PLA-7632, Ninth Six-Month Status Report in Response to March 12, 2012 Commission Oder Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

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Ninth Six-Month Status Report in Response to March 12, 2012 Commission Oder Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
ML17237A055
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/22/2017
From: Rausch T S
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17237A033 List:
References
EA-12-049, PLA-7632
Download: ML17237A055 (17)
v • d • e


Text

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

Upon separation of the Enclosure 2, this letter is decontrolled.

Timothy S. Rausch President and ChiefNuclear Officer Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@TalenEnergy.com AUG 2 2 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 ENERGY 10 CFR2.202 SUSQUEHANNA STEAM ELECTRIC STATION NINTH 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 (NRC ORDER EA-12-049)

PLA-7632 Docket No. 50-387 and No. 50-388

References:

1. NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 2. NRC interim Staff Guidance JLD-JSG-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. NE! 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, " Revision 0, dated August 2012 4. PPL Letter (PLA-6923), "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049)," dated October 29, 2012 5. PPL Letter (PLA-6981), "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2013 6. PPL Letter (P LA-7072), "Request for Implementation Date Relief in Response to March 12, 20 2 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2013 7. NRC Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013 8. PPL Letter (PLA-7071), "First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013 9. PPL Letter (PLA-7134), "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Basis External Events,'" dated February 20, 2014 10. NRC Letter from J S. Bowen to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2-Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January 24, 2014 (ADAMS# MLJ 3339A764)

Enclosure 2 of the Attachment contains security-related information.

Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.

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

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

Upon separation of the Enclosure 2, this letter is decontrolled. Document Control Desk PLA-7632 II. PPL Letter (PLA-7137), "Second Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2014 12. NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2-Relaxation of Certain Schedule Requirements for Order EA-12-049

'Issuance of Order to ModifY Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"'

dated April 15, 2014 (ML14065A028)

13. PPL Letter (PLA-7204), "Third Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 28, 2014 14. PPL Letter (PLA-7295), "Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 25, 2015 15. Talen Letter (PLA-7377), "Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2015 16. Ta/en Letter (PLA-7438), "Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 18, 2016 17. Talen Letter (PLA-7513), "Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order ModifYing Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 19, 2016. 18. Talen Letter (PLA-7570), "Eighth 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 (NRC Order EA-12-049)," dated Februmy 9, 2017. 19. Talen Letter (PLA-7610), "Report Of Full Compliance For Unit 2 With March 12, 2012 Commission Order ModifYing Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated May 31, 2017. The purpose of this letter is to provide Susquehanna Nuclear, LLC's (Susquehanna)

Ninth Six-Month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. Enclosure 1 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. Enclosure 2 is a revision of the Mitigation Strategies Overall Integrated Plan that includes several updates. Enclosure 2 contains information concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Information" as defined in 10 CFR 2.390 (d)(l). Accordingly, Susquehanna requests that the information provided in Enclosure 2 to the letter be withheld from public disclosure.

On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to Susquehanna.

Reference 1 was immediately effective and directs Susquehanna to develop, implement, and maintain guidance and strategies to Enclosure 2 of the Attachment contains security related information.

Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.

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

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

Upon separation of the Enclosure 2, this letter is decontrolled. Document Control Desk PLA-7632 maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference

1. 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 NEI 12-06, Revision 0 (Reference
3) with clarifications and exceptions identified in Reference
2. Reference 4 provided Susquehanna's initial status report regarding Mitigation Strategies.

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

6. The Request for Relaxation is based on NRC mandated changes to the Hardened Containment Vent System implementation dates that impact the Mitigation Strategy Overall Integrated Plan. Specifically, the change in implementation dates for the Hardened Containment Vent Order (NRC Order EA-12-050 was rescinded and superseded by NRC Order EA-13-109) impacts. the Mitigation Strategy Overall Integrated Plan and implementation timeline.

The NRC approved this relaxation in Reference

12.
  • Enclosure 1 to this letter documents that Susquehanna Unit 1 and Susquehanna Unit 2 have implemented all the necessary aspects of the Overall Implementation Plan in Enclosure 2 to this letter to be considered in compliance with the requirements of NRC Order EA-12-049, except for the NRC approved Request for Relaxation (Reference
12) regarding implementation of a Severe Accident Capable Hardened Containment Vent System per NRC Order EA-13-109.

Unit 2 now has a fully functional Wetwell Hardened Containment Vent, so Unit 2 is now in full compliance with the NRC Order EA-12-049 (Reference 19). This letter contains no new or revised regulatory c.ommitments.

