RS-15-057, February 2015 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)

February 2015 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)

ML15062A036
Person / Time
Site:	Nine Mile Point
Issue date:	02/19/2015
From:	Korsnick M Constellation Energy Nuclear Group, Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-057
Download: ML15062A036 (67)

Text

AMaria Korsnick A Exelon Generation.

• Senior Vice President. Northeast Operations Chief Nuclear Officer, CENG 100 Constellation Way Suite 500P Constellation Energy Nuclear Group, LLC Baltimore MID 21202 410-470-5133 Office 443-213-6739 Fax www.exeloncorp.com maria.korsnick@exeloncorp.com NRC Order No. EA-12-049 RS-15-057 February 19, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-410

Subject:

February 2015 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-1 2-049)

References:

(1) NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 12-049 (Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for Nile Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2 (NMP1 and NMP2). Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan.

Enclosures (1) and (2) provide the six-month Status Reports for NMP1 and NMP2, respectively.

The report updates the milestone accomplishments since the submittal of the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

There are no regulatory commitments contained in this letter.

If there are any questions regarding this letter, please contact Mr. Terry Syrell, Regulatory Assurance Manager, at (315) 349-5245.

U. S. Nuclear Regulatory Commission February 19, 2015 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1 9 th day of February 2015.

Respectfully, Mary G. Korsnick MGK/STD

Enclosures:

(1) NMP1 Six-Month Status Report (February 2015) for Mitigation Strategies for Beyond-Design-Basis External Events (2) NMP2 Six-Month Status Report (February 2015) for Mitigation Strategies for Beyond-Design-Basis External Events cc: Regional Administrator, Region I, USNRC NRC Project Manager, NRR - Nile Mile Point Nuclear Station NRC Senior Resident Inspector - Nile Mile Point Nuclear Station Director, Office of Nuclear Reactor Regulation J. A. Kratchman, NRC

ENCLOSURE (1)

NMP1 SIX-MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NINE MILE POINT NUCLEAR STATION, LLC February 19, 2015

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 1 Introduction The Nine Mile Point Unit 1 (NMP1) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2).

Subsequently, a supplement to the NMP1 OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis (if applicable).

Since the submittal of the last status report in August 2014 (Reference 11), NMP1 has progressed with engineering analysis, calculations, procedures and other activities that support the mitigating strategies and the modification concepts have been refined. Some changes to the mitigation strategies and planned modifications in support of the mitigation strategies have occurred and are explained within this document. Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued including review of proposed supporting equipment specifications that support NMP1 for FLEX Phase 3 and the development of the site specific SAFER Response Plan (SRP). The SRP is in the final review and approval phase.

By letter dated December 19, 2013, the NRC issued to the Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7). The Interim Staff Evaluation (ISE) contains open and confirmatory items for which Nine Mile Point will provide clarifying or additional information in Six Month Status Reports or compliance communications in order for the NRC to determine that the issues are satisfactorily resolved.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference

3) and are current as of January 16, 2015.

" Refueling Outage (RFO), including walk downs in support of pending modifications for installation for FLEX strategies (see status provided in 8/2013 OIP Update)

• Six Month Integrated Plan Progress Report submitted (Reference 6)

" Six Month Integrated Plan Progress Report submitted (Reference 8)

• Six Month Integrated Plan Progress Report submitted (Reference 11)

• Engineering and Design Completion - Equipment Storage Facility

• Engineering and Design Completion - Portable Equipment Connections 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMP1 OIP (References 1 and 3). 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. Any changes to the following target completion dates will be reflected in the notification of full compliance to the Commission.

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

Page 1 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of NMP1 FLEX OIP Milestones Revised Target Target Completion Completion Milestone Date Activity Status Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Implementation Plan February 2013 Complete Refueling Outage Spring 2013 Complete Six Month Integrated Plan Progress Report August 2013 Complete Engineering and Design Completion -

Equipment Storage Facility November 2014 Complete Six Month Integrated Plan Progress Report February 2014 Complete Engineering and Design Completion -

Portable Equipment Connections February 2014 Complete August 2014 Six Month Integrated Plan Progress Report August 2014 Complete Completed upon submittal Six Month Integrated Plan Progress Report February 2015 of this report Non-Outage Installation - Portable Equipment Connection March 201'5 Started Validation Walkdowns Complete March 2015 Started Portable Equipment Procedures Changes March 2015 Started FLEX Training April 2015 Started Outage Installation - Portable Equipment Connections May 2015 Not Started April 20151 Equipment Storage Facility Installation May 2015 Started April 20151 Final Implementation Notification to USNRC July 2015 Not Started June 2015 2 Note 1: Revised from previous NMP1 Six Month Status Report which identified May 2015. These activities are required to be completed for full implementation before startup from the spring 2015 refueling outage now scheduled to occur in April 2015.

Note 2: Revised from previous NMP1 Six Month Status Report which identified completion in May 2015. The new date reflects the Commission request to notify within 60 days of full implementation.

Page 2 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last Six Month Status Report. NMP1 will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures (References 9 and 10).

NMP1 will implement an alternative approach to the guidance in NEI 12-06 section 3.2.2 with regard to the amount of portable pump hoses maintained to support FLEX mitigation strategies.

As an alternative, the spare quantity of hose is adequate if it meets either of the two methods described below:

Method 1: Provide additional hose equivalent to 10% of the total length of each type/size of hose necessary for the "N" capability. For each type/size of hose needed for the "N" capability, at least 1 spare of the longest single section/length must be provided.

Method 2: Provide spare hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy.

For either alternative method, both the 'N' sets of hoses and the '+1' set of hoses will be kept in a location that meets the reasonable protection requirements for the site.

Basis for an alternative approach:

Hoses are passive devices unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided that the hoses are stored in areas with suitable environmental conditions. The hoses for the FLEX strategies will be stored and maintained in accordance with manufacturers' recommendations including any shelf life requirements. Initial inspections and periodic inspections or testing will be incorporated in the site's maintenance and testing program implemented in accordance with Section 11.5 of NEI 12-06.

Therefore, the probability of a failure occurring during storage is minimal, resulting in the only likely failure occurring during implementation. Mechanical damage will likely occur in a single section versus a complete set of hose. Therefore, the N+1 alternative addresses the longest individual section/length of hose.

Providing a spare hose of a length of 10% of the total length necessary for the "N" capability or alternatively providing spare hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy is sufficient to ensure a strategy can be implemented. Mechanical damage during implementation can be compensated for by having enough spares to replace any damaged sections with margin. It is reasonable to expect that an entire set of hoses would not be damaged provided they have been reasonably protected.

NMP1 will meet the guidance set forth in Method 1 described above.

Page 3 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS No other significant coping strategy changes have occurred since the previous Six Month Status Update provided on August 26, 2014 (Reference 11) 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation NMP1 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Table 2 provides a summary of the open items documented in the 0IP and those added in any subsequent Six Month Status Reports and the status of each item.

The following is a list of the open items from the 0IP that have been added, deleted or completed since the last Six Month Status Report with an explanation of the changes:

1. General Integrated Plan Elements BWR Open Item # 2: Evaluate deployment strategies and deployment routes for hazard impact.

This item is complete.

NMP has identified primary and alternate FLEX deployment routes, including hazard impacts for each route. Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been identified in the staffing study that has been performed and submitted to the Commission (Reference 12). Specifically, the staffing study provides for over two hours of dedicated debris removal time with a pay loader. A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

Open Item # 3: Evaluate requirements and options and develop strategies related to the storage on site of the FLEX portable equipment (including lighting tools such as flashlights and batteries) in accordance with the requirements of NEI 12-06 This item is complete.

Page 4 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The Nine Mile Point Nuclear Station is constructing a FLEX robust building (hereafter referred to as the 'FLEX building'). The FLEX building design meets or exceeds the most restrictive plant design requirements on site for external hazards. Thus, the FLEX building will meet the structural requirements in NEI 12-06 Revision 0, Section 5.3.1.1.a, 6.2.3.1.1.a, 7.3.1.1.a, 8.3.1.1.a and temperature requirements specified in NEI 12-06 section 9.3.1 for equipment protection.

Eventually, the sites FLEX storage buildings will consist of one FLEX building and one commercial building. The sites "N" and "+1" equipment will be stored in the robust FLEX building when the first unit on site (NMP1) implements NRC Order EA-12-049. The commercial building will be utilized for the sites "+1" equipment when the second unit (NMP2) implements NRC order EA-12-049. At that time, if NEI 12-06 Revision 1 has not been issued, Exelon Nine Mile Point Nuclear Station will submit an alternate approach.

FLEX portable diesel driven pumps and generators, as well as the refueling equipment for these vehicles, will be stored in the FLEX building. In addition, support equipment necessary for FLEX deployment shall be stored in the FLEX building including debris removal equipment and tow vehicles for FLEX portable diesel driven pumps and generators.

NMP1 Operations maintains an inventoried supply of flashlights and batteries that can be used in an emergency in the plant until the FLEX building equipment is retrieved.

For example, fire cabinets that include flashlights are located in multiple strategic locations and an Emergency Operating Procedure (EOP) tool box in the NMP1 MCR containing five (5) flashlights. FLEX building storage includes flashlights, headlights, batteries and other lighting tools routinely used by operators. The FLEX building will also contain a quantity of rechargeable LED battle lanterns to be used by operators within the plant when other lighting is insufficient. Periodic inventories of all equipment will ensure adequate amounts are maintained.

The FLEX building will be utilized to store other items deemed appropriate and necessary to respond to a beyond-design basis (BDB) event. Examples of these items include (this is a partial list for illustration only and does not include all material to be stored in the FLEX building);

" Tool boxes with general tools such as hammers, wrenches, and screw drivers

" Extension cords (multiple lengths and sizes)

• Heavy duty cold weather gear (coats, boots, hats, gloves)

• Personal Protective Equipment (safety glasses, hearing protection)

• Ice shelters and heaters

• Drinking water (small amount to be used for initial deployment staff)

Open Item # 4: Exceptions for the site security plan or other (license/site specific

- 10 CFR 50.54x) requirements of a nature requiring NRC approval will be communicated in a future Six Month Update following identification This item is complete.

Page 5 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Nine Mile Point Nuclear Station Unit 1 mitigation strategies are final and do not require specific exceptions to the site security plan or other license/site specific requirements of a nature requiring NRC approval.

Open Item # 14: Establish deployment routes from FLEX equipment storage location to connection points (including hazard impacts)

This item is complete.

Primary and alternate deployment paths have been identified and maps have been developed. Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been identified in the staffing study that was performed and submitted to the Commission (Reference 12). Specifically, the staffing study provides for over two hours of dedicated debris removal time with a pay loader. A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

As an example, an alternate deployment route south of NMP1 is available. A hazard that exists for this route is associated with an overhead line falling and impeding access. In this case, verification of line status (i.e. de-energized) is available locally from observation (and manual operation if necessary) of the high voltage disconnects located in the switchyard in the immediate vicinity, and at the high voltage breakers inside the unit at the switchgears.

Open Item # 15: Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site SAFER Staging Area "C" This item is complete.

Local Staging Area 'C' is defined as the regional airport outside of the 25 mile radius of the site. SAFER has made appropriate arrangements to provide requested portable FLEX equipment to Staging Area "C" (Syracuse Hancock International Airport). At this point, the equipment will be made ready for transport to the site by either roadway or air transport using helicopters.

The Nine Mile Point Nuclear Station has entered into a Memorandum of Understanding (MOU) with Syracuse Hancock International Airport for utilization of the facilities as a Staging Area (i.e. Staging Area 'C') in an emergency. SAFER has put in place appropriate contracts to transport the FLEX equipment from Staging Area 'C' to the NMP site Staging Area 'B' either by truck or air (helicopter). The Primary and Alternate truck transport routes are contained in Chapter 5 of the NMP SAFER Response Plan.

Open Item # 16: Establish a suitable local staging area for Phase 3 portable FLEX equipment to be deployed on site SAFER Staging Area "B" This item is complete.

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ENCLOSURE (I)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Staging Area 'B' is defined as the site delivery and preparation area outside the site Protected Area where the SAFER FLEX equipment is delivered and prepared for use (e.g., unloaded, assembled, and fueled) prior to transport to its final location on site for use. At NMP, this area is the site parking lot located south of the P-building, adjacent to the Site Access Building. Two alternative locations are available on site including the turn-around large parking area south of the Owner Controlled Area entrance point and the Nuclear Learning Center parking lot. These areas were identified and deemed acceptable during the SAFER Rehearsal of Concept meeting at Nine Mile Point in January 2014.

Open item # 17: Provide the necessary storage facilities in order to provide fuel to the transfer pumps during an ELAP event This item is complete.

NMP1 portable equipment refueling strategies for FLEX include use of gasoline engine driven fuel oil transfer pumps. These transfer pumps are capable of taking suction on the installed safety related (SR) fuel oil storage tanks on site and pumping fuel oil into smaller tanks reserved and dedicated for transporting fuel oil to the portable equipment.

The gasoline for the fuel oil transfer pumps exist in sealed storage cells providing an extended shelf life. The gasoline is to be stored in approved fire resistant storage cabinets. The fire resistant cabinets and fuel will be located in the FLEX building so that they are preserved for deployment.

Open Item # 24: Evaluate potential soil liquefaction for Nine Mile Point site considering final storage location of FLEX portable equipment and deployment routes established for this equipment This item is complete.

A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

Open Item # 26: Evaluate NMP1 containment integrity for Phases I through 3 and provide analysis in a future required Six Month Status Report (new Open Item added since original OIP as a result of further considerations of necessary analysis to support FLEX strategies)

This item is complete.

Plant specific analysis demonstrates that the primary containment parameters (average temperature, pressure, level) remain at acceptable levels for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an ELAP.

Page 7 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Although Drywell air space temperature for areas high in the containment and Torus air space temperature exceeds the design limit, the overage is relatively small (approximately 10'F) and is well within design safety margins. At the end of the analysis period, these parameters are relatively stable and are not expected to rise significantly beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Overall, this results in an insignificant challenge to the containment integrity. Increases in Drywell average air temperature and pressure and Torus air space pressure and temperature are continuing at a decreasing rate after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, with substantial overall margin remaining to limits that require further action.

Should containment parameters eventually reach the level that require containment venting, as required by EOPs, existing vent pathways may be utilized. Procedure direction and appropriate equipment is available in order to implement containment venting. It is reasonable to expect that this will alleviate any further challenge to containment integrity.

2. Maintain Core Cooling - BWR Installed Equipment Phase I Open Item # 28: Perform an evaluation to ensure that the recirculation pump seal operating conditions are consistent with the referenced vendor test report This item is complete.

