ML14069A015

Surry Power Station Units 1 and 2 - 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-

ML14069A015
Person / Time
Site:	Surry
Issue date:	02/27/2014
From:	Sartain M D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML14069A015 (61)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261February 27, 201410 CFR 2.202EA-12-049 Attention:

Document Control Desk Serial No.: 12-163EU.S. Nuclear Regulatory Commission NL&OS/MAE:

ROAWashington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FORMITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-1 2-0491

References:

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"

dated March 12, 20122. Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),

dated February 28, 2013 (Serial No. 12-163B)3. Virginia Electric and Power Company's Six Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),

dated August 23, 2013 (Serial No. 12-163D)4. NRC letter, "Nuclear Regulatory Audits of Licensee Responses to Mitigating Strategies Order EA-12-049,"

dated August 28, 2013 (ADAMS Accession No.ML13234A503)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference

1) to Virginia Electric and Power Company (Dominion).

Reference 1 wasimmediately effective and directed Dominion to develop, implement, and maintainguidance and strategies to maintain core cooling, containment, and spent fuel poolcooling capabilities in the event of a beyond-design-basis external event.Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a statusreport at six-month intervals following submittal of the OIP.Attachment 1 of this letter provides the second six-month status report and an update ofmilestone accomplishments since the submittal of the first six-month status report(Reference 3), including any changes to the compliance method, schedule, or need forrelief and the basis.-AH1 Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Page 2 of 3Attachment 2 provides the Phase 3 containment strategy and the ventilation

strategy, respectively, identified as Open Items 4 and 14 for the OIP. This information is providedin the template format used for the originally submitted OIP. The pages provided inAttachment 2 for Section D, "Maintain Containment" and Section F5, "Safety Functions Support (Ventilation)"

supersede Section D and Section F5 in the originally submitted OIP.Attachment 3 formally documents responses provided to several Audit Questions received for Surry Power Station during the Audit of Licensee Responses to Mitigating Strategies Order EA-12-049 (Reference 4).If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. SartainVice President

-Nuclear Engineering Virginia Electric and Power CompanyAttachments (3)Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIACOUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Virginia Electric andPower Company.

He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of hisknowledge and belief.Acknowledged before me thisj_ day of2014.My Commission Expires:

J.26, 3 O l 7.VICKI L. HULL '~Notary Public(SEAL) Notary PublicCommonwealth of Virginia140542,oMW (CnMMkISnn Fv irn UA.~, '24 ......V.'. A D.LIrm

....

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Ms. M. C. BarillasNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North AnnaU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 09 D211555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Six-Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External EventsFebruary 2014Surry Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 1 of 21Six-Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference

1) documenting thediverse and flexible strategies (FLEX) for Surry Power Station in response to NRCOrder Number EA-12-049 (Reference 2). This attachment provides an update ofmilestone accomplishments and open items since submittal of the last status report(Reference 15), including any changes to the compliance method, schedule, or need forrelief/relaxation and the basis, if any.2 Milestone Accomplishments The following milestones have been completed since the development of the OIP and iscurrent as of January 31, 2014.* Submit OIP* Develop Strategies 3 Milestone Schedule StatusThe following table provides an update to Attachment 2A of the OIP. It provides theactivity status of each item, and whether the expected completion date has changed.The dates are planning dates subject to change as design and implementation detailsare developed.

The revised milestone target completion dates for 'Develop Modifications' and 'DevelopStrategies/Contract with RRC' do not impact the Order implementation date.Target Activity Revised TargetMilestone Completion Status Completion Date DateSubmit Integrated Plan February 2013 CompleteDevelop Strategies October 2013 CompleteDevelop Modifications April 2014 Started July 2014 *Implement Modifications May 2015 StartedDevelop Training Plan April 2014 StartedImplement Training August 2014 Started Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 2 of 21Target ARevised TargetMilestone Completion Status Completion Date DateIssue FSGs and Associated Procedure Revisions September 2014 StartedDevelop Strategies/Contract with Regional Response Center April 2014 Started August 2014 *(RRC)Purchase Equipment February 2014 StartedReceive Equipment August 2014 StartedValidation Walk-throughs orDemonstrations of FLEX December 2014 Not StartedStrategies and Procedures Create Maintenance Procedures August 2014 Not StartedUnit 1 Outage Implementation April 2015 StartedUnit 2 Outage Implementation October 2015 Not Started* Refer to Section 8, Supplemental Information, for an explanation of Milestone changes.4 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion provided an OIP to address Beyond-Design-Basis (BDB) events at Surry Power Station (Surry) Units 1 and 2 (Reference 1)as required by Order Number EA-12-049, dated March 12, 2012 (Reference 2). Thefirst Six-Month Status Update of the OIP for Surry was provided by letter dated August23, 2013 (Reference 15). The following are changes to the compliance methodinformation provided in the Surry OIP; which continue to meet NEI 12-06 (Reference 3):a) Details of the strategy for the portable diesel generators (DGs) used to re-power the120VAC vital bus circuits, as described in Section F1.2 -PWR Portable Equipment Phase 2, of the OIP have changed for Surry. The primary and alternate strategies have been switched.

The primary strategy is to deploy a 480VAC diesel generator (DG) from the BDB Storage Building to the locations previously identified in OIPFigure 6. The generator will be used to power the 1/2A-2 and 1/2B-2 BatteryChargers which in turn supply power to the vital AC instrument panels. The 480VACDG connection strategy is unchanged.

As an alternate re-powering method for instrumentation, the 120/240VAC portableDGs will be used to power vital AC instrument panels via the BDB distribution panels. The 120/240VAC DGs will be stored in the BDB Storage Building.

The Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 3 of 21deployment locations and connection strategy for the 120/240VAC DGs isunchanged.

The station Class 1 E battery duty cycle of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> previously reported in Reference 4 is changed to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> for the purpose of retaining operational margin. Dominionconfirms that the Class 1 E battery duty cycle for Surry was calculated in accordance with the IEEE-485 methodology using manufacturer discharge test data applicable tothe licensee's FLEX strategy as outlined in the NEI white paper on Extended BatteryDuty Cycles. The detailed licensee calculations, supporting vendor discharge testdata, FLEX strategy battery load profile, and other inputs/initial conditions requiredby IEEE-485 are available on Dominion's web portal for documents and calculations.

The time margin between the calculated battery run-time for the FLEX strategy andthe expected deployment time for FLEX equipment to supply the DC loads isapproximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Surry.b) The BDB and Regional Response Center (RRC) equipment details in OIP Table 1,PWR Portable Equipment Phase 2, and OIP Table 2, PWR Portable Equipment Phase 3, respectively, have changed.

Updates to the 'List Portable Equipment',

'Performance Criteria,'

and usage categories are included as well as associated changes/deletions in footnotes.

Minor changes to the number of components havebeen included for some of the support equipment categories, but no changes aremade to the quantities of any of the major FLEX components.

Revised OIP Tables 1and 2 are included in this attachment.

