ML14251A231

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

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

Text

Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Uponseparation of the Enclosure 2, this letter is decontrolled.

ITimothy S. Rausch PPL Susquehanna, LLC 0Senior Vice President

& Chief Nuclear Officer 769 Salem Boulevard

0Berwick, PA 18603Tel. 570.542.3345 Fax 570.542.1504 tsrausch@pplweb.com AUG 22014 PPTU. S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATIONTHIRD SIX-MONTH STATUS REPORT INRESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARDTO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (NRC ORDER EA-12-049)

PLA-7204Docket No. 50-387and No. 50-388

References:

1.NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-O1, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events, " Revision 0, dated August 29, 20123. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"Revision 0, dated August 20124. PPL Letter (PLA-6923),

"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 29, 20125. PPL Letter (PLA-6981),

"Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049),

" dated February 28, 20136. PPL Letter (PLA-7072),

"Request for Implementation Date Relief in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049),"

dated August 26, 20137. NRC Order EA-13-109, "Order to Modifv, Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation under Severe Accident Conditions,"

dated June 6, 20138. PPL Letter (PLA-7071),

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

dated August 26, 20139. PPL Letter (PLA-7134),

"Request for Relaxation front NRC Order EA-12-049,

'OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'"

dated February 20, 201410. NRC Letter from J. S. Bowen to T. S. Rausch, "Susquehanna Steam Electric

Station, Units Iand 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To OrderEA-12-049 (Mitigation Strategies)

(TAC NOS. MF0888 and MF0889),"

dated January 24, 2014(ADAMS # ML13339A764)

Enclosure 2 of the Attachment contains proprietary information.

Withhold from public disclosure under10CFR2.390(d)(1),

as other than Safeguards Information, and designated as Security Sensitive Information.

WhenEnclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.

Ip&p Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Uponseparation of the Enclosure 2, this letter is decontrolled. Document Control DeskPLA-720411. PPL Letter (PLA-7137),

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

" dated February 28, 201412. NRC Letterfroom E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and2 -Relaxation of Certain Schedule Requirements for Order EA-12-049

'Issuance of Order toModify Licenses with Regard to Requirements for Mitigation Strategies for Beyond DesignBasis External Events. "' dated April 15, 2014The purpose of this letter is to provide PPL Susquehanna, LLC's (PPL) third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. Enclosure 1 providesan update of milestone accomplishments since the last status report, including anychanges to the compliance method, schedule, or need for relief and the basis, if any.Enclosure 2 is a revision of the Mitigation Strategies Overall Integrated Plan that includesseveral updates.

The information provided in Enclosure 2 is considered to containinformation concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Information" as defined in 10 CFR2.390 (d)(1). Accordingly, PPL requests that the information provided in Enclosure 2 tothe letter be withheld from public disclosure.

On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to PPL. Reference 1 was immediately effective and directsPPL to develop, implement, and maintain guidance and strategies to maintain or restorecore cooling, containment

cooling, and spent fuel pool cooling capabilities in the event ofa beyond-design-basis external event. Specific requirements are outlined in Attachment 2of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance ofthe final interim staff guidance (Reference

2) and an overall integrated plan pursuant toSection IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06,Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2.Reference 4 provided PPL's initial status report regarding Mitigation Strategies.

Reference 5 provided PPL's initial Mitigation Strategies Overall Integrated Plan.Reference 1 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan. Reference 3 provides direction regarding thecontent of the status reports.The Request for Relaxation contained in Reference 9 supersedes the Request for Reliefmade in Reference

6. The Request for Relaxation is based on NRC mandated changes tothe Hardened Containment Vent System implementation dates that impact the Mitigation Strategy Overall Integrated Plan. Specifically, the change in implementation dates for theHardened Containment Vent Order (NRC Order EA-12-050 was rescinded andsuperseded by NRC Order EA-13-109) impacts the Mitigation Strategy OverallEnclosure 2 of the Attachment contains proprietary information.

Withhold from public disclosure under10CFR2.390(d)(1),

as other than Safeguards Information, and designated as Security Sensitive Information.

WhenEnclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.

