L-14-025, Firstenergy Nuclear Operating Companys 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-
| ML14058A666 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse, Perry |
| Issue date: | 02/27/2014 |
| From: | Belcher S FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, L-14-025, TAC MF0841, TAC MF0842, TAC MF0961, TAC MF0962 | |
| Download: ML14058A666 (21) | |
Text
FENOC t
76 South Main Sfreef Akron. Ohio 44308 Samuel L. Belcher Senior Vice President and Chief Operating Officer February 27,2014 L-l4-025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-60 Docket No. 50-412, License No. NPF-T}
Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NpF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-S8 FirstEnersy Nuqlear Operatinq Company's (FENOC's)
Sqgond Six-Month Status,Report in Response to March 12, 2012 Commission Order Modifyino Licenses with Resard to ReQuirements for Mitiqation Strateoies for Beyond-Dqqign:Basis External Events (9,fde,t Number FA-12-,049)
And Relief/Relaxation Request (TAQ Nos. MFg841, MF08{2.
MF0961.
and MF0962)
On March 12,2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference 1) to FENOC. Reference 1 was immediately effective and directs FENOC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.
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 lV, Condition C. Referen ce 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-06, Revision 0 (Reference
- 3) with clarifications and exceptions identified in Reference
- 2. Reference 4 provided the FENOC initial status report regarding mitigation strategies. Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS),
and Perry Nuclear Power Plant (PNPP).
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the second
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-14-025 Page 2 six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference
- 1. The attached reports for BVPS, DBNPS, and PNPP (Attachments 1,2, and 3, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
As described in the BVPS status report (Attachment 1), FENOC plans to request relief/relaxation of the Reference 1 requirement for completion of full implementation for Unit No. 1 until the fall of 2016 to allow for reactor coolant pump shutdown seal installation.
The request is being submitted under a separate letter.
This letter contains no new regulatory commitments.
lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February e1,2014.
Respectfu lly subm itted, Samuel L. Belcher Attachments:
- 1.
Beaver Valley Power Station Second Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Davis-Besse Nuclear Power Station Second Six-Month Status Report for the f mplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Perry Nuclear Power Plant Second Six-Month Status Report for the f mpfementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirenrents for Mitigation Strategies for Beyond-Design-Basis External Events
References:
- 1.
NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2412 2.
3.
2.
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nucfear Power Plant L-14-025 Page 3 cc:
NRC f nterim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29,2412 NEI 1 2-06, Diverse and Flexible Coping Strategies (FLEX) lmplementation
- Guide, Revision 0, dated August 2012 FirstEnergy Nuclear Operating Company's (FENOC's) Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated October 26,2012 FirstEnergy Nuclear Operating Company's (FENOC'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-1 2-049), dated February 27,2013 Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS)
NRC Resident Inspector (DBNPS)
NRC Resident Inspector (PNPP)
NRC Project Manager (BVPS)
NRC Project Manager (DBNPS)
NRC Project Manager (PNPP)
Ms. Jessica A. Kratchman, NRFyJLD/PMB, NRC Director BRP/DEP (without Attachments)
Site BRP/DEP Representative (without Attachments)
Utility Radiological Safety Board (without Attachments) 3.
4.
5.
L-14-025 Beaver Valley Power Station Second Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 7 1
Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for BeaverValley Power Station, Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 MilestoneAccomplishments The following milestone(s) have been completed since July 19,2013 and are current as of January 31,2014.
Completed the Unit 1 plant modifications targeted for 1R22 (fall 2013 refueling outage).
3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt 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 d eveloped.
The revised milestone target completion dates do not impact the order implementation date.