Footnote 6 has been added to the quantity of BDB High Capacity pumps in Table 1.One BDB High Capacity pump is needed to implement the FLEX core and SpentFuel Pool (SFP) cooling strategies.

This pump will be stored in the Type 1 BDBStorage Building and protected from all hazards.

The other pump, the site 10 CFR50.54(hh)(2) high capacity pump (B.5.b),

has adequate capacity to backup the BDBHigh Capacity pump and serves to meet the N+1 requirement.

We are aware thatthe NRC expectation is that the 10 CFR 50.54(hh)(2) high capacity pump is to bereadily available for a imminent threat scenario.

However, we have determined thatuse of the 10 CFR 50.54(hh)(2) high capacity pump as a backup to the BDB HighCapacity pump does not degrade the mitigating strategies associated with B.5.b inthat the pump remains readily available in the event of a imminent threat scenario.

This 10 CFR 50.54(hh)(2) pump is stored onsite in a separate location that isreasonably protected from flooding, extreme heat, and extreme cold events.c) The OIP, submitted on February 28, 2013, contained an open item for thedevelopment of the coping strategy to maintain Containment integrity following anExtended Loss of AC Power (ELAP) event, if required.

OIP Section A.4 (Action Item16) and Attachment 1A, Sequence of Events, Item 16, discussed the timeframe forwhich action was required to address Containment temperature and pressure.

Conservative analysis has concluded that Containment temperature and pressure Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 4 of 21response will remain below design limits following an ELAP and that key parameter instrumentation subject to the Containment environment will remain functional for atleast seven days (Reference 14).The strategy for coping with Containment temperature and pressure increases hasbeen developed.

By maintaining these parameters below their design limits,Containment structural integrity is ensured.

To remain within analyzed limits forequipment qualification temperature, the Containment temperature will beprocedurally monitored and, if necessary, the temperature will be reduced.

This willrequire the implementation of the Phase 3 Containment cooling strategy such thatheat removal from Containment is initiated in a timely manner.The Phase 3 Containment coping strategy was not provided in the initial submittal ofthe OIP. It is provided in Attachment 2 of this submittal.

The Containment copingstrategy is presented in the original OIP template format as Section D and isintended to supersede the previous Section D in its entirety.

Attachment 2 alsocontains two new OIP figures (Figures 11 and 12) in support of the Section DContainment strategy.

d) The OIP for Surry, submitted on February 28, 2013, contained an open item for thedevelopment of the coping strategy to account for the loss of forced ventilation following an ELAP event. The loss of ventilation evaluation has been completed andconcluded that no special equipment or immediate actions are required to maintainthe equipment and personnel habitability in areas requiring access to implement theFLEX strategies (Reference 13). In the case of the upper level of the MSVH, wherethe SG PORVs are located, access to this area is necessary to isolate the normal airsupply to the PORVs such that the local bottle air supply can be utilized for localcontrol from a cooler area. One of the doors which leads to outside the MSVH(either the upper or lower level) will need to be opened to allow a "stack effect"circulation of air between the door and the ventilation openings at the top of theMSVH. This will ensure that the temperatures remain within the acceptable rangefor personnel habitability.

An additional ventilation concern applicable to Phase 2 is the potential buildup ofhydrogen in the battery rooms. Off-gassing of hydrogen from batteries is only aconcern when the batteries are charging.

Once a 480VAC power supply is restoredin Phase 2 and the station Class 1 E batteries begin re-charging, the doors to thebattery rooms will be opened and portable fans will be used to disperse anyhydrogen into the much larger volumes of the ESGR rooms and Turbine Building toprevent any significant hydrogen accumulation.

The coping strategy for the loss of ventilation following an ELAP event at Surry wasnot provided in the initial submittal of the OIP. It is provided in Attachment 2 of thissubmittal.

Attachment 2 is presented in the original OIP template format as Section Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 5 of 21F5 -Safety Function Support (Ventilation) and is intended to supersede the previousSection F5 in its entirety.

e) In response to the NRC staff concern that sufficient time and core flow conditions are available for adequate boron mixing, the PWROG, in conjunction withWestinghouse, developed a boron mixing position paper. This position paper hasbeen endorsed by the NRC with clarifications as stated in a letter from Jack Davis,Director Mitigating Strategies, US NRC to Jack Stringfellow, PWROG, Endorsing PWROG Position Paper, January 8, 2014. The Surry ELAP analyses verify that theconditions set forth in the NRC's endorsement of the boron mixing position paperwith the NRC's clarifications are met. Accordingly, the endorsed boron mixingmethodology has been applied to the final FLEX RCS inventory and reactivity management strategies.

f) The Emergency Condensate Storage Tank (ECST) and the Emergency Condensate Make-up Tank (ECMT) provide the initial water sources to feed the Turbine-Driven Auxiliary Feedwater (TDAFW) pump. Following depletion of these sources,additional water sources will be connected to continue the supply of water to theTDAFW pump. OIP Figure 3, as modified in the August 2013 Six-Month StatusUpdate, showed the configuration to attach various supplies to the piping which fillsthe ECST. The discharge from the tank would then continue to supply water to theTDAFW pump from the alternate sources.

Construction of the piping tie-in, asproposed, would have resulted in exceeding Technical Specification (TS) AllowedOut of Service Times as a result of the system configuration and the system crosstiewith the opposite unit. The revised tie-in location is to the supply piping of theTDAFW pump only and, therefore, does not cause the other pumps in this system tobe out of service, thereby ensuring the TS Allowed Out of Service Times were notexceeded.

This revision is shown in the attached revised Figure 3. As part of thisdesign adjustment, the pressure indicator was also re-positioned to the suctionpiping where the new tie-in is located.g) As stated in Section B.1 of the OIP, the Auxiliary Feedwater (AFW) system is pre-aligned for flow to all three Steam Generators (SGs), and the AC motor operatedflow control valves fail as-is (open) to maintain flow to all three SGs. Accordingly, manual control of feedwater (FW) to all three SGs is required to throttle the AFWflow and maintain a symmetric, three steam generator cooldown as stated in OIPAttachment 2B, Item 4. This information is accurate for the majority of the time theSurry Units 1 and 2 are operating.

However, during a limited period of time whenthe plant is between 350 deg F RCS temperature and Hot Shutdown conditions, theAFW supply lines to one SG are required to be isolated due to motor-driven AFWpump runout concerns.

If a BDB event initiates during this condition, and since the fail-as-is motor-operated AFW isolation valves are located inside Containment (inaccessible following an Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 6 of 21ELAP), AFW flow to one of the SGs will be unavailable and an asymmetric plantcooldown will be performed using the remaining two available SGs (References 11and 12). Justification for the acceptability of this limited condition will be providedthrough the audit process.5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date and no requiredrelief/relaxation has been identified at this time.6 Open Items from Overall Integrated PlanThe following table provides a summary of the status of open items documented inAttachment 2B of the Surry Overall Integrated Plan submitted February 28, 2013 andthe status of each item.Overall Integrated Plan Open Item01 # Description StatusVerify response times listed in timeline and perform staffing Not started.1 assessment.