If you have any questions regarding this report, please contact Mr. Jason Jennings, Manager-Nuclear Regulatory Affairs, at (570) 542-3155.

Enclosure 2 of the Attachment contains security related information.

Withhold from public disclosure under 10CFR2.390(d)(l), as other than Safeguards Information, and designated as Security Sensitive Information.

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

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

Upon separation of the Enclosure 2, this letter is decontrolled. Document Control Desk PLA-7632 I declare under penalty of perjury that the foregoing is true and correct. Executed on: Z l 1.'L r '1.,-<> l 1 Enclosure 1: Susquehanna Nuclear, LLC's Ninth Six Month Status Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Enclosure 2: Susquehanna Nuclear'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), (August 2017) Security-Related lnfonnation

-Withhold from Public Disclosure Under 10 CPR 2.390 Copy: NRC Region I Ms. L. H. Micewski, NRC Sr. Resident Inspector Ms. T. Hood, NRC Project Manager Ms. Jessica A. Kratchman, NRRJJLD/PMB, NRC Mr. M. Shields, PA DEP/BRP Enclosure 2 of the Attachment contains security related information.

Withhold from public disclosure under 10CFR2.390(d)(I), as other than Safeguards Information, and designated as Security Sensitive Information.

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

Enclosure 1 to PLA-7632 Susquehanna Nuclear, LLC's Ninth Six Month Status Report for the Implementation of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events I I I Enclosure 1 to PLA-7632 Page 1 of 12 Susquehanna Nuclear, LLC's Ninth Six Month Status Report for the Implementation ofNRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events 1. Introduction Susquehanna Nuclear, LLC (Susquehanna) developed an Overall Integrated Plan (Reference 8.1) documenting the diverse and flexible strategies (FLEX), in response to Reference 8.2. This Ninth Six-Month Status Report provides an update of milestone accomplishments since submittal of the Eighth Six-Month Status Report (Reference 8.18) related to the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. [NOTE: References cited in this enclosure are contained in Section 8.] 2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 8.1), and are current as of July 28, 2017.

  • Completed installation of the Unit 2 Severe Accident Capable Hardened Containment Vent System (Phase 1 Wetwell Vent).
  • Started installation of the Unit 1 Severe Accident Capable Hardened Containment Vent System (Phase 1 Wetwell Vent). 3. Milestone Schedule Status The following table provides an update to Attachment 2, Milestone Schedule, of the Overall Ititegrated 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 at this time. The Interim Staff Evaluation (ISE) from the NRC (Reference 8.9) was received in time to support implementation of the Mitigation Strategies.

The Open Item and Confirmatory Items identified in the ISE were addressed by the Regulatory Audit Process. The NRC performed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies issues.

Milestone Submit 60 Day Status Report Submit Overall Integrated Plan Expected receipt of draft SER from NRC (or ISE) Submit 6 Month Updates: Update 1 Update 2 Update 3 Update 4 Update 5 Update 6 Update 7 Update 8 Update 9 Update 10 FLEX Strategy Evaluation Unit2 FLEX Strategy Evaluation Unit 1 Validation by Walk-throughs or Demonstration( s): Walk-throughs or Demonstrations Unit 2 Walk-throughs or Demonstrations Unit 1 Perform Staffing Analysis Modifications:

Target Completion Date October 2012 February 2013 September 2013 August 2013 February 2014 August 2014 February 2015 August 2015 February 2016 August 2016 February 2017 August 2017 February 2018 April 2015 April 2016 April 2015 April 2016 October 2014 Activity Status Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete*

Not Started Complete Complete Complete Complete Complete Enclosure 1 to PLA-7632 Page 2of12 Revised Target Completion Date January 2014 May 2015 May 2015 Target Milestone Completion Date Modifications Evaluation June 2015 Unit 2 Design Engineering June 2014 Issue Unit 2 Design Change Documents (for all Phases) Unit 2 Implementation April 2015 Outage Unit 1 Design Engineering June 2015 -Issue Unit 1 Design Change Documents (for all Phases) Unit 1 Implementation March 2016 Outage Storage: Storage Design May 2014 Engineering Storage Implementation

-April 2015 Equipment storage (reasonable protection) ready for operation with required FLEX equipment available for use FLEX Equipment:

Procure On-Site April 2015 Equipment Contract with Vendor for March2013 National SAFER Response Center (NSRCs) established Develop Strategies with April 2015 NSRC Activity Status Complete .Complete*