In the 1990's, laboratory testing of the CAN2A recirculation pump seals was performed.

The recirculation pump seal station blackout test reports document the recirculation pump seal performance under loss of forced Reactor Building Closed Loop Cooling (RBCLC) seal cooling conditions. The testing models the reactor depressurization that is expected for a single EC loop reactor cool down profile. The seal test pressure profile follows the expected reactor depressurization defined in the vendor SBO analysis. These test conditions are expected to bound those conditions for seal performance under an event involving depressurization for a two EC loop reactor cool down profile, since a cool down with two EC loops will achieve conditions that remove challenges to seal integrity in a shorter period of time.

The pump seal testing includes the full scale integral pump seal cooler. The integral seal cooler under SBO conditions maintains the seal cooling sub cooled by the boiling heat transfer of the RBCLC coolant and counter current makeup RBCLC gravity driven makeup to the cooler. The test included a mockup of the RBCLC piping to simulate the static head available to maintain the boiling heat transfer and to model the counter current flow regime. The test report summarizes the seal sub cooling. Because the integral seal cooler maintained sub cooled inlet conditions, the SBO testing of the seal demonstrated the leakage remained single phase throughout the test time frame.

These test results adequately model operating conditions and provide an adequate basis for the leak rate assumed for an ELAP event.

Open Item # 49: Implement a design change to install a permanent connection point for FLEX portable pump injection through feed water This item is complete.

Page 8 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS A modification was designed and installation is complete. The modification eliminates the need to install a spool piece by providing welded piping and additional valves necessary to make the ability to inject fire water into the feed water system a permanent design feature of the system. This modification included a new fire hose connection that supports the FLEX mitigation strategies as the alternate injection point for RPV makeup capability in order to provide core cooling.

3. Maintain Core Cooling - BWR Portable Equipment Phase 2 Open Item #6: Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from the intake/discharge bays will consider Phase 2 requirements This item is complete.

A hydraulic analysis was completed as part of the design process to verify the capability of the pumps and piping/hose system to deliver the required amount of water to each required location in the plant. The hydraulic analysis included primary and alternate injection locations for the Reactor Pressure Vessel, EC shells and Spent Fuel Pool (SFP), and accounted for the Net Positive Suction Head (NPSH) and for conservative lengths of hoses and installed piping in any combination of primary and alternate connection points.

NMP1 mitigation strategies identify use of portable diesel driven centrifugal pumps.

The hydraulic analysis concluded that these pumps are sufficient to provide required flow rates to all required makeup points simultaneously at the expected pressures and with the required potential deployment configurations in the event of an ELAP. One pump is capable of supplying the makeup requirements. A second pump is necessary and available if the maximum spent fuel pool spray flow of 250 gpm is required while the first pump is supplying maximum make up to the Emergency Condensers and Reactor Pressure Vessel.

Open Item # 29: Perform an analysis of the portable generator to determine if it will be capable of supplying all expected battery loads This item is complete.

A plant specific calculation identifies that the portable diesel driven generator for NMP1 Phase 2 FLEX application is adequately sized to power the 600VAC/125VDC installed station static battery charger, which in turn can supply all associated DC loads and recharge the station battery. The calculation also provides necessary analysis that supports the appropriate cables and connection points. In addition, NMP1 makes use of the portable battery charger in place to satisfy National Fire Protection Association (NFPA) 805 requirements for use as the alternate power provision for DC battery boards supplied by the FLEX generator. Calculations identify that the portable battery charger is smaller than the installed station battery charger, and so the FLEX portable diesel driven generator is adequately sized in all FLEX applications.

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ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

4. Maintain Containment Pressure Open Item # 33: Perform an analysis to determine the containment pressure profile during an ELAP / LUHS event and verify the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function This item is complete.

Analyses were performed for both Primary Containment (PC) and Secondary Containment response following an ELAP. The calculated pressure, temperature and relative humidity profiles were used to compare with design and qualification parameters of essential instrumentation which are relied upon during an ELAP. The evaluation concluded that the functionality of instrumentation deemed critical for parameter monitoring is not negatively impacted by the conditions expected following an ELAP event.

5. Maintain Containment - BWR Portable Equipment Phase 2 Open Item # 35: Perform analysis to identify the heat load expected during ELAP conditions and the time required to open vents to maintain containment parameters This item is complete.

This Open Item was originally identified surmising that a Hardened Containment Vent System (HCVS) would be necessary for successful implementation of FLEX mitigation strategies. New HCVS requirements were initially provided in NRC Order EA-12-050

'Issuance of Order to Modify Licenses With Regard to Reliable Hardened Containment Vents' issued in March 2012, with installation time requirements that were consistent with those for full compliance of FLEX strategies. However, the NMP1 mitigation strategies make use of the EC loops, thereby significantly reducing the amount of decay heat that is deposited in the PC and the overall challenge to PC parameters. There is no reason for using a HCVS to control containment parameters to retain functionality for any system or strategy at NMP1. For this reason, use of a HCVS is not required for FLEX mitigation strategies in responding to an ELAP at NMPI. The NRC Order for a HCVS was further refined in NRC Order EA-13-109 'Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions'. The new Order (EA-13-109) superseded the previous Order (EA-12-50) and revised allowed installation times for a HCVS. Since the HCVS is not necessary for supporting FLEX strategies, NMP1 will utilize the allowable time for installation of the HCVS identified in the new Order.

Open Item # 38: Perform an evaluation to determine the effects and required actions for Spent Fuel Pool temperatures expected above design of 1401F during an ELAP This item is complete.

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ENCLOSURE (1)

NMPI SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS NMP1 has existing calculations that assess the functionality of the SFP structure for pool temperatures to 2121F. The calculations provide the assumption that concrete/liner forces and moments are proportional to the thermal gradient differential temperature. Functionality of the SFP means that structural integrity is maintained.

6. Safety Function Support - BWR Installed Equipment Phase 1 Open Item # 56: Implement necessary administrative controls to ensure that appropriate Meter and Test (M&T) temperature equipment is maintained in the Main Control Room (MCR) for use This item is deleted.

Temperature recording instruments are installed in the MCR and Auxiliary Control Room. These instruments were in place and controlled at the time the original OIP was written and so this action is not necessary to be performed. The recorders are controlled in accordance with the stations Meter and Test program and are used by operations personnel to obtain and verify acceptable area temperatures each shift.

7. Safety Function Support - BWR Portable Equipment Phase 2 Open Item # 8: Perform calculations and validate assumptions of fuel consumption and replenishment rate to ascertain the time before off-site replenishment is required This item is complete.

Nine Mile Point strategies to provide fuel oil for portable diesels are to use the supply of on-site SR storage tanks that would normally supply the stations emergency diesel generators during a loss of AC/off-site power event.

In order to ensure proper sizing and strategies for appropriate response for the eventual simultaneous full implementation of FLEX mitigation strategies at both NMP units, calculations associated with fuel consumption were performed assuming the equipment required for full implementation of mitigation strategies at both NMP1 and NMP2 are in operation simultaneously. With regard to this, only the equipment for NMP1 is required to be in place for full implementation for this OIP.

Fuel consumption for both NMP1 and NMP2 portable equipment to support FLEX (4 diesel driven portable pumps, 2 diesel driven portable generators and 1 diesel driven portable air compressor) is 130 gallons per hour (gph) for all items operating at full load.

The Technical Specification (TS) minimum fuel storage on site is over 141,000 gallons in the emergency diesel generator fuel oil storage and day tanks. For the purposes of this analysis, the fuel at NMP1 is not credited (fuel is not accessible during flooding conditions). Fuel available at NMP2 is assumed with one emergency diesel generator fuel oil storage tank unavailable (i.e. TS allowable). The remaining capacity of the two SR storage tanks at NMP2 is greater than 85,000 gallons and will provide over 25 days of fuel for all FLEX portable equipment. The SAFER equipment, as replacement or backup to Phase 2 on-site portable diesel driven equipment, can theoretically increase fuel consumption rate to 270 gph if all equipment were deployed and operated at full Page 11 of 37

ENCLOSURE (1)

NMPI SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS load. The higher rate is due to design differences and larger equipment (i.e. Turbine generator versus diesel generator, booster pump and main pump for water delivery).

Even at this consumption rate, on site fuel reserves would provide greater than 13 days of operation without off site replenishment. It is expected that the emergency response organization can ensure delivery of replenishment fuel as required within the times identified above.

NMP will utilize two 528 gallon fuel tanks mounted on separate trailers and stored in the FLEX building. Each tank has a pump that is powered from the towing vehicles DC power or an on-board battery, and will be used to refuel the FLEX portable equipment.

These 528 gallon tanks will be filled from the on-site SR fuel oil storage tanks identified above. Transfer pumps and fuel for them are to be stored in the FLEX building, and used during an event to pump the fuel oil out of the SR storage into the refueling tanks.

The pumps have been tested on-site and provide over 31 gpm flow (1860 gph). The pump capacity of the deployment tank pump/nozzle is approximately 20 gpm (1200 gph). These delivery rates are well above the full load usage rate of all FLEX Phase 2 portable equipment.

Open Item # 10: Perform an evaluation of the redundant power strategy for radio repeaters and design and implement modifications or programmatic changes as required This item is complete.

Evaluation has been completed and determined that for FLEX implementation, a redundant power strategy for radio repeaters is not required. Hand-held portable radios using the radio-to-radio feature also known as 'talk-around' mode will be utilized for on-site communications between the MCR and the operators in the plant. The backup strategy for on-site communications is Sound Powered Phones (SPP) between FLEX deployment locations and the MCR.

Open Item # 12: Perform an analysis for feasibility of utilizing the sound powered communications for onsite communications for FLEX strategies This item is complete.

The backup strategy for on-site communications is Sound Powered Phones (SPP) between FLEX deployment locations and the MCR. Evaluation has determined that the station Maintenance Communication System can be utilized to provide the necessary communication using SPP equipment.

Open Item # 25: Evaluate requirements and options and develop strategies related to the storage and transport of the on-site FLEX portable equipment This item is complete.

The FLEX building is designed and constructed to protect the contents of the building from all screened in hazards in NEI 12-06. For NMP1, in the interim period until full implementation of mitigation strategies at NMP2 (spring 2016), all N and +1 equipment required to satisfy the NMP1 mitigation strategies will be stored in the FLEX building, Page 12 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS built to meet the design requirements specified in NEI 12-06 for the protection of FLEX portable equipment for the site.

Transport of the mitigation strategy portable equipment during deployment will be accomplished utilizing a large tractor or equivalent for the portable diesel generators and an adequately sized truck for the portable diesel driven pumps. These deployment vehicles will be stored in the FLEX building with the portable equipment attached to the tow vehicle and ready to immediately deploy out of the building for deployment.

8. Maintain Spent Fuel Pool Cooling - BWR Portable Equipment Phase 2 Open Item # 39: Perform analysis to verify SFP temperature and level after an ELAP event and adequate level for maintaining radiological access to the refuel floor This item is complete.

With regard to SFP level following an ELAP event, estimations utilizing existing calculations for SFP heatup and makeup water requirements lead to a conclusion that SFP water level is not a significant concern for several hours after the onset of an ELAP. Using the existing heat load and design basis available calculations, SFP level will lower at approximately 1 foot every 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and take approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> to reach SFP Level 2 (10 feet above the top of the spent fuel).

With regard to SFP temperature, and given the above with regard to SFP level, analysis has been completed that indicates refueling floor radiological conditions will not be as restrictive as the conditions related to refueling floor heat up from spent fuel pool heatup and the radiative heat from the EC condensers. The analysis developed for Secondary Containment conditions following an ELAP indicate that refueling floor temperatures will rise to almost 120*F within one hour of the onset of an ELAP event. Given this rapid heat up and the restrictions associated with refuel floor access, response procedures have been revised to ensure refuel floor preparatory actions for mitigation strategy deployment are conducted immediately following the onset of an ELAP.

Page 13 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items NMP1 OIP Open Items Status

1. Define criteria for the local (25 mile) staging area Complete (see QIP Update 2/2014)

2. Evaluate deployment strategies and deployment routes for hazard Complete (2/2015) impact

3. Evaluate requirements and options and develop strategies related to the storage on site of the FLEX portable equipment (including Complete (2/2015) lighting tools such as flashlights and batteries) in accordance with the requirements of NEI 12-06

4. Exceptions for the site security plan or other (license/site specific -

10 CFR 50.54x) requirements of a nature requiring NRC approval Complete (2/2015) will be communicated in a future Six Month Update following identification

5. Determine schedule for when Regional Response Centers (RRC) Complete (see OIP will be fully operational Update 8/2013)

6. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow Complete (2/2015) requirements from the intake/discharge bays will consider Phase 2 requirements

7. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow Deleted (see OIP requirements from the intake/discharge bays will consider Phase 3 Update 8/2014) requirements

8. Perform calculations and validate assumptions of fuel consumption and replenishment rate to ascertain the time before off-site Complete (2/2015) replenishment is required

9. Perform an evaluation of the Uninterruptible Power Supply (UPS) strategy and design and implement as required or formalize the Started (2/2014) use of the small portable gas generators (communication strategies)

10. Perform an evaluation of the redundant power strategy for radio repeaters and design and implement modifications or Complete (2/2015) programmatic changes as required

11. Verify plans for the FLEX storage facilities in accordance with NEI Complete (see OIP 12-06 requirements; also accommodate the storage and availability Update 8/2014) of fuel for the small gas generators Update_8/2014)

Page 14 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

12. Perform an analysis for feasibility of utilizing the sound powered Complete (2/2015) communications for onsite communications for FLEX strategies

13. Evaluate required consumables and options for storage and availability during an ELAP and implement programmatic controls Started (2/2015) to ensure required inventory is maintained

14. Establish deployment routes from FLEX equipment storage Complete (2/2015) location to connection points (including hazard impacts)

15. Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site SAFER Complete (2/2015)

Staging Area "C"

16. Establish a suitable local staging area for Phase 3 portable FLEX Complete (2/2015) equipment to be deployed on site SAFER Staging Area "B"

17. Provide the necessary storage facilities in order to provide fuel to Complete (2/2015) the transfer pumps during an ELAP event

18. Develop site specific SAFER Response Plan (playbook) for delivery of portable FLEX equipment from the RRC to the site

19. Develop and implement a program and/or procedures to keep FLEX equipment deployment pathways clear or identify actions to Started (2/2015) clear the pathways

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM) recommendation and Electric Power Research Institute (EPRI) Started (8/2013) guidelines for FLEX equipment

21. Evaluate and implement procedures that direct immediate deployment of Phase 2 equipment during refueling conditions

22. Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport Started (8/2014)