Attachment 1
L-14-A25 Page 2 of 7 Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Gompletion Date Submit FLEX lntegrated lmplementation Plan 02t28113 Complete 6 Month NRC Status Updates 08128115 Started Update 1 jgt2gl13 Complete Update 2 02128114 Started Update 3 08128114 Not Started Update 4 02127115 Not Started Update 5 08128115 Not Started Gomplete FLEX Strategy Review March-2013 Complete Validation February-2015 Not Started Wal k-through s or Demonstrations February-2015 Not Started Gomplete Staffi ng Analysis Novemb er-2014 Started Submit NEI 12-01 Phase 1 Staffinq Studv April-2013 Complete Submit NEI 12-01 Phase 2 Staffinq Studv Novem b er-2014 Started Complete Plant Modifications November-2015 Started Target pl ant mod ificafions April-2013 Complete Unit 1 Modifications complete Mav-2015 Started Complete 1 R22 outase modificafions November-2013 Complete Complete on-line mod ifications Februarv-2015 Started Complete 1 R23 outaqe modifications Mav-2015 Started Unit 2 Modifications complete November-2015 Started Complete 2R1 7 outaqe modificafrons Mav-2014 Started Com plete on-l i ne modifications Auqust-2015 Started Complete 2R1 B outage modificafions November-2015 Started FLEX Storage Complete March-2015 Started Complete Buildinq Desiqn Decemb er-2013 Started June-201 4
Commence Construction June-2014 Not Started Complete Construction March-2015 Not Started River (UHS) Access Complete October-2014 Started Fence & Gate Modification Desiqn February-2014 Started New Fence & Gate Construction Auqust-2014 Not Started Securitv Barrier Pipe Penetrations Desiqn Ja n ua rv -2014 Started March-2014 Security Barrier Pipe Penetration Construction October-2014 Not Started On-site FLEX Equipment Decemb er-2414 Started Confirm FLEX Equipment Requirements Novem b er-2013 Completed FLEX Equipment Ordered Decemb er-2013 Started June-2014 FLEX Eq uipment Del ivered Decemb er-2014 Not Started Off-site FLEX Equipment April-2015 Started Develop Strategies with RRC June-2014 Started Phase 3 SrTe Access Strateqies in Place October-2A14 Started Complete Near Sife Sfaging Location (as needed)
April-2015 Not Started Procedures Complete Decemb er-2014 Started PWROG issues NSSS-sp ecific suidelines June-2013 Complete
/ssue Beaver Vallev FSG June-2014 Started
Attachment 1
L-14-025 Page 3 of 7 4
Changes to Gompliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC intends to request relief/relaxation of the Reference 2 requirement for completion of full implementation for Beaver Valley Power Station Unit No. 1 (BVPS-1 )
by the spring of 2015. As described in the OlP, some requirements of the mitigation strategies are dependent upon installation of Westinghouse low leakage reactor coolant pump (RCP) shutdown seals (SHIELD@
seals). Due to the need to enhance the design of these seals, FENOC intends to request relief/relaxation of the requirement for completion of full implementation at BVPS-1 until the fall of 2016 for RCP shutdown seal installation. This would allow two refueling outages to install all three enhanced RCP shutdown seals at BVPS-1.
Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe Interim Staff Evaf uation (lSE) (Reference 3) and the status of each item.
Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Gompletion Date
/ssue Maintenance Procedures December-2014 Not Started Training Gomplete April-2015 Started Develop Traininq Plan Septemb er-2014 Started lmplement Training April-2015 Not Started Submit Completion Report November-2015 Not Started Overall Integrated Plan Open ltem Status Ol 1. Finalize the location of the FLEX storage building. The deployment routes, distances, and times provided in this report are bounded for the currently proposed locations but will be updated as necessary.
Complete. The storage building will be located at the alternate proposed storage building location between the Unit 1 diesel generator building and the switchyard, consistent with the original OlP.
Deployment routes, distances and times are unaffected.
Ol 2. Perform containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.
Started. A MAAP-DBA calculation based on low leakage RCP seals is in progress and is expected to be completed by June 2414.
Based on current bounding
Attachment 1
L-14-025 Page 4 of 7 ISE Confirmatory ltem Status 3.1.1.4.A Confirm that primary and secondary staqinq areas for the RRC lreqional response Not started.
Overall Integrated Plan Open ltem Status assessment and prelinrinary results, containment integrity and instrument function are not chalfenged for at least six days.
Ol 3. Modify the RWST [refueling water storage tankl at each unit to protect it from tornado missiles or identify a borated source that is protected from tornados and can be utilized to provide core cooling when steam generators are not available.
Complete. RWSTs are desired but not required to implement the baseline FLEX strategy.
