit,the staff reviewed site specific documentation and upon completion of the audit, indicated thatfurther review of several items was not anticipated as Dominion proceeds towards compliancefor Orders EA-12-049 and EA-12-051. These items are identified in the following tables inSection 6. Note that the tables provided in Sections 6.4 and 6.5 are new and are the result ofthe ongoing audit process.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 5 of 316.1. Open Items from Overall Integrated PlanThe following table provides a summary of the status of Open Items (01) identified byDominion and documented in Attachment 2B of the NAPS Overall Integrated Plan submittedFebruary 28, 2013 and the status of each item.Overall Integrated Plan Open Items01 # Description StatusVerify response times listed in timeline and perform staffing Complete.assessment. (Reference 20)During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.Preliminary analyses have been performed to determine the time Complete.to steam generator overfill without operator action to reduce AFW2 flow, time to steam generator dryout without AFW flow, and time (Reference 4)to depletion of the useable volume of the ECST. The finaldurations will be provided when the analyses are completed.Preliminary analyses have been performed to determine the Complete.Class 1 E battery life based on implementation of load stripping (Reference 4)actions. The final battery life duration will be provided when theanalyses are completed. During the May 2014NRC Onsite Audit, theNRC Staff indicated that3 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 6 of 31Overall Integrated Plan Open Items01 # Description StatusThe Phase 3 coping strategy to maintain Containment integrity is Complete.under development. Methods to monitor and evaluate (Reference 13)Containment conditions and depressurize/cool Containment, ifnecessary, will be provided in a future update. During the May 2014NRC Onsite Audit, theNRC Staff indicated that4 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.Analyses will be performed to develop fluid components Complete.performance requirements and confirm fluid hydraulic-relatedstrategy objectives can be met. Hydraulic calculations forthe FLEX pumpsdeployed using theirassociated hose networkshave confirmed that thecore cooling/decay heatremoval, RCS inventory,and reactivity control(RCS Injection), and SFPmake-up strategies can5 be satisfactorilyaccomplished inresponse to anELAP/Loss of UltimateHeat Sink (LUHS) event.(References 6 and 7)Hydraulic calculationshave confirmed that theSW flows forContainment coolingoptions are adequate.(Reference 14).

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 7 of 31Overall Integrated Plan Open ItemsOI # [Description jStatusA study is in progress to determine the design features, sitelocation(s), and number of equipment storage facilities. The finaldesign for BDB equipment storage will be based on the guidancecontained in NEI 12-06, Section 11.3, Equipment Storage. Asupplement to this submittal will be provided with the results ofthe equipment storage study.Complete.6A single 10,000 sq. ft.Type 1 building is beingconstructed at NAPS forstorage of BDBequipment. The buildingis designed to meet theplant's design basis forthe Safe ShutdownEarthquake, high windhazards, snow, ice andcold conditions, and willbe located above theflood elevation from themost recent site floodinganalysis. The BDBStorage Building will besited in the OwnerControlled Area in theparking lot west ofWarehouse #5. Thisupdate provides thesupplemental informationreferred to in this openitem. (Reference 21)During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.FLEX Support Guidelines (FSGs) will be developed in Started.accordance with PWROG guidance. Existing procedures will berevised as necessary to implement FSGs. Scheduled completionI_ _ date: September 2014 Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 8 of 31Overall Integrated Plan Open Items01 # I Description StatusEPRI guidance documents will be used to develop periodictesting and preventative maintenance procedures for BDBequipment. Procedures will be developed to manageunavailability of equipment such that risk to mitigating strategycapability is minimized.Complete.(Reference 22)8EPRI guidancedocuments have beenused, where available, todevelop the testing andpreventative maintenancestrategies for the sites.Fleet-wide templateshave been developed andinput into the individualsite maintenancestrategies. SpecificPeriodic Maintenance(PM) procedures basedon these strategies will beimplemented prior to therequired North Annacompliance date forOrder EA-12-049.A fleet-wide FLEXStrategy ProgramDocument has beendeveloped (Refer to OpenItem 9). The programincludes the requirementto manage unavailabilityof equipment such thatrisk to mitigating strategycapability is minimized. Afleet-wide procedure hasbeen developed tospecifically addressequipment unavailability.An overall program document will be developed to maintain theFLEX strategies and their bases and provide configuration controland change management for the FLEX Program.Complete.