FLEX portable equipment during all modes of operation

23. Develop procedures/guidelines to address the criteria in NEI 12-06 to support existing symptom based strategies in the Emergency Started (2/2014)

Operating Procedures (EOPs)

24. Evaluate potential soil liquefaction for Nine Mile Point site considering final storage location of FLEX portable equipment and Complete (2/2015) deployment routes established for this equipment Page 15 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

25. Evaluate requirements and options and develop strategies related to the storage and transport of the on-site FLEX portable Complete (2/2015) equipment

26. Evaluate NMP1 containment integrity for Phases 1 through 3 and provide analysis in a future required Six Month Status Report (new Complete (2/2015)

Open Item added since original OIP as a result of further considerations of necessary analysis to support FLEX strategies)

27. Implement a design change to install a permanent connection point Added (see the for a portable pump to provide makeup to the Emergency 8/2013 OIP Condensers (ECs) (new Open Item added as a result of strategy Update) changes described in the August 2013 Six Month Update) Started (8/2014)

28. Perform an evaluation to ensure that the recirculation pump seal operating conditions are consistent with the referenced vendor test Complete (2/2015) report

29. Perform an analysis of the portable generator to determine if it will Complete (2/2015) be capable of supplying all expected battery loads

30. Perform an analysis to determine the flow/capacity needed for the Deleted (see OIP portable pump from the RRC to adequately supply the Emergency Update 8/2014)

Service Water (ESW) system

31. Evaluate the connection point for the RRC portable pump to ESW Deleted (see OIP and implement a design change to ensure that the pump can be Update 8/2014) connected

32. Evaluate implementation of makeup capability for the Reactor Deleted (see OIP Building Closed Loop Cooling (RBCLC) system expansion tank to Update 8/2014) support restarting the system in Phase 3

33. Perform an analysis to determine the containment pressure profile during an ELAP / LUHS event and verify the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function Page 16 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMPI OIP Open Items Status

34. Perform a site specific analysis to confirm that the containment Complete (see 01P parameters (temperature, pressure and level) stay below their Cplete (see14) design limits during Phase 1 following an ELAP Update 8/2014)

35. Perform analysis to identify the heat load expected during ELAP conditions and the time required to open vents to maintain Complete (2/2015) containment parameters

36. Perform an analysis to determine when ambient heat losses will be Deleted (see OIP enough to cool the containment with Shutdown Cooling (SDC) in Update 8/2014)

Phase 3

37. Evaluate a strategy to provide a pathway for steam and Complete (see OIP condensate or justify why it is not needed (for the refuel floor) Update 8/2014)

38. Perform an evaluation to determine the effects and required actions for Spent Fuel Pool temperatures expected above design Complete (2/2015) of 1401F during an ELAP

39. Perform analysis to verify SFP temperature and level after an ELAP event and adequate level for maintaining radiological access Complete (2/2015) to the refuel floor

40. Perform an analysis of Refuel Floor/SFP area for long term Complete (see OIP environmental conditions Update 8/2014)

41. Perform an analysis of SFP cooling system capability for restoration activities, will be performed considering that the SFP Deleted (see OIP temperatures will be elevated Update 8/2013)

42. Evaluate the ELAP/FLEX strategy to cope with the potential Complete (see OIP pressurization of the refueling floor and to prevent buildup of steam Update 8/2014) and condensation if required

43. Perform an analysis to evaluate long term temperature profiles in Deleted (see OIP NMP1 Main Control Room (MCR) under ELAP conditions Update 8/2013)

Page 17 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

44. Evaluate requirements and options and develop strategies to Deleted (see OIP maintain MCR habitability after the long-term MCR temperature dete (see13) profile is developed Update 8/2013)

45. Perform an analysis to validate the mild environment in NMP1 EC Deleted (see OIP Makeup Tank Area during an ELAP (Turbine Building) Update 8/2013)

46. Perform an analysis for long term environmental conditions in Complete (see OIP NMP1 Battery Rooms during an ELAP and evaluate any actions to Update 2/2014 mitigate the impact of this hydrogen production as required

47. Perform an analysis of the need for dewatering based on leak rates Deleted (see OIP and flood response capabilities and implement dewatering portable Update 8/2014) equipment and strategies based on this analysis

48. Implement a design change to install a permanent FLEX 600 VAC diesel generator (DG) connection point to the 600 VAC power Deleted (see OIP board (PB1 6B) and an alternative connection for the opposite 600 Update 8/2013)

VAC power board (PB17B)

49. Implement a design change to install a permanent connection point Complete (2/2015) for FLEX portable pump injection through feed water

50. Implement a design change to provide suction hose access points Started (2/2014) in the intake/discharge structures for FLEX portable pump suction

51. Design and implement a modification that will provide a makeup Deleted (see OIP connection to enable a portable pump to refill the Condensate Update 8/2013)

Storage Tanks (CSTs)

52. Evaluate and implement a design change to install permanent Deleted (see OIP generator connection points for 4160 VAC Update 8/2014)

53. Design and implement a modification that provides for connection Started (2/2014) of a FLEX portable pump to makeup to the SFP

54. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event Started (8/2014) to include both primary and alternate strategies Page 18 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP1 FLEX OIP Open Items (cont'd)

NMP1 OIP Open Items Status

55. Revise Station Blackout (SBO) procedures and ELAP procedures, when written, to direct that both EC's are immediately manually Started (8/2014) placed in service and to manually close Main Steam Isolation Valves (MSIVs) (to conserve RPV inventory)

56. Implement necessary administrative controls to ensure that appropriate Meter and Test (M&T) temperature equipment is Deleted (2/2015) maintained in the Main Control Room (MCR) for use

57. Perform time validation of the core cooling injection capabilities when detailed design is complete, implementation procedures are Started (2/2015) drafted and final storage facility locations are determined for the portable equipment

58. Implement a modification to provide a connection into the CRD Added (see OIP return line for a portable diesel pump connection (new Open Item Update 8/2013) based on strategy changes described in the August 2013 Six Month Update) Started (2/2014)

59. Implement a modification to connect a portable diesel generator Added (see OIP and portable battery charger to battery 11 and battery 12 (new Update 8/2013)

Open Item based on strategy changes described in the August 2013 Six Month Update) Started (2/2014)

60. Perform an evaluation in order to identify and implement the capability to provide motive power to restore the SDC system (new Deleted (see OIP Open Item added subsequent to original OIP submittal and Update 8/2014) described in the August 2013 Six Month Update)

61. In Phase 3, a modification to remove water from the torus using RRC supplied equipment will be evaluated and implemented as Deleted (see OIP required (new Open Item based on strategy changes described in Update 8/2014) the August 2013 Six Month Update)

Page 19 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 below provides a summary of the open and confirmatory items documented in the NRC's NMP1 ISE (Reference 7) and the status of each item. The following is a list of NMP1 ISE Open or Confirmatory Items submitted for closure for this update:

ISE Open Item # 1: ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, Section 5.3.3, Consideration 1, which considers the possible failure of seismically qualified electrical equipment by beyond-design-basis seismic events, was not discussed in the Integrated Plan or during the audit process ISE Open Item # 1 is submitted for closure.

Nine Mile Point Unit 1 procedure N1-SOP-29.1 EOP Key Parameter - Alternate Instrumentation was developed and implemented to provide operators with alternate instrumentation to utilize in the event the primary instrumentation used for implementing EOP's malfunctions. The specified alternate instrumentation can then be used to obtain key EOP parameter readings to support successful EOP implementation.

In response to the requirement contained in NEI 12-06 Section 5.3.3 Consideration 1, a reference source document has been developed for NMP1 critical instrumentation which provides guidance on how and where to measure key instrument readings at local instrument sources (i.e. transmitter, penetration, panel connection, connector, etc.). The reference source document information will be added to existing Operations procedure N1-SOP-29.1.

NMP1 FLEX Phase 1 through Phase 3 coping strategies relies upon the Emergency Condenser system (EC) to meet core cooling requirements. The EC system fails on (into service) upon loss of control power (DC) or loss of instrument air. The NMP1 ELAP procedure, N1-SOP33A.2, specifies placing both ECs in service and having at least one remain in service for the duration of the loss of all AC power. If control power were to fail, the ECs will go into service automatically as required by the procedure.

ISE Open Item # 2: ISE Open Item 3.2.1.3.A - The coping strategies for maintaining core cooling were updated in the August 27, 2013 Six Month Update. However, the licensee has not yet updated the sequence of events timeline and the discussion of time constraints ISE Open Item # 2 is submitted for closure.

The actions required and the time constraints that those actions need to be accomplished to support the coping strategies to maintain core cooling, spent fuel cooling and containment integrity are summarized in Attachment 1 to this Enclosure.

ISE Confirmatory Item # 3: ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event (BDBEE) was not discussed in the Integrated Plan or during the audit process.

Also, there was no discussion of securing large portable equipment for protection during a seismic hazard Page 20 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Item # 3 is submitted for closure.

Nine Mile Point 1 will satisfy storage of 'N' and '+1' FLEX portable equipment by construction of a robust (protected) building for this purpose, meeting the requirements in NEI 12-06, Section 5.3.2, Consideration 5; Section 6.2.3.2, Consideration 9; and Section 7.3.2, Consideration 4. All required NMP1 FLEX equipment will be stored within the robust FLEX building.

The FLEX building design requires the installation of 77 tie downs embedded within the concrete floor (cast-in place), which will anchor the equipment within the building to prevent seismic damage. This addresses NEI 12-06 Sections 5.3.1.2 and 5.3.1.3.

ISE Confirmatory Item # 4: ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris and potential soil liquefaction. Movement of equipment and procedural interfaces during a BDBEE were not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 4 is submitted for closure.

NMP1 deployment routes have been finalized and reviewed for impacts. Primary and alternate deployment paths are identified and maps developed.

Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been allotted in the staffing study for debris removal. This accounts for dispatching an operator within 30 minutes of the onset of an event to begin route assessment and debris removal. This resource is assigned (in the staffing study) for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for clearing paths of debris. The FLEX vehicles are capable of traveling over small debris.

A pay loader will be used to remove large debris as required. The pay loader will be stored in the FLEX building and Operators will be trained and qualified for operating the loader.

A soil liquefaction evaluation of the primary and alternate travel paths has been completed. The evaluation is applicable to all identified primary and alternate deployment paths as referenced above. Based upon the original site borings, the extensive borings conducted for the installation of the Independent Spent Fuel Storage Installation (ISFSI) and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

Based on the results of the Flooding Hazard Reevaluation performed for NMP, the maximum flood level in the vicinity of NMP1 is 262.2 feet due to probable maximum precipitation. This exceeds the building entrance elevation of 261' for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />, In the reevaluation, a map of maximum flood depths for the site indicates that the maximum water depth associated with FLEX equipment staging/deployed areas is approximately 2.5 feet with one very localized area just under 3 feet. For all areas on the north side of NMP1, the primary deployment pathway flood depths are under 2 feet.

For this reason, with the type of vehicles NMP is utilizing for towing, debris removal and Page 21 of 37

ENCLOSURE (1)

NMPI SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS refueling, and the duration of the flood event, it is expected that movement for the purposes of restocking supplies will not be impeded by site flooding.

ISE Confirmatory Item # 5: ISE Confirmatory Item 3.1.1.4.A - Utilization of offsite resources, the local staging area, and the method to deliver the FLEX equipment to the site were not discussed in the context of impacts of BDBEEs in the Integrated Plan or during the audit process ISE Confirmatory Item # 5 is submitted for closure.

Nine Mile Point Nuclear Station (NMP) has signed contracts for participation in SAFER.

Each NSRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. The two NSRCs are located in Phoenix, Arizona and Memphis, Tennessee.

All licensees, including Exelon Generation Company, relying on SAFER and the NSRC, have executed contractual agreements with Pooled Equipment Inventory Company (PEICo) which allows for the capabilities (considerations) in Section 12.2 of NEI 12-06.

The NRC staff evaluated the NSRCs and the SAFER program, plans, and procedures against these 10 capabilities (considerations) from NEI 12-06, Section 12.2. The NRC audit results concluded that that the NSRCs and the SAFER plans and procedures conform to the guidance described by the 10 capabilities (considerations) of NEI 12-06, Section 12.2.

The NRC findings are documented in a letter from the NRC (Jack R. Davis) to the Nuclear Energy Institute (Joseph E. Pollock), Staff Assessment of National Safer Response Centers Established in Response to Order EA-12-049, dated September 26, 2014 (ML14265A107)

The NSRC will support initial portable FLEX equipment delivery to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a request for deployment per the site specific response plan. Designated local staging areas have been selected to support deliveries of requested SAFER equipment from the NSRC to NMP.

Local Staging Area 'A' is defined as the final location on site delineated in the FLEX procedures where the SAFER equipment will be placed into service to support the FLEX strategies if needed. The site has equipment that will be able to transfer the portable equipment from SAFER at Staging Area 'B' on-site to Staging Area 'A' inside the protected area. This equipment includes those identified for deployment considerations that will be stored in the FLEX building such as a pay loader, large tractor and large truck.

Local Staging Area 'B' is defined as the site delivery and preparation area outside the site Protected Area where the SAFER equipment is delivered and prepared for use (e.g.,

unloaded, assembled, and fueled) prior to transport to Staging Area 'A' for use. At NMP, this area is the site parking lot located south of the P-building, adjacent to the Site Access Building.

Page 22 of 37

ENCLOSURE (1)

NMPI SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Local Staging Area 'C' is defined as the regional airport outside of the 25 mile radius of the site. SAFER will provide requested portable equipment through contracts with FedEx via truck transport or air freight to Staging Area "C" where the equipment will be made ready for transport to the site by either roadways using trucks or air transport using helicopters. For NMP, Staging Area 'C' is the Overflow Parking Lot at Syracuse Hancock International Airport.

SAFER has contracts in place with FedEx to truck transport the FLEX equipment from Staging Area 'C' to NMP site Staging Area 'B'. SAFER also has contracts in place for air lift transportation of the equipment from Staging Area 'C' to Staging Area 'B' at NMP using freight helicopters if both Primary and Alternate transportation path roadways are not available for use. The Primary and Alternate truck transport routes are contained in Chapter 5 of the NMP SAFER Response Plan which is currently in review and approval.

ISE Confirmatory Item # 11: ISE Confirmatory Item 3.2.1.2.A - There was no discussion of the applicability of the assumed recirculation system leakage rates and the recirculation pump seal leakage rates to the ELAP event; the pressure dependence of the leak rates; whether the leakage was determined to be single-phase, two-phase, or steam at the donor cell; and how mixing of the leakage flow with the drywell atmosphere was modeled ISE Confirmatory Item # 11 is submitted for closure.