Scheduled completion date: December 2014Preliminary analyses have been performed to determine the Complete.

Class 1 E battery life based on implementation of load (Provided in Reference 2 stripping actions.

The final battery life duration will be 4)provided when the analyses are completed.

See Section 4, Item a.Preliminary analyses have been performed to determine the Complete.

time to steam generator overfill without operator action to (Provided in Reference reduce AFW flow, time to steam generator dryout without 4)3 AFW flow, and time to depletion of the useable volume of theECST and ECMT. The final durations will be provided whenthe analyses are completed.

The Phase 3 coping strategy to maintain Containment Complete.

integrity is under development.

Methods to monitor andevaluate Containment conditions and depressurize/cool See Attachment 2, OIPContainment, if necessary, will be provided in a future update. Section D.4See Open Item 5 forconfirmation of theeffectiveness of Phase 3Containment strategies.

5 Analyses will be performed to develop fluid components Started.performance requirements and confirm fluid hydraulic-related Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 7 of 21Overall Integrated Plan Open Item01 # Description

[ Statusstrategy objectives can be met.Hydraulic calculations for the FLEX pumpsdeployed using theirassociated hosenetworks haveconfirmed that the corecooling/decay heatremoval, RCS Inventory, and Reactivity Control(RCS Injection),

andSFP Make-up strategies can be satisfactorily accomplished inresponse to anELAP/Loss of UltimateHeat Sink (LUHS)event.(References 6 and 7)Phase 3: Thermal andhydraulic calculations, which confirm that theContainment strategies are adequate, will becompleted by April2014.Scheduled completion date is revised fromSeptember, 2013 toApril 2014 **A study is in progress to determine the design features, sitelocation(s),

and number of equipment storage facilities.

Thefinal design for BDB equipment storage will be based on theguidance contained in NEI 12-06, Section 11.3, Equipment Storage.

A supplement to this submittal will be provided withthe results of the equipment storage study.6Complete.

A single 10,000 sq. ft.Type 1 building will beconstructed at Surry forstorage of BDBequipment.

Thebuilding will be designedto meet the plant'sdesign basis for theSafe ShutdownEarthquake, high windhazards, snow, ice andcold conditions, and will Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 8 of 21Overall Integrated Plan Open Item01 # Description Statusbe located above theflood elevation from themost recent site floodinganalysis.

The BDBStorage Building will besited just east of thesouth employee parkinglot, inside the OwnerControlled Area. Thelocation lies in an areabetween the SurryNuclear Information Center and the IntakeCanal. This updateprovides thesupplemental information referred to inthis open item.FLEX Support Guidelines (FSGs) will be developed in Started.7 accordance with PWROG guidance.

Existing procedures will Scheduled completion be revised as necessary to implement FSGs. date: September 2014EPRI guidance documents will be used to develop periodic Not started.testing and preventative maintenance procedures for BDB Scheduled completion 8 equipment.

Procedures will be developed to manage date: December 2014unavailability of equipment such that risk to mitigating strategycapability is minimized.

An overall program document will be developed to maintain Started.9 the FLEX strategies and their bases and to provide Scheduled completion configuration control and change management for the FLEX date: December 2014Program.The Dominion Nuclear Training Program will be revised to Started.assure personnel proficiency in the mitigation of BDB events Scheduled completion 10 is developed and maintained.

These programs and controls date: December 2014will be developed and implemented in accordance with theSystematic Approach to Training (SAT).Plant modifications will be completed for permanent plant Started.11 changes required for implementation of FLEX strategies.

Scheduled completion date: See Milestone Schedule above.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 9 of 21Overall Integrated Plan Open Item01 # Description StatusThe following actions will be completed to qualify the ECMT Started.as a source of water to the TDAFW pump in response to anELAP/LUHS event: (1) Upgrade the piping system from the Scheduled completion 12 ECMT to the TDAFW pump suction to Seismic Category 1 (2) date: May 2015Modify the TDAFW pump discharge piping to install local AFWflowrate indication (3) Confirm adequate TDAFW pump NPSHfrom the ECMT through the idle AFW booster pumps usingconservative analysis.

Complete the evaluation of TDAFW pump long term Complete.

operation with </= 290 psig inlet steam pressure.

TDAFW pump operation 13 and adequate AFW flowto the SGs at SGpressures

< 290 psighas been confirmed.

(Reference 5)Details of the ventilation strategy are under development and Complete.

14 will conform to the guidance given in NEI 12-06. The detailsof this strategy will be provided at a later date. See Attachment 2, OIPSection F5.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 10 of 21Overall Integrated Plan Open ItemOI# Description StatusAnalyses will be performed to develop electrical components performance requirements and confirm electrical loading-related strategy objectives can be met.Started.15Phase 2: Preliminary results for the sizing andloading analysis of the120VAC and 480VACgenerators confirm theelectrical loading-related strategy objectives canbe met. Finalcalculations confirming these results will becompleted by the end ofMarch 2014.Phase 3: Calculations identifying the Phase 34160VAC generator load requirements andpower cable ampacityrating along withbreaker coordination between the RRCequipment andDominion equipment willbe completed by June2014.Scheduled completion date: June 2014 **An evaluation of all BDB equipment fuel consumption and Not started.16 required re-fill strategies will be developed including any Scheduled completion gasoline required for small miscellaneous equipment.

date: June 2014A lighting study will be performed to validate the adequacy of Started.17 supplemental lighting and the adequacy and practicality of Scheduled completion using portable lighting to perform FLEX strategy actions.

date: June 2014 Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 11 of 21Overall Integrated Plan Open Item01 # Description StatusA comprehensive study of communication capabilities is being Complete.

performed in accordance with the commitments made inDominion letter S/N 12-208F dated October 29, 2012 in A study documenting response to Recommendation 9.3 of the 10 CFR 50.54(f) the communications letter dated March 12, 2012. The results of this study will strategy has beenidentify the communication means available or needed to completed.

The plan18 implement command and control of the FLEX strategies at concludes that FLEXSurry. Validation of communications required to implement strategies can beFLEX strategies will be performed as part of Open Item No. 1. effectively implemented with a combination ofsound powered phones,satellite phones andhand-held radios.(Reference 8)Preferred travel pathways will be determined using the Started.guidance contained in NEI 12-06. The pathways will attemptto avoid areas with trees, power lines, and other potential The soil liquefaction obstructions and will consider the potential for soil study has beenliquefaction.

completed (Reference 9), which supports thelocation of the storagebuilding and the haul19 routes. The results willbe included with thefinal design package forthe storage building(Reference 10).Scheduled completion date: June 2014The equipment listed in Table 1 will be received on site. Started.20 Scheduled completion date: August 2014** Refer to Section 8, Supplemental Information, for an explanation of the changes to OpenItems.7 Potential Safety Evaluation ImpactsDominion is participating in the ongoing industry effort to develop guidance for theOverall Program Document that will support NRC preparation of the Safety Evaluation Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 12 of 21documenting Surry's compliance with Order EA-12-049.