Enclosure 2 of the Attachment contains Security-Related information and must be protected accordingly.

Uponseparation of the Enclosure 2, this letter is decontrolled. Document Control DeskPLA-7204Integrated Plan and implementation timeline.

The NRC approved this relaxation inReference 12.This letter contains no new or revised regulatory commitments.

If you have any questions regarding this report, please contact Mr. John L. Tripoli,Manager -Nuclear Regulatory

Affairs, at (570) 542-3100.

I declare under penalty of perjury that the foregoing is true and correct.ý-Iaý 11+Executed on:Sincerely, T. S. RauschEnclosure 1:Enclosure 2:PPL Susquehanna, LLC's Third Six Month Status Report for theImplementation of NRC Order EA- 12-049, Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External EventsPPL Susquehanna's Overall Integrated Plan in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049),

(August 2014) Security-Related Information

-Withhold from Public Disclosure Under 10 CFR 2.390Copy: NRC Region IMr. J. E. Greives, NRC Sr. Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRCMr. J. A. Whited, NRC Project ManagerMr. L. J. Winker, PA DEP/BRPEnclosure 2 of the Attachment contains proprietary information.

Withhold from public disclosure under10CFR2.390(d)(1),

as other than Safeguards Information, and designated as Security Sensitive Information.

WhenEnclosure 2 of the Attachment is separated, the remainder of the Attachment and this cover letter are decontrolled.

Enclosure 1 to PLA-7204PPL Susquehanna, LLC's Third Six MonthStatus Report for the Implementation of NRCOrder EA-12-049, Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents Enclosure 1 to PLA-7204Page 1 of 9PPL Susquehanna, LLC's Third Six Month Status Report for theImplementation of NRC Order EA-12-049, Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events1. Introduction PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan(Reference

1) documenting the diverse and flexible strategies (FLEX), inresponse to Reference

2. This Third Six Month Status Report provides anupdate of milestone accomplishments since submittal of the First Six MonthStatus Report (Reference

7) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.[NOTE: References cited in this enclosure are contained in Section 8.]2. Milestone Accomplishments The following milestone(s) have been completed since the development of theOverall Integrated Plan (Reference 1), and are current as of July 31, 2014." Open Items 1, 4, 7, 8, 9, 13 and 14 have been completed.

Numerous milestones have been started and are in progress as listed onthe Section 3, Milestone Schedule Status table, for example -Phase 2Staffing

Analysis, construction of the equipment storage building, modification installation, and training.

3. Milestone Schedule StatusThe following table provides an update to Attachment 2, Milestone

Schedule, of the Overall Integrated Plan. It provides the activity status of each item, andwhether the expected completion date has changed.

The dates are planningdates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the Orderimplementation date at this time. The Interim Staff Evaluation (ISE) from theNRC (Reference

9) has been received in time to support implementation of theMitigation Strategies.

The Open Item and Confirmatory Items identified in theISE will be addressed by the Regulatory Audit Process.

Enclosure 1 to PLA-7204Page 2 of 9RevisedTarget Activity TargetMilestone Completion Status Completion Date DateSubmit 60 Day Status Report October 2012 CompleteSubmit Overall Integrated February 2013 CompletePlanExpected receipt of draft SER September Complete January 2014from NRC (or ISE) 2013Submit 6 Month Updates:Update 1 August 2013 CompleteUpdate 2 February 2014 CompleteUpdate 3 August 2014 Complete*

Update 4 February 2015 Not StartedUpdate 5 August 2015 Not StartedUpdate 6 February 2016 Not StartedUpdate 7 August 2016 Not StartedFLEX Strategy Evaluation April 2015 StartedUnit 2FLEX Strategy Evaluation April 2016 StartedUnit 1Validation by Walk-throughs orDemonstration(s):

Walk-throughs or April 2015 Not StartedDemonstrations Unit 2Walk-throughs or April 2016 Not StartedDemonstrations Unit 1Perform Staffing Analysis October 2014 StartedModifications:

Modifications Evaluation June 2015 Started Enclosure 1 to PLA-7204Page 3 of 9RevisedTarget Activity TargetMilestone Completion Status Completion Date DateUnit 2 Design Engineering June 2014 Complete*