In the 1990's, laboratory testing of the CAN2A recirculation pump seals was performed.

The recirculation pump seal station blackout test reports document the recirculation pump seal performance under loss of forced Reactor Building Closed Loop Cooling (RBCLC) seal cooling conditions. The testing models the reactor depressurization that is expected for a single EC loop reactor cool down profile. The seal test pressure profile follows the expected reactor depressurization defined in the GE Station Blackout reference analysis. These test conditions are expected to bound those conditions for seal performance under an event involving depressurization for a two EC loop reactor cool down profile, since a cool down with two ECs will achieve conditions that remove challenges to seal integrity in a shorter period of time.

The pump seal testing includes the full scale integral pump seal cooler. The integral seal cooler under SBO conditions maintains the seal cooling sub cooled by the boiling heat transfer of the RBCLC coolant and counter current makeup RBCLC gravity driven makeup to the cooler. The test included a mockup of the RBCLC piping to simulate the static head available to maintain the boiling heat transfer and to model the counter current flow regime. The test report summarizes the seal sub cooling. Because the integral seal cooler maintained sub cooled inlet conditions, the SBO testing of the seal demonstrated the leakage remained single phase throughout the test time frame.

Page 23 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The test results adequately model operating conditions and provide an adequate basis for the leak rate assumed for an ELAP.

Recirculation system leakage is simulated using the GOTHIC computer program. The primary containment model is a sub-divided GOTHIC model. The leakage is in the form of very fine droplets and mixes with drywell atmosphere at lower elevation (representation of Recirculation Pump seal leakage).

ISE Confirmatory Item # 15: ISE Confirmatory Item 3.2.4.2.B - A summary of battery performance with elevated or lowered temperatures in the Battery Room due to an ELAP event will be provided in the future update ISE Confirmatory Item # 15 is submitted for closure.

Calculations have been performed to determine the minimum and maximum battery temperatures required to perform their intended function during an ELAP.

With the minimum design outdoor temperature of -10°F, assuming restoration of a battery charger within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the room temperature at the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time frame for both battery rooms is steady state at approximately 56°F. This is consistent with, and bounded by, the minimum temperature of 55 0 F determined for an 8-hour Appendix R event.

In addition, for maximum battery temperature, the ELAP event is bounded by the 8-hour Appendix R event contained within a SR approved calculation. The Appendix R event calculation identifies that the maximum room temperature of approximately 113 0 F is reached within the first hour, followed by steady state conditions at approximately 105 0 F within approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The evaluation within the Appendix R calculation concludes that the highest temperature has no adverse impact on battery capacity during the ELAP event.

Based on the above, the high and low battery room temperatures caused by a loss of ventilation will have negligible impact on battery performance during an ELAP.

Temperature conditions in the battery board rooms (as opposed to the battery rooms) during an ELAP are also presented here for reference.

The maximum temperature in the battery board room is bounded by existing SR analysis. The maximum steady state temperature in the battery board room is 103.73°F which is less than the design limit of 104 0 F. The design basis calculation is specifically written for a Loss of Coolant Accident (LOCA)/Loss of Offsite Power (LOOP) but envelopes an ELAP event since the LOCA/LOOP event uses an electrical load that is considerably higher than the ELAP event (more than half of the loads used in the LOCA/LOOP event calculation will be removed in less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> into the ELAP event).

Page 24 of 37

ENCLOSURE (1)

NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The existing calculation also analyzes the minimum air temperatures in the battery board rooms 11 and 12 for a LOCA/LOOP event using numerical method (transient analysis).

The minimum temperature is determined to be steady state at approximately 42°F at day

7. This result bounds the ELAP since there are no heat loads credited within the battery board rooms in the LOCA/LOOP event for minimum room temperature analysis. The calculation identifies that the minimum temperature for operability of the SR components in the battery board rooms is 32°F, which is considerably less than the minimum room temperature of approximately 42°F expected during the ELAP.

In conclusion, temperature profiles during an ELAP are acceptable and there is no adverse impact on the components in the battery or battery board rooms.

ISE Confirmatory Item # 16: ISE Confirmatory Item 3.2.4.4.A - The restoration of Emergency Lighting in Phase 2, that may be restored when Battery Board 12 is repowered, is currently under evaluation (i.e. battery loading calculation for ELAP). NMP1 will provide a summary of the restoration of Emergency Lighting in a future update ISE Confirmatory Item # 16 is submitted for closure.

The primary DC power electrical mitigation strategy at NMP1 provides for a portable diesel generator to re-power an installed SR battery charger to SR Battery Board 12.

The alternate DC power electrical mitigation strategy provides for a portable battery charger and portable diesel generator to power SR Battery Board 12. An additional alternate capability is to provide a portable battery charger and portable diesel generator to power the opposite SR Battery Board 11.

A portion of (approximately 50%) the Emergency Lighting for the Unit 1 MCR and Auxiliary Control Room is fed from SR Battery Board 12 (the other portion is fed from non-SR Battery Board 14 and is not considered available during a BDB event). Unless it is necessary to re-power Battery Board 11 in lieu of Battery Board 12, this lighting will be available throughout the ELAP event. In the case that the alternate DC battery board (Battery Board 11) must be used in lieu of Battery Board 12, lighting in the MCR will be via flashlights and re-chargeable LED battle lanterns.

Several other lighting capabilities exist. Eight-hour battery-pack lighting is provided in all areas of the plant required for operation of any safe shutdown equipment, and in access and egress routes to meet the requirements of 10CFR50 Appendix R. Fire cabinet supplies, including flashlights, are provided in strategic storage locations throughout the site. These flashlights are inventoried on a periodic base. An EOP tool box is located in the MCR that contains 5 flashlights. These are inventoried and tested quarterly per preventative maintenance procedures. Flashlights and re-chargeable battle lanterns will be stored in the FLEX building to be used by operators within the plant when other lighting is insufficient. These lanterns will also be inventoried periodically with other FLEX equipment.

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Item # 18: ISE Confirmatory Item 3.2.4.6.A - Licensee to provide calculation and basis for use of extrapolated SBO evaluation for Main Control Room habitability ISE Confirmatory Item # 18 is submitted for closure.

The maximum temperature in the control complex (MCR and Auxiliary Control Room) during an ELAP event has been evaluated in a plant specific calculation in order to verify the extrapolation information used by interpreting current Appendix R and SBO calculation results. The existing heat loads in the MCR and Auxiliary Control Room are assumed to remain unchanged after the eight (8) hour Appendix R event, which bounds the NMP1 four (4) hour SBO event. The Appendix R heat loads are then extrapolated to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The calculation identified that to maintain areas less than the allowable temperature value of 104 0 F, MCR and Auxiliary Control Room doors must be opened when the Control Room complex temperature reaches 94 0 F. With these doors open, the maximum air temperature in the MCR is approximately 101°F and the Auxiliary Control Room is approximately 103.60 F, at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the ELAP event.

The FLEX procedures have been written to provide for monitoring control complex temperatures and to open MCR and Auxiliary Control Room doors before temperature reaches 94 0 F, and to remove loads consistent with those required during Appendix R or SBO events.

The functionality of equipment in these areas is not expected to be affected by the loss of ventilation during the ELAP event provided the instrument cabinet doors are opened within 30 minutes of the onset of the event. The cabinet doors are opened to promote the cooling of the instruments by natural convection, consistent with current SBO calculation and procedure requirements.

ISE Confirmatory Item # 19: ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is completed, the specific details on the protection schemes to protect Class 1E equipment from faults from the portable FLEX equipment will be provided in a future update ISE Confirmatory Item # 19 is submitted for closure.

The primary method to restore and maintain the NMP1 SR DC power is through a SR fusible disconnect switch. Therefore, the portable diesel generator and non-safety related cabling and connections will be isolated from the FLEX diesel driven portable generator by the current design of the installed SR static battery charger and by a SR fusible disconnect switch. In either case, the FLEX diesel driven portable generator output breaker is isolated from the battery or battery board in the primary configuration.

The alternate method to restore and maintain the NMP1 SR DC power is through existing SR fusible connections on the SR battery board 11 or 12. The SR battery boards are isolated from the FLEX diesel driven portable generator by the portable battery charger and SR fuses. The potential loss of either DC battery board 11 or 12, due to a fault on the new non-safety related portable battery charger, is precluded by the use of existing (battery board 11) or new (battery board 12) SR fuses that have an Page 26 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS interrupting rating that exceeds the available fault current of the FLEX portable equipment.

ISE Confirmatory Item # 20: ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an updated summary of the sizing calculations for the FLEX generators at a future update ISE Confirmatory Item # 20 is submitted for closure.

A plant specific calculation identifies that the portable diesel driven generator for NMP1 Phase 2 FLEX application is adequately sized to power the 600VAC/125VDC installed station static battery charger, which in turn can supply all associated DC loads and recharge the station battery. The calculation also provides necessary analysis that supports the appropriate cables and connection points. In addition, NMP1 makes use of the portable battery charger in place to satisfy National Fire Protection Association (NFPA) 805 requirements for use as the alternate power provision for DC battery boards supplied by the FLEX generator. Calculations identify that the portable battery charger is smaller than the installed station battery charger, and so the FLEX portable diesel driven generator is adequately sized in all FLEX applications.

SAFER will supply a Turbine Marine 1.1 MW 480 VAC generator with a step up transformer to 600VAC. These capabilities exceed and therefore envelope the on-site Phase 2 diesel generator size (450 kW). The SAFER generators come with the same size cable connectors as the on-site Phase 2 FLEX generators.

SAFER will also provide six (6) NSRC 6 kW diesel generators to provide power to emergency lighting towers and will not be connected to or provide power for equipment within the plant.

ISE Confirmatory Item # 21: ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a summary of the refueling strategies for FLEX equipment will be provided when finalized at a future date ISE Confirmatory Item # 21 is submitted for closure.

Nine Mile Point strategies to provide fuel oil for portable diesels are to use the supply of on-site SR storage tanks that would normally supply the stations emergency diesel generators during a loss of AC/off-site power event.

In order to ensure proper sizing and strategies for appropriate response for the eventual simultaneous full implementation of FLEX mitigation strategies at both NMP units, calculations associated with fuel consumption were performed assuming the equipment required for full implementation of mitigation strategies at both NMP1 and NMP2 are in operation simultaneously. With regard to this, only the equipment for NMP1 is required to be in place for full implementation for this OIP.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Fuel consumption for both NMP1 and NMP2 portable equipment to support FLEX (4 diesel driven portable pumps, 2 diesel driven portable generators and 1 diesel driven portable air compressor) is 130 gallons per hour (gph) for all items operating at full load.

The Technical Specification (TS) minimum fuel storage on site is over 141,000 gallons in the emergency diesel generator fuel oil storage and day tanks. For the purposes of this analysis, the fuel at NMP1 is not credited (fuel is not accessible during flooding conditions). Fuel available at NMP2 is assumed with one emergency diesel generator fuel oil storage tank unavailable (i.e. TS allowable). The remaining capacity of the two SR storage tanks at NMP2 is greater than 85,000 gallons and will provide over 25 days of fuel for all FLEX portable equipment. The SAFER equipment, as replacement or backup to Phase 2 on-site portable diesel driven equipment, can theoretically increase fuel consumption rate to 270 gph if all equipment were deployed and operated at full load. The higher rate is due to design differences and larger equipment (i.e. Turbine generator versus diesel generator, booster pump and main pump for water delivery).

Even at this consumption rate, on site fuel reserves would provide greater than 13 days of operation without off site replenishment. It is expected that the emergency response organization can ensure delivery of replenishment fuel as required within the times identified above.

NMP will utilize two 528 gallon fuel tanks mounted on separate trailers and stored in the FLEX building. Each tank has a pump that is powered from the towing vehicles DC power or an on-board battery, and will be used to refuel the FLEX portable equipment.

These 528 gallon tanks will be filled from the on-site SR fuel oil storage tanks identified above. Transfer pumps and fuel for them are to be stored in the FLEX building, and used during an event to pump the fuel oil out of the SR storage into the refueling tanks.

The pumps have been tested on-site and provide over 31 gpm flow (1860 gph). The pump capacity of the deployment tank pump/nozzle is approximately 20 gpm (1200 gph). These delivery rates are well above the full load usage rate of all FLEX Phase 2 portable equipment.

ISE Confirmatory Item # 22: ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, DC load profile, discussion of loads shed, and minimum DC voltage will be provided in a future update ISE Confirmatory Item # 22 is submitted for closure.

A Battery 11 and 12 Load Shed Coping Time for ELAP Event calculation has been completed which addresses the NMP1 DC battery performance under ELAP conditions.

The calculation includes an acceptable DC load profile. The battery coping times for the ELAP Event with implementation of DC load shedding were found to be 8.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for Battery 11, and 8.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Battery 12.

Computer modeling evaluated steady state terminal voltages at selected equipment and the calculation states that "the lowest battery voltage at any point in time for any of the scenarios will be 106.02 V[DC] rather than 105 V[DC]."

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS A calculation was performed specific to an ELAP event using the specific equipment to be shed during an ELAP event. There is no difference in the loads that are to be shed during an ELAP and those that are currently shed for SBO and Appendix R. The difference is that the ELAP strategy requires all loads to be shed within 30 minutes, rather than the longer periods for SBO and the partial loads shed in 15 minutes for Appendix R (i.e. all load shedding will be completed within 30 minutes). A review also concluded there is no reduction in defense-in-depth or redundancy resulting from the load shedding, nor is there a change in mitigating strategies associated with the timing of the load shedding.

The loads to be shed and the associated function are not different than current SBO or Appendix R loads as previously delineated. The ability to accomplish the load shedding actions was validated with operators in accordance with station procedures for time validation of operator actions.

ISE Confirmatory Item # 23: ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 23 is submitted for closure.

Request for support from SAFER is made as directed in changes to FLEX Support Guidelines (FSGs) for the actual ELAP if attempts to restore AC power are not successful within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from event initiation. The request is initiated by notifying the Exelon Corporate Nuclear Duty Manager (NDO). Communications to the NDO to request SAFER are prescribed in changes to both the FSG as well as the Emergency Procedure checklist for the Emergency Director/Shift Manager. The NDO will then contact SAFER and request implementation of the NMP SAFER Response Plan which initiates SAFER FLEX equipment deployment to the site. Training on the changes to procedures that support notification and request of equipment from the NSRC has been completed with appropriate Emergency Response Organization personnel.