Complete Complete (except HCVS, see Ref. 8.11) Complete Complete Complete Complete Complete Complete Enclosure 1 to PLA-7632 Page 3of12 Revised Target Completion Date August 2015 May 2015 August 2015 May 2015 May 2015 Feb 2015 Milestone Establish offsite staging location [Install Off-Site Delivery Station (if Necessary)]

National SAFER Response Centers in service for Susquehanna Procedures:

BWROG issue Emergency Procedure and Severe Accident Guidelines (EPGs/SAGs)

Rev. 3 Procedures Complete Unit 2 FLEX Implementation (including FSGs and maintenance)

Procedures Complete Unit 1 FLEX Implementation (including FSGs and maintenance)

Training:

Develop Training Plan Training Complete Unit2 FLEX Implementation Unit 1 FLEX Implementation Target Completion Date May 2015 December 2014 February 2013 April 2015 April 2016 May 2014 February 2016 April 2015 April 2016 Activity Status Complete Complete Complete Complete Complete (except HCVS, see Ref. 8.11) Complete Complete (except HCVS, see Ref. 8.11) Complete*

Complete (except HCVS, see Ref. 8.11) Enclosure 1 to PLA-7632 Page 4of12 Revised Target Completion Date Feb 2015 May 2015 April 2016 May 2015 Target Milestone Completion Date Full Site FLEX April 2016 Implementation (except HCVS) Unit 2 Severe Accident April 2017 Capable Hardened Containment Vent System Phase 1 Unit 1 Severe Accident April 2018 Capable Hardened Containment Vent System Phase 1 Unit 1 Severe Accident April 2018 Capable Hardened Containment Vent System Phase 2 Unit 2 Severe Accident April 2019 Capable Hardened Containment Vent System Phase 2 August2019 (after HCVS Submit Completion Report Order actions are complete per Ref 8.11)* Enclosure 1 to PLA-7632 Page 5of12 Revised Activity Target Status Completion Date Complete (except Ul HCVS, see Ref. 8.11) Complete*

Design Complete*, Non-Outage Installation Started Design Started, Implementation Not Started Design Started, Implementation Not Started Not Started *Revised since the six month update submitted February 9, 2017 (Reference 8.18)

4. Changes to Compliance Method Enclosure 1 to PLA-7632 Page 6of12 NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging,-or installing of equipment needed for the strategies.

Reference

8.1 provided

Susquehanna's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions. The Reference

8.1 enclosure

describes Susquehanna's Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification is required to install a Hardened Containment Vent System. Thus the Susquehanna response to NRC Order EA-12-049 provided in Reference 8 .1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

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

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved as described in Reference 8.8. This relaxation was granted in Reference 8.11. Unit 2 now has a fully functional Wetwell Hardened Containment Vent, so Unit 2 is now in full compliance with the NRC Order EA-12-049 (Reference 8.19). 5. Need for Relief/Relaxation and Basis for the Relief/Relaxation Susquehanna expects to comply with NRC Order EA-12-049, but needs relaxation of the implementation dates. The specific details have been submitted in a separate document (Reference 8.8). NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

Reference

8.1 provided

Susquehanna's response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-12-050 will also Enclosure 1 to PLA-7632 Page 7of12 affect implementation of the Mitigation Strategies NRC Order EA-12-049 actions. The Reference

8.1 enclosure

describes the Susquehanna Mitigation Strategies that is based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System is required.

Thus Susquehanna's NRC Order EA-12-049 response provided in Reference 8 .1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

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

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 8.1 for Susquehanna Units 1 and 2 will not be achieved until compliance with NRC Order EA-13-109 is achieved.

Relaxation of the NRC Order EA-12-049 IV.A.2 requirements is required and has been requested (Reference 8.8). This relaxation was granted in Reference 8.11. Unit 2 now has a fully functional Wetwell Hardened Containment Vent, so Unit 2 is now in full compliance with the NRC Order EA-12-049 (Reference 8.19). 6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary and status as of December 30, 2016 of the open items documented in the Overall Integrated Plan and ISE. The Open Item and Confirmatory Items identified in the ISE will be addressed by the Regulatory Audit Process. The NRC performed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies issues. Overall Integrated Plan Open Item Status 1. Phase 3 Shutdown Cooling Capability Complete 2. EOP changes required to support Complete Mitigation Strategies.