For RCS inventory/boration, the water sources are the boric acid storage tanks with inventory loss limited by low leakage RCP seals. The preferred water sources for make up to the SFPs, if needed, are the RWSTS.
However, the Ohio River is considered protected against all hazards and would be used if both RWSTs were not available.
Interim Staff Evaluation Open ltem Status 3.2.1.6.A Verify that the TDAFW [turbine driven auxiliary feedwater] pump exhaust stacks are adequately protected from tornado missile hazards.
Started.
3.2.1.8.A Verify resolution of the generic concern associated with the modeling of the timing and uniformity of the mixing of a liquid boric acid solution injected into the RCS [reactor coolant system] under natural circulation conditions potentially involving two-phase flow.
Complete. The analyses and evaluations supporting the OIP demonstrate that the FLEX RCS makeup pump is being implemented more than one hour prior to the loop flow rate decreasing below the loop flow rate corresponding to single-phase natural circulation for the assumed highest applicable leakage rate of 4 gpm at normal operating pressure and temperature for the reactor coolant pump seals and unidentified reactor coolant system leakage.
Attachment 1
L-14-025 Page 5 of 7 ISE Confirmatory ltem Status centerl equipment have been selected and will meet the requirements of the applicable site response plan.
3.1.2.4.4 Confirm that the primary and secondary staging areas have been identified and that the plan for the use of offsite resources will comply with NEf 12-06, Section 6.2.3.4 regarding the need to evaluate for flooding hazard This confirmation should include a description of the methods to be used to deliver the equipment to the site.
Not started.
3.1.3.1.A Confirm that the location of the storage and protection building for FLEX equipment has been identified. Confirm that the FLEX storage building is designed to withstand tornado missiles at a level equal to, or greater than, the plant's tornado missile design basis.
Started.
3.1.3.4.A Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06, Section 7.3.4 regarding high wind hazards.
Not started.
3.1.4.4.4 Confirm that the licensee's plan for the use of offsite resources would provide reasonable assurance that the plan will comply with NEI 12-06 Section 8.3.4 regarding snow, ice and extreme cold hazards.
Not started.
3.2.1.1.A Confirm that the licensee has verified that reliance on the NOTRUMP code for the ELAP
[extended loss of AC power] analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. This includes specifying an acceptable definition for reflux condensation coolinq.
Not started.
3.2.1.1.8 Confirm that the application of the WCAP-176A1 analysis simulating the ELAP transient is properly established.
Not started.
3.2.1.2.4 Confirm that, if the licensee continues to credit SHIELD shutdown seals, as planned, (e.9.,
1 gallon per minute leakage/seal) in the ELAP analyses for the RCS response, then the impacts of the Westinghouse 10 CFR ParI21 report, "Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21 :'dated July 26,2013 (ADAMS Accession No. ML13211A168) on the use of the low seal leakage rate in the ELAP analysis are addressed.
Started.
Attachment 1
L-14-025 Page 6 of 7 ISE Confirmatory ltem Status 3.2.1.2.8 Confirm that if the seals are changed, the acceptability of the seals used is addressed, and the RCP seal leakage rates for use in the ELAP analysis are iustified.
Not started.
3.2.2.A Since the RWSTs are not currently fully protected against tornado missiles, confirm that the licensee has completed their review to determine whether or not the RWST will need to be further protected against missile hazards.
Complete. See Ol 3 above.
3.2.2.8 Confirm that opening doors provides adequate ventilation for SFP lspent fuel pooll area.
Not started.
3.2.3.A Confirm that containment evaluations for all phases are performed based on the boundary conditions described in Section 2 of NEI 12-06.
Based on the results of this evaluation, confirm that required actions to ensure maintenance of containment integrity and required instrument function have been developed.
Not started.
3.2.4.2.4 Confirm that the licensee has clarified why the Integrated Plan stated the maximum temperature of the Unit 1/Unit 2 AFW [auxiliary feedwaterl pump rooms would reach 115.91112.3 degrees Fahrenheit ('F), respectively, while Cafculation 8700-DMC-2312, described during the audit process, indicated that the maximum temperature would reach 142.9"F.
Not started.