The NSRC will support initial portable FLEX equipment delivery to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a request for deployment. A site specific response plan for Nine Mile Point delineates the transport logistics, staging area setup and preparation, and communications protocols between the SAFER Control Center (SCC), the NSRC, the Staging Areas, and NMP. This response plan provides the detail necessary to ensure the successful delivery of the portable FLEX equipment from the NSRC to the local staging area and from the local staging area to the site.

ISE Confirmatory Item # 24: ISE Confirmatory Item 3.4.B - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant connection points was not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 24 is submitted for closure.

The portable diesel generator for NMP1 Phase 2 FLEX application has been evaluated as being adequately sized at 450 kW per calculation (see ISE Open Item # 20). The NSRC will supply a 480VAC, 1.1 MW portable Turbine Marine generator with a step up transformer to 600 VAC (NMP1 SR distribution system is 600 VAC) and will come with Page 29 of 37

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS the same style (same manufacturer) connectors and cable sizes as the on-site Phase 2 FLEX generators. The NSRC generator size exceeds and envelopes the capability of the NMP Phase 2 generators.

The Phase 2 FLEX pump hose connections are standard 3 inch hose with 2.5 inch threaded normal fire hose (NH) fittings. The NSRC supplied equipment utilized to support NMP has the same 2.5 inch NH fittings or a 5 inch Storz fitting. NMP has one 5 inch Storz to 2.5 inch NH hose adapter for each Phase 2 FLEX portable diesel driven pump to adapt the NSRC fittings to the NMP1 Phase 2 FLEX connections. The NSRC pumps that would be utilized to support as a backup to the Phase 2 NMP FLEX pumps are the SG/RPV Makeup Pump rated at 500 psi and 500 gpm, and/or the Low Pressure/Medium Flow Pump rated at 300 psi and 2500 gpm, in conjunction with the Suction Lift Booster Pump for supporting required suction lift at up 2500 gpm. These pumps meet/exceed and therefore envelope the NMP1 Phase 2 FLEX strategy requirements delineated in NMP1 FLEX Hydraulic calculations.

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP1 Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status 1 ISE Open Item 3.1.1.3.A- Seismic procedural interface consideration NEI 12-06, Section 5.3.3, Consideration 1, which Submitted for considers the possible failure of seismically qualified electrical closure (2/2015) equipment by beyond-design-basis seismic events, was not discussed in the Integrated Plan or during the audit process

2. ISE Open Item 3.2.1.3.A - The coping strategies for maintaining core cooling were updated in the August 27, 2013 Six Month Submitted for Update. However, the licensee has not yet updated the sequence closure (2/2015) of events timeline and the discussion of time constraints ISE Confirmatory Items Status

3. ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design- Submitted for Basis External Event (BDBEE) was not discussed in the closure (2/2015)

Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard

4. ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris Submitted for and potential soil liquefaction. Movement of equipment and procedural interfaces during a BDBEE were not discussed in the Integrated Plan or during the audit process

5. ISE Confirmatory Item 3.1.1.4.A - Utilization of offsite resources, the local staging area, and the method to deliver the FLEX Submitted for equipment to the site were not discussed in the context of impacts closure (2/2015) of BDBEEs in the Integrated Plan or during the audit process

6. ISE Confirmatory Item 3.2.1.1.A - MAAP benchmarks must be Submitted for identified and discussed which demonstrate that MAAP4 is an closure (see OIP appropriate code for the simulation of an ELAP event Update 8/2014)

7. ISE Confirmatory Item 3.2.1.1.B - MAAP Analysis-collapsed Submitted for level must remain above Top of Active Fuel (TAF) and the cool closure (see OIP down rate must be within technical specification limits Update 8/2014)

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP1 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

8. ISE Confirmatory Item 3.2.1.1.C - MAAP4 must be used in Submitted for accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4. 5 of the June closure (see OIP 2013 position paper Update 8/2014)

9. ISE Confirmatory Item 3.2.1.1.D - MAAP modeling parameters Submitted for must be identified and justified closure (see OIP Update 8/2014)

10. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis Submitted for case that was used to validate the timing of mitigating strategies in closure (see OIP the Integrated Plan must be identified and should be available for Update 8/2014) review

11. ISE Confirmatory Item 3.2.1.2.A - There was no discussion of the applicability of the assumed recirculation system leakage rates and the recirculation pump seal leakage rates to the ELAP event; Submitted for the pressure dependence of the leak rates; whether the leakage closure (2/2015) was determined to be single-phase, two-phase, or steam at the donor cell; and how mixing of the leakage flow with the drywell atmosphere was modeled

12. ISE Confirmatory Item 3.2.3.A - The licensee has yet to Submitted for evaluate containment integrity for Phases 1 through 2 and closure (see OIP provided the finalized analysis for review Update 8/2014)

13. ISE Confirmatory Item 3.2.3.B - A modification to remove water Submitted for from the torus in Phase 3 using RRC supplied equipment will be closure (see OIP evaluated and implemented as required Update 8/2014)

14. ISE Confirmatory Item 3.2.4.2.A- Evaluation of the refueling floor SFP area for steam and condensation was not yet Submitted for completed. Mitigating strategies, including establishing a vent closure (see OIP pathway for steam and condensate from the area, were not Update 8/2014) discussed in the Integrated Plan or during the audit process

15. ISE Confirmatory Item 3.2.4.2.B - A summary of battery Submitted for performance with elevated or lowered temperatures in the Battery closure (2/2015)

Room due to an ELAP event will be provided in the future update Page 32 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMPI Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

16. ISE Confirmatory Item 3.2.4.4.A - The restoration of Emergency Lighting in Phase 2, that may be restored when Battery Board 12 Submitted for is repowered, is currently under evaluation (i.e. battery loading closure (2/2015) calculation for ELAP). NMP1 will provide a summary of the restoration of Emergency Lighting in a future update

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of commitments, as discussed in the staff analysis (ML13100A236) for Started (8/2014t communications assessment, is required

18. ISE Confirmatory Item 3.2.4.6.A - Licensee to provide Submitted for calculation and basis for use of extrapolated SBO evaluation for closure (2/2015)

Main Control Room habitability

19. ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is Submitted for completed, the specific details on the protection schemes to protect Class 1E equipment from faults from the portable FLEX equipment will be provided in a future update

20. ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an Submitted for updated summary of the sizing calculations for the FLEX generators at a future update

21. ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a Submitted for summary of the refueling strategies for FLEX equipment will be closure (2/2015) provided when finalized at a future date

22. ISE Confirmatory Item 3.2.4.1O.A - The licensee stated that a finalized summary of battery coping time, DC load profile, Submitted for discussion of loads shed, and minimum DC voltage will be closure (2/2015) provided in a future update

23. ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan sube(2/201 closure for5) or during the audit process

24. ISE Confirmatory Item 3.4.B - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant Submitted for connection points was not discussed in the Integrated Plan or closure (2/2015) during the audit process Page 33 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the OIP described in this enclosure.

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February

28. 2013

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

3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 8, 2013

4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letter on 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, dated August 2012

6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), 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 27, 2013

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF1130), dated December 19, 2013

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), February 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 Number EA-12-049), dated February 27, 2014

9. NEI Position Paper Shutdown and Refueling: ADAMS Accession No. ML13273A514

10. NRC Endorsement of NEI Shutdown and Refueling paper: ADAMS Accession No. ML13267A382

11. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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 Number EA-12-049), dated August 26, 2014 Page 34 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS

12. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, °Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2 and 6 - Phase 2 Staffing Assessment Page 35 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Attachment 1 Updated Annotated Sequence of Events Timeline NINE MILE POINT I Overall Integrated Plan Time Action Elapsed Action constraint Remarks/Applicability Item Time Y/N Procedure Poeueapial applicable foro Enter SOP-33A.2 Station 1 0 min EnterS P Y 2min the duration of the Blackout/ELAP SBO/ELAP Manually placed in 2 0-3 min Manually place 1 and 12 ECs in serviceERsaeon Y 3 min service to minimize time ERVs are open Need to be clear to Unit 1 30-15 min Dispatch operator for debris Y lhr pump deployment area in removal 1 hr - continues for 2 hrs total Actions for loss of air: SOP- CRS directs, THEN, NLO 4 0-30 min 33A.2 Y 30 min performs (EC shell level Attachment 2 control within 30 min)

Actions for DC load shed CRS directs, THEN, NLO 5 0-30 min SOP-33A.2 Y 30 min performs ( SR batteries Attachment 4 at 30 min)

Refuel Floor Actions: Lay Directed by CRS:

6 0-60 min out hose for SFP Alternate Y 1 hr personnel carry out in Makeup and Spray < 1hr from t=0 Deploy 1st FLEX pump for 4 people total to help 7 1 hr primary RPV, EC & SFP Y 3 hrs with installation of suction MU hose 8 2 hr Deploy FLEX generator for Y 4 hrs 2 people SR battery charging Establish makeup capability Capability comes from 9 4 hr to the RPV through CRD Y 5.7 hrs the FLEX pump deployed return line in Action Item 7 Page 36 of 37

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NMP1 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Attachment I Updated Annotated Sequence of Events Timeline NINE MILE POINT 1 Overall Integrated Plan (cont'd)

Time Action Elapsed Action constraint Remarks/Applicability Item TimeYN

_________YIN ___

Doors on 261 opened when hose deployed into Establish Reactor Building Reactor Bldg.

Vent to maintain TB door and wall vents 10 8 hrs habitability and Y 8 hrs can be opened any time qualification for prior to RB 340 airlock.

instruments Person controlling EC level on TB 369 (Within 8 hrs T = 0 Establish make up to 12 EC (primary) or makeup to Capability comes from 11 8 hrs 11 and 12 EC with FLEX Y 8 hrs the FLEX pump deployed pump via Fire Water in Action Item 12 system (alternate) 2 people with one truck and trailered 528 fuel 12 10 hrs Deploy the capability to Y 10 hrs tank.

Refuel Portable Equipment Additional truck/tank is available Deploy 2 nd FLEX pump to Establish makeup to the Screen House for 13 12 hrs SFP Y 45 hrs Alternate SFP make up may be required 4 people if it is Page 37 of 37

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENT NINE MILE POINT NUCLEAR STATION, LLC February 19, 2015

ENCLOSURE (2)

NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS I Introduction The Nine Mile Point Unit 2 (NMP2) Overall Integrated Plan (OIP) was submitted to the Nuclear Regulatory Commission (NRC) in February 2013 (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2).

Subsequently, a supplement to the NMP2 OIP for FLEX was submitted to the NRC in March 2013 (Reference 3). This enclosure provides an update of milestone accomplishments since submittal of the last status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis (if applicable).

Since the submittal of the last status report in August 2014 (Reference 11), NMP2 has progressed with engineering analysis, calculations, procedures and other activities that support the mitigating strategies and the modification concepts have been refined. Some changes to the mitigation strategies and planned modifications in support of the mitigation strategies have occurred and are explained within this document. Work with the Strategic Alliance for FLEX Emergency Response (SAFER) has continued including review of proposed supporting equipment specifications that support NMP2 for FLEX Phase 3 and the development of the site specific SAFER Response Plan (SRP). The SRP is in the final review and approval phase.

By letter dated December 19, 2013, the NRC issued to CENG the Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MF 1130) (Reference 7).

The Interim Staff Evaluation (ISE) contains open and confirmatory items for which CENG will provide clarifying or additional information in Six Month Status Reports in order for the NRC to determine that the issues are satisfactorily resolved.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference 3), and are current as of January 16, 2015.

" Six Month Integrated Plan Progress Report submitted (8/2013)

" Six Month Integrated Plan Progress Report submitted (2/2014)

• Refueling Outage (RFO), including walk downs in support of pending modifications for installation for FLEX strategies (8/2014)

" Six Month Integrated Plan Progress Report submitted (Reference 11)

" Engineering and Design Completion - Equipment Storage Facility 3 Milestone Schedule Status Table 1 provides an update to Attachment 2 of the NMP2 OIP (References 1 and 3). 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. Any changes to the following target completion dates will be reflected in subsequent Six Month Status Reports.

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

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table I Status of NMP2 FLEX OIP Milestones Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Implementation Plan Six Month Integrated Plan Progress August 2013 Complete Report Engineering and Design Completion - November Complete Equipment Storage Facility 2014 Six Month Integrated Plan Progress February 2014 Complete Report Refueling Outage April 2014 Complete Six Month Integrated Plan Progress August 2014 Complete Report Engineering and Design Completion - November Started March 20151 Portable Equipment Connections 2014 Completed Six Month Integrated Plan Progress February 2015 upon submittal Report of this report Equipment Storage Facility installation May 2015 Started April 20152 Six Month Integrated Plan Progress August 2015 Not Started Report Non-Outage Installation - Portable January 2016 Not Started Equipment Connection Six Month Integrated Plan Progress February 2016 Not Started Report Validation Walkdowns Complete February 2016 Not Started Portable Equipment Procedures March 2016 Started Changes FLEX Training March 2016 Not Started Page 2 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 1 Status of NMP2 FLEX OIP Milestones (cont'd)

Revised Target Completion Activity Target Milestone Date Status Completion Date Refueling Outage April 2016 Not Started Outage Installation - Portable May 2016 Not Started Equipment Connections Final Implementation Notification to July 2016 Not Started USNRC Note 1: Revised from previous NMP2 Six Month Status Report which identified November 2014.

NMP2 portable equipment connections design is currently scheduled to be completed in March 2015 to support full implementation in May 2015.

Note 2: Revised from previous NMP2 Six Month Status Report which identified completion in May 2015. The storage facility will be completed in time to support NMP1 full implementation in April 2015.

4 Changes to Compliance Method Changes were made to the information provided in the OIP that do not change the compliance method with Nuclear Energy Institute (NEI) 12-06 (Reference 5) and were provided in the last Six Month Status Report. NMP2 will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures (References 9 and 10).

No significant coping strategy changes have occurred since the previous Six Month Status Update provided on August 26, 2014 (Reference 11).

Remaining design specifications and requirements and strategy revisions will be determined upon completion of the final design.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation NMP2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Table 2 below provides a summary of the open items documented in the OIP and those added in any subsequent Six Month Status Reports and the status of each item.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The following is a list of the open items from the alP that have been added, deleted or completed since the last Six Month Status Report with an explanation of the changes:

1. General Integrated Plan Elements - BWR Open Item # 2: Evaluate deployment strategies and deployment routes for hazard impact.

This item is complete.

NMP has identified primary and alternate FLEX deployment routes, including hazard impacts for each route. Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been identified in the NMP1 staffing study that has been performed and submitted to the Commission (Reference 12). Specifically, the staffing study provides for over two hours of dedicated debris removal time with a pay loader for both NMP1 and NMP2 deployment paths. A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

Open Item # 14: Establish deployment routes from FLEX equipment storage location to connection points (including hazards impacts)

This item is complete.