As this Overall ProgramDocument is developed, potential challenges and impacts will be identified in thissection of future Six-Month Status Reports.8 Supplemental Information This supplemental information provides details of the changes identified in the statusupdates above and addresses the following topics: a) a revision to Milestone Task'Develop Modifications' b) a revision to Milestone Task 'Develop Strategies/Contract with RRC', c) a revision to Open Item No. 5, and d) a revision to Open Item No. 15.a) Surry. Milestone Task 'Develop Modifications':

The revision to the scheduled milestone target completion date is needed to complete minor modifications supporting FLEX strategies (e.g., standpipe, hose adapters, etc.).b) Surry, Milestone Task 'Develop Strategies/Contract with RRC': The revisionto the scheduled milestone target completion date is consistent with the date theRRC will be fully operational.

c) Surry, Open Item 5: The Open Item completion date is revised to April 2014.Additional time is required to complete the thermal and hydraulic calculations confirming that the Containment strategies are adequate using the Phase 3 RRCpumps.d) Surry, Open Item 15: This Open Item was previously reported as completed inthe August 2013 Six-Month Status Report. However, only the Phase 2calculations had been completed at that time and the Open Item was therefore not fully complete.

The completion date for Open Item 15 is revised to June 2014. Additional time isrequired to obtain design specification information on the Phase 3 RRC electrical components and to complete the calculations needed to confirm the electrical loading-related strategy objectives can be met with this equipment.

9 References The following references support the updates to the OIP described in this attachment.

1. Virginia Electric and Power Company Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),

dated February 28, 2013 (Serial No. 12-163B).

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 13 of 212. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events,"dated March 12, 2012.3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012.4. Virginia Electric and Power Company Supplement to Overall Integrated Plan inResponse to March 21, 2012 Commission Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis Events (OrderNumber EA-12-049),

dated April 30, 2013 (Serial No. 12-163C).

5. Dominion Calculation ME-0969, "Evaluation of the TDAFW Pump Performance atLow Steam Generator Pressures,"

August 2013.6. Dominion Calculation ME-0967, "Beyond Design Basis (BDB) -BDB HighCapacity Pump and BDB AFW Pump Hydraulic Analysis for Spent Fuel PoolMakeup and AFW Injection at SPS Units 1 and 2," Rev. 0.7. Dominion Calculation ME-0964, "Evaluate the High Head Injection Pump forBeyond Design Basis (BDB) at the Primary and Alternative Supply Locations inModes 1-4, and the BDB AFW Pump in Modes 5 and 6," Rev. 0.8. ETE-CPR-2013-0003, Beyond Design Basis Communications Strategy/Plan, Rev. 0.9. Geotechnical Engineering Report, BDB FLEX Storage Building, Surry PowerStation, Surry County, VA, Schnabel Reference

1. 13613080, September 19, 2013,including Addendum No. 1.10. Design Change SU-13-00015, BDB Storage Building/

Surry Power Station/

Units 1&2.11.ET-NAF-06-0045 "Evaluation of Proposed Change to Surry FW-MOV-151/251 Operation and Alignment,"

Revision 0.12.Surry Operating Procedure 1/2-GOP 1.3, "Unit Startup, RCS Heatup From 3450FTo HSD," Revision 52/54.13. Calculation ME-0973, "Evaluation of Room Air Temperatures Following ExtendedLoss of AC Power (ELAP),"

Revision 0 including Addendum OA.14.Calculation MISC-11793, Evaluation of Long-Term Containment Pressure andTemperature Profiles Following and Extended Loss of AC Power (ELAP), Rev. 0.15.Virginia Electric and Power Company's Six Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049),

dated August 23, 2013 (Serial No. 12-163D).

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 14 of 21Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential!

flexibility)

Diverse Uses Performance Maintenance CriteriaMaintenance

/ Preventive List Portable Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements BDB High Capacitydiesel-driven pump 1200 gpm @ Will follow EPRI(2)6 and assoc. 150 psid template requirements hoses and fittingsBDB AFW pump (3) 300 gpm @ Will follow EPRIand assoc. hoses X 500 d template requirements and fittings psiBDB RCS Injection pump (2)5 and assoc. X 45 gpm @ Will follow EPRIhoses and fittings 3000 psid template requirements 120/240VAC generators (2) 3 and Will follow EPRIassociated cables, X 35 kW template requirements connectors andswitchgear Serial No. 12-163EDocket Nos. 50-280/281 Order EA- 12-049Attachment 1Page 15 of 21Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential

/ flexibility)

Diverse Uses Performance Maintenance CriteriaMaintenance

/ Preventive List Portable Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements 120/240VAC generators (8)2 andassociated cables, X 5-6.5 kW Will follow EPRIconnectors and template requirements switchgear (to powersupport equipment) 480VAC generators (2)3 and associated cables, connectors Will follow EPRIand switchgear (to X X 320 kW Will followeEPR tre-power battery template requirements

chargers, inverters, and Vital Buses)Portable boric acid XWill follow EPRIbatching tank (2) X 1000 gal template requirements Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 16 of 21Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/flexibility)

Diverse Uses Performance Maintenance CriteriaMaintenance

/ Preventive List Portable Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Light plants (2) + Will follow EPRILight strings (15)2 X template requirements Front endloader (1)2 X Will follow EPRItemplate requirements Tow vehicles (2) 2 X X X X Will follow EPRItemplate requirements Hose trailer (2) and Will follow EPRIUtility vehicle (1)2 Xtemplate requirements Fans / blowers (10)2 X Will follow EPRItemplate requirements Air compressors (6) 2 X X Will follow EPRItemplate requirements Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 17 of 21Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential!

flexibility)

Diverse Uses Performance Maintenance CriteriaMaintenance

/ Preventive List Portable Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Fuel truck (1) with Will follow EPRI1,100 gal. tank and X X X X X template requirements pumpsFuel carts with Will follow EPRItransfer pumps (2)2 X X X X X template requirements Communications Will follow EPRIequipment 4 X X X X X template requirements Misc. debris removal Will follow EPRIequipment 2 X template requirements Misc. Support Will follow EPRIEquipment 2 template requirements Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 18 of 21Table 1 -PWR Portable Equipment Phase 21 [Open Item 20]Use and (potential/

flexibility)

Diverse Uses Performance Maintenance CriteriaMaintenance

/ Preventive List Portable Equipment Core Containment SFP Instrumentation Accessibility Maintenance Requirements Cables for 4kv DGgenerator connection X X X X X(3 sets)NOTES:1. This table is based on one BDB Storage Building.

2. Support equipment.

Not required to meet N+1.3. 120/240VAC generators are an alternate strategy to the 480VAC generators.

Therefore, only N is required.

4. Quantities are identified in ETE-CPR-2013-0003 that was developed in response to the results of the studyperformed for Recommendation 9.3 of the 10 CFR 50.54(f) letter dated March 12, 2012.5. One BDB RCS Injection pump can be shared between units if necessary.

