Text

Calvert Cliffs, Units 1 and 2, August 2014 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 EA-12
	ML14241A379
Person / Time
Site:	Calvert Cliffs
Issue date:	08/26/2014
From:	Korsnick M G; Constellation Energy Nuclear Group, Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, FLL-14-027
	Download: ML14241A379 (36)
	v • d • e

AMaria KorsnlckASenior Vice President, Northeast OperationsA Exelon Generation, Chief Nuclear Officer, CENG100 Constellation WaySuite 500PConstellation Energy Nuclear Group, LLC Baltimore, MD 21202410-470-5133 Office443-213-6739 Faxwww.exeloncorp.commaria.korsnick@exeloncorp.comNRC Order No. EA-12-049FLL-14-027August 26, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852Calvert Cliffs Nuclear Power Plant, Units 1 and 2Renewed Facility Operating License Nos. DPR-53 and DPR-69Docket Nos. 50-317 and 50-318

Subject:

August 2014 Six-Month Status Report in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049)

References:

(1) NRC Order Number EA-12-049, Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents, dated March 12, 2012 (ML12054A735)(2) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Response to NRC Letter on Technical Issues for Resolution RegardingCommunications Submittals Associated with Near Term Task ForceRecommendation 9.3, dated February 22, 2013 (ML13066A710)(3) Letter from B. K. Vaidya (NRC) to G. H. Gellrich (CENG), Calvert CliffsNuclear Power Plant, Unit Nos. 1 and 2 -Staff Assessment in Response toRecommendation 9.3 of the Near-Term Task Force Related to the FukushimaDai-ichi Nuclear Power Plant Accident (TAC Nos. ME9947 and ME9948),dated April 24, 2013 (ML13100A240)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 12-049(Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for Calvert Cliffs NuclearPower Plant, LLC (CCNPP), Units 1 and 2. Reference (1) requires submission of a statusreport at six-month intervals following submittal of the overall integrated plan. Attachment (1)provides the six-month Status Report for CCNPP. The report updates the milestoneaccomplishments since the submittal of the last status report, including any changes to thecompliance method, schedule, or need for relief and the basis, if any.In Reference (2), CCNPP committed to include the status of the implementing actions identifiedin Section 4.12 of the Communications Assessment as part of the six-month status reports U. S. Nuclear Regulatory CommissionAugust 26, 2014Page 2required by Section IV.C.2 of NRC Order EA-12-049. Attachment (1) includes an update of thestatus of these implementing actions. This will be the last status update for those actions.Future six-month status reports submitted in accordance with Section IV.C.2 of NRC OrderEA-12-049 will not include a status of the implementing actions identified in Section 4.12 of theCommunications Assessment, as these updates have negligible safety significance. Thus, thisletter deletes the regulatory commitment made in Reference (2). As documented inReference (3), the regulatory commitments to implement the CCNPP Units 1 and 2improvements related to mitigating strategies (FLEX) derived from the results of thecommunications assessment will be completed: a) prior to the startup of CCNPP Unit 1following the Spring 2016 refueling outage and b) prior to the startup of CCNPP Unit 2 followingthe Spring 2015 refueling outage.There are no regulatory commitments contained in this letter.If there are any questions regarding this letter, please contact Bruce Montgomery, ActingManager -Licensing, at 443-532-6533.I declare under penalty of perjury that the foregoing is true and correct. Executed on the26th day of August, 2014.Rpsectfully,,Mar GI~sn ickMGK/STDAttachment (1) Six-Month Status Report (August 2014) for Mitigation Strategies for Beyond-Design-Basis External Eventscc: Regional Administrator, Region I, USNRCNRC Project Manager, NRR -Calvert Cliffs Nuclear Power PlantNRC Senior Resident Inspector -Calvert Cliffs Nuclear Power PlantDirector, Office of Nuclear Reactor RegulationJ. A. Kratchman, NRC ATTACHMENT (1)ISIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FORBEYOND-DESIGN-BASIS EXTERNAL EVENTSCALVERT CLIFFS NUCLEAR POWER PLANT, LLCAugust 26, 2014 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS1 IntroductionThe Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) Overall Integrated Plan (OIP) was submitted tothe Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse andflexible strategies (FLEX) in response to NRC Order Number EA-12-049 (Reference 2). Subsequently, asupplement to the CCNPP Oil for FLEX was submitted to the NRC in March 2013 (Reference 3). Thisattachment provides an update of milestone accomplishments since the last status report, including anychanges to the compliance method, schedule, or need for relief/relaxation and associated basis (ifapplicable).CCNPP developed an Interim Action Implementation Schedule as part of an Assessment ofCommunications during an Extended Loss of AC Power (ELAP) (Reference 4). A commitment wasmade in Reference 4 to include the status of the implementing actions identified in Section 4.12 ofCCNPP's communications assessment as part of the six-month status reports prepared pursuant to SectionIV.C.2 of NRC Order EA-12-049. The updated status of the communications assessment interim actionsis provided in Section 8. It should be noted that this is the last status report in which an update ofcommunications assessment interim actions will be provided. This change in regulatory commitment isaddressed in the cover letter submitting this status report.Since the submittal of the last two status reports in August 2013 (Reference 6) and February 2014(Reference 8), CCNPP FLEX has progressed with engineering analysis, calculations and design ofmodifications that support the mitigating strategies while making some refinements to modificationconcepts. However, no significant changes to the mitigation strategies or planned modifications insupport of the mitigation strategies have occurred. Work to formalize agreements to utilize local spacesas staging areas has progressed with some owners while remaining a challenge with others.By letter dated December 17, 2013, the NRC issued to CENG the Calvert Cliffs Nuclear Power Plant,Units 1 and 2 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to OrderEA-12-049 (Mitigation Strategies) (TAC Nos. MF 1142 and MF 1143) (Reference 7). The Interim StaffEvaluation (ISE) contains open and confirmatory items for which Exelon, the CCNPP licensee, has begunto provide clarifying or additional information in the February 2014 and this six-month status reports inorder for the NRC to determine that the issues are on a path to satisfactory resolution. This informationand the item status are given in Table 3.2 Milestone AccomplishmentsThe following milestones have been completed since the development of the OIP (References 1 and 3),and are current as of July 15, 2014:" Performed exploratory fluid system walk downs in support of pending modifications for FLEXstrategies during spring 2013 Refueling Outage (RFO). (8/2013)* Performed exploratory electrical system walk downs in support of pending modifications for FLEXstrategies during spring 2013 RFO. (8/2013)* Performed preliminary site walk downs in support of FLEX equipment deployment and storagestrategies. (8/2013)* Submitted the first six-month FLEX status report in August 2013. (8/2013).Page 1 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS* Submitted the second six-month FLEX status report in February 2014. (2/2014)* Submitted the third six-month FLEX status report in August 2014. (8/2014)* Developed Strategies/Contract with the Regional Response Center (RRC), (8/2014)3 Milestone Schedule StatusTable 1 provides an update to Attachment 2-1 of the CCNPP OIP (Attachment 4 -References 1 and 3). Itprovides the activity status of each item, and whether the expected completion date has changed. Thedates are planning dates subject to change as design and implementation details are developed. Anychanges to the indicated target completion dates will be reflected in subsequent 6-month status reports.The revised milestone target completion dates do not impact the Order implementation date.Walk-throughs or demonstrations encompassing all FLEX equipment points of connection/tie-ins forPhase 2 and Phase 3 strategies will be performed as presented in Table 1. A detailed schedule for walk-throughs or demonstrations, including individual target dates, has not been developed.Table 1Status of CCNPP FLEX O1P MilestonesTarget Revised TargetMilestone Completion Activity Status Completion DateDateSubmit 60 Day Status Report October 2012 CompleteSubmit Overall Integrated Plan February 2013 CompleteU-2: October 2013Commence Engineering and November 2013 StartedDesign U-1: October 2014Commence Procurement of U-2: January 2015June 2015 StartedEquipment U-i: January 2016Commence Installation ofEqimen t March 2016 Not Started October 2014EquipmentSubmit 6-Month Status Report August 2013 CompleteU-2: SeptemberDevelop Modifications October 2013 Started 2014U-i: July 2015Develop Strategies/Contractwith the Regional Response November 2013 CompleteCenter (RRC)Perform Staffing Analysis January 2014 Not Started August 2014Page 2 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 1Status of CCNPP FLEX OIP MilestonesTarget Revised TargetMilestone Completion Activity Status Completion DateDateSubmit 6-Month Status Report February 2014 CompleteComplete Engineering and March 2014 Started U-2: October 2014Design U-I: June 2015Create Maintenance anddJune 2014 Started December 2014Testing ProceduresSubmit 6-Month Status Report August 2014 CompleteProcedure Changes Training September 2014 Started December 2014Material