(Reference 23)9During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 and Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 9 of 31Overall Integrated Plan Open ItemsOI # Description StatusEA-1 2-051.The Dominion Nuclear Training Program will be revised to assure Complete.personnel proficiency in the mitigation of BDB events isdeveloped and maintained. These programs and controls will be Documentation of the Job10 developed and implemented in accordance with the Systematic Analysis performed forApproach to Training (SAT). new operational taskshas been provided via theongoing NRC auditprocess. (Reference 19)Complete the evaluation of TDAFW pump long term operation Complete.with < 290 psig inlet steam pressure.TDAFW pump operation11 and adequate AFW flowto the SGs at SGpressures < 290 psig hasbeen confirmed.(Reference 5)Plant modifications will be completed for permanent plant Started.changes required for implementation of FLEX strategies.12 Scheduled completiondate: See MilestoneSchedule above.Details of the ventilation strategy are under development and will Complete.13 conform to the guidance given in NEI 12-06. The details of thisstrategy will be provided at a later date. (Reference 13)Complete installation of N-9000 RCP seals in 2 of 3 RCPs in Started.each unit.14 Scheduled completiondate:April 2015 (Unit 1)Oct 2014 (Unit 2)Analyses will be performed to develop electrical components Complete.performance requirements and confirm electrical loading-relatedstrategy objectives can be met. Final calculationsconfirming the sizing andloading analysis of the120VAC, 480VAC, and4KV generators confirm15 the electrical loading-related strategyobjectives can be met arecomplete (References 16,17, & 18).During the May 2014NRC Onsite Audit, theNRC Staff indicated that Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 10 of 31Overall Integrated Plan Open Items01 # Description Statusfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.An evaluation of all BDB equipment fuel consumption and Complete.required re-fill strategies will be developed. (Reference 21)During the May 2014NRC Onsite Audit, theNRC Staff indicated that16 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.A lighting study will be performed to validate the adequacy of Complete.supplemental lighting and the adequacy and practicality of using (Reference 21)portable lighting to perform FLEX strategy actions.During the May 2014NRC Onsite Audit, theNRC Staff indicated that17 further review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.A comprehensive study of communication capabilities is being Complete.performed in accordance with the commitments made inDominion letter S/N 12-207F dated October 29, 2012 in response A study documenting theto Recommendation 9.3 of the 10 CFR 50.54(f) letter dated communications strategyMarch 12, 2012. The results of this study will identify the has been completed.communication means available or needed to implement The plan concludes thatcommand and control of the FLEX strategies at NAPS. FLEX strategies can be18 Validation of communications required to implement FLEX effectively implementedstrategies will be performed as part of Open Item No. 1. with a combination ofsound powered phones,satellite phones andhand-held radios.(Reference 10)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 11 of 31Overall Integrated Plan Open Items01 # Description StatusDuring the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051. +Preferred travel pathways will be determined using the guidancecontained in NEI 12-06. The pathways will attempt to avoidareas with trees, power lines, and other potential obstructionsand will consider the potential for soil liquefaction.19Complete.The soil liquefaction studyhas been completed(Reference 8), whichsupports the location ofthe storage building andthe haul routes. Theresults will be includedwith the final designpackage for the storagebuilding (Reference 9).During the May 2014NRC Onsite Audit, theNRC Staff indicated thatfurther review of thisitem was notanticipated asDominion proceedstowards compliance forOrders EA-12-049 andEA-1 2-051.20 The equipment listed in Table 1 will be received on site. Complete.6.2. Open Items from the Interim Staff Evaluation (ISE)The following table provides a summary of the Open Items (01) from the NAPS Interim StaffEvaluation (Reference 12) and the current status of each item.