Overall Integrated Plan Open Item 3. Develop SSES "Response Plan" for use of the National SAFER Response Centers (NSRC). 4. FLEX Equipment Storage 5. Review GEH Report NEDC 33771P, GEH Evaluation of FLEX Implementation Guidelines and identify exceptions to the report as required in Attachment lB. 6. Determine appropriate use ofRCIC or FLEX pump mitigation strategy if ELAP occurs when operating in Mode 4 and when transitioning to mode 3. 7. Evaluate the impact ofRCIC pump seal failures.

EC-050-1034, Rev. 0 approved 12/13/2013'

8. Evaluate potential RCIC pump modifications.
9. Establish method of venting the Refuel Floor. EC-012-6122, Rev 0 approved on 4/29/2014.
10. Evaluate means to assure continued long term gas supply for ADS/SRVs.
11. Evaluate means to transfer diesel fuel oil from storage tanks to the diesel fueled equipment.
12. Evaluate the effects of injecting Spray Pond water (UHS) to the RPV over a long period.oftime of72 hours or longer. . Enclosure 1 to PLA-7632 Page 8of12 Status Complete Complete Complete Complete Complete Complete Complete Complete Complete Complete Overall Integrated Plan Open Item . 13. The calculation EC-030-1006, Rev 14, Control Structure Temperature Response to a Station Blackout or Fire Induced Loss of Control Structure HV AC was performed.

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

The calculation has now been reviewed and approved.

14. The calculation EC-SBOR-0504, Rev 6, Reactor Building Heatup Analysis during Station Blackout was performed.

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

Revision 7 of this calculation was approved on 3/20/2014.

Appendix 0 was added to identify and evaluate mitigating measures that could be implemented to enhance Switchgear and Load Center Room cooling, as needed, for time > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 15. Fuel consumption and refuel intervals will be determined during the procurement process for the 4160V AC generators.

Enclosure 1 to PLA-7632 Page 9of12 Status Complete Complete Complete *Revised since the six month update submitted February 9, 2017 (Reference 8.18) 7. Potential Draft Safety Evaluation Impacts None -Susquehanna received the ISE and closed the Open Item and Confirmatory Items via the audit process. The NRC performed the Mitigation Strategies and Spent Fuel Pool Level Instrumentation Audit at Susquehanna the week of December 8th, 2014. During the Audit Exit meeting the NRC considered all Mitigation Strategies related items to be closed. The NRC's Audit Report documented the closure status of the Mitigation Strategies issues.

8. References Enclosure 1 to PLA-7632 Page 10of12 The following references support the updates to the Overall Integrated Plan described in this enclosure:

8.1 PLA-6981, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2013. 8.2 NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012. 8.3 NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August, 2012. 8.4 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. 8.5 PLA-7072, "Request for Implementation Date Relief in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2013. 8.6 NRC Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013. 8.7 PLA-7071, "First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013. 8.8 PLA-7134, "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'" dated February 2014. 8.9 NRC Letter from J. S. Bowen to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1And2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0888 and MF0889)," dated January 24, 2014 (ADAMS# ML13339A764).

___J Enclosure 1 to PLA-7632 Page 11 of 12 8.10 PLA-713 7, "Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 28, 2014. 8.11 NRC Letter from E. J. Leeds to T. S. Rausch, "Susquehanna Steam Electric Station Units 1 and 2 -Relaxation of Certain Schedule Requirements for Order EA-12-049

'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,"'

dated April 15, 2014 (ML 14065A028).

8.12 PLA-7204, "Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 28, 2014. 8.13 PLA-7295, "Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated February 25, 2015. 8.14 PLA-7377, "Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 26, 2015. 8.15 NRC Letter from John D. Hughey to T. S. Rausch, "Susquehanna Steam Electric Station, Units 1 and 2 -Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-12-051 (TAC NOS. MF0888, MF0889, MF0890 and MF0891)" dated April 13, 2015 (ML15089A123).

8.16 PLA-7438, "Six.th 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 (NRC Order EA-12-049);" dated Fel?ruary 18, 2016. 8.17 PLA-7513, "Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)," dated August 19, 2016. 8.18 PLA-7570, "Eighth 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 (NRC Order EA-12-049)," dated February 9, 2017 Enclosure 1 to PLA-7632 Page 12of12 8.19 Talen Letter (PLA-7610), "Report Of Full Compliance For Unit 2 With March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Design-Basis External Events (NRC Order EA-12-049)," dated May 31, 2017.

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