CompleteDevelop Training Plan November 2014 Started April 2014Submit 6-Month Status Report February 2015 Not StartedIssue FLEX Support March 2015 Started U-2: January 2015Guidelines (FSG) U-1: January 2016Unit 2 ModificationImplementation Outage April 2015 Not Started March 2015Unit 2: MarchWalk-throughs or 2015StartedDemonstrations Unit 1: March2016Implement Training June 2015 Started U-2: April 2014U-i: April 2015Submit 6-Month Status Report August 2015 Not StartedComplete Procurement of U-2: SeptemberEquipment 2014August 2015 StartedU-i: September2015Submit 6-Month Status Report February 2016 Not StartedUnit 1 ModificationImplementation Outage April 2016 Not Started March 2016Page 3 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 1Status of CCNPP FLEX OIP MilestonesTarget Revised TargetMilestone Completion Activity Status Completion DateDateSubmit 6-Month Status Report August 2016 Not StartedFull compliance with EA November 2016 Not Started049 is achievedSubmit Completion Report December 2016 Not Started4 Changes to Compliance MethodThere are no changes to the compliance method as documented in the Overall Integrated Plan(Reference 1) and Nuclear Energy Institute (NED 12-06 (Reference 5).5 Need for Relief/Relaxation and Basis for the Relief/RelaxationCCNPP expects to comply with the Order implementation date and no relief/relaxation is required at thistime.6 Open Items from Overall Integrated Plan and Draft Safety EvaluationTable 2 provides a summary of the open items documented in the OIP and those added in a subsequentsix month status report and the status of each item.Table 3 provides a summary of the open items and confirmatory items documented in the NRC's CCNPPISE (Reference 7) and the status of each item.Page 4 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 2Status of CCNPP FLEX OIP Open ItemsCCNPP OIP Open Items Status1. Add margin to design FLEX components and hard Started.connection points to address future requirementsas re-evaluation warrants. Portable FLEXcomponents will be procured commercially (Notification provided in Reference 8)2. Implement a design change to install permanent Started.protected FLEX equipment connection points(Notification provided in Reference 8)3. Evaluate deployment strategies and deployment Started.routes to ensure they are assessed for and addressapplicable hazards impact. (Notification provided in Reference 8)4. Develop a process for implementation ofexceptions for the site security plan or other Stad(license/site specific -10CFR50.54X)requirements of a nature requiring NRC approval (Notification provided in Reference 8)will be communicated in a future 6 month updatefollowing identification.)5. Define implementation routes upon finalizing a Started.location or locations for FLEX equipment storagelocation(s). (Notification provided in Reference 6)6. Evaluate requirements, options, and develop Started.strategies to provide reasonably protected storageon site for the FLEX portable equipment. (Notification provided in Reference 6)7. Design and build a protected storage location or Started.locations for the FLEX equipment. Ensure thedesign meets the requirements of NEI 12-06. (Notification provided in Reference 6)8. Identify analysis needed to develop or support Started.mitigating strategies.(Notification provided in Reference 6)9. Providean administrative program governing theFLEX deployment strategy, marking of setup Started.locations, including primary and alternatepathways, maintaining the pathways clear, and (Notification provided in Reference 8)clearing the pathways.10. Determine the location of the CCNPP localstaging area, primary and alternate delivery routes, Cand delivery methods to the proposed onsite (Addressed in Reference 8)laydown areas.11. Determine schedule for when RRCs will be fully Complete.operational.(Addressed in Reference 6)12. Define criteria for the local staging area by June Complete.2013.(Addressed in Reference 8)Page 5 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status13. Establish a suitable local staging area for portable Started.FLEX equipment to be delivered from the RRC tothe site. (Notification provided in this status report)14. Develop site specific SAFER Response Plan Started.(playbook) for delivery of portable FLEXequipment from the RRC to the site. (Notification provided in Reference 8)15. Original open item text:Implement a design change to replace the 1 ft.diameter wheel with a 3 ft. wheel on eachAtmospheric Dump Valve (ADV) chain operator. Started.Modified open item text: (Notification provided in Reference 8)Implement a design change to improvemechanical advantage on each Atmospheric DumpValve (ADV) chain operator.16. Evaluate the feasibility of the WCAP-17601-P Deleted.recommendation to install a remotely operatedRCP CBO return line isolation valve. (Addressed in Reference 6)17. Develop a procedure or FSG to perform an early Started.cooldown and depressurization as recommendedby WCAP-17601-P. (Notification provided in Reference 6)18. Perform engineering analyses to confirm thatCCNPP maintains an adequate level of Shutdown Complete.Margin (SDM) for an RCS cooldown to 350'F, to (Addressed in Reference 8)cover a period of at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .19. Implement a design change to re-power the Started.[Safety Injection Tank] SIT level and pressureindicators from a vital 120 VAC instrument bus. (Notification provided in Reference 8)20. Implement a design change to install new leak- Deleted.tight SIT vent Solenoid Valves (SV) that willallow the vent line pipe caps to remain off. (Addressed in Reference 6)21. Original open item text:Implement design changes to install "plug andplay" protected hose connections for the portablealternate [Auxiliary Feedwater] AFW pump toAFW on the exterior of the Auxiliary Buildingwest wall with piping run to the 27 ft. Eastpenetration Rooms to connect to the AFW to S/G Started.headers.(Notification provided in Reference 8)Modified open item text:Utilize flexible hose to connect a FLEX pump to anewly installed, dedicated hose connections (oneper unit) located on the motor driven AFW pumpcross-connect lines on the 5 ft. elevation of theAuxiliary Building.Page 6 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status22. Implement a design change to install reliable local Deleted.level indicators on all of the water storage tankslocated in the 11, 12 and 21 CSTs, 11 DWST, and (Addressed in Reference 8)11 and 12 PWSTs. (AddressedinReference_8)23. Perform an analysis to determine the necessary Started.scope of the DC load shedding strategy.(Notification provided in Reference 8)24. Implement a design change to clearly identify the Sted.set of DC load breakers that will either be leftenergized or load shed by identifying the selected (Notification provided in Reference 8)breakers by their unique numbers and load title.25. Implement a procedure or FSG to perform the DC Started.load shedding.(Notification provided in Reference 6)26. Complete a time-motion study to validate that DC Started.load shedding can be accomplished on each unit inone (1) hour. (Notification provided in Reference 8)27. Original open item text:Implement a design change to install an 8-hourUninterruptible Power Supply (UPS) on theMansell RCS Level Monitoring System. Started.Modified open item text: (Notification provided in Reference 8)Implement a design change to connect a portablediesel generator to the Mansell RCS LevelMonitoring System.28. Perform engineering analyses and developstrategies for providing RCS make-up and corecooling while in Modes 5 and 6, for all possible Started.RCS conditions, following an ELAP. Theanalysis should determine the FLEX pump (Notification provided in Reference 8)capacity needed to provide adequate flow in allRCS conditions.29. Perform an analysis to determine that there is Complete.sufficient decay heat generated for TDAFWoperation 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months after shutdown. (Addressed in Reference 8)30. Implement a design change to provide dedicated Started.hose connections and piping to the SafetyInjection System. (Notification provided in Reference 8)31. Develop a procedure or FSG to mimic the AFW Started.makeup strategy described in ERPIP-611,Attachment 1. (Notification provided in Reference 6)32. Install a design change to add makeup and pump Deleted.suction hose connections for FLEX pumpconnection to 12 CST. (Addressed in Reference 8)Page 7 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status33. Install a design change to replace the 2-1/2 inchhose connections with 4 inch hose connections at11 and 21 CSTs, 11 DWST, and 11 and 12 (Addressed in Reference 6)PWSTs.34. Install a design change to add hose connections at Started.11 and 21 Refueling Water Storage Tanks (RWT)for makeup and suction for the FLEX pumps. (Notification provided in Reference 8)35. Install design change to add 4" hose connections Deleted.to the Reactor Coolant Waste Receiver Tanks(RCWRTs) and Reactor Coolant Waste Monitor (Addressed in Reference 8)Tanks (RCWMTs).36. Perform an analysis to determine the survivabilityof the wells as a long-term source of make-up Started.water. Analysis should include any modificationsneeded to improve the survivability of theassociated Well Water System piping and toprovide 480 VAC power to the well pumps.37. Perform an analysis to determine the long-term Started.effect on the S/Gs from use of water from the[Ultimate Heat Sink] UHS as a cooling medium.38.Perform an analysis to determine station batterycoping time with DC load shedding. Analysis Started.should consider battery age, battery performancewithout battery room ventilation, and load and (Notification provided in Reference 8)load duration