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 12 of 31Interim Staff Evaluation Open Items01 # Description Status3.2.1.2.B Demonstration of the acceptability of the use the Flowserve This ISE 01 is beingN-9000 seals with the abeyance feature and validation of an addressed through theacceptable leakage rate for these seals. ongoing NRC auditprocess. (Generic)(Reference 19)3.2.1.8.A The Pressurized-Water Reactor Owners Group (PWROG) During the May 2014submitted to NRC a position paper, dated August 15, 2013 NRC Onsite Audit, the(ADAMS Accession No. ML13235A135 (non-public for NRC Staff indicatedproprietary reasons)), which provides test data regarding that further review ofboric acid mixing under single-phase natural circulation this item was notconditions and outlined applicability conditions intended to anticipated asensure that boric acid addition and mixing would occur under Dominion proceedsconditions similar to those for which boric acid mixing data is towards complianceavailable. During the audit process, the licensee informed the for Orders EA-12-049NRC staff that its boric acid mixing model is based on the and EA-12-051.PWROG method. Since the audit discussions, the NRC (References 19 and 21)endorsed the PWROG guidance with several clarifications inletter dated January 8, 2014. The licensee should addressthe clarifications in alignment with the NRC endorsementletter for the development of an adequate model fordetermining the mixing of boric acid in the reactor coolantsystem during natural circulation with the potential for two-_ _ phase flow conditions.6.3. Confirmatory Items from Interim Staff Evaluation (ISE)The following table provides a summary of the Confirmatory Items (CI) from the NAPS InterimStaff Evaluation (Reference 12) and the current status of each item.Interim Staff Evaluation Confirmatory ItemsCI # Description Status3.1.1. 1.A Storage & Protection of FLEX equipment -Confirm final During the May 2014design of FLEX storage structure conforms to NEI 12-06, NRC Onsite Audit, theSections 5.3.1, 6.2.3.1, 7.3.1, and 8.3.1 for storage NRC Staff indicatedconsiderations for the hazards applicable to North Anna. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 13 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.1.1.3.A Procedural Interface Considerations (Seismic) -Confirm FLEX During the May 2014support guideline to provide operators with direction on how to NRC Onsite Audit, theestablish alternate monitoring and control capabilities. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 24)3.1.1.4.A Off-Site Resources -Confirm RRC local staging area, This ISE Cl is beingevaluation of access routes, and method of transportation to addressed through thethe site. ongoing NRC auditprocess. (Reference 19)3.1.5.2.A In the Integrated Plan, the licensee did not address During the May 2014considerations for any manual actions required by plant NRC Onsite Audit, thepersonnel in high temperature conditions as recommended in NRC Staff indicatedNEI 12-06, Section 9.3.2. Discuss effects of high that further review oftemperatures on any manual action performed by plant this item was notpersonnel and any applicable contingencies and any related anticipated asprocedural changes or enhancements. Dominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)3.2.1.1 .A Confirm that the use of NOTRUMP code for the ELAP analysis This ISE Cl is beingof North Anna is limited to the flow conditions before reflux addressed through thecondensation initiates, including specification of an acceptable ongoing NRC auditdefinition for reflux condensation cooling, process.(Generic)(Reference 21)3.2.1.1.B Confirmation that the generic analysis in Section 5.2.1 of This ISE Cl is beingWCAP-17601-P is applicable or bounding with respect to addressed through theNorth Anna for an appropriate figure of merit for defining entry ongoing NRC auditinto the reflux condensation cooling mode. process.I __ (References 19 and 29)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 14 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.2.1.1.C Confirm the consistency of the margin imposed to prevent During the May 2014accumulator nitrogen injection with the cooldown terminus NRC Onsite Audit, theassumed in WCAP-1 7601-P. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 25)3.2.1.2.C Confirm that stresses resulting from a cooldown of the RCS During the May 2014will not result in the failure of seal materials. NRC Onsite Audit, theAs applicable, confirm that reestablishing cooling to the seals NRC Staff indicatedwill not result in increased leakage due to thermal shock. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(References 25 and 26)3.2.1.6.A Sequence of Events -Confirm that the final timeline has been This ISE Cl is beingtime validated after detailed designs are completed and addressed through theprocedures are developed. The results will be provided in a ongoing NRC auditfuture 6-month update. process.(Reference 19)3.2.1.8.B Complete calculations demonstrating adequate shutdown During the May 2014margin for North Anna in ELAP scenarios with and without NRC Onsite Audit, theseal leakage. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 15 of 31Interim Staff Evaluation Confirmatory 'ItemsCI # Description Status3.2.1.8.C Confirm that shutdown margin calculations will be verified to During the May 2014remain bounding for future operating cycles and clarify the NRC Onsite Audit, themethod that will be used to make this determination. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 19)3.2.1.9.A Confirm that the licensee provides sufficient BDB RCS During the May 2014Injections Pumps to conform to the spare capability (N+1) NRC Onsite Audit, theguidance of NEI 12-06, Section 3.2.2. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.1.9.B Confirm that calculations documenting the AFW supply, SFP During the May 2014makeup, and RCS inventory hydraulic analysis demonstrate NRC Onsite Audit, thethe pumps have adequate capacity for the strategies they NRC Staff indicatedsupport. that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(References 6, 7, and14)3.2.2.A SFP venting -Confirm that opening of the roll-up doors would This ISE Cl is beingprovide an adequate ventilation path for the SFP area. addressed through theongoing NRC auditprocess. (Reference 19)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 16 of 31Interim Staff Evaluation Confirmatory ItemsCl # Description Status3.2.3.A Containment -Confirm Containment analysis to determine During the May 2014any Containment temperature and pressure actions beyond NRC Onsite Audit, theseven days. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(References 13 and 21)3.2.4.2.A Ventilation -Equipment Cooling -Confirm development of the This ISE Cl is beingventilation strategy. addressed through theongoing NRC auditprocess. (References 13,19, and 21)3.2.4.2.B Confirm the adequacy of the battery room ventilation provided During the May 2014in the context of an ELAP. NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.4.4.A Verify the lighting study validates the adequacy of During the May 2014supplemental lighting and the adequacy and practicality of NRC Onsite Audit, theusing portable lighting to perform FLEX strategy actions. NRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)3.2.4.4.B Communications -Confirm the licensee's proposed This ISE CI is beingenhancements and interim measures to the site's addressed through thecommunications systems and that they have been ongoing NRC auditcompleted. process.I_ (References 10 and 19)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 17 of 31Interim Staff Evaluation Confirmatory ItemsCI # Description Status3.2.4.8.A Electrical Power Sources -Confirm load calculations for the This ISE Cl is beingphase 2 and 3 FLEX generators will support supplied loads, addressed through theongoing NRC auditprocess.(References 16, 17, 18,and 19)3.2.4.9.A Fuel Supplies -Confirm the adequacy of the fuel consumption During the May 2014evaluation. Confirm that the procedural guidance governing NRC Onsite Audit, there-fueling strategies addresses: (a) how the quality of the fuel NRC Staff indicatedoil and gasoline supplies will be controlled in order to ensure that further review ofproper diesel or gasoline-powered FLEX equipment operation, this item was not(b) available sources of gasoline and how those sources will anticipated asbe protected to ensure availability following a BDB event, and Dominion proceeds(c) if the onsite fuel capacity provides an indefinite supply of towards compliancefuel or if the RRC is capable of providing an indefinite, ongoing for Orders EA-12-049supply of fuel (both diesel and gasoline), and EA-12-051.(Reference 21)3.4.A Confirm the implementation of considerations 2 through 10 in This ISE CI is beingNEI 12-06, Section 12.2. addressed through theongoing NRC auditprocess.(Reference 19)6.4. Audit Question Reviewed During NAPS Onsite AuditVarious NAPS Audit Questions (AQs) were evaluated during the NAPS NRC Onsite Audit. Thefollowing AQs were evaluated and remained "Open".Audit Provide the direct current (dc) load profile with the required This AQ is beingQuestion loads for the mitigating strategies to maintain core cooling, addressed through the#43 containment, and spent fuel pool cooling, ongoing NRC auditprocess.(Reference 19)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 18 of 316.5. Additional Items Reviewed During NAPS Onsite AuditThe following table provides a list of the additional Safety Evaluationidentified and evaluated during the NAPS NRC Onsite Audit and the(SE) Review itemsstatus of each item.Safety Feb 2014 Update Section 4a. Portable 120/240VAC DG will During the May 2014Evaluation now be pre-staged. NRC Onsite Audit, theReview NRC Staff indicatedItem #1 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(See Section 4a.)Safety SW reservoir and lake are credited as indefinite source of During the May 2014Evaluation water. SW has a finite volume of water. Therefore, if the SW NRC Onsite Audit, theReview reservoir is used as a source for make-up flow, the SW NRC Staff indicatedItem #2 reservoir will eventually need make-up water from the lake. that further review ofThe licensee is not clear in stating whether the dam forming this item was notthe lake is seismically qualified or if