-Issue Unit 2 Design (except HCVS,Change Documents (for all see Ref. 11)Phases)Unit 2 Implementation April 2015 Not StartedOutageUnit 1 Design Engineering June 2015 Complete*

-Issue Unit 1 Design (except HCVS,Change Documents (for all see Ref. 11)Phases)Unit 1 Implementation April 2016 Not StartedOutageStorage:Storage Design May 2014 Complete*

Engineering Storage Implementation

-April 2015 StartedEquipment storage(reasonable protection) ready for operation withrequired FLEX equipment available for useFLEX Equipment:

Procure On-Site April 2015 StartedEquipment Contract with Vendor for March 2013 CompleteNational SAFER ResponseCenter (NSRCs)established Develop Strategies with April 2015 StartedNSRCEstablish offsite staging May 2015 Startedlocation

[Install Off-SiteDelivery Station (ifNecessary)]

Enclosure 1 to PLA-7204Page 4 of 9RevisedTarget Activity TargetMilestone Completion Status Completion Date DateNational SAFER Response December 2014 Started*

JanuaryCenters in service 2015*Procedures:

BWROG issue Emergency February 2013 CompleteProcedure and SevereAccident Guidelines (EPGs/SAGs)

Rev. 3Procedures Complete Unit April 2015 Started2 FLEX Implementation (including FSGs andmaintenance)

Procedures Complete Unit April 2016 Started1 FLEX Implementation (including FSGs andmaintenance)

Training:

Develop Training Plan May 2014 CompleteTraining Complete February 2016 Started*Unit 2 FLEX April 2015 Started*Implementation Unit 1 FLEX April 2016 Started*Implementation Full Site FLEX April 2016 Started*Implementation Submit Completion Report August 2016 Not Started* Revised since the six month update submitted February 28, 2014 (Reference 10)4. Changes to Compliance MethodNRC Order EA-12-049 requires implementation of Mitigation Strategies toinclude procedures,

guidance, training, and acquisition,

staging, or installing of equipment needed for the strategies.

Enclosure 1 to PLA-7204Page 5 of 9Reference 1 provided PPL's response to the NRC Order EA-12-049.

Thecover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will affectimplementation of the Mitigation Strategies NRC Order EA-12-049 actions.The Reference 1 enclosure describes PPL's Mitigation Strategies that arebased on venting the containment using the Hardened Containment VentSystem. It also describes that a modification is required to install a HardenedContainment Vent System.Thus the PPL response to NRC Order EA-12-049 provided in Reference 1was premised on installation and use of a Hardened Containment Vent Systemas required by NRC Order EA-12-050.

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

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

8. This relaxation was granted inReference 11.5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with NRC Order EA- 12-049, but needs relaxation ofthe implementation dates. The specific details have been submitted in aseparate document (Reference 8).NRC Order EA-12-049 requires implementation of Mitigation Strategies toinclude procedures,

guidance, training, and acquisition,

staging, or installing of equipment needed for the strategies.

Reference 1 provided PPL's response to the NRC Order EA-12-049.

Thecover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will also affectimplementation of the Mitigation Strategies NRC Order EA-12-049 actions.The Reference 1 enclosure describes the PPL Susquehanna Mitigation Strategies that is based on venting the containment using the HardenedContainment Vent System. It also describes that a modification to install aHardened Containment Vent System is required.

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

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

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

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required andhas been requested (Reference 8). This relaxation was granted in Reference 11.6. Open Items from Overall Integrated Plan and Draft SafetyEvaluation The following tables provide a summary and status as of July 31, 2014 of theopen items documented in the Overall Integrated Plan and ISE. The OpenItem and Confirmatory Items identified in the ISE will be addressed by theRegulatory Audit Process.Overall Integrated Plan Open Item Status1. Phase 3 Shutdown Cooling Capability Complete*

2. EOP changes required to support StartedMitigation Strategies.

3. Develop SSES "Response Plan" for use Startedof the National SAFER ResponseCenters (NSRC).4. FLEX Equipment Storage Complete*

5. Review GEH Report NEDC 33771P, CompleteGEH Evaluation of FLEXImplementation Guidelines and identifyexceptions to the report as required inAttachment 11B.6. Determine appropriate use of RCIC or CompleteFLEX pump mitigation strategy if ELAPoccurs when operating in Mode 4 andwhen transitioning to mode 3.7. Evaluate the impact of RCIC pump seal Complete*

failures.