prior to completion of DC loadshedding.39. Track the completion of ECP-1 1-000293 and -Started.000294, the Reserve Battery distribution systemmodification that is currently in progress. (Notification provided in Reference 6)40. Develop and implement procedures to supply Started.power to critical instrumentation using primaryand alternate methods. (Notification provided in Reference 6)41. Perform an analysis to determine that the assumed Complete.load capacity of the FLEX 480 VAC DG issufficient to provide power to the selected loads. ECP-14-000052 includes an analysis to determine that theassumed load capacity of the FLEX 480 VAC DG is sufficientto provide power to the selected loads.42. Implement a design change to connect a FLEX480 VAC Diesel generator to either of the A or B Started.train 480 VAC load centers on each unit toprovide power to the battery chargers and other (Notification provided in Reference 8)critical AC equipment.Page 8 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status43. Implement a design change to provide directconnection of a portable 100 kW diesel generatorto reactor [Motor Control Centers] MCCs 104 or Staed.114 and 204 or 214 to provide power to theinverter backup bus (which can power the (Notification provided in Reference 8)120VAC vital bus), the SIT Outlet [MotorOperated Valves] MOVs, and the AFW PumpRoom Vent Fans.44. Implement a design change to install connection Deleted.points, conduit, cabling, and transfer switcheslocally at battery chargers to provide for direct (Addressed in Reference 6)connection from the FLEX 480 VAC DGs.45. Perform an analysis to determine the feasibility of Not Started.the S/G "batch" feeding strategy.46. Implement a procedure to connect a 4160 VAC Staed.RRC DG to either of the A or B Train 1E 4160VAC Buses on each unit to provide power for (Notification provided in Reference 8)Phase 3.47. Develop procedures or FSGs for repower vital Started.4160 VAC Class lE buses from RRC FLEX 4KVDGs. (Notification provided in Reference 8)48. Provide modified 4160 VAC breakers for directRRC DG connection for use in place of the normal D4160 VAC breakers in service for LPSI Pump and (Addressed in Reference 8)SW Pump power supplies.49. Implement a design change to power containment Started.dome and reactor cavity temperaturesinstrumentation from a vital 120 VAC instrument (Notification provided in Reference 8)bus. (NotificationprovidedinReference_8)50. Perform an analysis to determine containmenttemperature and pressure response over a period Complete.of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Perform analysis with and withoutRCS cooldown and with and without restoration (Addressed in Reference 6)of containment air cooling.51. Implement a design change to install a hose Deleted.connection on the A-Train and B-Train[Containment Spray] CS headers in the Auxiliary (Addressed in Reference 6)Building.Page 9 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status52. Purchase additional special check valve bonnets Deleted.and store them inside each [Emergency CoreCooling System] ECCS Pump Room. The scope of this action was to build additional hose bonnettools for each ECCS pump room rather than one tool thatwould have to be moved from room to room if being used tosupport the FLEX mitigation strategy. The CCNPP FLEXstrategy for containment cooling will no longer use thisconnection path. FLEX will not use the same means to coolcontainment as B.5.b uses for containment flooding throughthe spray header. Therefore additional tools, as wereoriginally planned, are not needed for this scope of FLEXmodification.53. Perform an analysis to determine the feasibility of Started.providing Containment cooling with CAC Unitsusing an alternate cooling water strategy.54. Install hose connections on the Service Water Deleted.(SRW) supply and return lines to the CAC forconnection to a RRC portable heat exchanger. (Addressed in Reference 8)55. Implement a design change to install reliable wide Started.range spent fuel pool (SFP) level instrumentationin accordance with NRC Order EA-12-051. (Notification provided in Reference 6)56. Implement a design change to provide a 6" hose Started.connection to each RWT.(Notification provided in Reference 8)57. Implement a design change to provide dedicated Started.hose connections to the SFP Cooling system.(Notification provided in Reference 8)58. Develop and implement procedures or FSGs that Started.include the SFP Cooling FLEX makeup flow path.(Notification provided in Reference 6)59. Develop procedures or FSGs that mimic the Started.ERPIP-612 sections for SFP makeup and SFPspray. (Notification provided in Reference 6)60. Implement a design change to install reliable wide Duplicate Open Item.range SFP fuel pool level instrumentation inaccordance with NRC Order EA-12-051 See Open Item #5561. Perform an analysis to determine the Control Complete.Room temperature response over a period of 72hours. Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the roomenvironment acceptable for occupancy as well as equipmentfor 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottestpart of the day.Page 10 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status62. Perform an analysis to confirm that TDAFW Complete.Pump room air temperature remains acceptableover 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of pump operation. Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the roomenvironment acceptable for occupancy as well as equipmentfor 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottestpart of the day.63. Develop primary and alternate strategies for Complete.ventilating the TDAFW Pump Room.(Addressed in Reference 6)64. Perform an analysis to confirm the [ProbableMaximum Precipitation] PMP event maximum Complete.flood height will not impact the operation of (Addressed in Reference 6)TDAFW or preclude access to the room.65. Perform an analysis to determine the possibleeffects of Beyond Design Basis External Events(BDBEEs) on the Turbine Building structure andthe potential effect on access to the TDAFWPump Room.Complete.The turbine building was originally designed to therequirements for a Seismic Class II structure, including windload and seismic load. The building is an integrated steelstructure with metal siding, supported on reinforced concretefoundations. In addition, all of the structural steel columns,beams, and roof trusses of the building have been designed asindependent members and in accordance with AmericanInstitute of Steel Construction, Inc. specifications. It wasdetermined that facilities which were built to the requirementof basic construction codes have the ability to surviveseismically-induced loadings and stresses well in excess of theoriginal allowances. Although a quantitative evaluation of theseismic capability of the turbine building has not beenperformed, it is unlikely that catastrophic failure of the turbinebuilding would occur.Class II structures are designed in accordance with designmethods of accepted codes and standards insofar as they areapplicable. Wind design (25 psf zone) is in accordance withthe UBC, with a one third increase in the allowable stresses.Seismic design is in accordance with the UBC. Seismicforces were based on Seismic Probability Zone 3 multipliedby a ratio of 0.08/0.30. A one third increase in allowablestresses was not allowed. All of the structural steel columns,beams, and roof trusses of the building have been designed asindependent members and in accordance with AISCSpecifications. The Turbine Building is constructed belowgrade from the turbine deck down to its base mat.In addition, taking the position stated in the NRC-endorsedGeneric Imolementation Procedure (GIP), it is a fact thatPage I 1 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open ItemsStatuslarge, commercial industrial structures, such the steel-constructed Turbine Building, have behaved very well duringstrong motion earthquakes with seismic ground motion inexcess of 0.9gs. They have retained their structural andsystem integrity with the exception of localized damage due toinsufficiently anchored equipment. Facilities which were builtto the requirements of basic code construction have beenfound to have the ability to survive seismic-induced loadingsand stresses well in excess of the original allowables.A review of the Turbine Building structural design revealedthat it is a ductile structure with inherent damping and energyabsorbing capacity. The building is built to withstand 90 mphwinds, thereby resisting lateral loads in excess of UBCseismic requirements. As a result, the review of the TurbineBuilding at CCNPP and NRC-endorsed GIP statements, theturbine building has the ability to survive an SSE without thepotential for damage to its piping systems and there is a highlikelihood the structure will remain standing following aBeyond Design Basis External Event (BDBEE).66. Develop an alternate access strategy for access Complete.into the TDAFW Pump Room.Based on the determination that the Turbine Building canwithstand a BDBEE, it can be concluded that the normalaccess path to the TDAFW pump room will not be blocked.Consequently, there is no need to consider an alternate routeto reach the TDAFW pump room. Consideration to have analternate access path to the TDAFW pump room was givenprior to concluding that the Turbine Building would not sufferany damage during a BDBEE.67. Perform an analysis to determine the temperature Complete.profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area around ADVenclosures. Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the areaenvironment acceptable for occupancy as well as equipmentfor 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times possible during the hottestpart of the day.68. Perform an analysis to determine the Cable Complete.Spreading Room temperature response over aperiod of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the roomenvironment acceptable for occupancy as well as equipmentfor 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with limited stay times.Page 12 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status69. Investigate changing Appendix R lighting Deleted.batteries to a longer life battery or new batterytechnology to lengthen the duration of lighting (Addressed in Reference 8)available in vital areas of the plant.70. Procure battery operated hardhat mounted lights("miners" lights) for on-shift and Emergency Not Started.Response Organization (ERO) personnel.71. Procure a sufficient quantity of hand-held battery ot Started.operated lanterns for on-shift and ERO personnel.72. Procure six (6) portable diesel generator powered Complete.exterior lighting units with 30 ft. masts and aminimum 400,000 lumens. (Addressed in Reference 8)73. Change Appendix R lighting from incandescent to Deleted.LED to lengthen the duration of lighting availablein vital areas of the plant. (Addressed in Reference 8)74. Implement a design change to install a protected,backup power supply capable of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of Started.operation, for the Plant Public Address system.This includes backup power for the individual (Notification provided in Reference 8)building speaker network amplifiers.75. Implement a design change to modify the 800MHz Radio System to provide protection fromexternal hazards, transmitter and antennasprotected from seismic, wind, and wind-drivenmissiles, including back-up power supply capable (Notification provided in Reference 8)of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months operation for the system and repeaters,or install an alternative communication system inlieu of the 800 MHz Radio system.76. Implement a design change to modify the FixedDedicated Satellite Phone System to provideprotection from external hazards, and transmitter Started.and antennas protected from seismic, wind, andwind-driven missiles, including back-up power (Notification provided in Reference 8)supply capable of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months operation for thesystem.77. Purchase one wheeled and one tracked vehicle Complete.with bucket/blade and grapple of sufficient sizeand load handling capacity to remove debris. (Addressed in Reference 8)78. Purchase the portable equipment needed to outfit Deleted.CCNPP Fire Engine 171 for debris removal.(Addressed in Reference 6)79. Implement a design change to install a protectedalternate means of accessing the UHS for allBDBEEs, including installing necessary Started.modifications to meet required deployment times.The strategy must also address how debris in the (Notification provided in Reference 8)UHS will be filtered / strained and how theresulting debris will effect core cooling.Page 13 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open ItemsStatus80. Develop strategies for use of the Control Roomand Cable Spreading Room Appendix RVentilation System during an ELAP.Deleted.The use of the Control Room and Cable Spreading RoomAppendix R Ventilation System for ELAP is no longer beingpursued. The opening of doors and the activation of a 2,000cfm portable fan units are planned for the Control Room. Theopening of doors is planned for the Cable Spreading Rooms(Refer to Calculation CA08253). It was concluded thattemporary power required to reactivate the Control Room andCable Spreading Room Appendix R Ventilation Systemduring an ELAP would be not be provided given that thisequipment is in a non-protected location and likely would notsurvive a BDBEE.81. Perform an analysis to evaluate hydrogen buildup Complete.in the battery rooms during charging and the longterm room temperature profiles. Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the batteryroom environment acceptable for occupancy as well asequipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with possible limited stay times andthat hydrogen concentration will remain well belowflammable limits.82. Perform an analysis to determine the Switchgear Complete.Room temperature response under the abovescenario and assuming various 480 VAC load Calculation CA08253, "Room Heatup for FLEX Evaluationcenter and 4160 VAC bus loadings over a period (Loss of HVAC)" has been completed. The conclusion is thatof 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . the planned compensatory measures (e.g., opening doors,using temporary fans and air coolers) will maintain the roomenvironment acceptable for occupancy as well as equipmentfor 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.83. Perform an analysis to verify the above strategy Complete.will provide sufficient air flow to vent steam fromthe SFP Area. Calculation CA08253, "Room Heatup for FLEX Evaluation(Loss of HVAC)" has been completed. The conclusion is thatthe planned compensatory measures (e.g., opening doors), willprovide sufficient air flow to vent steam and maintain thespent fuel pool area environment acceptable for occupancy aswell as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.84. Evaluate the cost of draining 21 Fuel Oil Storage Started.Tank (FOST) and IA DG FOST and refilling withultra-low sulfur (<15 ppm) diesel fuel oil. (Notification provided in Reference 8)Page 14 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSCCNPP OIP Open Items Status85. Original open item text:Implement a design change to install dedicatedFLEX hose connections on 21 FOST, IA DGFOST, and the I B, 2A, and 2B DG fuel oil Y- Started.strainers.(Notification provided in this status report)Modified open item text:Implement a design change to install dedicatedFLEX hose connections on the 21 FOST.86. Provide a permanent, fully protected diesel FOST Deleted.for refueling the FLEX diesel-driven equipment.The existing 21 Fuel Oil Storage Tank (FOST) will bemodified to accommodate connections to take fuel for FLEXequipment through an air-driven pump that will be mountedinside the enclosure. Air will be supplied via a FLEXportable air compressor. As a result, there will no longer be aneed to provide a permanent, protected Diesel FOST forrefueling the FLEX Diesel-driven equipment. (See themodified text of OIP Open Item 85.)87. Perform an analysis of the fuel consumption rate Sted.for all of the FLEX equipment that could be inoperation during an ELAP for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Notification provided in Reference 8)to determine a conservative refueling interval.88. Develop strategies to reduce the transport time for Started.fuel oil loading and delivery.(Notification provided in Reference 6)89. Purchase the consumables that should be stockedto support at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of site operation Started.independent of offsite support.90. Provide a procedure governing the maintenanceand distribution of the consumables that will be Started.stocked to support at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of siteoperation independent of offsite support.91. Develop a strategy to protect onsite consumables Staed.for use after a BDBEE.92. Develop equipment operating procedures or FSGs, Started.considering vendor technical manual operatingprocedures, for each of the pieces of portable (Notification provided in Reference 8)FLEX equipment that will be procured.93. Install connection points on Class 1E 4KV Buses Deleted.for the RRC 4KV portable DG.(Addressed in Reference 8)94. Develop procedures or FSG for each of the RRC Started.based strategies and for operation of theequipment provided by the RRC. (Notification provided in Reference 8)Page 15 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 3Status of CCNPP Interim Staff Evaluation (ISE) Open and Confirmatory ItemsISE Open ItemsStatus1. ISE Open Item 3.2.1.1.A -The licensee willneed to perform a plant specific analysis ofRCS cooling and inventory control. If theCENTS code is used, the value of flowquality at the upper region of [SteamGenerator] SG tubes for the condition whenthe RCS makeup pump is required to injectwater into the RCS will also need to besubmitted, and the licensee should confirmthat CENTS is not used outside of any rangesof applicability discussed in the white paperaddressing the use of CENTS (e.g., prior tothe reflux boiling initiation). If other codesare used for the ELAP analysis, the licenseewill need to justify the acceptance of thecodes for this use.Started.