A BDB RCS Injection pump from theRRC will be deployed from the RRC by 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, if required, to replace an inoperable on-site BDB RCS Injection pump.6. One BDB High Capacity pump is needed to implement the FLEX core and SFP cooling strategies.

This pump isstored in the Type 1 BDB Storage Building and protected from hazards.

The 50.54(hh)(2) high capacity pump iscredited to meet the N+1 requirement as a backup to the BDB High Capacity pump. This pump is stored onsite ina location other than the BDB Storage Building.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 19 of 21Table 2 -PWR Portable Equipment Phase 3Use and (Potential/Flexibility)

Diverse Uses Performance Criteria Maintenance NotesList Portable Quantity Quantity Power Core Cont. Access Instrumentation RCS Preventative Equipment Req'd Provided Cooling Cooling/

Inventory Maintenance

/Unit I Unit Integrity RequiredMedium...

..`Ve X 4.16 KV 2 MW Performed by (1)Turb....)

RRCGenerators Low Voltage 0 1 Jet X X X 480VAC 1100 Performed byGenerators Turb. RRCHighPressure 0...Diesel X 3000#....PM Performed byInjection 0 1 Diesel X 3000# 60 GPM RRC (2)Pum p .. .. .'___. ,_* " _...:.S/G RPV.... .. *Performed byMakeup 0 1 Diesel X X 500# 500 GPM rrm (2)Pump RRC (2)LowPressure

/Medium Performed by0 1 Diesel X 300# 2500 GPM (2)Flow (De- ' :;i.":...*R RCwatering)

PumpLowPressure/

1 Diesel X X 1 5000 GPM Performed byHigh Flow RRC.(3)Pum p _ _...__ _ _._. ._. __._ ..

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 20 of 21Table 2 -PWR Portable Equipment Phase 3Use and (Potential/Flexibility)

Diverse Uses Performance Criteria Maintenance NotesList Portable Quantity Quantity Power Core Cont. Access Instrumentation RCS Preventative Equipment Req'd Provided Cooling Cooling/

Inventory Maintenance

/Unit I Unit Integrity RequiredLighting 01 D.eselX40,000 Lu Performed byTower Diesel x 40,00 Xu (4)"Prredb Towers A RRCDiesel Fuel 0 AR N/A X X X X X 500 Gal Performed byTransfer RRC (2)Mobile ..Performed byWater 0 2 Diesel X X 150 GPM RRC (2) (5)Treatment MobileBoration 0 1 N/A X 1000 Gal Performed bySkid(2)Note 1 -RRC 4KV generator supplied in support of Phase 3 for Core Cooling, Containment

Cooling, and Instrumentation FLEX Strategies.

Note 2 -RRC Generic Equipment

-Not required for FLEX Strategy

-Provided as Defense-in-Depth Note 3 -RRC Low Pressure

/ High Flow pump supplied in support of Phase 3 for core cooling and Containment cooling FLEX Strategies.

Note 4 -RRC components provided for low light response plans.Note 5 -Usage dependent on Westinghouse Water Quality Study results.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 1Page 21 of 21FROMF P , I- TK-3I ,-CN-T-2" I-FW-631-CN-PI vV ~ ~ T ST- I-W38 I ENERATORrwi t TDF I-RC-E*IA PUMP___PF 26EAE *wTO STEAM GENERATOR IL-RC-E-18

-C-66 011 AFw O :*TO STE'AM GENERATOR PUMIP DISCHARGE I-RC-E-IC PIMARY6 CONAECTEION T8 ICSTT'sE-F ILL.-.---"---

PERMANENT iNNIE(;I"ION INSTAL.LATION AFW PUMP ROOM ,I10B AFW 7 PUMPA LGENDs~C 80 u~ 8 .OOIFICATIO.

PRIMARY 808 A.FW CONNECTIONS

--x-TO UNIT 2 STEAMN.C.HOSE FROM 80N AFW ALTADAPTER (TYP))B FWPUP" CI.FI.ONNECTION EVALVEBODY TO STEAM GENERATOR I-RC-E-IC TO STEAM GENERATOR I-RC-E-tB FROM UNIT IANW PUM'PSALTERNATE BOB AFW CONNECTION FIGURE 3 (FEBRUARY 2014 UPDATE)CORE COOLING AND DECAY HEAT REMOVALPRIMARY AND ALTERNATE CONNECTIONS SURRY POWER STATION UNIT 1(UNIT 2 TYPICAL)FROM UNIT 2AFW PUMPS Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Overall Integrated PlanSection D -Maintain Containment Section F5 -Safety Functions Support (Ventilation)

Surry Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 1 of 19D -Maintain Containment Determine Baseline coping capability with installed coping1 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:* Containment Spray* Hydrogen igniters (ice condenser Containments only)D.1 -PWR Installed Equipment Phase 1:Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain Containment.

Identify methods (Containment spray/Hydrogen igniter) and strategy(ies) utilized to achieve this coping time.The Phase 1 coping strategy for Containment involves verifying Containment isolation per ECA-0.0, Loss of All AC Power, and continuing to monitor Containment temperature and pressureusing installed instrumentation.

Evaluations have been performed and conclude that Containment temperature and pressure willremain below design limits, and key parameter instruments subject to Containment environment will remain functional for at least 7 days. (Reference Calculations MISC-11793 and MISC-11794). Therefore, actions to reduce Containment temperature and pressure and to ensurecontinued functionality of the key parameters will not be required immediately and will utilize off-site equipment and resources during Phase 3.Details:D.1.1 -Provide a briefdescription of Procedures Procedural guidance for monitoring Containment pressure is/ Strategies

/ Guidelines provided by ECA-0.0, Loss of All AC power.D.1.2 -Identifymodifications No plant modifications are required to support implementation ofthis Phase 1 strategy.

D.1.3 -Key Containment List instrumentation credited for this coping evaluation.

Parameters Containment Pressure

-Containment pressure indication isavailable in the MCR throughout the event.Containment Temperature

-Containment temperature indication isavailable in the MCR throughout the event.Notes:The information provided in this section is based on the following reference(s):

Engineering Technical Evaluation, ETE-CPR-2012-001 1, "Beyond Design Basis -FLEX StrategyOverall Integrated Plan Basis Document,"

Revision 2.Coping modifications consist of modifications installed to increase initial coping time, i.e. generators topreserve vital instruments or increase operating time on battery powered equipment.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 2 of 19D -Maintain Containment Calculation MISC-1 1793, "Evaluation of Long Term Containment Pressure and Temperature Profiles Following Loss of Extended AC Power (ELAP),"

Revision 0, February 18, 2013.Calculation MISC-1 1794, "Evaluation of North Anna, Surry, and Millstone Containment Instrumentation Following Extended Loss of AC (ELAP),"

Revision 0, February 18, 2013.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 3 of 19D. Maintain Containment D.2 -PWR Portable Equipment Phase 2:Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain Containment.