3.2.4.2.8 Confirm that the licensee has provided an analysis or calculation to demonstrate that the dissipation of heat generated by the batteries via natural circulation will be adequate to maintain the temperatures in the battery rooms within acceptable levels.
Started.
3.2.4.2.C Confirm that the licensee has addressed how hydrogen concentration in the battery rooms will be limited to acceptable levels.
Started.
3.2.4.6.4 Confirm that the licensee has completed a review of Unit 1 AFW room and developed any plans required to maintain a suitable environment.
Not started.
3.4.A Confirm that the licensee has fully addressed considerations (2) through (10) of NEI 12-06, Section 12.2, Minimum Capability of Off-Site Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.
Not started.
L-14-025 Page 7 of 7 7
Potential Interim Staff Evaluation lmpacts There are no potential impacts to the ISE identified at this time.
8 References The following references support the updates to the OIP described in this attachment.
- 1. FirstEnergy Nuclear Operating Company's (FENOC's) Overall lntegrated 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-1 2-049), dated February 27,2013.
- 2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.
- 3. Beaver Valley Power Station, Units 1 and 2 - lnterim Staff Evaluation Related To Overall Integrated Plan In Response To Order EA-1 2-049 (Mitigation Strategies),
dated January 29,2014.
L-14-025 Davis-Besse Nuclear Power Station Second Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 3 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),
documenting the diverse and flexible strategies (FLEX), in response to Reference2.
This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 MilestoneAccomplishments The following milestone(s) have been completed since July 19,2013 and are current as of Janu ary 31, 201 4.
o PWROG issued NSSS-specific guidelines.
3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt 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.
Attachment 2
L-14-025 Page 2 of 3 Milestone Target Gompletion Date Activity Status (as of 11311141 Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Complete 6 Month NRC Status Updates 02128116 Started Update 1 08128113 Complete Update 2 02128114 Started Update 3 08128114 Not Started Update 4 02127115 Not Started Update 5 08128115 Not Started Update 6 02128116 Not Started Validation April-2016 Not Started Wal k-th ro uq h s or De m o n stratio n s April-2016 Not Started Complete Staffinq Analvsis October-2015 Not Started Submit NEI 12-01 Phase 2 Staffins Studv October-2015 Not Started Complete Plant Modifications April-2016 Started Tarqet plant modifications Mav-2013 Complete Mod ifications com plete April-2016 Started Complete 1 R1 B outase modifications June-2014 Complete*
Complete on-l ine mod ifications February-2016 Started Complete 1 Rl9 outaqe modificafrons April-2016 Started Com pl ete Com m u n ication s Modificafions April-2016 Started Complete SFP Level lndication Modifications April-2016 Started FLEX Storage Complete April-201 6
Not Started Complete Buildinq Desiqn Decemb er-2014 Not Started March-2015 Commence Construction June-2015 Not Started Complete Construction April-201 6
Not Started On-site FLEX Equipment April-201 6
Started Confirm FLEX Equipment Requirements January-2014 Started Julv-2014 FLEX Equipment Ordered Januarv-2015 Not Started FLEX Eq uip ment Delivered April-2016 Not Started Off-site FLEX Equipment April-2016 Started Develop Sfrafeqie s with RRC June-2014 Started Auqust-2015 Phase 3 Sife Access Strateqies in Place April-2016 Not Started Complete Near Sife Sfaging Location (as needed)
April-2016 Not Started Procedures Complete April-2016 Started PWROG issues NSSS-sp ecific quidelines Auqust-2013 Complete
/ssue Davis-Besse FLEX Strategy Guidelines June-2015 Not Started
/ssue Maintenance Procedures April-2016 Not Started Training Complete April-201 6
Not Started Develop Traininq Plan Seotemb er-2015 Not Started lmplement Training April-201 6
Not Started Submit Completion Report April-2016 Not Started
- Modifications are targeted for 1R19 and on-line; none targeted for 1R18.
L-14-025 Page 3 of 3 4
Ghanges to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.
6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (lSE) and the status of each item.
Interim Staff Evaluation Open ltem Status N/A N/A 7
Potential Interim Staff Evaluation lmpacts There are no potential impacts to the ISE identified at this time.