a viable suction source anticipated ascan be maintained at the lake following a loss of the dam. Dominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 27)Safety 1. (RCS Venting) The generic analysis in WCAP-17601-P During the May 2014Evaluation strictly addressed ELAP coping time without consideration of NRC Onsite Audit, theReview the actions directed by a site's mitigating strategies. WCAP- NRC Staff indicatedItem #3 17792-P extends these analytical results through explicit that further review ofconsideration of mitigating strategies involving RCS makeup this item was notand boration. In support of the RCS makeup and boration anticipated asstrategies proposed therein, a generic recommendation is Dominion proceedsmade that PWRs vent the RCS while makeup is being towards complianceprovided. Please provide the following information in regard to for Orders EA-12-049this topic: a. Will the mitigating strategy include venting of the and EA-12-051.RCS? b. If so, please provide the following information: i. The (References 21 and 28)vent path to be used and the means for its opening andclosure. ii. The criteria for opening the vent path. iii. Thecriteria for closing the vent path. iv. Clarification as to whetherthe vent path could experience two-phase or single-phaseliquid flow during an ELAP. If two-phase or liquid flow is apossibility, please clarify whether the vent path is designed toensure isolation capability after relieving two-phase or liquidflow. If relief of two-phase or liquid flow is to be avoided,please discuss the availability of instrumentation or othermeans that would ensure that the vent path is isolated prior to Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 19 of 31departing from single-phase steam flow. vi. If a pressurizerPORV is to be used for RCS venting, please clarify whetherthe associated block valve would be available (or the timelineby which it could be repowered) in the case that the PORVwere to stick open. If applicable, please further explain whyopening the pressurizer PORV is justified under ELAPconditions if the associated block valve would not be available.vii. If a pressurizer PORV is to be used for RCS venting,please clarify whether FLEX RCS makeup pumps and FLEXsteam generator makeup pumps will both be available prior toopening the PORV. If they will not both be available, pleaseprovide justification. c. If RCS venting will not be used, pleaseprovide the following information: i. The expected RCStemperature and pressure after the necessary quantity ofborated makeup has been added to an unvented RCS. ii.Adequate justification that the potential impacts of unventedmakeup will not adversely affect the proposed mitigatingstrategy (e.g., FLEX pump discharge pressures will not bechallenged, plant will not reach water solid condition, adequateboric acid can be injected, increased RCS leakage will notadversely affect the integrated plan timeline, etc.).SafetyEvaluationReviewItem #42. (Westinghouse Standard RCP Seals: NSAL-14-1) OnFebruary 10, 2014, Westinghouse issued Nuclear SafetyAdvisory Letter (NSAL)-14-1, which informed licensees ofplants with standard Westinghouse RCP seals that 21 gpmmay not be a conservative leakage rate for ELAP analysis.This value had been previously used in the ELAP analysisreferenced by many Westinghouse PWRs, including thegeneric reference analysis in WCAP-17601-P. Therefore,please clarify whether the assumption of 21 gpm of sealleakage per RCP (at 550 degrees F, 2250 psia) remains validin light of the issues identified in NSAL-14-1. In so doing,please identify the specifics of the seal leak off line design and#1 seal faceplate material relative to the categories in NSAL-14-1 and identify the corresponding presumed leakage ratefrom NSAL-14-1 that is deemed applicable.This SE Review Item isbeing addressed throughthe ongoing NRC auditprocess.(Reference 19)

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 20 of 31SafetyEvaluationReviewItem #54. (RVLIS Measurement Principle) Please clarify whether thereactor vessel level instrumentation system (RVLIS) indicationprovides a measure of collapsed level that can be used withFigures 3.3-1 through 3.3-3 of WCAP-17792-P. If the RVLISsystem does not provide an indication of collapsed level, thenplease clarify how the required timing for RCS makeup will bedetermined and provide justification.During the May 2014NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 21)4 tSafetyEvaluationReviewItem #6(Timeline to reflux cooling) Please clarify whether proceduralguidance for the timing of providing makeup to the reactorcoolant system is based on analysis in WCAP-17792-P, pages3-10 through 3-16. If so, please further provide adequatejustification for basing the timing of primary makeup on theassumption that reactor coolant pump seal leakage rates thatare less than the maximum expected value under ELAPconditions will not increase.During the May 2014NRC Onsite Audit, theNRC Staff indicatedthat