EC-050-1034, Rev. 0 approved12/13/2013 Enclosure 1 to PLA-7204Page 7 of 9Overall Integrated Plan Open Item Status8. Evaluate potential RCIC pump Complete*

modifications.

9. Establish method of venting the Refuel Complete*

Floor. EC-012-6122, Rev 0 approved on4/29/2014.

10. Evaluate means to assure continued long Startedterm gas supply for ADS/SRVs.

11. Evaluate means to transfer diesel fuel oil Startedfrom storage tanks to the diesel fueledequipment.

12. Evaluate the effects of injecting Spray CompletePond water (UHS) to the RPV over along period of time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or longer.13. The calculation EC-030-1006, Rev 14, Complete*

Control Structure Temperature Responseto a Station Blackout or Fire InducedLoss Of Control Structure HVAC wasperformed.

However, final review andapproval of the calculation EC-030-1006, Rev 14, have not been performed.

Thecalculation has now been reviewed andapproved.

14. The calculation EC-SBOR-0504, Rev 6, Complete*

Reactor Building Heatup AnalysisDuring Station Blackout was performed.

However, final review and approval ofthe calculation EC-SBOR-0504, Rev 6have not been performed.

Revision 7 ofthis calculation was approved on3/20/2014.

Appendix 0 was added toidentify and evaluate mitigating measures that could be implemented toenhance Switchgear and Load CenterRoom cooling, as needed, for time > 72hours.

Enclosure 1 to PLA-7204Page 8 of 9Overall Integrated Plan Open Item Status15. Fuel consumption and refuel intervals Startedwill be determined during theprocurement process for the 4160VACgenerators.

• Revised since the six month update submitted February 28, 2014 (Reference 10)7. Potential Draft Safety Evaluation ImpactsNone -PPL has received the ISE and will be closing the Open Item andConfirmatory Items via the audit process.8. References The following references support the updates to the Overall Integrated Plandescribed in this enclosure:

1. PPL Letter (PLA-698 1), "Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (NRC Order EA-12-049),"

dated February 28, 2013.2. NRC Order EA- 12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"

dated March 12, 2012.3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)Implementation Guide," Revision 0, dated August, 2012.4. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External events,"Revision 0, dated August 29, 2012.5. PPL Letter (PLA-7072),

"Request for Implementation Date Relief inResponse to March 12, 2012 Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049),"

dated August 26, 2013.6. NRC Order EA-13-109, "Order to Modify Licenses with Regard toReliable Hardened Containment Vents Capable of Operation UnderSevere Accident Conditions,"

dated June 6, 2013.7. PPL Letter (PLA-707 1), "First Six Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (Order Number EA-12-049),"

dated August 26, 2013.

Enclosure 1 to PLA-7204Page 9 of 98. PPL Letter (PLA-7134),

"Request for Relaxation from NRC OrderEA-12-049,

'Order Modifying Licenses With Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events"'

datedFebruary 20, 2014.9. NRC Letter from J. S. Bowen to T. S. Rausch, "Susquehanna SteamElectric

Station, Units 1 And 2 -Interim Staff Evaluation Relating ToOverall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies)

(TAC NOS. MF0888 and MF0889),"

dated January 24, 2014(ADAMS # ML13339A764).

10. PPL Letter(PLA-7137),

"Second Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (NRC Order EA-12-049),"

dated February 28, 2014.11. NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna SteamElectric Station Units 1 and 2 -Relaxation of Certain ScheduleRequirements for Order EA- 12-049 'Issuance of Order to ModifyLicenses with Regard to Requirements for Mitigation Strategies forBeyond Design Basis External Events,"'

dated April 15, 2014.