I References The following references support the updates to the OIP described in this attachment.
- 1. FirstEnergy Nuclear Operating Company's (FENOC's) Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requrrements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),
dated February 27,2013.
- 2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.
Overall Inteqrated Plan Open ltem Status Ol 1. Finalize locations for FLEX storage buildings.
Deployment routes, distances and times contained in the submittal are bounded for the currently proposed locations but will be updated as necessary.
Started.
Ol 2. Finalize the strategy for providing a protected source of borated water to support FLEX strateqies.
Started.
Ol 3. Determine if a mobile boration unit and/or water purification unit is required to support the FLEX strategies.
Started.
L-14-025 Perry Nuclear Power Plant Second Six-Month Status Report for the lmplementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Page 1 of 8 1
Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.
2 Milestone Accomplishments The following milestone(s) have been completed since July 19,2013 and are current as of January 31,2014.
o Completed development of EOP Training Plan.
3 Milestone Schedule Status The following provides an update to Attachment 2 of the OlP. lt 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.
Attachment 3
L-14-025 Page 2 of 8 Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Completion Date Submit FLEX Integrated lmplementation Plan 02t28t13 Complete 6 Month Status Updates 02127115 Started Update I 08/01
/1 3 Complete Update 2 02128114 Started Update 3 08128114 Not Started Update 4 02t27 t15 Not Started FLEX Strategy Review Mav-201 3 Complete Validation March-2015 Not Started Wal k-thro u g h s or D e m o n strati o n s March-2015 Not Started Gomplete Staffinq Analvsis October-2014 Not Started Gomplete Plant Modifications March-2O15 Started Target plant modifications Mav-2013 Complete Complete on-line modifications Decem b er-2014 Started Complete 1 R1 5 outaqe modifications March-2O15 Started FLEX Storase Januarv-2015 Started Complete Unit 2 Aux Building for storage and Use Januarv-2015 Started Convert Unit 2 diese/ Building for storage and Use January-2015 Started Lake (UHS) Access Novemb er-2014 Started Regrade road to barge slip area October-2014 Not Started Fence & Gate Construction modifications October-2014 Not Started Securitv Barrier Pipe Penetrations Desiqn Februarv-2014 Started Security Barrier Pipe Penetration Construction Novemb er-2014 Not Started On-site FLEX Equipment October-2014 Started Ordered November-2413 Started March-2014 Delivered October-2014 Not Started Off-site FLEX Equipment March-2015 Not Started Develop Strateqies with RRC June-2014 Not Started Complete Near SrTe Sfaging Location (as needed)
March-2015 Not Started Phase 3 Sffe Access Strateqies in Place Novemb er-2014 Not Started Procedures March-2015 Started lmplement EPG/SAG Rev 3 Guidance Auqust-2014 Started Create Perrv FSG Mav-2014 Started lmplement Perrv FSG March-2015 Not Started Create Maintenance Proced ures Julv-2014 Not Started Training March-2015 Started Develop EOP Trainins Plan Januarv-2014 Complete lmplement EOP Training March-2015 Started Develop SAMG Traininq Plan Januarv-2014 Not Started June-2014 lmplement SAMG Traininq March-2015 Not Started Develop FLEX Training Plan Auqust-2014 Started
Attachment 3
L-14-025 Page 3 of B 4
Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.
6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe Interim Staff Evaluation (lSE) (Reference 3) and the status of each item.
Overall Integrated Plan Open ltem Status N/A N/A Interim Staff Evaluation Open ltem Status 3.2.1.7.4 FENOC has not indicated their intent to follow the provisions of the NRC-endorsed NEI position paper on Shutdown/Refueling Modes that describes how licensees will develop and maintain an appropriate plan for mitigating strategies capability in all plant modes (ADAMS Accession Nos. ML13273A514 and ML13267A382). FENOC should either confirm that PNPP will follow the endorsed guidance, or provide an alternate approach acceptable to the NRC staff.
Complete. FENOC intends to follow the N RC-endorsed guidance contained in the NEI position paper on S h utdown/Refuel i ng fModes.