further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)Safety Please provide adequate basis that calculations performed During the May 2014Evaluation with the NOTRUMP code (e.g., those in WCAP-17601-P, NRC Onsite Audit, theReview WCAP-1 7792-P) are adequate to demonstrate that criteria NRC Staff indicatedItem #7 associated with the analysis of an ELAP event (e.g., that further review ofavoidance of reflux cooling, promotion of boric acid mixing) are this item was notsatisfied. NRC staff confirmatory analysis suggests that the anticipated asneed for implementing certain mitigating strategies for Dominion proceedsproviding core cooling and adequate shutdown margin may towards complianceoccur sooner than predicted in NOTRUMP simulations. for Orders EA-12-049and EA-12-051.(Reference 21)Safety Please provide adequate basis that, when considering mixing This SE Review Item isEvaluation time, there is sufficient flow capacity to support borated being addressed throughReview makeup to both units from a single RCS makeup pump taking the ongoing NRC auditItem #8 suction from a portable batching tank. process.(Reference 19)Safety Please provide a clearly labeled sketch or marked-up plant This SE Review Item isEvaluation drawing of the plan view of the SFP area, depicting the SFP being addressed throughReview inside dimensions, the planned locations/placement of the the ongoing NRC auditItem #9 primary and back-up SFP level sensor, and the proposed process.routing of the cables that will extend from these sensors (Reference 19)toward the location of the read-out/display device.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 21 of 31Safety Human factors questions addressed during walkdowns of plant During the May 2014Evaluation equipment as well as in discussion with personnel. NRC Onsite Audit, theReview NRC Staff indicatedItem #10 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-1 2-049and EA-12-051.(Reference 19)Safety Unprotected water sources in Modes 5 & 6 This SE Review Item isEvaluation being addressed throughReview the ongoing NRC auditItem #11 process.(See Section 4b andReferences 19 and 21)Safety Provide details on maintenance and testing and Storage of This SE Review Item isEvaluation 120v/480v pre-staged cables. being addressed throughReview the ongoing NRC auditItem #12 process.(Reference 19)Safety Provide discussion on evaluation of diesel powered equipment This SE Review Item isEvaluation exhaust regarding habitability of other areas, being addressed throughReview the ongoing NRC auditItem #13 process.(Reference 19)Safety When do we plan to deploy hoses in SFP prior to bulk boiling During the May 2014Evaluation to minimize exposure. NRC Onsite Audit, theReview NRC Staff indicatedItem #14 that further review ofthis item was notanticipated asDominion proceedstowards compliancefor Orders EA-12-049and EA-12-051.(Reference 21)Safety Walk-through of building access procedures, to include any This SE Review Item isEvaluation unique access control devices being addressed throughReview the ongoing NRC auditItem #15 process.(Reference 19)

Serial No. 14-394Docket Nos. 50-338/339Order EA-1 2-049Page 22 of 317 Potential Safety Evaluation ImpactsSection 6.5 provides a list of the additional Safety Evaluation (SE) Review items identified andevaluated during the NAPS NRC Onsite Audit and the status of each item.Additionally, Dominion is participating in the ongoing industry effort to develop guidance for theFinal Integrated Plan that will support NRC preparation of the Safety Evaluation documentingNAPS's compliance with Order EA-12-049. The format of the Final Integrated Plan isconsistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davismemorandum (ML14161A643)(Reference 15).8 Supplemental InformationThis supplemental information provides details of the changes identified in the status updatesabove and addresses a) Open Item 14, b) the Milestone Task 'Implement Modifications,' c) theMilestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies andProcedures' and d) the Milestone Task 'Create Maintenance Procedures' as follows:a) NAPS, Open Item 14: The revision to the status wording more accurately reflects thestatus for each North Anna Unit. The split completion schedule reflects the currentoutage schedules.b) NAPS, Milestone Task 'Implement Modifications': The revision separates Units 1and 2 to more accurately reflect the actual tasks as they will occur for each NAPS Unit.The updated completion schedules accurately reflect the current outage schedules.The revised Milestone Tasks and Completion Schedules are as follows:Milestone Task: Implement Unit 1 ModificationsCompletion Schedule: April 2015Milestone Task: Implement Unit 2 ModificationsCompletion Schedule: October 2014c) NAPS, Milestone Task 'Validation Walk-throuqhs or Demonstrations of FLEXStrategies and Procedures': The revision to the scheduled milestone targetcompletion date is needed to allow for completion of the walk-throughs, which are