RA-13-051, 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)

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)

ML13240A267
Person / Time
Site:	Oyster Creek
Issue date:	08/28/2013
From:	Jim Barstow Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, RA-13-051, RS-13-125
Download: ML13240A267 (13)

Text

1 Exelon Generation Order No. EA-12-049 RS-13-125 RA-13-051 August 28,2013 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

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)

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 0, dated August 29, 2012

3. NEI12-06, "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-13-023)

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs 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 of Reference 1.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28,2013 Page 2 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI12-06, Revision 0 (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 Oyster Creek Nuclear Generating Station overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first 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. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

The enclosed report, Section 4, describes changes to the method of compliance with NEI 12-06 (Reference 3) that have been made to the Oyster Creek FLEX conceptual designs. These changes are alternatives to NEI 12-06, but still meet the requirements of NRC Order EA-12-049 (Reference 1). The compensatory measures described in Section 4 provide technical justification for the alternative methods of compliance.

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 28 th day of August 2013.

Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Oyster Creek Nuclear Generating Station First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

u.s. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2013 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Robert J. Fretz, Jr, NRRlJLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Eric E. Bowman, NRR/DPRlPGCB, NRC Manager, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

u.s. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2013 Page 4 bcc: Site Vice President - Oyster Creek Nuclear Generating Station Vice President Operations Support Plant Manager, Oyster Creek Nuclear Generating Station Site Engineering Director - Oyster Creek Nuclear Generating Station Regulatory Affairs Manager Regulatory Assurance Manager - Oyster Creek Nuclear Generating Station Severe Accident Management Director Site Operations Director - Oyster Creek Nuclear Generating Station Corporate Licensing Manager - East Corporate Licensing Director - East Exelon Records Management Vinod Aggarwal Steven Pierson David Schupp Eric DeMonch

Enclosure Oyster Creek Nuclear Generating Station First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (8 pages)

Enclosure Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Oyster Creek Nuclear Generating Station developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments None.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Milestone Schedule Target Revised Target Activity Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Contract with RRC Complete Submit 6 Month Updates:

Complete with Update 1 August 2013 this submittal Update 2 February 2014 Not Started Update 3 August 2014 Not Started Update 4 February 2015 Not Started Update 5 August 2015 Not Started Update 6 February 2016 Not Started Update 7 August 2016 Not Started Page 1 of 8

Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 Target Revised Target Activity Completion Activity Status Completion Date Date Submit Completion Report October 2016 Not Started Modification Development &

Implementation:

Modification Development (All FLEX August 2015 Not Started August 2016 Phases)

Modification Implementation (All FLEX October 2016 Not Started Phases)

Procedures:

Create Site-Specific Procedures October 2016 Not Started Validate Procedures (NEI 12-06, Sect.

October 2016 Not Started 11.4.3)

Create Maintenance Procedures October 2016 Not Started Perform Staffing Analysis June 2016 Not Started Storage Plan and Construction October 2016 Not Started FLEX Equipment Acquisition October 2016 Started Training Completion October 2016 Not Started Regional Response Center Operational December 2015 Started December 2014 Unit 1 FLEX Implementation October 2016 Not Started Full Site FLEX Implementation October 2016 Not Started 4 Changes to Compliance Method The following changes to the method of compliance with NEI 12-06 (Reference 3) have been made to the Oyster Creek FLEX conceptual designs. These changes are alternatives to NEI 12-06 but still meet the requirements of NRC Order EA 049 (Reference 2). The compensatory measures described below provide technical justification for the alternative methods of compliance.

1. NEI 12-06, Section 5.3.2 Deployment of FLEX Equipment Requirement: At least one connection point of FLEX equipment will only require access through seismically robust structures.

Change to compliance method:

Access to the Oyster Creek Reactor Building used for the strategies is not a robust structure.

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Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28,2013 Compensatory measure(s) implemented:

In the event of a seismic event, an alternate access path will be used. This path will be pre-identified in the implementing strategies. To satisfy the deployment in a seismic event Oyster Creek will utilize an alternate routing path for the hoses and cables. This path would be through the northwest door of the turbine building north mezzanine, through the hallway past the lower cable spreading room, and down the stairs to the northwest airlock to the manifold. The time to complete the routing will not significantly affect the time of deployment. This path will be validated once the strategies have been finalized.

2. Section 8.3.1 Protection of FLEX Equipment Requirement: These considerations apply to the protection of FLEX equipment from snow, ice, and extreme cold hazards:

1. For sites subject to significant snowfall and ice storms, portable FLEX equipment should be stored in one of two configurations:

a. In a structure that meets the plant's design basis for the snow, ice and cold conditions (e.g., existing safety-related structure).

b. In a structure designed to or evaluated equivalent to ASCE 7-10, Minimum Design Loads for Buildings and Other Structures for the snow, ice, and cold conditions from the site's design basis

c. Provided the N FLEX equipment is located as described in a. or b. above, the N+ 1 equipment may be stored in an evaluated storage location capable of withstanding historical extreme weather conditions and the equipment is deployable

2. Storage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The equipment should be maintained at a temperature within a range to ensure its likely function when called upon. For example, by storage in a heated enclosure or by direct heating (e.g., jacket water, battery, engine block heater, etc.).