Primary and alternate deployment paths have been identified and maps have been developed. Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been identified in the NMP1 staffing study that was performed and submitted to the Commission (Reference 12). Specifically, the staffing study provides for over two hours of dedicated debris removal time with a pay loader for both NMP1 and NMP2 deployment paths. A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

As an example, an alternate deployment route south of NMP1 is available. A hazard that exists for this route is associated with an overhead line falling and impeding access. In this case, verification of line status (i.e. de-energized) is available locally from observation (and manual operation if necessary) of the high voltage disconnects located in the switchyard in the immediate vicinity, and at the high voltage breakers inside the unit at the switchgears.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Open Item # 15: Establish a suitable local staging area for portable FLEX equipment to be delivered from the RRC to the site SAFER Staging Area "C" This item is complete.

Local Staging Area 'C' is defined as the regional airport outside of the 25 mile radius of the site. SAFER has made appropriate arrangements to provide requested portable FLEX equipment to Staging Area "C" (Syracuse Hancock International Airport). At this point, the equipment will be made ready for transport to the site by either roadway or air transport using helicopters.

The Nine Mile Point Nuclear Station has entered into a Memorandum of Understanding (MOU) with Syracuse Hancock International Airport for utilization of the facilities as a Staging Area (i.e. Staging Area 'C') in an emergency. SAFER has put in place appropriate contracts to transport the FLEX equipment from Staging Area

'C' to the NMP site Staging Area 'B' either by truck or air (helicopter). The Primary and Alternate truck transport routes are contained in Chapter 5 of the NMP SAFER Response Plan.

Open Item # 16: Establish a suitable local staging area for Phase 3 portable FLEX equipment to be deployed on site SAFER Staging Area "B" This item is complete.

Staging Area 'B' is defined as the site delivery and preparation area outside the site Protected Area where the SAFER FLEX equipment is delivered and prepared for use (e.g., unloaded, assembled, and fueled) prior to transport to its final location on site for use. At NMP, this area is the site parking lot located south of the P-building, adjacent to the Site Access Building. Two alternative locations are available on site including the turn-around large parking area south of the Owner Controlled Area entrance point and the Nuclear Learning Center parking lot. These areas were identified and deemed acceptable during the SAFER Rehearsal of Concept meeting at Nine Mile Point in January 2014.

Open Item # 24: Evaluate potential soil liquefaction for Nine Mile Point site considering final storage location of FLEX portable equipment and deployment routes established for this equipment This item is complete.

A soil liquefaction evaluation of the primary and alternate travel paths has been completed. Based upon the original site borings, and the extensive borings conducted for the installation of the ISFSI and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX Storage Building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Open Item # 32: Perform an analysis to identify necessary actions, (e.g.,

modifications or programmatic changes) to maximize battery coping time to at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> This item is complete.

With Operations input in order to extend the battery coping time, a specific calculation was performed to determine the actions necessary to maximize the coping time for the Division I and II safety related batteries. The calculation concluded that the station's battery coping time with implementation of additional DC load shedding, will be a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for an ELAP event for each divisional battery. The loads to be shed are itemized in the calculation. The minimum battery voltage design input for the calculation is a minimum cell voltage of 1.75 volts per cell (60 cells in the battery) or 105 VDC for the battery.

An existing NMP2 safety related calculation specifically for DC cable sizing provides the basis for the required terminal voltage of 105 VDC and includes an evaluation that determines that the terminal voltage at each load meets the minimum requirements for operating the equipment.

In order to provide the DC loads with power for the specified coping time during an ELAP event, load shedding for the safety related batteries will be performed within 60 minutes. The load shed process will be accomplished per procedure (Station Blackout support procedure).

2. Maintain Containment - BWR Portable Equipment Phase 3 Open Item # 36: Perform an analysis to determine when ambient heat losses will be low enough such that with Residual Heat Removal (RHR) in a Phase 3 mode of shutdown cooling, venting of the primary containment will no longer be required This item is deleted.

Activities to restart Residual Heat Removal (RHR) for shutdown cooling operation are considered to be restoration. The FLEX mitigation strategies for Phase 2 provide indefinite coping for the key safety functions associated with core and containment cooling. This will be accomplished by utilizing portable equipment for reactor makeup to maintain RPV level above the Top of Active Fuel (TAF) and by venting the containment to ensure pressure and temperature are maintained to support the strategy. Restoration of RHR is not required for consideration for the FLEX strategies.

Makeup to the RPV with portable equipment will utilize on site protected equipment in accordance with the guidance provided in NEI 12-06 (Reference 5). The ability to vent the Primary Containment will be established by installation of hardened vent capability in accordance with the requirements of NRC Order EA-13-109 'Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions' (ML13143A321). Primary containment venting capability with the hardened vents will be required indefinitely.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Although Phase 2 strategies achieve indefinite coping, Phase 3 strategy is support from SAFER NSRC to deliver portable equipment for backup or redundant capability of Phase 2 equipment.

3. Maintain Spent Fuel Pool Cooling - BWR Installed Equipment Phase I Open Item # 43 - Perform an evaluation to determine the effects and required actions for Spent Fuel Pool temperatures expected above design of 150*F during an ELAP This item is complete.

An evaluation of existing calculations and licensing information concluded that the structural integrity of the NMP2 SFP is maintained for a SFP temperature of 212 0 F.

Given the evaluation conclusion, the NMP2 FLEX strategies to allow SFP heat up and boiling, and providing makeup water to maintain adequate submergence to ensure spent fuel cooling is acceptable.

4. Safety Functions Support - BWR Portable Equipment Phase 2 Open Item # 8: Perform calculations and validate assumptions of fuel consumption and replenishment rate to ascertain the time before off-site replenishment is required This item is complete.

Nine Mile Point strategies to provide fuel oil for portable diesels are to use the supply of on-site safety related (SR) storage tanks that would normally supply the stations emergency diesel generators during a loss of AC/off-site power event.

In order to ensure proper sizing and strategies for appropriate response for the eventual simultaneous full implementation of FLEX mitigation strategies at both NMP units, calculations associated with fuel consumption were performed assuming the equipment required for full implementation of mitigation strategies at both NMP1 and NMP2 are in operation simultaneously.

Fuel consumption for both NMP1 and NMP2 portable equipment to support FLEX (4 diesel driven portable pumps, 2 diesel driven portable generators and 1 diesel driven portable air compressor) is 130 gallons per hour (gph) for all items operating at full load. The Technical Specification (TS) minimum fuel storage on site is over 141,000 gallons in the emergency diesel generator fuel oil storage and day tanks. For the purposes of this analysis, the fuel at NMP1 is not credited (fuel is not accessible during flooding conditions). Fuel available at NMP2 is assumed with one emergency diesel generator fuel oil storage tank unavailable (i.e. TS allowable). The remaining capacity of the two SR storage tanks at NMP2 is greater than 85,000 gallons and will provide over 25 days of fuel for all FLEX portable equipment. The SAFER equipment, as replacement or backup to Phase 2 on-site portable diesel driven equipment, can theoretically increase fuel consumption rate to 270 gph if all equipment were deployed and operated at full load. The higher rate is due to design differences and larger equipment (i.e. Turbine generator versus diesel generator, Page 7 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS booster pump and main pump for water delivery). Even at this consumption rate, on site fuel reserves would provide greater than 13 days of operation without off site replenishment. It is expected that the emergency response organization can ensure delivery of replenishment fuel as required within the times identified above.

NMP will utilize two 528 gallon fuel tanks mounted on separate trailers and stored in the FLEX building. Each tank has a pump that is powered from the towing vehicles DC power or an on-board battery, and will be used to refuel the FLEX portable equipment. These 528 gallon tanks will be filled from the on-site SR fuel oil storage tanks identified above. Transfer pumps and fuel for them are to be stored in the FLEX building, and used during an event to pump the fuel oil out of the SR storage into the refueling tanks. The pumps have been tested on-site and provide over 31 gpm flow (1860 gph). The pump capacity of the deployment tank pump/nozzle is approximately 20 gpm (1200 gph). These delivery rates are well above the full load usage rate of all FLEX Phase 2 portable equipment.

Open Item # 17: Provide the necessary storage facilities in order to provide fuel to the transfer pumps during an ELAP event This item is complete.

NMP2 portable equipment refueling strategies for FLEX include use of gasoline engine driven fuel oil transfer pumps. These transfer pumps are capable of taking suction on the installed SR fuel oil storage tanks on site and pumping fuel oil into smaller tanks reserved and dedicated for transporting fuel oil to the portable equipment. The gasoline for the fuel oil transfer pumps exist in sealed storage cells providing an extended shelf life. The gasoline is being stored in approved fire resistant storage cabinets. The fire resistant cabinets and fuel will be located in the FLEX building so that they are preserved for deployment.

Open Item # 22: Purchase and maintain the required equipment to ensure debris removal capability to re-establish deployment routes and transport FLEX portable equipment during all modes of operation This item is complete.

Nine Mile Point mitigation strategies identify the use of three dedicated deployment vehicles that are to be stored with the Phase 2 portable equipment in the FLEX robust storage building. These include two large flatbed trucks for portable pump deployment and a large tractor or equivalent for portable diesel generator deployment. One of the large trucks is capable of deploying either a portable pump or generator. The large tractor can also deploy the FLEX pumps. Furthermore, for added defense in depth, the debris removal equipment (i.e. pay loader) is large enough and capable of deploying either a portable pump or generator. All other support equipment can be deployed by any of the vehicles described above.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been allotted in the staffing study that has been performed for debris removal.

The strategy includes dispatching an operator from NMP1 within the first 30 minutes to begin route assessment and debris removal. This operator is dedicated to debris removal (in the staffing study) for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for clearing paths to both units' deployment sites. The FLEX vehicles are capable of traveling over small debris. A wheeled pay loader will be used to remove debris as required. This will be stored in the robust FLEX building and Operators are to receive training/qualification for operation of the loader.

5. Safety Functions Support - BWR Portable Equipment Phase 3 Open Item # 48: Perform an analysis of the light coverage during ELAP conditions and determine if the lighting loads should be re-energized from the non-safety related buses by the RRC FLEX generator This item is complete.

Some plant lighting could be provided for the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by Appendix R lights throughout the plant. The appendix R lights are seismically mounted, not to interfere with safety related equipment, but are not seismically qualified.

The emergency lighting system was designed to provide adequate illumination in areas required for operating safety-related equipment during emergency conditions.

The emergency lighting system normally receives power from Division 1,11 and III 600 VAC emergency busses. Portions of this lighting may be restored when Division I or Division II 600 VAC is repowered during a BDB event. If available after the event, the emergency lighting will supply a portion of the lighting in the MCR, Relay Room, Divisional Switchgear and Remote Shutdown Rooms and the Divisional Emergency Diesel Rooms.

From the onset of the event, operators will utilize battery powered portable lighting sources. When a safety related switchgear has been re-energized (current FLEX electrical mitigation strategy), it is expected that a portion of the safety related lighting in the Control Building may be restored.

Lighting systems within the plant are designed for a number of diverse events, but none are able to be fully credited to survive a BDB seismic event. For this reason, only personal portable lighting devices with batteries are credited. Currently, battery-powered portable hand lights have been provided for use by the Fire Brigade and other operations personnel. Fire cabinet supplies, including flashlights, are provided in strategic storage locations throughout the site. Inventory of the Fire cabinets is performed on periodic bases (typically quarterly). In addition, there are two (2)

Emergency Operating Procedure (EOP) tool boxes in the NMP2 Main Control Room (MCR) that contain 10 flashlights. These flashlights are inventoried and tested quarterly. There also is a Station Blackout (SBO) tool box immediately outside the MCR containing 22 flashlights that is inventoried and tested quarterly.

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The FLEX Storage Building will have a quantity of rechargeable LED battle lanterns to be used by operators within the plant. These lanterns are to be inventoried and tested periodically.

Table 2 Status of NMP2 FLEX OIP Open Items NMP2 OIP Open Items Status

1. Define criteria for the local (25 mile) staging area Complete (see OIP Update 2/2014)

2. Evaluate deployment strategies and deployment routes for hazard Complete impact (2/2015)

3. Evaluate requirements and options and develop strategies related to the storage on-site of the FLEX portable equipment (including lighting Started (8/2013) tools such as flashlights and batteries) in accordance with the requirements of NEI 12-06

4. Exceptions for the site security plan or other (license/site specific - 10 CFR 50.54x) requirements of a nature requiring NRC approval will be Started (8/2013) communicated in a future Six Month Update following identification

5. Determine schedule for when Regional Response Centers (RRCs) will Complete (see OIP Update be fully operational 8/2013)

6. Perform an analysis to validate the FLEX equipment ability to deliver sufficient flow under all expected conditions. Flow requirements from Started (2/2014) the dry hydrants will consider Phase 2 requirements

7. Perform an analysis to validate the FLEX equipment ability to deliver Deleted (see OIP sufficient flow under all expected conditions. Flow requirements from dete (see14) the dry hydrants will consider Phase 3 requirements Update 8/2014)

8. Perform calculations and validate assumptions of fuel consumption Complete and replenishment rate to ascertain the time before off-site (2/2015) replenishment is required

9. Perform an evaluation of the Uninterruptible Power Supply (UPS) strategy and design and implement as required or formalize the use of Started (2/2014) the small portable gas generators (communication strategies)

10. Perform an evaluation of the redundant power strategy for radio repeaters and design and implement modifications or programmatic Started (2/2014) changes as required Page 10 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

11. Verify plans for the FLEX storage facilities in accordance with NEI 12- Completed (see 06 requirements also accommodate the storage and availability of fuel OIP Update for the small gas generators 8/2014)

12. Perform an analysis for feasibility of utilizing the sound powered Started (2/2014) communications for onsite communications for FLEX strategies

13. Evaluate required consumables and options for storage and availability during an ELAP and implement programmatic controls to Not Started ensure required inventory is maintained

14. Establish deployment routes from FLEX equipment storage location to Complete connection points (including hazards impacts) (2/2015)

15. Establish a suitable local staging area for portable FLEX equipment to Complete be delivered from the RRC to the site SAFER Staging Area "C" (2/2015)

16. Establish a suitable local staging area for Phase 3 portable FLEX Complete equipment to be deployed on site SAFER Staging Area "B" (2/2015)

17. Provide the necessary storage facilities in order to provide fuel to the Complete transfer pumps during an ELAP event (2/2015)

18. Develop site specific SAFER Response Plan (playbook) for delivery of Started (8/2013) portable FLEX equipment from the RRC to the site

19. Develop and implement a program and/or procedures to keep FLEX equipment deployment pathways clear or identify actions to clear the Started (2/2015) pathways

20. Develop preventive maintenance and testing procedures with frequencies based on Original Equipment Manufacturer (OEM) Started (8/2013) recommendation and Electric Power Research Institute (EPRI) guidelines for FLEX equipment

21. Evaluate and implement procedures that direct immediate deployment Started (2/2014) of Phase 2 equipment during Refueling conditions

22. Purchase and maintain the required equipment to ensure debris Complete removal capability to re-establish deployment routes and transport (2/2015)

FLEX portable equipment during all modes of operation Page 11 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

23. Develop procedures/guidelines to address the criteria in NEI 12-06 to support existing symptom based strategies in the Emergency Started (2/2014)

Operating Procedures (EOPs)

24. Evaluate potential soil liquefaction for Nine Mile Point site considering Complete final storage location of FLEX portable equipment and deployment (2/2015) routes established for this equipment

25. Evaluate requirements and options and develop strategies related to Started 2/2014 the storage and transport of the on-site FLEX portable equipment

26. Implement a design change to Reactor Core Isolation Cooling (RCIC) that will support operation of the system at elevated Suppression Pool Not Started temperatures as identified in GEH 000-0155-1545 (BWROG RCIC Pump and Turbine Durability Evaluation - Pinch Point Study)

27. Perform an analysis of long term RCIC Room temperatures (for equipment qualification and habitability) under ELAP conditions considering elevated Suppression Pool and Secondary Containment temperatures

28. Perform an evaluation of containment structures to identify necessary actions to enable implementation of the strategy with running RCIC Not Started with elevated temperatures

29. Perform additional plant specific analysis to verify acceptable Suppression Pool levels during a long term operation of RCIC beginning with suction from the Condensate Storage Tanks (CSTs).