inprogress.d) NAPS, Milestone Task 'Create Maintenance Procedures': The Milestone is to berestated as 'Develop Maintenance Strategies." This change is to revise the currentmilestone to reflect the intended activity which was to develop the maintenancestrategies based on industry and vendor supplied information. As per the responseprovided above for Open Item 8, the restated task has been completed. The designchange implementing the FLEX Mitigating Strategies Program identifies themaintenance strategies required for the FLEX implementation and requires that PeriodicMaintenance (PM) procedures be developed. Submittal of requests for creation ofthese PMs is in accordance with the Design Control Program and will be tracked. ThePMs will be prioritized such that the near-term requirements, (e.g., 30 day walkdowninspections) are in-place prior to FLEX Mitigating Strategy implementation date. The Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 23 of 31PMs for the longer term requirements will be implemented prior to their firstperformance interval.9 ReferencesThe following references support the updates to the OIP described in this attachment and areavailable in ADAMS or have been provided to the staff for their review.1. "Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," datedFebruary 28, 2013 (Serial No. 12-162B).2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"Revision 0, dated August 2012.4. "Supplement to Overall Integrated Plan in Response to March 21, 2012 CommissionOrder Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis Events (Order Number EA-12-049)," dated April 30, 2013 (SerialNo. 12-162C).5. Dominion Calculation ME-0968, "Evaluation of the TDAFW Pump Performance at LowSteam Generator Pressures," August 2013.6. Dominion Calculation ME-0965, "Evaluate the BDB High Head Injection pump for BeyondDesign Basis (BDB) at the primary and alternative supply locations in Modes 1-4, and theBDB AFW Pump in Modes 5 and 6," Revision 0.7. Dominion Calculation ME-0966, "Beyond Design Basis (BDB) -BDB High Capacity Pumpand BDB AFW Pump Hydraulic Analysis for Spent Fuel Pool Makeup and AFW Injectionat NAPS Units 1 and 2," Revision 0.8. Geotechnical Engineering Report, "BDB FLEX Storage Building," North Anna PowerStation, Louisa, VA, Schnabel Reference #13613081, October 3, 2013, Addendum 1.9. Design Change NA-1 3-00016, "BDB Storage Building/ North Anna Power Station/ Units 1& 2."10. ETE-CPR-2013-0003, "Beyond Design Basis Communications Strategy/Plan," Rev. 111. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 23, 2013 (Serial No. 12-162D).12."North Anna Power Station, Units 1 and 2 -Interim Staff Evaluation Relating to OverallIntegrated Plan in Response to Order EA-12-049 (Mitigating Strategies)," dated January29, 2014.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 24 of 3113. "Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2014 (Serial No. 12-162E).14. Dominion Calculation ME-12126, "FLEX Beyond Design Basis (BDB) Service Water (SW)Containment Integrity Strategy Hydraulic Analysis," Rev 0.15. Memorandum from Jack R. Davis, JLD, Office of NRR, to Stewart N. Bailey, Sheena A,Whaley, and Jeremy S. Bowen, "Supplemental Staff Guidance for the Safety Evaluationsfor Order EA-12-049 on Mitigation Strategies for Beyond-Design-Basis External Eventsand Order EA-12-051 on Spent Fuel Pool Instrumentation," dated July 1, 2014(ML14161A643).16. Dominion Calculation EE-0863, "NAPS BDB FLEX Electrical 480 and 120 VAC SystemLoading Analysis," Rev. 1 (Unit 1).17. Dominion Calculation EE-0865, "NAPS BDB FLEX Electrical 480 and 120 VAC SystemLoading Analysis," Rev. 0 (Unit 2).18.Dominion Calculation EE-0871, "NAPS BDB FLEX Electrical 4160VAC System LoadingAnalysis," Rev. 0.19. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate to All OperatingReactor Licensees and Holders of Construction Permits, "Nuclear RegulatoryCommission Audits of Licensee Responses to Mitigating Strategies Order EA-12-049,"dated August 28, 2013 (ML13234A503).20. Dominion Letter to NRS titled "North Ann Power Station Units 1 and 2, March 12, 2012Information Request, Phase 2 Staffing Assessment Report," dated May 7, 2014 (SN:14-199)21. ETE-CPR-2012-0012, Rev. 4, "Beyond Design Basis -FLEX Strategy Overall IntegratedPlan Basis Document."22.Procedure CM-AA-BDB-102, "Beyond Design Basis FLEX Equipment UnavailabilityTracking."23. Procedure CM-AA-BDB-10, Beyond Design Basis FLEX Program.24. FSG-7, "Loss of Vital Instrumentation or Control Power."25. Procedure ECA-0.0, "Station Blackout."26. FlowServe document, "White Paper on the Response for the N-Seal Reactor CoolantPump (RCP) Seal Package to Extend Loss of AC Power (ELAP)," Rev. 0 dated February11, 2014 (Proprietary)27. North Anna Power Station Updated Final Safety Analysis Report (UFSAR), Section3.8.3.1.28. FSG-8, "Alternate RCS Boration."29. ETE-CPR-2012-0150, Rev. 1, Add. 0, "Core Cooling Evaluation for Dominion Fleet andPrepared Input for Response to Order EA-1 2-049."