Change to compliance method:

Oyster Creek will store FLEX portable equipment outside. The equipment will have block heaters installed.

Compensatory measure(s):

The Oyster Creek severe weather procedure will be revised to require moving the FLEX portable equipment from the outside storage location to the inside truck bays (6) during periods of predicted snow fall, ice, or extreme cold to protect the equipment from these hazards.

5 Need for ReliefIRelaxation and Basis for the ReliefIRelaxation Oyster Creek expects to comply with the order implementation date and no relieflrelaxation is required at this time.

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Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Section Reference Overall Integrated Plan Open Item Status Sequence of events (p. 10-12) The times to complete actions in the Not Started Events Timeline are based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures developed.

Sequence of events (p. 11-12) Initial evaluations were used to Not Started determine the fuel pool timelines.

Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.

Identify how strategies will be Transportation routes will be developed Not Started deployed in all modes (p. 13) 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.

Identification of storage areas and creation of the administrative program are open items.

Identify how the programmatic An administrative program for FLEX to Not Started controls will be met (p. 14) establish responsibilities, and testing &

maintenance requirements will be implemented.

Maintain Spent Fuel Pool Complete an evaluation of the spent fuel Not Started Cooling (p.36) pool area for steam and condensation.

Safety Functions Support (p. 44) Evaluate the habitability conditions for Not started the Main Control Room and develop a strategy to maintain habitability.

Safety Functions Support (p. 44) Develop a procedure to prop open Not Started Page 4 of 8

Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 battery room doors upon energizing the battery chargers to prevent a buildup of hydrogen in the battery rooms.

Sequence of events (p. 10) Issuance of BWROG document NEDC- Completed. Attached to 33771P, "GEH Evaluation of FLEX this 6-month update Implementation Guidelines" on (Attachment 1) 01/31/2013 did not allow sufficient time to perform the analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document prior to commencing regulatory reviews of the Integrated Plan. This analysis is expected to be completed, documented on Attachment lB, and provided to the NRC in the August 2013 six month status update.

Draft Safety Evaluation Open Item Status NIA NIA 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. Oyster Creek's Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013.

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

3. NEI 12-06, Rev. 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012.

4. NEDC-33771P, GEH Evaluation of FLEX Implementation Guidelines, Rev. 1, January 2013.

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Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 9 Attachments

1. NSSS Significant Reference Analysis Deviation Table (Attachment 1B of Overall Integrated Plan)

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Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 Attachment 1 NSSS Significant Reference Analysis Deviation Table (Attachment IB of Overall Integrated Plan)

NEDC-33771 NEDC-33771P P Design Item Parameter of Interest Rev 2 Value Page Plant Applied Value Value Gap and Discussion NEDC-33771P Rev 1 Section 4.5.1.1 (BWR/2/3. Mark I and EC System Assumptions) and Table 4.5.2-1 Appendix A are closest to the Oyster Creek Nuclear Generating Station and associated response. Differences between the GEH SHEX case and the MAAP analysis of the Oyster Creek strategy are listed below.

Input Parameter Values 1 Core thermal power Proprietary 15 1930 MWT NA The GEH model BWR 2/3 Mark I information. reference plant has lower core thermal Refer to report power rating.

for value.

2 Primary System Leakage Proprietary 15 35gpm NA The reference plant has a higher leak information. rate. The leak rate for Oyster Creek was Refer to report calculated using the Recirculation pump for value. seal vendor input and worst case unidentified leakage.

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Oyster Creek Nuclear Generating Station First Six Month Status Report for the Implementation of FLEX August 28, 2013 NEDC-33771 NEDC-33771P P Design Item Parameter of Interest Rev 2 Value Page Plant Applied Value Value Gap and Discussion 3 Emergency Condenser capacity Proprietary 15 (2.05xl08 Btu/hr)x2 4.1xl08 Two Emergency condensers provide a information. Oyster Creek has Btu/hr heat removal capability of 4.1xl08 Refer to report two Emergency Btu/hr which is more than what was used for value. condensers in the referenced plant (accounts for higher thermal power).

4 Wetwell Free Volume Proprietary 16 122,400fe NA The differences in reference plant information. structural design and minor differences in Refer to report assumed parameter values at time zero for value. should have a negligible effect on the I progression of the event after a few hours.

5 EC actuation pressure Proprietary 16 1051 psig EC actuation pressure for Oyster Creek is information. at a lower pressure than the referenced Refer to report plant. ECs will initiate at a lower reactor for value pressure to limit the reactor pressure on the RPV isolation.

6 Suppression pool volume and initial Proprietary 16 87,000 cubic feet at The differences in reference plant temperature information. 90.2 degrees (F) structural design and minor differences in Refer to report assumed parameter values at time zero for value should have a negligible effect on the progression of the event after a few hours.

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