ISE Confirmatory ltem Status 3.1.1.3.A FENOC indicated that the gravity discharge system passively performs the mitigation of groundwater instrusion. lt was not clear how the passive portion of this system will maintain groundwater elevation below the 590 foot elevation with no pumping power when the flood level around the plant may be at the 620 foot elevation. The licensee needs justification for goundwater mitigation durinq floodinq conditions.
Not started.
Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Gompletion Date I mplement FLEX Training March-201 5
Not Started Submit Gompletion Report March-2O1 5
Not Started
Attachment 3
L-14-025 Page 4 of 8 ISE Confirmatory ltem Status 3.1.1.4.4 With regard to offsite resources, the licensee will develop a plan that will address the logistics for equipment transportation, area set up, and other needs for ensuring the equipment and commodities to sustain the site's copinq strateqies.
Not started.
3.1.2.1.A During the audit, the licensee was requested to provide the elevations of FLEX equipment that will be deployed or staged across the site. In response, the licensee stated that the flooding re-analysis will need to be reviewed to determine the potential impacts. Confirm the location of FLEX equipment that will be deployed or staged is finalized with that consideration.
Not started.
3.2.1.1.A Benchmarks must be identified and discussed which demonstrate that Modular Accident Analysis Program (MAAP) is an appropriate code for the simulation of an ELAP [extended loss of AC powerl event at PNPP, Unit 1, consistent with the NRC endorsement of the industry position paper on MAAP (ADAMS Accession No. ML132754318).
Not started.
3.2.1.1.8 Confirm that the collapsed reactor pressure vessel level remains above Top of Active Fuel and the reactor coolant system cool down rate is within technical specifications limits.
Not started.
3.2.1.1.C Confirm that MAAP is used in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.
Not started.
3.2.1.1.D Confirm that, in using MAAP, the licensee identifies and justifies the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP Application Guidance, Desktop Reference for Using MAAP Software, Revision 2" (Electric Power Research Institute Report 1020236).
Not started.
3.2.1.2.4 Calculations prepared in support of the licensee's Integrated Plan determined the required Phase 1 flow rate needed to stablilize boil-off, using suppression pool water, was well within the RCIC
[reactor core isolation cooling] System injection capacity of 700 gallons per minute. The licensee indicated that further information regarding the specific assumptions and calculations for quantification of inventory losses are captured in proprietary analysis used for Integrated Plan preparation. The licensee should demonstrate adequate RCIC capacity.
Not stafted.
Attachment 3
L-14-025 Page 5 of 8 ISE Gonfirmatory ltem Status 3.2.1.3.4 The licensee stated that Boiling Water Reactor Owners Group Emergency Procedure Guideline/Severe Accident Guideline, Revision 3, would allow the temperature limit of the suppression pool to be exceeded. The licensee should demonstrate why exceeding this temperature limit is acceptable for PNPP.
Not started.
3.2.3.A Confirm that containment response calculation is completed, commensurate with the level of detail contained in GE Hitachi Report NEDC-33771P/NED0-33771
, Revision 1, "GEH Evaluation of FLEX lmplementation Guidelines,"
ADAMS Accession No. ML130370742.
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3.2.3.8 The licensee should provide results from the successful completion of the evaluations and possible modifications which demonstrate that the Suppression Pool Cleanup pump and piping are seismically "robust".
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3.2.4.2.4 lt is not clear that (1) the assumed temperatures of the various critical rooms, e.9.,
RCIC Room and Control Room, are adequately evaluated for the potentially high temperature that may occur in these areas or that (2) time critical actions are not required to be taken to maintain equipment functionality or personnel habitability limits. Confirm that these analyses/evaluations are completed.
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3.2.4.2.8 The licensee provided insufficient information on monitoring temperatures and hydrogen concentration levels in the battery rooms to ensure temperature and hydrogen concentration level are within acceptable level. Confirm that battery room temperature and hydrogen concentration remain acceptable.
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3.2.4.4.4 Confirm that the proposed communications upgrades in the licensee's communications assessment are completed as planned.
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3.2.4.7.4 The licensee should confirm that the quality of water injected into the reactor pressure vessel supports and maintains acceptable long term core cooling.
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3.2.4.8.4 During the audit process, the licensee indicated that the basis for the minimum bus voltage for Division 1 and Division 2 batterv svstems is the Not started.