Verify containment limitations are not exceeded

30. Perform an analysis to verify acceptable parameters (e.g., Net Positive Suction Head (NPSH) requirements) for RCIC operation with Started 2/2015 the higher temperatures and anticipated changes in Suppression Pool level

31. Perform an analysis to validate containment vent sizing to maintain Started (2/2014)

Suppression Pool parameters to support RCIC capability

32. Perform an analysis to identify necessary actions, (e.g., modifications Complete or programmatic changes) to maximize battery coping time to at least (2/2015) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Page 12 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2.FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

33. Evaluate NMP2 containment integrity for Phases 1 through 3 and Started (2/2015) update calculations

34. Implement an alternative Containment Cooling strategy, if required, Not Started when the analysis of structural temperatures are complete

35. Perform an analysis to determine the containment pressure profile during an ELAP / Loss of Ultimate Heat Sink (LUHS) event and verify Started (2/2015) the instrumentation and controls in containment which are relied upon by the operators are sufficient to perform their intended function

36. Perform an analysis to determine when ambient heat losses will be low enough such that with Residual Heat Removal (RHR) in a Phase Deleted (2/2015) 3 mode of shutdown cooling, venting of the primary containment will no longer be required

37. Perform an analysis to verify assumptions related to an adequate nitrogen supply during ELAP conditions and revise or provide ELAP Not Started procedures that optimize Safety Relief Valve (SRV) control during an ELAP condition

38. Perform an analysis to verify the capability of the portable diesel Started (2/2014) generator (DG) to power all expected loads

39. Perform an analysis to determine the limiting conditions for an RHR loop to be restarted (e.g., RHR Room, seals and fluid temperatures) Deleted (see OIP and adjust the strategy to start in Shutdown Cooling (SDC) based on Update 8/2014) the results of the analysis

40. Perform a load distribution analysis for safety related equipment restoration utilizing either two RRC Diesel Generators paralleled on Deleted (see OIP one 4160 VAC bus or one RRC Diesel Generator on each safety Update 8/2013) related bus (i.e., one on Division 1 and one on Division 2)

41. Perform an analysis to determine the service water cooling water flow Deleted (see QIP needed to accommodate all expected cooling loads and resulting Update 8/2013)

RRC pump size requirement

42. Evaluate a strategy to provide a vent pathway for steam and Started (2/2014) condensate from the SFP or justify why it is not needed Page 13 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

43. Perform an evaluation to determine the effects and required actions Complete for Spent Fuel Pool temperatures expected above design of 150'F (2/2015) during an ELAP

44. Perform analysis to verify SFP temperature and level after an ELAP event and adequate level for maintaining radiological access to the Started (2/2014) refuel floor

45. Perform an analysis to evaluate long term temperature profiles in the Deleted (see OIP NMP2 Main Control Room (MCR) under ELAP condition (Phase 1) Update 8/2013)

46. Perform an analysis for long term environmental conditions in the NMP2 Battery Rooms during an ELAP and evaluate any actions to Started (2/2014) mitigate the impact of this hydrogen production as required

47. Evaluate the strategy for repower of select Emergency Lighting loads when the FLEX portable Diesel Generator reenergizes the 600 VAC Started (2/2014) bus

48. Perform an analysis of the light coverage during ELAP conditions and Complete determine if the lighting loads should be re-energized from the non- (2/2015) safety related buses by the RRC FLEX generator

49. Perform an analysis of the need for dewatering based on leak rates Deleted (see OIP and flood response capabilities Update 8/2014)

50. Implement a design change to install permanent 4160 VAC bus connection points to be able to connect to the RRC supplied Diesel Deleted (see OIP Generator, including paralleling capability, as required to connect Update 8/2014) more than one Diesel Generator to an electrical bus

51. Implement a design change to receive large capacity RRC pumps to Deleted (see OIP supply the service water distribution header Update 8/2014)

52. Design and implement a modification that provides for connection of a Started (8/2014)

FLEX portable pump to makeup to the SFP

53. Implement a design change to install connections for FLEX portable Started (8/2014) pumps to RHR for both RHR 'A' and 'B'

54. Implement a design change to install portable generator connections Started (8/2014) for 600 VAC primary (2EJS*US1) and alternate (2EJS*US3) busses Page 14 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 2 Status of NMP2 FLEX OIP Open Items (cont'd)

NMP2 OIP Open Items Status

55. Revise procedures to provide reactor pressure control direction during Not Started an ELAP event

56. Develop and implement procedure direction to ensure that the Main Not Started Turbine Hydrogen is vented prior to battery depletion

57. Revise current EOPs to implement EOP actions necessary to support the strategy to terminate emergency depressurization to preserve Started (2/2014)

RCIC operation

58. Develop and implement procedures to provide direction for re-energizing the Solenoid Operated Valves (SOVs) and ensuring long Not Started term pneumatic supply during an ELAP

59. Develop procedures to implement the connection of a FLEX portable pump to makeup water to the SFP during an ELAP event to include Started (8/2014) both primary and alternate strategies

60. Develop and implement procedures that provide direction for Deleted (see OIP restoration of SFP cooling during ELAP conditions (Phase 3) Update 8/2013)

61. Implement a design change to install permanent dry hydrants in the Started (2/2015) intake structure for FLEX portable pump suctions Page 15 of 26

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NMP2 SIX MONTH STATUS REPORT (FEBRUARY 2015)

FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 below provides a summary of the open and confirmatory items documented in the NRC's NMP2 ISE (Reference 7) and the status of each item.

ISE Open Item # 3: ISE Open Item 3.2.3.C - Revision 3 to the [Boiling Water Reactor Owner's Group] BWROG Emergency Procedure Guidance (EPG) Severe Accident Guidance (SAG) is a Generic Concern because the BWROG has not addressed the potential for the revised venting strategy to increase the likelihood of detrimental effects on containment response for events in which the venting strategy is invoked (identified as a 'Significant Concern' in the Notes for this Open Item in the ISE)

ISE Open Item # 3 is submitted for closure.

The BWROG, through the Nuclear Energy Institute (NEI), provided a Technical Report entitled 'BWR Containment Venting' for NRC Order EA-12-049 (ML1335A066, ML1335A079). The report documents the benefits and consequences of proposed protective action to perform Anticipatory Venting of BWR containments during an extended loss of AC power (ELAP) event.

Anticipatory venting is a feature of the latest revision to the BWROG emergency procedure guidance (EPG/SAG Rev 3), which was developed based on lessons-learned from the March 2011 Fukushima Dai-ichi accident. The technical report outlines the benefits of anticipatory venting as a protective action that limits containment pressure, containment temperature, suppression pool temperature and provides time for implementation of Phase 2 and Phase 3 core and containment cooling mitigation strategies and allowing portable pumps to inject water into the reactor at lower pressures.

The NRC provided endorsement of the BWROG Technical Report and revised venting strategies provided in BWROG EPG/SAG Rev 3 in a letter to NEI on January 9, 2014 (ML13358A206).

ISE Confirmatory Item # 5: ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris and potential soil liquefaction. Movement of equipment and procedural interfaces during a BDBEE were not discussed in the Integrated Plan or during the audit process. Deployment of temporary flood barriers, restocking of supplies in the context of a flood with long persistence and the potential impact of surface icing were also not addressed ISE Confirmatory Item # 5 is submitted for closure.

NMP2 deployment routes have been finalized and reviewed for impacts. Primary and alternate deployment paths are identified and maps developed.

Small sections of the travel paths, primarily at the storage building and at the deployment sites, may require some debris removal. Time, equipment and resources have been allotted in the staffing study for debris removal. This accounts for dispatching an operator within 30 minutes of the onset of an event to begin route assessment and debris removal. This resource is assigned (in the staffing study) for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Page 16 of 26

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS clearing paths of debris. The FLEX vehicles are capable of traveling over small debris.

A pay loader will be used to remove large debris as required. The pay loader will be stored in the FLEX building and Operators will be trained and qualified for operating the loader.

A soil liquefaction evaluation of the primary and alternate travel paths has been completed. The evaluation is applicable to all identified primary and alternate deployment paths as referenced above. Based upon the original site borings, the extensive borings conducted for the installation of the Independent Spent Fuel Storage Installation (ISFSI) and the associated Heavy Haul Path, and the recent vendor soil borings for the design of the FLEX building, the soil liquefaction potential for the primary and alternate deployment paths are considered minimal.

Based on the results of the Flooding Hazard Reevaluation performed for NMP, the maximum flood level in the vicinity of NMP2 is 262.4 feet due to persistent maximum precipitation. This exceeds the building entrance elevation of 261' for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />. A map of maximum flood depths for the site indicates that the maximum water depth associated with FLEX equipment staging/deployed areas is approximately 2.5 feet with one very localized area just under 3 feet. All areas to the north, the primary deployment pathway, are under 2 feet. For this reason, with the type of vehicles NMP has for towing, debris removal, and refueling, and the duration of the flood event, it is expected that movement for the purposes of restocking supplies will not be impeded by site flooding.

ISE Confirmatory Item # 6: ISE Confirmatory Item 3.1.1.4.A - Concerning utilization of offsite resources during a BDBEE, the local staging area and access routes were not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 6 is submitted for closure.

Nine Mile Point Nuclear Station (NMP) has signed contracts for participation in SAFER.

Each NSRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. The two NSRCs are located in Phoenix, Arizona and Memphis, Tennessee.

All licensees, including Exelon Generation Company, relying on SAFER and the NSRC, have executed contractual agreements with Pooled Equipment Inventory Company (PEICo) which allows for the capabilities (considerations) in Section 12.2 of NEI 12-06.

The NRC staff evaluated the NSRCs and the SAFER program, plans, and procedures against these 10 capabilities (considerations) from NEI 12-06, Section 12.2. The NRC audit results concluded that that the NSRCs and the SAFER plans and procedures conform to the guidance described by the 10 capabilities (considerations) of NEI 12-06, Section 12.2.

The NRC findings are documented in a letter from the NRC (Jack R. Davis) to the Nuclear Energy Institute (Joseph E. Pollock), Staff Assessment of National Safer Response Centers Established in Response to Order EA-12-049, dated September 26, 2014 (ML14265A107)

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The NSRC will support initial portable FLEX equipment delivery to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a request for deployment per the site specific response plan. Designated local staging areas have been selected to support deliveries of requested SAFER equipment from the NSRC to NMP.

Local Staging Area 'A' is defined as the final locations on site delineated in the FLEX procedures where the SAFER equipment will be placed into service to support the FLEX strategies if needed. The site has equipment that will be able to transfer the portable equipment from SAFER at Staging Area 'B' on-site to Staging Area 'A' inside the protected area. This equipment includes those identified for deployment considerations that will be stored in the FLEX building such as a pay loader, large tractor and large truck.

Local Staging Area 'B' is defined as the site delivery and preparation area outside the site Protected Area where the SAFER equipment is delivered and prepared for use (e.g.,

unloaded, assembled, and fueled) prior to transport to Staging Area 'A' for use. At NMP, this area is the site parking lot located south of the P-building, adjacent to the Site Access Building.

Local Staging Area 'C' is defined as the regional airport outside of the 25 mile radius of the site. SAFER will provide requested portable equipment through contracts with FedEx via truck transport or air freight to Staging Area "C" where the equipment will be made ready for transport to the site by either roadways using trucks or air transport using helicopters. For NMP, Staging Area 'C' is the Overflow Parking Lot at Syracuse Hancock International Airport.

SAFER has contracts in place with FedEx to truck transport the FLEX equipment from Staging Area 'C' to NMP site Staging Area 'B'. SAFER also has contracts in place for air lift transportation of the equipment from Staging Area 'C' to Staging Area 'B' at NMP using freight helicopters if both Primary and Alternate transportation path roadways are not available for use. The Primary and Alternate truck transport routes are contained in Chapter 5 of the NMP SAFER Response Plan which is currently in review and approval.

ISE Confirmatory Item # 18: ISE Confirmatory Item 3.2.4.6.A - Licensee to provide calculation and basis for use of extrapolated station blackout (SBO) evaluation for Main Control Room habitability ISE Confirmatory Item # 18 is submitted for closure.

NMP2 currently has an approved safety related calculation that provides indication that the maximum temperature in the MCR during an 8-hour SBO event is about 100OF at hour 1.6 into the SBO event. The peak temperature then starts lowering and is approximately constant at <100 0 F at the end of an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> calculated SBO event.

The heat loads in the MCR during the 72-hour ELAP event will actually be lower than that in the SBO event since enhanced load shedding will be implemented during the ELAP in order to maximize the battery coping time. Therefore, it is reasonable to conclude that the temperature in the MCR will not exceed 100°F and habitability is not a concern during the ELAP event based on results from the existing SBO calculation.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ISE Confirmatory Item # 20: ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an updated summary of the sizing calculations for the FLEX generators at a future update ISE Confirmatory Item # 20 is submitted for closure.