Identify methods (Containment spray/hydrogen igniters) and strategy(ies) utilized to achieve this coping time.Evaluations have been performed and conclude that Containment temperature and pressure willremain below design limits, and key parameter instruments subject to Containment environment will remain functional for at least 7 days. (Reference Calculations MISC-1 1793 and MISC-1 1794).Therefore, actions to reduce Containment temperature and pressure and to ensure continued functionality of the key parameters will not be required immediately and will utilize off-siteequipment and resources during Phase 3. There is no separate Phase 2 strategy.

Details:D.2.1 -Provide a brief Confirm that procedure/guidance exists or will be developed todescription of Procedures support implementation I Strategies

/ Guidelines None required for Phase 2D.2.2 -Identify List modifications modifications None required for Phase 2D.2.3 -Key Containment List instrumentation credited or recovered for this coping evaluation.

Parameters Although a Phase 2 strategy is not required to maintain Containment, the Phase 1 Containment monitoring instrumentation will continue tobe powered during Phase 2 from portable generators.

D.2.4 -Storage / Protection of Equipment:

Describe storage I protection plan or schedule to determine storage requirements Seismic List how equipment is protected or schedule to protectNone required for Phase 2Flooding List how equipment is protected or schedule to protectNone required for Phase 2Severe Storms with High List how equipment is protected or schedule to protectWindsNone required for Phase 2 Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 4 of 19D. Maintain Containment Snow, Ice, and Extreme List how equipment is protected or schedule to protectColdNone required for Phase 2High Temperatures List how equipment is protected or schedule to protectNone required for Phase 2D.2.5 -Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection isthe equipment will be deployed protected to the point of use.None required for Phase 2 None required for Phase 2 None required for Phase 2Notes:The information provided in this section is based on the following reference(s):

Engineering Technical Evaluation, ETE-CPR-2012-0011, "Beyond Design Basis -FLEX StrategyOverall Integrated Plan Basis Document,"

Revision 2.Calculation MISC-1 1793, "Evaluation of Long Term Containment Pressure and Temperature Profiles Following Loss of Extended AC Power (ELAP),"

Revision 0, February 18, 2013.Calculation MISC-1 1794, "Evaluation of North Anna, Surry, and Millstone Containment Instrumentation Following Extended Loss of AC (ELAP),"

Revision 0, February 18, 2013.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 5 of 19D. Maintain Containment D.3 -PWR Portable Equipment Phase 3:Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain Containment.

Identify methods (Containment spray/hydrogen igniters) and strategy(ies) utilized to achieve this coping time.An evaluation has been performed and concludes that Containment temperature and pressure willremain below design limits, and key parameter instruments subject to Containment environment will remain functional for at least 7 days. To remain within analyzed limits for equipment qualification temperature, the Containment temperature will be procedurally monitored and, ifnecessary, the temperature will be reduced.

This will require the implementation of the Phase 3Containment cooling strategy such that heat removal from Containment is initiated in a timelymanner.The strategy to reduce Containment temperature is to provide for Containment heat removalthrough water spray into the Containment atmosphere using portable pumps, the installed Recirculation Spray (RS) system pumps, and Containment Spray (CS) rings. This strategy requiresrepowering a Class 1 E 4160VAC and 480VAC bus using a 4160VAC DG from the RegionalResponse Center (RRC) and restoration of cooling water flow (Service Water) to the RS heatexchanger.

An alternate strategy is also available which will provide Containment ventilation cooling using the Containment Air Recirculation (CAR) system fans.Primary Containment Cooling Strategy

-Containment Recirculation SprayThe 4160VAC DG from the RRC will be aligned to power a Class 1 E 4160VAC and 480VAC bus asdescribed in Section F1.3, which will provide power to the RS pump 480VAC motor.The Containment sump must be filled to provide a suction water source for the RS pump. Waterfrom the Refueling Water Storage Tank (RWST) will be pumped through the spray ring headernozzles into Containment using the BDB AFW pump or the RRC Low Pressure

/ Medium Flowpump connected to the BDB RCS Pump Suction connection and discharging to the BDB BlindFlange connection, both located in the Containment Spray Pump House (CSPH) (refer to Figure11). This initial flow will provide heat removal from the Containment atmosphere and will fill theContainment sump in preparation for initiation of Containment RS flow. When the Containment sump level is adequate, an RS pump will be started to draw water from the sump and recirculate flow through an RS heat exchanger and the spray ring nozzles.

Service Water (SW) system flowwill be established through the RS heat exchangers to provide a heat sink. In this manner,Containment atmosphere heat will be rejected to the ultimate heat sink via the sump waterrecirculation spray flowpath.

The RWST is not high wind and associated missile protected, and if unavailable as a water sourceto fill the Containment sump, adequate sump inventory can be provided from the James River viathe plant Discharge Canal. Raw water from this source can be pumped to the suction of the BDBAFW pump using the BDB High Capacity pump. Water strainers are provided at the suction of theBDB High Capacity pump for this use to prevent clogging of the CS ring header nozzles.

(Refer toFiaure 11).

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 6 of 19D. Maintain Containment The CSPH is not high wind and associated missile protected, and if the BDB RCS Pump Suctionconnection and/or the BDB Blind Flange connection are not available, the alternate strategy forContainment cooling will be implemented (described later under heading Alternate Containment Cooling Strategy

-Containment Ventilation Cooling).

SW system flow will be provided to the RS heat exchanger by filling the Circulating Water (CW)system Intake Canal, if necessary, and maintaining level within the canal using the diesel-driven Emergency Service Water (ESW) pumps located at the Low-Level Intake Structure in the seismicClass I Emergency Service Water Pump House. Once sufficient Intake Canal level is established (within approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> from empty with one of three ESW pumps operating),

the flowpaththrough the RS heat exchanger will be aligned and water flow established by gravity flow consistent with normal system operation.

In the event that the ESW pumps are unavailable, the Intake Canallevel will be maintained by a RRC Low Pressure

/ High Flow pump drawing from the James Riverand discharging to the Intake Canal. Fueling requirements for the ESW pumps are beingevaluated.

[Open Item 16]In the event that the CW Intake Canal is not available, SW flow can be provided to the RS heatexchanger by pumping water from the Discharge Canal to the SW system using an RRC LowPressure

/ High Flow pump. The RRC Low Pressure

/ High Flow pump will draw from theDischarge Canal through a strainer and discharge to the SW system through a 24" flanged manwayconnection in the piping, located below the Turbine Building floor slab, using a hose adapter.

Thisconnection is in a seismically-designed portion of the SW system, which is protected from highwind generated missiles.

System alignments will be made to direct flow through the RS heatexchanger.