(Notification provided in this status report)2. ISE Open Item 3.2.1.1.B -The licensee'splan for analysis for core and containmentcooling is still under development and CENGwill identify additional analysis to supportthe mitigating strategies. The subjects of theanalyses are: maintaining core cooling (e.g.,confirm shutdown margin during cooldown,DC load shedding, and adequate steampressure for TDAFW pump operation),containment temperature and pressureresponse for containment cooling, andvarious safety functions regarding ventilationand cooling systems (e.g., for the maincontrol room, TDAFW pump room, cablespreading room, battery rooms, switchgearrooms and the SFP area). Review of theseanalyses is needed to confirm acceptability ofthe mitigating strategies.Complete.Calculation CA08023, "Minimum Allowable RCSTemperature to Support FLEX Implementation" has beencompleted. The conclusion is that the cycle-independentestablished time for which a cooldown to 325°F could beperformed without boration while maintaining reactivitymore negative than -1000 pcm is 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months following reactortrip. Beyond 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months , boration is required in order toprovide confidence that the reactor remains shut down bymore than 1000 pcm.DC load shedding: To confirm the safety-related stationbatteries will support the vital instrumentation required forthe Phase 1 FLEX mitigation strategy at Calvert Cliffs untilthe Phase 2 diesel generators are deployed, the followingcalculations are prepared corresponding to the four safety-related station batteries: CA08256 -Battery 11 Load ShedCoping Time for ELAP Event; CA08257 -Battery 12 loadShed Coping Time for ELAP Event; CA08258 -Battery 21Load Shed Coping Time for ELAP Event; CA08259 -Battery 22 Load Shed coping Time for ELAP Event.An analysis was performed to determine that there issufficient decay heat generated for TDAFW operation 36hours after shutdown. The results of the analysis show thatthere is sufficient decay heat to support adequate steampressure for TDAFW pump operations for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .Page 16 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Open Items StatusContainment temperature and pressure response:Calculation CA07961 evaluates the containmenttemperature and pressure response to an ELAP.Room ventilation and cooling: Calculation CA08253evaluates the temperature response of auxiliary and turbinebuilding area in response to the loss of forced ventilation(HVAC) during an Extended Loss of A/C Power (ELAP)event. The purpose of this analysis is to establish thenecessary mitigating actions and required timing of thoseactions to support the FLEX Overall Integrated Plan (OIP)of ensuring survivability of coping equipment and theoperator's ability to perform the required mitigating actionsin a safe and timely manner. The mitigating actions will bedetailed in Emergency Response Plan ImplementingProcedure ERPIP-0652, "Alignment for Area Cooling" andinclude establishing ventilation pathways, e.g. openingpersonnel and equipment doors, and staging portableventilation equipment, e.g. portable fan units powered bysmall portable diesel generators. No permanent plantmodifications are planned in order to implement thesemitigating actions. The plant areas addressed include:Charging Pump Rooms; Battery Rooms, Cable SpreadingRooms, Spent Fuel Pool Heat Exchanger and Pump Room;East Piping Penetration Rooms, Main Steam PipingPenetration Rooms, Main Steam Piping Penetration Rooms,West Piping Penetration Rooms, Switchgear Rooms, MainControl room, Truck Bay Loading Area, Spent Fuel PoolLevel Instrumentation Area, Atmospheric Dump ValveArea, East Electrical Penetration Rooms, Spent Fuel PoolArea, Main Plant Exhaust Equipment Room, and TurbineDriven Auxiliary Feedwater (TDAFW) Pump Rooms.3. ISE Open Item 3.2.1.8.A -During the auditprocess, the licensee informed the NRC staff ofits intent to abide by the Pressurized-WaterReactor Owners Group (PWROG) generic Started.approach regarding boric acid mixing discussedin Section 3.2.1.8 of this report; however, the (Notification provided in Reference 8)NRC staff concluded that the August 15, 2013,position paper was not adequately justified andthat further information is required.ISE Confirmatory Items Status1. ISE Confirmatory Item 3.1.1.1.A -On page Complete.8 of the Integrated Plan, the licensee specifiedthat Phase 2 FLEX components will be stored FLEX equipment storage locations have been selected. Oneat the site in a location or locations such that robust storage building and one commercial building will bePage 17 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Statusthey are reasonably protected and that no one constructed at CCNPP. The robust building, the Flexexternal event can reasonably fail the site Storage Robust Building (FSRB), will be of reinforcedFLEX capability. Provision will be made for concrete approximately 60' wide x 140' long x 21' high andmultiple sets of portable on-site equipment located outside of the Protected Area to the west. Thestored in diverse locations or through storage commercial building, the Flex Storage Commercial Buildingin structures designed to reasonably protect (FSCB), will be a pre-engineered building approximatelyfrom applicable external events. FLEX 60' wide x 60' long x 18' high and located outside of theequipment storage location(s) have not been Protected Area to the south. The distance between the twoselected. buildings is approximately 2,685 feet.2. ISE Confirmatory Item 3.1.1.1.B -Thelicensee will provide the specific protectionrequirements described in NEI 12-06 for the (Notification provided in Reference 8)applicable hazard.3. ISE Confirmatory Item 3.1.1.4.A -Thelicensee has not yet identified the localstaging area or described the methods to beused to deliver the equipment to the site for Started.all hazards. The licensee will develop aplaybook which will provide the detail (Notification provided in Reference 8)necessary to ensure the successful delivery ofthe portable FLEX equipment from the RRCto the local staging area and from the localstaging area to the site.4. ISE Confirmatory Item 3.1.2.2.A -Thelicensee identified two open items; oneregarding evaluating deployment strategiesand deployment routes to ensure they areassessed for and address applicable hazards Started.impact. The second was to provide anadministrative program governing the FLEX (Notification provided in Reference 8)deployment strategy, marking of setuplocations, including primary and alternatepathways, maintaining the pathways clear,and clearing the pathways.5. ISE Confirmatory Item 3.1.2.2.B -Regarding the open items noted in 3.1.2.2.A,evaluations are needed to assure thatconnection points for portable equipment Started.remain viable for the flooded condition, andthat the effects of the maximum storm surge (Notification provided in Reference 8)or probable maximum hurricane should beconsidered in evaluating the adequacy of thebaseline deployment strategies.Page 18 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory ItemsStatus6. ISE Confirmatory Item 3.1.2.2.C -Thelicensee specified that primary access to theUHS is via the openings in the [CirculatingWater] CW Discharge Structure (plantoutfall). An alternate UHS location has notbeen established; however the licensee hasidentified an open item to implement a designchange to install a protected alternate meansof accessing the UHS for all BDBEEs,including installing necessary modificationsto meet required deployment times. Thestrategy must also address how debris in theUHS will be filtered and/or strained and howthe resultin2 debris will affect core cooling.Started.(Notification provided in Reference 8)7. ISE Confirmatory Item 3.1.3.2.A -The Complete.licensee specified that CCNPP currently has avaried array of wheeled vehicles, e.g., Equipment that has been procured and evaluated in supportforklifts, small tractors, and a backhoe, that of the FLEX effort and that will be dedicated for use duringcould be used for debris removal. However, an ELAP event will be stored in the FLEX storage buildingsthe licensee did not specify if this equipment (see Item 3.1.1.1 .A). The decision to store which equipmentwould be protected from high wind and other in what building is based on the guidance given in NEI 12-hazards. 06.8. ISE Confirmatory Item 3.1.4.2.A -The Started.licensee did not address procurementrequirements to ensure that the FLEX FLEX equipment is being procured to the extreme hot andequipment can be operated in extreme hot or cold temperature environments specified in Calvert Cliffs'cold temperature environments or how hot or Design Criteria Document "Implementation of Diverse andcold temperatures will affect manual actions. Flexible Coping Strategies (FLEX)".Page 19 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory ItemsStatus+9. ISE Confirmatory Item 3.1.4.2.B -Deployment of FLEX equipment has not beenaddressed for conditions of snow, ice andextreme cold. The current screening omits adiscussion of deployment of FLEX equipmentfor hazards due to ice blockage or formationof frazil ice on the UHS.Complete.Calvert Cliffs Units 1 and 2 use its circulating water (CW)and saltwater (SW) systems suction and discharge structuresfor the ELAP Ultimate Heat Sink (UHS) water source for allBDBEEs. The primary access to the UHS water source isvia openings in the CW/SW discharge structure (plantoutfall). The alternate access to the UHS water source is viathe intake structure downstream of the circulating waterscreens through existing access hatches associated with theCW screen wash pumps. The alternate UHS water sourcecan be readily accessed to meet required deploymentstrategies and is protected from debris and ice by the CWscreens. There are 12 CW pumps (6 per Unit) rated at200,000 gpm each and 6 SW pumps (3 per Unit) rated at15,500 gpm each, resulting in a normal flow through theintake and discharge structures of approximately 2,500,000gpm. Under ELAP conditions, the maximum expected flowthrough the intake structure will be less than 20,000 gpm(1% of the normal flow), and more like reverse flow throughthe CW screens, which significantly reduces the intakevelocity into the intake area and screens as well as providingsignificant margin for screen clogging due to debris or ice asdescribed in the Exelon Position Paper, "FLEX WaterSource Debris Clogging at Suction Point." Similarly, whileCalvert Cliffs has been found not to be susceptible to frazilice (Ref. Station Response to INPO SOER 2007-02, "IntakeCooling Water Blockage"), this reduced intake velocity alsoprovides significant margin for screen blockage due to frazilice, if it were to occur concurrent with a BDBEE.10. ISE Confirmatory Item 3.2.1.2.A -TheRCP seal initial maximum leakage rateshould be greater than