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 25 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance IList Portable PreventiveEquipment Core Containment SEP Instrumentation Accessibility MaintenanceRequirementsBDB HighCapacity diesel- Will follow EPRIdriven pump (2)6 X X X 1200 gpm @ templateand assoc. hoses 150 psid requirementsand fittingsBDB AFW pump 300 gpm @ Will follow EPRI(3) and assoc. X templatehoses and fittings 500 psid requirementsBDB RCS Injection Will follow EPRIpump (2)5 and 45 gpm @ Wilateassoc. hoses and X 3000 psid templatefittings requirements120/240VACgenerators (3) 3 Will follow EPRIand associated X 40 kW templatecables, connectors requirementsand switchgear Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 26 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential! Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibilit MaintenanceRequirements120/240VACgenerators (8)2and associated Will follow EPRIcables, connectors X 5-6.5 kW templateand switchgear (to requirementspower supportequipment)480VACgenerators (2)3and associatedcables, connectors Will follow EPRIand switchgear (to X X 350 kW templatere-power battery requirementschargers,inverters, and VitalBuses)Portable boric acid Will follow EPRIbatching tank (2) X 1000 gal templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 27 of 31Table 1 -PWR Portable Equipment Phase 21Use and (Potential/ Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable Core Containment SFP Instrumentation Accessiblit PreventiveEquipment MaintenanceRequirementsWill follow EPRILight plants (2)2 X templaterequirementsFront end loader Will follow EPRI(1) 2 X templaterequirementsWill follow EPRITow vehicles (2) 2 X X X X templaterequirementsHose trailer (2) Will follow EPRIand Utility vehicle X X X X template(1)2 requirementsFans / blowers Will follow EPRI(10)2 X templaterequirementsAir compressors Will follow EPRI(6)2 X X templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 28 of 31Table I -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibility MaintenanceRequirementsFuel truck (1) with Will follow EPRI1,100 gal. tank X X X X X templateand pumps requirementsFuel carts with Will follow EPRItransfer pumps (2) X X X X X template2 requirementsCommunications Will follow EPRIequipmenti4 X X X X X templaterequirementsMisc. debris Will follow EPRIremoval X templateequipment 2 requirementsMisc. SWill follow EPRIEquipment 2 X templaterequirements Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 29 of 31Table I -PWR Portable Equipment Phase 21Use and (Potential / Flexibility) Diverse Uses Performance MaintenanceCriteriaMaintenance /List Portable PreventiveEquipment Core Containment SFP Instrumentation Accessibilit MaintenanceRequirementsNOTES:1. This table is based on one BDB Storage Building.2. Support equipment. Not required to meet N+1.3. 480VAC generators are an alternate strategy to the 120/240VAC generators. Therefore, only N is required.4. Quantities are identified in ETE-CPR-2013-0003 that was developed in response to the results of thecommunications study performed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.5. One BDB RCS Injection pump can be shared between units if necessary. A BDB RCS Injection pump from theRRC will be deployed from the RRC by 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, if required, to replace an inoperable on-site BDB RCSInjection pump.6. One BDB High Capacity pump is needed to implement the FLEX core and SFP cooling strategies. This pumpis stored in the Type 1 BDB Storage Building and protected from hazards. The 50.54(hh)(2) high capacitypump is credited to meet the N+1 requirement as a backup to the BDB High Capacity pump. This pump isstored onsite in a location other than the BDB Storage Building.

Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 30 of 31Table 2 -PWR Portable Equipment Phase 3Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance NotesList Quantity Quantity Power Core Cont. Access Instrumentation. RCS PreventativePortable Req'd Provided Cooling Cooling/ Inventory MaintenanceEquipment /Unit I Unit Integrity RequiredMedium Jet PerformedVoltage 2 3 Turb. X X X 4.16 KV 1 MW by RRC (1)GeneratorsLow Jet PerformedVoltage 0 1 Turb X X X 480VAC 1100 KW by RRC (2)Generators T bRCHighPressure 1 Diesel 3000# 60 GPM (2)Injection by RRCPumpS/G RPV PerformedMakeup 0 1 Diesel X X 500# 500 GPM by RRC (2)PumpLowPressure 2500 PerformedMedium Diesel X X 300# GPM by RRC (2)Flow PumpLowPressure / 5000 PerformedHigh Flow Diesel X X 150# GPM by RRC (3)Pump _.__ _ ..._"Lighting 0 1 Diesel X 40,000 Lu Performed (4)Towers by RRC Serial No. 14-394Docket Nos. 50-338/339Order EA-12-049Page 31 of 31Table 2 -PWR Portable Equipment Phase 3Use and (Potential I Flexibility) Diverse Uses Performance Criteria Maintenance NotesList Quantity Quantity Power Core Cont. Access Instrumentation. RCS PreventativePortable Req'd Provided Cooling Cooling/ Inventory MaintenanceEquipment /Unit I Unit Integrity RequiredDiesel Fuel 0 AR N/A X X X X X 500 Gal Performed (2)Transfer by RRCMobile Performed (2)Water 0 2 Diesel X X 150 GPMTretmntby RRC (5)Treatment ., .. .MobileBoration 0 1 N/A X 1000 Gal Performed (2)Skid*. .by RRCSkid , Note 1 -RRC 4KV generator supplied in support of Phase 3 for Core Cooling, Containment Cooling, and Instrumentation FLEX Strategies. (Includes adistribution panel and sufficient cables for connection to site 4kV buses.)Note 2 -RRC Generic Equipment -Not required for FLEX Strategy -Provided as Defense-in-Depth.Note 3 -RRC Low Pressure / High Flow pump supplied in support of Phase 3 for Core Cooling and Containment Cooling FLEX Strategies.Note 4 -RRC components provided for low light response plans.Note 5 -Usage dependent on Westinghouse Water Quality Study results.