RS-17-001, Peach Bottom Atomic Power Station, Unit 2 - Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12: Difference between revisions

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#REDIRECT [[RS-17-001, Report of Full Compliance with 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)]]
| number = ML17006A167
| issue date = 01/06/2017
| title = Peach Bottom Atomic Power Station, Unit 2 - Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-
| author name = Barstow J
| author affiliation = Exelon Generation Co, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000277
| license number = DPR-044
| contact person =
| case reference number = EA-12-049, RS-17-001
| document type = Letter type:RS, Licensee Response to Enforcement Action
| page count = 10
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:Exelon Generation
(<, RS-17-001 January 6, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277 Order No. EA-12-049
 
==Subject:==
Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)  
 
==References:==
: 1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," dated March 12, 2012 2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision O, dated August 29, 2012 3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012 5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-024)
: 6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August28, 2013 (RS-13-127)
: 7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2014 (RS-14-014)
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page2 8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 (RS-14-212)
: 9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2015 (RS-15-023) 1 O. Exelon Generation Company, LLC Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2015 (RS-15-214)
: 11. Exelon Generation Company, LLC Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2016 ( RS-16-026)
: 12. Exelon Generation Company, LLC Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 26, 2016 (RS-16-149)
: 13. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049, (Mitigation Strategies) (TAC Nos. MF0845 and MF0846), dated November 22, 2013 14. NRC Letter, Request for Information Pursuant to Title 1 O of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 15. Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Pursuant to Title 1 O of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness
-Staffing, Requested Information Items 1, 2, and 6 -Phase 2 Staffing Assessment, dated May 8, 2015 (RS-15-114)
: 16. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 -Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0845, MF0846, MF0849, MF0850), dated September 23, 2015 On March 12, 2012, the Nuclear Regulatory Commission
("NRC" or "Commission")
issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference
: 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference
: 1.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 3 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference
: 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision O (Reference
: 3) with clarifications and exceptions identified in Reference
: 2. Reference 4 provided the EGC initial status report regarding mitigation strategies.
Reference 5 provided the Peach Bottom Atomic Power Station, Unit 2 OIP. Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 6, 7, 8, 9, 10, 11, and 12 provided the first, second, third, fourth, fifth, sixth, and seventh six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Peach Bottom Atomic Power Station, Unit 2. The purpose of this letter is to provide the report of full compliance with the 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) (Reference
: 1) pursuant to Section IV, Condition C.3 of the Order for Peach Bottom Atomic Power Station, Unit 2. Peach Bottom Atomic Power Station, Unit 2 has developed, implemented, and will maintain the guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event in response to Order EA-12-049.
The information provided herein documents full compliance for Peach Bottom Atomic Power Station, Unit 2 with Reference
: 1. OIP open items have been addressed and closed as documented in References 6, 7, 8, 9, 10, 11, and 12, and are considered complete pending NRC closure. EGC's response to the NRC Interim Staff Evaluation (ISE) open and confirmatory items identified in Reference 13 have been addressed and closed as documented in References 7, 8, 9, 10, 11, and 12, and below, and are considered closed as documented in Reference
: 16. EGC's response to the NRC ISE confirmatory items identified as open in Reference 16 are addressed in Reference 12, and below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in References 6, 10, and 12, and are considered complete pending NRC closure. The following tables provide completion references for each OIP open item and NRC ISE open or confirmatory item, and NRC Audit Report open items. Overall Integrated Plan Open Items Section Reference Overall Integrated Plan Open Item Completion Response Reference Multiple Sections Item 1) Transportation routes will be developed Reference 11 from the equipment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation.
The location of the storage areas, identification of the travel oaths and U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 4 Section Reference Overall Integrated Plan Open Item creation of the administrative program are open items. Programmatic Controls Item 2) An administrative program for FLEX to (p. 7) establish responsibilities, testing and maintenance requirements will be implemented.
Describe Training Plan Item 3) Training materials for FLEX will be (p. 8) developed for all station staff involved in implementino FLEX strategies.
Maintain Spent Fuel Pool Item 4) Complete an evaluation of the spent fuel Cooling (p. 30) pool area for steam and condensation to determine vent path strategy requirements.
Safety Function Support Item 5) RCIC room temperature analysis is still (p. 38) in proqress.
Safety Function Support Item 6} Evaluate the habitability of the Main (p.38) Control Room and develop a strategy to maintain habitability.