or equal to the upperbound expectation for the seal leakage rate forthe ELAP event discussed in the PWROG Complete.white paper addressing the RCP seal leakagefor CE plants. If the RCP seal leakage rate (Addressed in Reference 8)used in the plant-specific ELAP analysis isless than upper bound expectation for the sealleakage rate discussed in the white paper,justification should be provided.11. ISE Confirmatory Item 3.2.1.5.A -The Complete.licensee has not provided sufficient analysesto confirm instruments are reliable and Confirmation that instruments are reliable and accurate inaccurate in the containment harsh conditions the containment harsh conditions is provided in Engineeringwith high moisture levels, temperature and Change Package ECP-14-000024, Instrument Re-Powerpressure during the ELAP event. Modification.Page 20 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory ItemsStatus.1-12. ISE Confirmatory Item 3.2.1.6.A -Thefollowing references used as basis for severalsequence of events (SOE) Action Timeconstraints were not available for review:CCNOO12-17-STUDY-001, and CCNPPFLEX Strategy Table Top.Complete.CCN0012-17-STUDY-001, Rev. 0, Analysis of CalvertCliffs DC Systems in Support of INPO Event Report 11-4,is a 596-page document. It will be posted to the CCNPPePortal and be available for review. It should be noted thatthe DC Systems study has been superseded by detailed DCsystem analyses. (Refer to ISE Open Item 3.2.1.l.B).On the other hand, "CCNPP FLEX Strategy Table Top "isnot a document. It was a compilation of notes the meetingorganizer took while conducting the table tops. These noteswere discarded sometime after the table tops were conductedand their results were reviewed.13. ISE Confirmatory Item 3.2.1.6.B -Thelicensee has not completed final analysisregarding validation of the action timesreported in the Sequence of Events, including Sany SOE changes that may result from (Notification provided in Reference 8)ongoing evaluations for; RCP seal leakage,plant specific CENTS analysis, and anyrevised battery load shed analysis.14. ISE Confirmatory Item 3.2.1.7.A -The Complete.Generic Concern related to the shutdown andrefueling modes, required clarification of CCNPP will implement PWROG Shutdown mode guidanceCCNPP's approach to demonstrate that the PA-PSC-1 126, Core Team Interim Guidance for Earlystrategies can be implemented in all modes. Implementers as provided in letter OG-14-101, dated MarchDuring the audit, the licensee informed the 14, 2014. This includes implementing Shutdown ModeNRC of their plans to abide by this generic FSG-14, Shutdown RCS Makeup and FSG-15, Shutdownresolution. The implementation of these plans Water Management.is identified as Confirmatory Item 3.2.1.7.A. WaterManagement.15. ISE Confirmatory Item 3.2.1.9.C -During Complete.the audit process, the licensee stated that itwill provide revised analyses as detailed Detailed engineering evaluations of each Phase 3 FLEXengineeiing evaluations are performed for component and modification strategy are provided in theeach Phase 3 FLEX component and following Engineering Change Packages:modification strategy.* ECP-14-000153, Phase 3 4160 VAC RRC DGConnection Mod (Note: 10% package only)* ECP-14-000105: Phase 30 Long Term Coping for Reactor Core Cooling viaShutdown Cooling* Provide boric acid batching capability for RWT /RCS makeup* Maintain Spent Fuel Pool (SFP)Page 21 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Status16. ISE Confirmatory Item 3.2.1.9.D -Thelicensee provided an open item, to performengineering analysis to determine that there is Complete.sufficient decay heat generated for TDAFWoperation 36-hours after shutdown and that (Addressed in Reference 8)the TDAFW pumps can operate reliablyprovided there is greater than 65 psia steampressure in one of the SGs.17. ISE Confirmatory Item 3.2.2.A -The Complete.licensee did not discuss the impacts ofsalt/brackish water on the structures and The source of spent fuel pool makeup water will be selectedcomponents of the SFP system, and the fuel. based on availability, priority of use, and water quality.During the audit process the licensee Condensate-grade water from any available condensatespecified that they will perform an analysis to storage or demineralized water tank is the preferred source,determine the effects of salt/brackish water on followed by pre-treated (fire) water, well water, and finally,the structures and components (including as a last resort, Chesapeake Bay (brackish) water via B.5.binstrumentation) of the SFP system and the (10 CFR 50.54 (hh) (1)) methods in response to potentialstored fuel. aircraft threats. As brackish water is already approved foruse in response to 10 CFR 50.54 (hh) (1), analysis of theeffects of brackish water on SFP structures and components,including instrumentation and fuel, is not planned. It shouldbe noted that the newly installed spent fuel pool levelinstrumentation would not be affected by brackish waterbecause the cone, its closest part to the water, hangs 2.5 ft.above the pool water surface.18. ISE Confirmatory Item 3.2.2.B -The Complete.licensee will perform an analysis to verifythat the proposed strategy for SFP ventilation Calculation CA08253, "Room Heatup for FLEX Evaluationwill provide sufficient air flow to vent steam (Loss of HVAC)" has been completed. The conclusion isfrom the SFP area, in order to determine that the planned compensatory measures (e.g., openingwhether natural air circulation is sufficient, or doors), will provide sufficient air flow to vent steam andforced ventilation provided by FLEX maintain the spent fuel pool area environment acceptable forequipment will be required. occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limitedstay times.19. ISE Confirmatory Item 3.2.3.A -Thelicensee specified that an analysis of theContainment response during the ELAP eventindicated that the Containment would notrequire additional cooling. During the audit, Started.the licensee provided a document entitled"CCNPP Containment Analysis" that was (Notification provided in Reference 8)based on the GOTHIC code, however, thetabulated results did not match thosetransmitted in the August 2013 6-monthupdate.20. ISE Confirmatory Item 3.2.4.1.A -Complete.Charging Pump Room ventilation is providedby the non-safety related Auxiliary Building Calculation CA08253, "Room Heatup for FLEX EvaluationPage 22 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items StatusSupply and Exhaust Ventilation System. An (Loss of HVAC)" has been completed. The conclusion isevaluation will be performed to determine if that the planned compensatory measures (e.g., openingthe Charging Pumps can meet their mission doors, using temporary fans and air coolers) will maintaintime without room ventilation, the charging pump room environment acceptable foroccupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .21. ISE Confirmatory Item 3.2.4.2.A -The Complete.licensee identified an open item to perform ananalysis to determine the Control Room Calculation CA08253, "Room Heatup for FLEX Evaluationtemperature response over a period of 72 (Loss of HVAC)" has been completed. The conclusion ishours. that the planned compensatory measures (e.g., openingdoors, using temporary fans and air coolers) will maintainthe room environment acceptable for occupancy as well asequipment for 72 hrs with limited stay times possible duringthe hottest part of the day.22. ISE Confirmatory Item 3.2.4.2.B -The Deleted.licensee identified an open item to developstrategies for use of the Control Room and The use of the Control Room and Cable Spreading RoomCable Spreading Room Appendix R Appendix R Ventilation System for ELAP is no longerVentilation System during an ELAP. being pursued. The opening of doors and the activation of a2,000 cfm portable fan units are planned for the ControlRoom. The opening of doors is planned for the CableSpreading Rooms (Refer to Calculation CA08253). It wasconcluded that temporary power required to reactivate theControl Room and Cable Spreading Room Appendix RVentilation System during an ELAP would be not beprovided given that this equipment is in a non-protectedlocation and would likely not survive a BDBEE.23. ISE Confirmatory Item 3.2.4.2.C -The Complete.licensee identified an open item to perform ananalysis' to evaluate hydrogen buildup in the Calculation CA08253, "Room Heatup for FLEX Evaluationbattery rooms during charging and room (Loss of HVAC)" has been completed. The conclusion istemperature profiles. that the planned compensatory measures (e.g., openingdoors, using temporary fans and air coolers) will maintainthe battery room environment acceptable for occupancy aswell as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with possible limited staytimes and that hydrogen concentration will remain wellbelow flammable limits.24. ISE Confirmatory Item 3.2.4.2.D -The Complete.licensee identified an open item to perform ananalysis to determine the Switchgear Room Calculation CA08253, "Room Heatup for FLEX Evaluationtemperature response following the (Loss of HVAC)" has been completed. The conclusion isreenergizing of buses and assuming various that the planned compensatory measures (e.g., opening480 VAC load center and 4160 VAC bus doors, using temporary fans and air coolers) will maintainloadings over a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . the room environment acceptable for occupancy as well asequipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.Page 23 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Status25. ISE Confirmatory Item 3.2.4.2.E -The Complete.West Electrical Penetration Rooms will beginto heat up after the Reactor motor control Calculation CA08253, "Room Heatup for FLEX