(See Figure 12)Thermal/hydraulic and Containment analyses will be performed to support this Containment coolingstrategy

[Open Item 5].Alternate Containment Cooling Strategy

-Containment Ventilation CoolingThe 4160VAC DG from the RRC will be aligned to power a Class 1 E 4160VAC and 480VAC bus asdescribed in Section F1.3, which will provide power to Component Cooling (CC) Water system 4kVmotors and CAR fan 480VAC motors. Containment ventilation flow will be established by startingthe CAR fan with air flow through the CAR fan coil unit and recirculating within the Containment.

Instrument Air (IA) system pressure will be restored, or portable compressed air bottles will beutilized, to operate valves to align CC water flow to the CAR fan coil unit. SW system flow will beestablished from the Intake Canal through a CC heat exchanger to provide a heat sink, and CCflow will be established through the CAR fan coil unit and the CC heat exchanger to transfer heat tothe SW system. In this manner, Containment atmosphere heat will be rejected to the ultimate heatsink via the recirculation of Containment atmosphere through the CAR fan coil unit.In the event that the CW Intake Canal is unavailable, cooling water flow to the CC heat exchanger will be established by pumping water to the SW system as described for the primary Containment cooling strategy and aligning flow through the CC heat exchanger.

(See Figure 12)

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 7 of 19D. Maintain Containment Thermal/hydraulic and Containment analyses will be performed to support this Containment coolingstrategy

[Open Item 5].Details:D.3.1 -Provide a brief Confirm that procedure/guidance exists or will be developed todescription of Procedures support implementation I Strategies

/ Guidelines Site specific procedural guidance governing the Containment coolingstrategy will be developed using industry guidance and will addressthe necessary steps to align and operate permanent plantequipment, deploy portable pumps and hoses, establish connections, and operate the portable equipment to perform therequired function.

[Open Item 7]D.3.2 -Identify List modifications modifications None.D.3.3 -Key Containment List instrumentation credited for this coping evaluation.

Parameters Containment Pressure

-Containment pressure indication is available in the MCR throughout the event.Containment Temperature

-Containment temperature indication isavailable in the MCR throughout the event.D.3.4 -Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection isthe equipment will be deployed None. protected to the point of use.The primary strategy for The BDB RCS Pump Suction The protection of the BDB RCSContainment cooling is to connection is described in Pump Suction connection isprovide Containment RS flow Section C.3.4. described in Section C.3.4.using installed plant equipment and portable pumps. The BDB Blind FlangeWater from the RWST will be connection is located in thepumped into Containment to fill seismic category I CSPH, andthe Containment sump using is protected from flood, andthe BDB AFW pump or the extreme high and lowRRC Low Pressure

/ Medium temperatures.

The connection Flow pump connected to the is not protected from high windBDB RCS Pump Suction generated missiles.

connection and discharging to Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 8 of 19D. Maintain Containment the BDB Blind Flangeconnection, located in theCSPH, through flexible hoses.The BDB AFW pump will bedeployed from the BDBStorage Building and staged inthe yard area near the RWST.If used instead, the RRC LowPressure

/ Medium Flow pumpwill be received from the RRCand staged similarly.

Hoseswill be routed to inside theCSPH to the BDB connections providing pump suction anddischarge flowpaths.

SeeFigure 11.The RWST is not protected from high winds and associated missiles.

If this tank is notavailable for response to anELAP, raw water from theJames River (via the plantDischarge Canal) can bepumped to the suction of theBDB AFW pump or the RRCLow Pressure

/ Medium Flowpump using the BDB HighCapacity pump. The BDB HighCapacity pump would bedeployed from the BDBStorage Building and locatednear the Discharge Canal.Pump discharge flexible hoseswould be routed to the BDBAFW pump (or RRC LowPressure

/ Medium Flow pump)suction.

Water strainers areprovided at the BDB HighCapacity pump suction toprevent clogging of the CS ringheader nozzles.

See Figure11.SW system flow will beprovided to the RS heatThe SW connections in theTurbine Building are in aseismically-designed portion ofthe SW system, which isprotected from high windgenerated

missiles, flood, andextreme high and lowtemperatures.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 9 of 19D. Maintain Containment exchanger by filling the CWsystem Intake Canal, ifnecessary, and maintaining level within the canal using thediesel-driven ESW pumpslocated at the Low-Level IntakeStructure in the seismic Class IEmergency Service WaterPump House. In the event thatthe ESW pumps areunavailable, the Intake Canallevel will be maintained by aRRC Low Pressure

/ High Flowpump drawing from the JamesRiver and discharging to theIntake Canal. The RRC LowPressure

/ High Flow pump willbe received from the RRC andstaged near the river's edge.Flexible hoses will be routedfrom the pump suction to theJames River and from thepump discharge to the IntakeCanal.In the event that the CW IntakeCanal is not available, SW flowcan be provided to the RS heatexchanger by pumping waterfrom the Discharge Canal tothe SW system using an RRCLow Pressure

/ High Flowpump. The RRC Low Pressure/ High Flow pump will bereceived from the RRC, andlocated near the Discharge Canal. Flexible hoses will berouted from the pump suctionto the canal and draw waterthrough a strainer.

The pumpdischarge will be routed usingflexible hoses to the SWsystem through a 24" flangedmanway connection in thepiping, located below theTurbine Buildinq floor slab, Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 10 of 19D. Maintain Containment using a hose adapter.

(SeeFigure 12)The alternate strategy forContainment cooling is toprovide Containment ventilation cooling using installed plantequipment and portablepumps. In the event that theCW Intake Canal isunavailable, cooling water flowto the CC heat exchanger willbe established by pressurizing the SW system as described for the primary Containment cooling strategy.

See Figure12.Notes:The information provided in this section is based on the following reference(s):

Engineering Technical Evaluation, ETE-CPR-2012-001 1, "Beyond Design Basis -FLEX StrategyOverall Integrated Plan Basis Document,"

Revision

2.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 11 of 19I-IIFLANGE004 ýýp OF SANINECTIItCS-6 PumpS-FEGuARFOR CONTAINMENT SUHP FILLFROM RWST. FLOW IS LIMITED BYTHE 4 DIA SUCTION CONNECTION FIGURE 11CONTAINMENT COOLINGBDB FLEX PRIMARY MECHANICAL CONNECTIONS SURRY POWER STATION Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 12 of 19----------------------------------------------------

I-PO.IS)ENG,3 AV ASTE M'FERNote: Unit I RS connection shown.Unit 2 is similarFIGURE 12CONTAINMENT COOLINGBDB FLEX ALTERNATE MECHANICAL CONNECTIONS SURRY POWER STATION Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 13 of 19F5 -Safety Functions Support (Ventilation)

Determine Baseline coping capability with installed coping2 modifications notincluding FLEX modifications.

F5.1 -PWR Installed Equipment Phase 1Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions.

Identify methods and strategy(ies) utilized to achieve coping times.The FLEX strategies for maintenance and/or support of safety functions involve severalelements.

One element is to ensure that ventilation,

heating, and cooling are adequate tomaintain acceptable environmental conditions for equipment operation and personnel habitability.

Per the guidance given in NEI 12-06, FLEX strategies must be capable ofexecution under the adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expected following a BDB External Event resulting in an ELAP/LUHS.