Safety Function Support Item 7) Develop a procedure to prop open (p. 38} battery room doors and utilize portable fans or utilize installed room supply and exhaust fans upon energizing the battery chargers to prevent a buildup of hvdrooen in the battery rooms. Sequence of Events Item 8) Timeline walk through will be completed (p. 4) for the FLEX generator installations when the detailed design and site strategy is finalized.
The final timeline will be validated once the detailed designs are developed.
Sequence of Events Item 9) Timeline walk through will be completed (p. 4) for the FLEX pump installations when the detailed design and site strategy is finalized.
The final timeline will be validated once the detailed designs are developed.
The results will be provided in a future 6-month update. Sequence of Events Item 10) Additional analysis will be performed (p. 5) during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throuQhout the event. Sequence of Events Item 11) Analysis of deviations between (p. 5) Exelon's engineering analyses and the analyses contained in BWROG Document NEDC-33771 P, "GEH Evaluation of FLEX Implementation Guidelines and documentation of results on Att. 18, "NSSS SiQnificant Completion Response Reference Reference 11 Reference 1 O Reference 1 O Reference 11 Reference 1 O Reference 1 O Reference 11 Reference 1 O Reference 11 Reference 1 o U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 5 Section Reference Overall Integrated Plan Open Item Completion Response Reference Reference Analysis Deviation Table." Planned to be completed and submitted with August 2013 Six Month Update. Safety Function Support Item 12) Evaluate the effect of additional load Reference 11 (p. 38) shed on the battery coping time. Interim Staff Evaluation Open Items Open Item Completion Response Reference Item No. 3.2.3.A Reference 1 O Item No. 3.2.4.3.A Reference 1 O Item No. 3.2.4.4.A Reference 1 O Item No. 3.2.4.5.A Reference 1 O Interim Staff Evaluation Confirmatory Items Open Item Completion Response Reference Item No. 3.1.1 .1.A Reference 12 Item No. 3.1.1.2.A Reference 11 Item No. 3.1.1.2.C Reference 1 O Item No. 3.1.1.3.A Reference 1 O Item No. 3.1.1.3.B Reference 1 O Item No. 3.1.1.4.A Reference 11 Item No. 3.1.2.A Reference 12 Item No. 3.1.2.1.A Reference 11 Item No. 3.1.2.2.A Reference 1 O Item No. 3.1.3.2.A Reference 1 O Item No. 3.1.4.2.A Reference 11 Item No. 3.2.1.1 .A Reference 1 O Item No. 3.2.1.1.B Reference 1 O Item No. 3.2.1.1.C Reference 1 O Item No. 3.2.1.1.D Reference 1 O Item No. 3.2.1.1.E Reference 1 O Item No. 3.2.1.2.A Reference 1 O Item No. 3.2.1.4.A Reference 12 Item No. 3.2.1.4.B Reference 11 Item No. 3.2.1.4.C Reference 11 Item No. 3.2.1.4.D Reference 1 O Item No. 3.2.2.A Reference 10 Item No. 3.2.4.2.A Reference 11 U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 6 Open Item Completion Response Reference Item No. 3.2.4.2.B Reference 1 O Item No. 3.2.4.4.B Reference 12 and updated with this submittal as provided below Item No. 3.2.4.6.A Reference 11 Item No. 3.2.4.7 .A Reference 1 O Item No. 3.2.4.8.A Reference 1 O Item No. 3.2.4.9.A Reference 1 O Item No. 3.4.A Reference 1 O Item No. 3.4.B Reference 1 O NRC Audit Report Open Items Audit O p en Item Com p letion Res p onse Reference ISE Cl 3.1.2.A Reference 12 ISE Cl 3.1.1.1.A Reference 12 ISE Cl 3.2.1.4.A Reference 12 ISE Cl 3.2.4.4.B Reference 12 and updated with this submittal as p rovided below AQ40 Reference 12 OIP.9 References 1 O and 12 OIP.11 References 6 and 12 SE.10 Reference 12 SE.12 Reference 12 The following table documents completion of the final remaining open items. As previously stated, EGC provides the response for the following items and considers them to be complete for Peach Bottom Atomic Power Station, Unit 2. Item Description Reference ISE Cl 3.2.4.4.B The PBAPS plan provides for the installation and Complete connection of EMNet Voice over IP (VoIP) phones C ommunications System and new network switches (Power over Ethernet Upgrades (PoE) capable) for the MCA to an existing Level 2 network. Four EMNet phone connections have been installed to re p lace Emen::i enc v Res p onse U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 7 Organization (ERO) hotlines, Nuclear Accident Reporting System (NARS) or dedicated ring downs in the MCA. These phones are located on the Control Room Supervisor's desk, the Plant Reactor Operator's desk with one each on the Unit 2 and Unit 3 Reactor Operators' desks. A network cable has been run to the MCR north office area that can be the location of the temporary TSC when the current TSC, Unit 1 control room, is unavailable.
The satellite system uses a fixed mount dish that is installed on the Radwaste building roof. This dish is reasonably protected from winds with mounting designed for 150 mph. The dish can survive winds up to 125 mph. If the permanently mounted dish is damaged during the event, a portable satellite dish is available for setup and use which is stored in the FLEX storage building which is protected.
In-plant communications utilizes a duplicate radio repeater system located inside of the Unit 3 reactor building with a deployable antenna to allow operators to use their radios for communication after a BDBEE. The plant radio "Talk Around" is adequate for line of sight communications and extra batteries and chargers are available and stored in the FLEX Robust Building.
Three portable satellite phones are available for offsite communications.
MILESTONE SCHEDULE -ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall lntearated Plan Februarv 28, 2013 Contract with National SAFER Response Center February 14, 2013 Submit 6 Month Updates: Update 1 August28,2013 Update 2 Februarv 28, 2014 Update 3 August 28, 2014 Update 4 February 27, 2015 Update 5 Auaust 28, 2015 Update 6 February 26, 2016 Update 7 August26,2016 Modification Development:
Phases 1 and 2 modifications November 11, 2016 National SAFER Response Center Operational September 30, 2014 Procedure Development:
Strateav procedures October 21, 2016 U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 8 Milestone Validate Procedures (NEI 12-06, Sect. 11.4.3) Maintenance procedures StaffinQ analysis Modification Implementation Phases 1 and 2 modifications StoraQe plan and construction FLEX equipment acquisition TraininQ completion Unit 2 implementation date Completion Date October 30, 2016 October 21, 2016 May 8, 2015 November 11, 2016 October 21, 2015 October 21 2015 October 14, 2015 November 10, 2016 ORDER EA-12-049 COMPLIANCE ELEMENTS
 