Evaluationcenters (MCC) are re-energized from the (Loss of HVAC)" has been completed. The conclusion isFLEX 480 VAC DGs, therefore, they will that the planned compensatory measures (e.g., openingneed to be evaluated for limiting temperatures doors, using temporary fans and air coolers) will maintainfor equipment survivability, the West Electrical Penetration Rooms environmentacceptable for occupancy as well as equipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .26. ISE Confirmatory Item 3.2.4.4.A -On page56 of the Integrated Plan, the licenseeidentified five open items to; 1) investigate Complete.changing Appendix R lighting batteries to alonger life battery or new battery technology The status of these five open items is as follows:to lengthen the duration of lighting availablein vital areas of the plant, 2) procure battery 1. On-shift individuals and members of the Emergencyoperated hardhat mounted lights ("miners" Response Organization will be provided with hardhatlights) for on-shift and emergency response mounted lights ("miners" lights). Therefore, there is noorganization (ERO) personnel, 3) to procure a longer a need to change Appendix R lighting fromsufficient quantity of hand-held battery incandescent to LED.operated hardhat lanterns for on-shift and 2. See Item 1ERO personnel, 4) to procure six (6) portable 3. See Item 1diesel generator powered exterior lighting 4. The six portable diesel generator-powered exteriorunits with 30 ft. masts and a miinimum lighting units have been purchased and are at CCNPP.400,000 lumens, and 5) to change Appendix 5. See Item 1R lighting from incandescent to LED tolengthen the duration of lighting available invital areas of the plant.27. ISE Confirmatory Item 3.2.4.4.B -TheNRC staff reviewed the licenseecommunications assessment and hasdetermined that the assessment for Complete.communications is reasonable, and theanalyzed existing systems, proposed The assessment for satellite communications has started.enhancements, and interim measures will help The assessment for radios is on-going with the final phaseto ensure that communications are scheduled by the summer of 2014. At that time the scope ofmaintained. Confirmation that upgrades to the modification for 800MHz radio system will be determined.site's communications systems have beencompleted will be accomplished at a laterdate.28. ISE Confirmatory Item 3.2.4.5.A -Thelicensee has not completed its evaluation of Started.the primary and alternate access pointsPage 24 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Status29. ISE Confirmatory Item 3.2.4.6.A -The Complete.licensee has identified an open item toperform an analysis to determine the Calculation CA08253, "Room Heatup for FLEX Evaluationtemperature profile over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the area (Loss of HVAC)" has been completed. The conclusion isaround the Atmospheric Dump Valve that the planned compensatory measures (e.g., openingenclosures. doors, using temporary fans and air coolers) will maintainthe area environment acceptable for occupancy as well asequipment for 72 hrs with limited stay times possible duringthe hottest part of the day.30. ISE Confirmatory Item 3.2.4.6.B -The Complete.licensee' identified an open item to perform ananalysis' to determine the Cable Spreading Calculation CA08253, "Room Heatup for FLEX EvaluationRoom temperature response over a period of (Loss of HVAC)" has been completed. The conclusion is72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . that the planned compensatory measures (e.g., openingdoors, using temporary fans and air coolers) will maintainthe room environment acceptable for occupancy as well asequipment for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , with limited stay times.31. ISE Confirmatory Item 3.2.4.6.C -The Complete.licenseeý identified two open items to performan analysis to determine the possible effects The Turbine Building was originally designed to theof BDBEE on the Turbine Building structure requirements for a Seismic Class H1 structure, including windand the potential effect on access to the load and seismic load. The building is an integrated steelTDAFW Pump Room, and to develop an structure with metal siding, supported on reinforced concretealternate access strategy for access into the foundations. In addition, all of the structural steel columns,TDAFW Pump Room. beams, and roof trusses of the building have been designedas independent members and in accordance with AmericanInstitute of Steel Construction, Inc. specifications. It wasdetermined that facilities which were built to therequirement of basic construction codes have the ability tosurvive seismically-induced loadings and stresses well inexcess of the original allowances. Although a quantitativeevaluation of the seismic capability of the turbine buildinghas not been performed, it is unlikely that catastrophicfailure of the turbine building would occur.Class II structures are designed in accordance with designmethods of accepted codes and standards insofar as they areapplicable. Wind design (25 psf zone) is in accordance withthe UBC., with a one third increase in the allowable stresses.Seismic design is in accordance with the UBC. Seismicforces were based on Seismic Probability Zone 3 multipliedby a ratio of 0.08/0.30. A one third increase in allowablestresses was not allowed. All of the structural steel columns,beams, and roof trusses of the building have been designedas independent members and in accordance with AISCSpecifications. The Turbine Building is constructed belowgrade from the turbine deck down to its base mat.Page 25 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items StatusIn addition, taking the position stated in the NRC-endorsedGeneric Implementation Procedure (GIP), it is a fact thatlarge, commercial industrial structures, such the steel-constructed Turbine Building, have behaved very wellduring strong motion earthquakes with seismic groundmotion in excess of 0.9gs. They have retained theirstructural and system integrity with the exception oflocalized damage due to insufficiently anchored equipment.Facilities which were built to the requirements of basic codeconstruction have been found to have the ability to surviveseismic-induced loadings and stresses well in excess of theoriginal allowables.A review of the Turbine Building structural design revealedthat it is a ductile structure with inherent damping andenergy absorbing capacity. The building is built towithstand 90 mph winds, thereby resisting lateral loads inexcess of UBC seismic requirements. As a result, thereview of the Turbine Building at CCNPP and NRC-endorsed GIP statements, the turbine building has the abilityto survive an SSE without the potential for damage to itspiping systems and there is a high likelihood the structurewill remain standing following a Beyond Design BasisExternal Event (BDBEE).Based on the determination that the Turbine Building canwithstand a BDBEE, it can be concluded that the normalaccess path to the TDAFW pump room will not be blocked.Consequently, there is no need to consider an alternate routeto reach the TDAFW pump room. Consideration to have analternate access path to the TDAFW pump room was givenprior to concluding that the Turbine Building would notsuffer any damage during a BDBEE.32. ISE Confirmatory Item 3.2.4.8.A -Themedium voltage 4160VAC generators and thelow voltage 480VAC 800kW generators thatwill arrive from the RRC will have protective Started.devices as specified in AREVA document 51-9199717-000. An evaluation will beperformed to verify the internal protection isadequate to protect the IE buses.Page 26 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Status33. ISE Confirmatory Item 3.2.4.8.B -One480VAC/675KVA diesel generator set will bedeployed for each unit to connect to one vital Started480 VAC Load Center on that unit. The480VAC/125KVA diesel generators are Engineering Change Package ECP-14-000052, 480 VACintended as an alternate strategy to connect to FLEX Diesel Generator Connection Modification evaluatesone of two vital reactor MCCs on each unit. the 480VAC/500KW and 480VAC/100KW dieselThe supplied reactor MCC can be cross- generators for their intended use.connected to the redundant train reactor MCCon that unit. An evaluation to validate theintended use of these diesel generators ispending'.34. ISE Confirmatory Item 3.2.4.9.A -Thelicensee identified Open items to perform ananalysis of the fuel consumption rate for all ofthe FLEX equipment that could be in Started.operation during an ELAP for a period of 72hours to determine a conservative refueling (Notification provided in this status report)interval, and to develop strategies to reducethe trans'port time for fuel oil loading anddelivery.35. ISE Confirmatory Item 3.2.4.10.A -Onpage 19 of the Integrated Plan, the licenseeidentified Open Items: to implement a designchange to clearly identify the set of [DC] loadbreakers-that will either be left energized or Started.load shed by identifying the selected breakers Sby their unique numbers and load title; to (Notification provided in Reference 8)implement a procedure or FSG to perform the[DC I load shedding; and to complete a time-motion study to validate that DC loadshedding can be accomplished on each unit inone hour.36. ISE Confirmatory Item 3.2.4.10.B -Maintenance of vital 125 VDC power will Complete.include aligning the Reserve Battery to one ofthe four vital 125 VDC buses via bus work The reserve battery is not being credited in the Station'sand disconnects that are currently being FLEX strategy because the battery load shedding strategyinstalled'under an existing plant modification. per ERPIP-653 (FSG-4) provides sufficient time (> 