Attachment 3
L-14-025 Page 6 of 8 Potential Interim Staff Evaluation lmpacts FENOC is currently evaluating enhancements to the PNPP FLEX mitigating strategies to be employed for Phase 2 coping during a postulated Beyond-Design-Basis External Event (BDBEE), as described in the PNPP OlP. The supporting plant modifications required to employ these strategies are also under evaluation.
ISE Confirmatory ltem Status coil voltage required to operate the 4160 volt ac breakers (diesel generator output breakers) on the divisional busses and operation of Automatic Depressurization System SRV [safety relief valve]
solenoids. Confirm that the battery loading analyses considers the appropriate minimum voltage.
3.2.4.8.8 The applicable electrical drawing(s) provided during the audit process were not legible.
The licensee should provide a legible copy of electrical drawinqs for NRC staff review.
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3.2.4.8.C During the audit, the licensee indicated a
total load of 429 kilowatts for the FLEX diesel generator which does not appear to match the total sum of all the loads provided during the audit. The licensee should explain and/or resolve this discrepancy.
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3.2.4.9.4 With respect to refueling of deployed equipment, PNPP is currently evaluating the feasibility of either procuring a fuel trailer (trailer mounted tank with on-board pump mechanism),
or mounting a fuel tank within the bed of a heavy-duty truck, with appropriate pumping mechanisms. The licensee shoud provide a description of the final plans for refueling once these evaluations are complete.
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3.2.4.10.A The licensee should provide the battery dc load profile with the required loads for the mitigating strategies to maintain core cooling, containment, and spent fuel pool cooling.
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3.2.4.10.8 The licensee shoud provide the final load shedding procedure for review when it is completed.
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3.4.A The licensee did not address considerations 2 through 10 of NEI 12-06, Section 12.2, regarding offsite resources. This information should be confirmed and documented.
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Attachment 3
L-14-025 Page 7 of 8 As of January 31,2014, the following strategy enhancements are under evaluation:
Utilization of 4160VAC portable generators in lieu of the OIP-specified 480VAC units. The 4160VAC generators, if selected, would be used to power an existing safety-related Unit 2 4160VAC distribution bus. Provisions would be provided for cross-connecting this Unit 2 bus to corresponding Unit 1 4160VAC distribution buses, along with Unit 2 480VAC power as described in the PNPP OlP.
Utilization of an emergency spent fuel pool inventory make-up capability in accordance with the guidance of NEI 12-06 (reference Table C-3). The abilityto provide inventory make-up without accessing the refuel floor, utilizing hoses, or portable spray nozzles will be provided through the use of new plant piping and/or hose connection points. This approach would be used in lieu of a fixed overhead spray system as documented in the PNPP OlP.
Utilization of Phase 2 motor-driven pumps stored nearthe location of deployment within the emergency service water pumphouse (ESWPH), which is robust for all applicable hazards (seismic, flood, wind, missiles). The pumps establish suction/discharge via deployable hoses and utilizing water inventory available via the seismically robust plant intake/discharge structures. This approach would be used in lieu of deployable Phase 2 pumps (fire trucks) establishing suction/discharge at the PNPP barge slip.
Utilization of a closed loop containment cooling strategy for rejection of suppression pool excess heat via RHR heat exchangers utilizing process flow motive force provided by existing plant 480VAC pumps. Cooling water will be provided by existing emergency service water (ESW) system piping with cooling water supplied from pumps staged in the location of deployment in the ESWPH.
The changes described above are currently being reviewed internally by FENOC to ensure compliance with NEI 12-06 for the restoration of key safety functions. Once FENOC has conclusively determined these strategy changes to be in the best interest of preserving public health and safety while coping with beyond design basis events, FENOC intends to submit a revised OlP.
References The following references support the updates to the OIP described in this attachment.
- 1. FirstEnergy Nuclear Operating Company's (FENOC'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-1 2 -049), dated February 27,2013.
- 2. NRC Order Number EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12,2012.
L-14-A25 Page 8 of 8
- 3. Perry Nuclear Power Plant, Unit 1 - Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-1 2-49 (Mitigation Strategies), dated January 22,2014.