A preliminary plant specific evaluation identifies that the portable diesel generator for NMP2 Phase 2 FLEX is adequately sized to power the required loads defined by the NMP2 FLEX Phase 2 strategy. The breakers utilized at the 600 VAC load centers are adequately sized and have sufficient short circuit rating for this application. The calculation also provides necessary analysis that supports the appropriate cables and connection points. The evaluation considered the installed safety related battery charger as the primary load and delineates the capability of the portable diesel generator to provide both steady state and starting (in rush) current. Additional loads both required and identified as optional by Operations were also considered in the evaluation and indicated that worst case loading conditions will result in operation of the portable diesel generator at under 80%.

SAFER will supply a Turbine Marine 1.1 MW 480 VAC generator with a step up transformer to 600VAC. These capabilities exceed and therefore envelope the on-site Phase 2 diesel generator size (450 kW). The SAFER generators come with the same size cable connectors as the on-site Phase 2 FLEX generators.

SAFER will also provide six (6) NSRC 6 kW diesel generators to provide power to emergency lighting towers and will not be connected to or provide power for equipment within the plant.

Final calculations and analysis will be provided as a function of the design modification process and will serve to verify the preliminary sizing evaluation. In addition, the formal modification process outcome will be used to develop procedural controls for operation, loading and controlling portable diesel generator load.

ISE Confirmatory Item # 21: ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a summary of the refueling strategies for FLEX equipment will be provided when finalized at a future date ISE Confirmatory Item # 21 is submitted for closure.

Nine Mile Point strategies to provide fuel oil for portable diesels are to use the supply of on-site SR storage tanks that would normally supply the stations emergency diesel generators during a loss of AC/off-site power event.

In order to ensure proper sizing and strategies for appropriate response for the eventual simultaneous full implementation of FLEX mitigation strategies at both NMP units, calculations associated with fuel consumption were performed assuming the equipment required for full implementation of mitigation strategies at both NMP1 and NMP2 are in operation simultaneously.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Fuel consumption for both NMP1 and NMP2 portable equipment to support FLEX (4 diesel driven portable pumps, 2 diesel driven portable generators and 1 diesel driven portable air compressor) is 130 gallons per hour (gph) for all items operating at full load.

The Technical Specification (TS) minimum fuel storage on site is over 141,000 gallons in the emergency diesel generator fuel oil storage and day tanks. For the purposes of this analysis, the fuel at NMP1 is not credited (fuel is not accessible during flooding conditions). Fuel available at NMP2 is assumed with one emergency diesel generator fuel oil storage tank unavailable (i.e. TS allowable). The remaining capacity of the two SR storage tanks at NMP2 is greater than 85,000 gallons and will provide over 25 days of fuel for all FLEX portable equipment. The SAFER equipment, as replacement or backup to Phase 2 on-site portable diesel driven equipment, can theoretically increase fuel consumption rate to 270 gph if all equipment were deployed and operated at full load. The higher rate is due to design differences and larger equipment (i.e. Turbine generator versus diesel generator, booster pump and main pump for water delivery).

Even at this consumption rate, on site fuel reserves would provide greater than 13 days of operation without off site replenishment. It is expected that the emergency response organization can ensure delivery of replenishment fuel as required within the times identified above.

NMP will utilize two 528 gallon fuel tanks mounted on separate trailers and stored in the FLEX building. Each tank has a pump that is powered from the towing vehicles DC power or an on-board battery, and will be used to refuel the FLEX portable equipment.

These 528 gallon tanks will be filled from the on-site SR fuel oil storage tanks identified above. Transfer pumps and fuel for them are to be stored in the FLEX building, and used during an event to pump the fuel oil out of the SR storage into the refueling tanks.

The pumps have been tested on-site and provide over 31 gpm flow (1860 gph). The pump capacity of the deployment tank pump/nozzle is approximately 20 gpm (1200 gph). These delivery rates are well above the full load usage rate of all FLEX Phase 2 portable equipment.

ISE Confirmatory Item # 22: ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, DC load profile, discussion of loads shed, and minimum DC voltage will be provided in a future update ISE Confirmatory Item # 22 is submitted for closure.

With Operations input in order to extend the battery coping time, a specific calculation was performed to determine the actions necessary to maximize the coping time for the Division I and II safety related batteries. The calculation concluded that the station's battery coping time with implementation of additional DC load shedding, will be a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for an ELAP event for each divisional battery. The loads to be shed are itemized in the calculation. The minimum battery voltage design input for the calculation is a minimum cell voltage of 1.75 volts per cell (60 cells in the battery) or 105 VDC for the battery.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS An existing NMP2 safety related calculation specifically for DC cable sizing provides the basis for the required terminal voltage of 105 VDC and includes an evaluation that determines that the terminal voltage at each load meets the minimum requirements for operating the equipment.

In order to provide the DC loads with power for the specified coping time during an ELAP event, load shedding for the safety related batteries will be performed within 60 minutes.

The load shed process will be accomplished per procedure (Station Blackout support procedure).

ISE Confirmatory Item # 23: ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 23 is submitted for closure.

The request for support from SAFER will be made as directed in changes to FLEX Support Guidelines (FSGs) for the actual ELAP if attempts to restore AC power are not successful within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from event initiation. The request is initiated by notifying the Exelon Corporate Nuclear Duty Officer (NDO). Communications to the NDO to request SAFER are prescribed in changes to both the FSG as well as the Emergency Procedure checklist for the Emergency Director/Shift Manager. The NDO will then contact SAFER and request implementation of the NMP SAFER Response Plan which initiates SAFER FLEX equipment deployment to the site. Training on the changes to procedures that support notification and request of equipment from the NSRC is scheduled to be performed prior to FLEX full compliance for the first Nine Mile Point Unit implementing FLEX (NMP1).

The National SAFER Regional Centers (NSRC) will support initial portable FLEX equipment delivery to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a request for deployment. A site specific response plan for Nine Mile Point delineates the transport logistics, staging area setup and preparation, and communications protocols between the SAFER Control Center (SCC), the NSRC, the Staging Areas, and NMP. This response plan provides the detail necessary to ensure the successful delivery of the portable FLEX equipment from the NSRC to the local staging area and from the local staging area to the site ISE Confirmatory Item # 24: ISE Confirmatory Item 3.4.8 - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant connection points was not discussed in the Integrated Plan or during the audit process ISE Confirmatory Item # 24 is submitted for closure.

The portable diesel generator for NMP2 Phase 2 FLEX application has been evaluated as being adequately sized at 450 kW per calculation (see ISE Open Item # 20). The NSRC will supply a 480VAC, 1.1 MW portable Turbine Marine generator with a step up transformer to 600 VAC (NMP2 safety related distribution system is 600 VAC) and will come with the same style (same manufacturer) connectors and cable sizes as the on-site Phase 2 FLEX generators. The NSRC generator size exceeds and envelopes the capability of the NMP2 Phase 2 generator.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS The Phase 2 FLEX pump hose connections are standard 3 inch hose with 2.5 inch threaded normal fire hose (NH) fittings. The NSRC supplied equipment utilized to support NMP has the same 2.5 inch NH fittings or a 5 inch Storz fitting. NMP has one 5 inch Storz to 2.5 inch NH hose adapter for each Phase 2 FLEX portable diesel driven pump to adapt the NSRC fittings to the NMP2 Phase 2 FLEX connections. The NSRC pumps that would be utilized to support as a backup to the Phase 2 NMP FLEX pumps are the SG/RPV Makeup Pump rated at 500 psi and 500 gpm, and/or the Low Pressure/Medium Flow Pump rated at 300 psi and 2500 gpm, in conjunction with the Suction Lift Booster Pump for supporting required suction lift at up 2500 gpm. These pumps meet/exceed and therefore envelope the NMP2 Phase 2 FLEX strategy requirements delineated in preliminary NMP2 FLEX Hydraulic calculations.

Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items ISE Open Items Status

1. ISE Open Item 3.1.1.3.A - Seismic procedural interface consideration NEI 12-06, Section 5.3.3, Consideration 1, which considers the possible failure of seismically qualified electrical Started (8/2014) equipment by beyond-design-basis seismic events, was not discussed in the Integrated Plan or during the audit process

2. ISE Open Item 3.2.3.B - The licensee has not performed finalized calculations to demonstrate that the assumed timeline is Started (2/2014) appropriate and that containment functions will be restored and maintained following an ELAP event

3. ISE Open Item 3.2.3.C - Revision 3 to the [Boiling Water Reactor Owner's Group] BWROG Emergency Procedure Guidance (EPG)

Severe Accident Guidance (SAG) is a Generic Concern because the BWROG has not addressed the potential for the revised Submitted for venting strategy to increase the likelihood of detrimental effects on Closure (2/2015) containment response for events in which the venting strategy is invoked (identified as a 'Significant Concern' in the Notes for this Open Item in the ISE)

ISE Confirmatory Items Status

4. ISE Confirmatory Item 3.1.1.1.A - The design of the storage facility for FLEX equipment is under development. The method selected for protection of equipment during a Beyond-Design-Basis External Event (BDBEE) was not discussed in the Started (2/2014)

Integrated Plan or during the audit process. Also, there was no discussion of securing large portable equipment for protection during a seismic hazard Page 22 of 26

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

5. ISE Confirmatory Item 3.1.1.2.A - Deployment routes have not yet been finalized or reviewed for possible impacts due to debris and potential soil liquefaction. Movement of equipment and procedural Submitted for interfaces during a BDBEE were not discussed in the Integrated Plan Closure or during the audit process. Deployment of temporary flood barriers, (2/2015) restocking of supplies in the context of a flood with long persistence and the potential impact of surface icing were also not addressed

6. ISE Confirmatory Item 3.1.1.4.A - Concerning utilization of offsite Submitted for resources during a BDBEE, the local staging area and access routes Closure were not discussed in the Integrated Plan or during the audit process (2/2015)

7. ISE Confirmatory Item 3.2.1.1.A - MAAP benchmarks must be identified and discussed which demonstrate that MAAP4 is an Started (2/2014) appropriate code for the simulation of an ELAP event

8. ISE Confirmatory Item 3.2.1.1.B - MAAP Analysis collapsed level must remain above Top of Active Fuel (TAF) and the cool down rate Started (2/2014) must be within technical specification limits

9. ISE Confirmatory Item 3.2.1.1.C - MAAP4 must be used in accordance with Sections 4.1, 4.2, 4.3, 4.4 and 4.5 of the June 2013 Started (2/2014) position paper

10. ISE Confirmatory Item 3.2.1.1.D - MAAP modeling parameters Started (2/2014)

11. ISE Confirmatory Item 3.2.1.1.E - The specific MAAP4 analysis case that was used to validate the timing of mitigating strategies in the Integrated Plan must be identified and should be available for review

12. ISE Confirmatory Item 3.2.1.2.A - There was no discussion of the applicability of the assumed recirculation system leakage rates and the recirculation pump seal leakage rates to the ELAP event; the pressure dependence of the leak rates; whether the leakage was Not Started determined to be single-phase, two-phase, or steam at the donor cell; and how mixing of the leakage flow with the drywell atmosphere was modeled

13. ISE Confirmatory Item 3.2.2.A - Evaluation of the refueling floor SFP area for steam and condensation was not yet completed. Started (2/2014)

Mitigating strategies were not discussed in the Integrated Plan or during the audit process Page 23 of 26

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

14. ISE Confirmatory Item 3.2.3.A - Perform an evaluation of containment structures to identify necessary actions to enable implementation of the strategy with running RCIC with elevated temperatures

15. ISE Confirmatory Item 3.2.4.2.A - The completion and determination of acceptable results for all of the calculations associated with the proposed strategies for ventilation and critical equipment cooling (e.g., RCIC and Battery Rooms) are required

16. ISE Confirmatory Item 3.2.4.4.A - The potential restoration of a portion of the Emergency Lighting System when Division I 600 VAC Unit Substation 2EJS*US1 (or alternatively Division II 2EJS*US3) is repowered is currently under evaluation. NMP2 will provide a summary of the restoration of Emergency Lighting expected to be restored in a future update

17. ISE Confirmatory Item 3.2.4.4.B - Follow-up of communication commitments as discussed in the staff analysis (ML13100A236) Started (2/2015) is required

18. ISE Confirmatory Item 3.2.4.6.A - Licensee to provide Submitted for calculation and basis for use of extrapolated station blackout Closure (2/2015)

(SBO) evaluation for Main Control Room habitability

19. ISE Confirmatory Item 3.2.4.8.A - The licensee stated that when the design review of the portable generator protection is completed, the specific details on the protection schemes to Not Started protect Class 1 E equipment from faults from the portable FLEX equipment will be provided in a future update

20. ISE Confirmatory Item 3.2.4.8.B - The licensee will provide an Submitted for updated summary of the sizing calculations for the FLEX Closure (2/2015) generators at a future update

21. ISE Confirmatory Item 3.2.4.9.A - The licensee stated that a Submitted for summary of the refueling strategies for FLEX equipment will be Closure (2/2015) provided when finalized at a future date

22. ISE Confirmatory Item 3.2.4.10.A - The licensee stated that a finalized summary of battery coping time, DC load profile, Submitted for discussion of loads shed, and minimum DC voltage will be Closure (2/2015) provided in a future update Page 24 of 26

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS Table 3 Status of NMP2 Interim Staff Evaluation (ISE) Open and Confirmatory Items (cont'd)

ISE Confirmatory Items Status

23. ISE Confirmatory Item 3.4.A - The program or process to request RRC equipment was not discussed in the Integrated Plan sube(2/2015)

Closure for or during the audit process

24. ISE Confirmatory Item 3.4.8 - Sizing calculations of RRC FLEX equipment and the compatibility of RRC equipment to plant Submitted for connection points was not discussed in the Integrated Plan or Closure (2/2015) during the audit process 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS 8 References The following references support the updates to the OIP described in this enclosure.

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February

28. 2013

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

3. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 8, 2013

4. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to NRC Letter on 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, dated August 2012

6. Letter from E. D. Dean (CENG) to Document Control Desk (NRC), 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 27, 2013

7. Letter from J. S. Bowen (NRC) to J. A. Spina, Nine Mile Point Nuclear Station, Units 1 and 2 - Interim Staff Evaluations Relating to Overall Integrated Plans in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF 1129 and MFl130), dated December 19, 2013

8. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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 February 27, 2014

9. NEI Position Paper Shutdown and Refueling: ADAMS Accession No. ML13273A514

10. NRC Endorsement of NEI Shutdown and Refueling Paper: ADAMS Accession No. ML13267A382

11. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), 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 Number EA-12-049), dated August 26, 2014

12. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2 and 6 - Phase 2 Staffing Assessment Page 26 of 26