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months sThis action will extend the coping time for to restore battery charging to at least one battery per Unit).one vital 125 VDC bus to greater than 20 However, the reserve battery has similar capacity to two ofhours. The licensee needs to provide a copy the station batteries and slightly smaller capacity than theof the analysis/calculations which shows other two station batteries and therefore would significantlyaligning the Reserve Battery to one of the four increase the battery copying time should there be a delay in125VDC buses can extend the coping time for restoring battery charging.one vital'125 VDC bus to greater than 20hours.Page 27 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSISE Confirmatory Items Status37. ISE Confirmatory Item 3.4.A -Thelicensee's plans for the use of off-siteresources conform to the minimumcapabilities specified in NEI 12-06 Section Started.12.2, with regard to the capability to obtainequipment and commodities to sustain and (Notification provided in this status report)backup the site's coping strategies. Thelicensee did not address the remainingminimum capabilities of Section 12.2.7 Potential Draft Safety Evaluation ImpactsThere are no potential impacts to the Draft Safety Evaluation identified at this time.8 Communications Assessment Interim Actions StatusTable 4 provides a listing of the implementing actions documented in the Assessment of Communicationsduring an ELAP (Reference 4). It provides the status of each action, and whether the expectedcompletion date has changed. The dates are planning dates subject to change as design andimplementation details are developed. It should be noted that this is the last status report in which anupdate of communications assessment interim actions will be provided. This change in regulatorycommitment is addressed in the cover letter submitting this status report.Page 28 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 4Status of CCNPP Communications Assessment Interim ActionsCommunications Assessment Target Revised TargetImplementing Actions Completion Status CompletionDate DateFixed Satellite Phone System and Antennas1. Determine the status of existing fixed Complete.satellite phone system and antennas interms of suitability of being "reasonably (Addressed inprotected." Reference 8)2. Install additional antennas/dishes as Started.necessary to support the use of fixed Startup 2016satellite phones at all locations. RFO Unit 1 (Notificationprovided in thisstatus report)3. Stage portable satellite dishes as necessary Startup 2016to support the use of fixed satellite phones RFO Unit 1 Not Started.at all locations.North Service Building and Switchyard House1. Determine whether or not the North Complete.Service Building (NSB) and Switchyard 12/31/2013Houstage "reasonably protected." (Addressed inReference 8)Portable Satellite Phones1. Stage~satellite phones Complete.(Addressed in_ _ _ Reference 6)2. Stage, batteries and chargers in the Complete.applicable ERO Facilities. 10/31/2013 (Addressed in_ _ _ Reference 8)3. Update work instructions for portable Complete.satellite phone inventory. 10/31/2013(Addressed inReference 8)4. Develop/update preventive maintenance Complete.and testing procedures for portable 12/31/2013satellite phones, batteries and chargers. (Addressed inReference 8)5. Include information on portable satellite Complete.phone locations and usage in procedures. 12/31/2013 (Addressed in_ _Reference 8)Page 29 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 4Status of CCNPP Communications Assessment Interim ActionsCommunications Assessment Target Revised TargetCompletion Status CompletionImplementing ActionsDaeatDate Date6. Procure and install a high power UPS or 12/31/2014 Complete.similar modification providing backuppower for the battery chargers for (Notificationportable satellite phones. provided in thisstatus report)Fixed Satellite Phones1. Procure and install fixed satellitephones, fixed satellite dishes anduninterruptable power supplies for theTechnical Support Center Startup 20161 12/31/2014 Started.(TSC)/Operations Support Center RFO Unit 1(OSC), Emergency Operations Facility(EOF), and Joint Information Center(JIC).2. Update work instructions for fixed Complete.satellite phone inventory(Addressed inReference 6)3. Develop/update preventive maintenance Complete.and testing procedures for fixed satellitephones. (Addressed inReference 6)4. Include information on fixed satellite Complete.phone locations and usage inprocedures. (Addressed inReference 6)5. Determine the acceptability of thebackup UPS in its present location. 8/31/2014 Started. 12/31/2014Relocate higher, if necessary.6. Provide instructions for use at every Complete.fixed satellite phone location.(Addressed inReference 6)Communication with ORO Facilities1. Provide each Offsite ResponseOrganization (ORO) identified in Complete.Section 4.0 of the Communications 10/31/2013Assessment with instructions for proper (Addressed instorage and rotation of satellite phone Reference 8)batteries.Page 30 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 4Status of CCNPP Communications Assessment Interim ActionsCommunications Assessment Target Revised TargetomemuntinActions AsseCompletion Status CompletionImplementing Actions Date Date2. Provide each Offsite ResponseOrganization (ORO) identified in Startup 2016 Staed.Section 4.0 of the Communications RFO Unit 1Assessment with fixed satellite dish.Portable Generators1. Develop portable generator fueling plan Complete.to ensure ability to provide power for a 8/31/2015minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (Addressed inReference 8)2. Develop procedures to maintain and test Complete.the portable generators. 12/31/2013 (Addressed inReference 8)3. Update work instructions to inventory Complete.portable generators and ensure adequate 12/31/2013volume of fuel. (Addressed inReference 8)4. Develop preventive maintenance Complete.procedure for portable generators fuel 12/31/2013supply. (Addressed inReference 8)5. Procure additional generators as Complete.required to support FLEX andcommunications strategies. 6/30/20 14 (Addressed inReference 8)(see note 1)6. Determine a process for relocatingportable generators to the appropriate Startup 2015 Not Started.locations to power the necessary RFO Unit 2equipment.Plant Paging (Announcement) System1. Provide a battery backed power sourcefor the Tellabs Peripheral Equipmentand the Power Block Amplicenters or Startup 2015otherwise modify the paging system to RFO Unit 2 Started.attain battery backed operation in theevent of a loss of all AC power at thesite.Page 31 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTSTable 4Status of CCNPP Communications Assessment Interim ActionsCommunications Assessment Target Revised TargetCompletion Status CompletionImplementing Actions Date Date2. Revise ERPIP 3.0, Immediate Actions, to Complete.provide guidance to the Shift Manager onhow to implement back-up site 12/31/2013 (Addressed inannouncements if the Site Paging system Reference 8)is not functional.3. Revise ERPIP 750, Security, to provide Complete.specific guidance on how to execute the 12/31/2013public address announcements if the (Addressed inplant paging system is not functional. Reference 8)4. Revise ERPIP-B. 1, Equipment Complete.Checklist, to add necessary bull horns to 12/31/2013support back-up method for site (Addressed inannouncements. Reference 8)Training1. Evaluate training needs specific to theuse of, portable and fixed satellitephones, radios and implementation ofback-up methods for siteannouncements during an extended lossof AC power event.2. Develop and implement training on the Startup 2015 Staed.use of portable generators. RFO Unit 2Portable Radios1. Procure and install a high power UPSor similar modification providing Startup 2015 Not Started.backup power for the radio system RFO Unit 2repeaters2. Complete estimates of portable radio Started.battery life and purchase additionalbatteries as necessary based on an 10/31/2013 (Notification December 2014estimate of minimum talk time to provided inensure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation. Reference 6)Note:1. Complete with respect to Communication but not to FLEX9 ReferencesThe following references support the updates to the OIP described in this attachment.1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan forMitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013.Page 32 of 33 ATTACHMENT (1)CCNPP SIX-MONTH STATUS REPORT (AUGUST 2014)FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS2. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to OverallIntegrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, datedMarch 8, 2013.4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letteron Technical Issues for Resolution Regarding Communication Submittals Associated with Near-Term Task Force Recommendation 9.3, dated February 22, 2013.5. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, datedAugust 2012.6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), Calvert Cliffs Nuclear PowerPlant, Units 1 and 2- Six-Month Status Report in Response to March 12, 2012 Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013 (ADAMS AccessionNo. ML 13254A278)7. Letter from J. S. Bowen (NRC) to J. A. Spina (CENG), Calvert Cliffs Nuclear Power Plant, Units 1and 2 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1142 and MF 1143), dated December 17, 2013.8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), February 2014 Six-MonthStatus Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated February 27, 2014 (ADAMS Accession No. ML 14069A318)Page 33 of 33

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