==SUMMARY==
The elements identified below for Peach Bottom Atomic Power Station, Unit 2 as well as the site OIP response submittal (Reference 5), the 6-Month Status Reports (References 6, 7, 8, 9, 10, 11, and 12), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.
Strategies
-Complete Peach Bottom Atomic Power Station, Unit 2 strategies are in compliance with Order EA-12-049.
There are no strategy related Open Items, Confirmatory Items, or Audit Questions/
Audit Report Open Items. The Peach Bottom Atomic Power Station, Units 2 and 3, Final Integrated Plan for mitigating strategies will be provided upon full compliance for Peach Bottom Atomic Power Station, Unit 3 (Fall 2017). Modifications
-Complete The modifications required to support the FLEX strategies for Peach Bottom Atomic Power Station, Unit 2 have been fully implemented in accordance with the station design control process. Equipment
-Procured and Maintenance
& Testing -Complete The equipment required to implement the FLEX strategies for Peach Bottom Atomic Power Station, Unit 2 has been procured in accordance with NEI 12-06, Sections 11.1 and 11.2, and has been received at Peach Bottom Atomic Power Station, Unit 2; and initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use. Periodic maintenance and testing will be conducted through the use of the Peach Bottom Atomic Power Station, Unit 2 Preventative Maintenance program such that equipment reliability is achieved.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 9 Protected Storage -Complete The storage facilities required to implement the FLEX strategies for Peach Bottom Atomic Power Station, Unit 2 have been completed and provide protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Peach Bottom Atomic Power Station, Unit 2 is stored in its protected configuration.
Procedures
-Complete FLEX Support Guidelines (FSGs) for Peach Bottom Atomic Power Station, Unit 2 have been developed and integrated with existing procedures.
The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program. Training -Complete Training for Peach Bottom Atomic Power Station, Unit 2 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6. Staffing -Complete The Phase 2 staffing study for Peach Bottom Atomic Power Station, Unit 2 has been completed in accordance with 1 OCFR50.54(f), "Request for Information Pursuant to Title 1 O of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 14), as documented in Reference
: 15. National SAFER Response Center -Complete EGC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination.
It has been confirmed that PEICo is ready to support Peach Bottom Atomic Power Station, Unit 2 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan. Validation
-Complete EGC has completed the performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) for Order EA-12-049.
FLEX Program Document -Established The Peach Bottom Atomic Power Station, Unit 2 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 January 6, 2017 Page 10 This letter contains no new regulatory commitments.
If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6 1 h day of January 2017. Respectfully submitted, cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator
-Region I NRC Senior Resident Inspector
-Peach Bottom Atomic Power Station NRC Project Manager, NRA -Peach Bottom Atomic Power Station Mr. Peter J. Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection
-Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R.R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection}}

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