The primary concern with regard to ventilation is the heat buildup which occurs with theloss of forced ventilation in areas that continue to have heat loads.The key areas identified for all phases of execution of the FLEX strategy activities are theMCR, ESGR, MSVH (SG PORV area), MSVH (TDAFW pump room), Containment SprayPumphouse, and the Auxiliary Building.

These areas have been evaluated using theGOTHIC-7.2a computer code to determine the temperature profiles following anELAP/LUHS event. With the exception of the SG PORV area in the upper portion of theMSVH, results of the calculation have concluded that temperatures remain withinacceptable limits based on conservative input heat load assumptions and with no actionsbeing taken to reduce heat load or to establish either active or passive ventilation (e.g.,portable fans, open doors, etc.)In the case of the upper level of the MSVH, where the SG PORVs are located, access tothis area is necessary in order to isolate the normal air supply to the PORVs such that thelocal bottle air supply can be utilized for local control from a cooler area. One of thedoors which leads to outside air (either the upper or lower level) in the MSVH will need tobe opened to allow a "stack effect" circulation of air between the door and the ventilation openings at the top of the MSVH. This will ensure that the temperatures remain withinthe acceptable range for equipment and personnel habitability.

The high temperatures expected in the MSVH for local operation of the SG PORV (OIPSection B.1) are similar to conditions experienced during normal station operations,

testing, and maintenance.

Therefore, actions performed for FLEX activities will be2 Coping modifications consist of modifications installed to increase initial coping time, i.e. generators topreserve vital instruments or increase operating time on battery powered equipment.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 14 of 19essentially the same as those performed for the current site procedure ECA-0.0, Loss ofAll AC Power, which also addresses local operation of the SG PORVs. This action isonly necessary for access to isolate the normal air supply to the PORVs as stated above.Once this action is performed, no further access is required to this area for Phase 1 orany other phase during the ELAP/LUHS event response.

Details:F5.1.1 -Provide a briefdescription ofProcedures

/Strategies

/ Guidelines Confirm that procedure/guidance exists or will be developed tosupport implementation.

The FLEX strategy procedures will include the action to openthe door at the upper elevation of the MSVH to create a "stackeffect" circulation of air. This action alone will ensure that thetemperatures in the room remain within the range normallyexperienced during operation.

No other actions are required tomaintain equipment operation or personnel habitability following an ELAP/LUHS event in Phase 1.F5.11.2 -Identify List modifications and describe how they support coping time.modifications No ventilation related modifications are required for any phaseof the ELAP/LUHS response.

F5.1.3 -Key List instrumentation credited for this coping evaluation phase.Parameters No key ventilation parameters have been identified as requiredto maintain acceptable equipment and personnel environments for any phase of the ELAP/LUHS response.

Notes:The information provided in this section is based on the following reference(s):

-Calculation ME-0973, Evaluation of Room Air Temperatures Following ExtendedLoss of All AC Power (ELAP), Revision 0, Addendum A.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 15 of 19F5 -Safety Functions Support (Ventilation)

F5.2 -PWR Portable Equipment Phase 2Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain and/or support safetyfunctions.

Identify methods and strategy(ies) utilized to achieve coping times.Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution underthe adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expectedfollowing a BDBEE resulting in an ELAP/LUHS.

A calculation has been performed toevaluate ventilation concerns for areas where Phase 2 FLEX strategy activities areperformed.

Results of the calculation have concluded that temperatures remain withinacceptable limits in these areas based on conservative input heat load assumptions andwith no additional actions being taken to reduce heat load or to establish either active orpassive ventilation (e.g., portable fans, open doors, etc.). Therefore, no Phase 2 actionsare required to maintain equipment operation or personnel habitability.

An additional ventilation concern applicable to Phase 2 is the potential buildup of hydrogenin the battery rooms. Off-gassing of hydrogen from batteries is only a concern when thebatteries are charging.

Once a 480VAC power supply is restored in Phase 2 (OIP SectionF1.2) and the station Class 1 E batteries begin re-charging, power will be restored to theESGR room power receptacles.

The doors to the battery rooms will be opened andportable fans will be used to disperse any hydrogen into the much larger volume of theESGR rooms to prevent any significant hydrogen accumulation.

Details:F5.2.1 -Provide a brief Confirm that procedure/guidance exists or will be developed todescription of support implementation with a description of the procedure

/Procedures I Strategies strategy/guideline.

I Guidelines No procedures/strategies are required to maintain any Phase 2equipment operation or personnel habitability following anELAP/LUHS event.F5.2.2 -Identify List modifications necessary for phase 2modifications No ventilation related modifications are required for any phaseof the ELAP/LUHS response.

F5.2.3 -Key Parameters List instrumentation credited or recovered for this copingevaluation.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 16 of 19F5 -Safety Functions Support (Ventilation)

F5.2 -PWR Portable Equipment Phase 2No key ventilation parameters have been identified as requiredto maintain acceptable equipment and personnel environments for any phase of the ELAP/LUHS response.

F5.2.4 -Storage/

Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic List how equipment is protected or schedule to protectNo Phase 2 BDB equipment is required.

Flooding List how equipment is protected or schedule to protectNote: if stored below currentflood level, then ensure No Phase 2 BDB equipment is required.

procedures exist to moveequipment prior toexceeding flood level.Severe Storms with High List how equipment is protected or schedule to protectWindsNo Phase 2 BDB equipment is required.

Snow, Ice, and Extreme List how equipment is protected or schedule to protectColdNo Phase 2 BDB equipment is required.

High Temperatures List how equipment is protected or schedule to protectNo Phase 2 BDB equipment is required.

F5.2.5 -Deployment Conceptual DesignStrategy Modifications Protection of connections

a. Identify Strategy including Identify modifications Identify how the connection how the equipment will be is protected deployed to the point of use.There is no required No ventilation related No ventilation relateddeployment of supplemental modifications are needed to connections are needed toventilation equipment in the support the implementation support the implementation Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 17 of 19F5 -Safety Functions Support (Ventilation)

F5.2 -PWR Portable Equipment Phase 2ELAP/LUHS coping of any ELAP/LUHS coping of any ELAP/LUHS copingstrategies.

strategies.

strategies.

No additional compensatory cooling measures areexpected to be necessary, other than those identified for the upper level of theMSVH. However, fordefense in depth, theoperating staff willperiodically monitor areatemperatures to insurehabitability and equipment survivability conditions areacceptable.

Additional natural convection flowpaths or portable ventilation fans and/or stand alone ACunits may be utilized if thearea temperature measurements indicateunacceptable increasing trends.Notes:The information provided in this section is based on the following reference(s):

-Calculation ME-0973, Evaluation of Room Air Temperatures Following ExtendedLoss of All AC Power (ELAP), Revision

0.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 18 of 19F5 -Safety Functions Support (Ventilation)

F5.3 -PWR Portable Equipment Phase 3Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain and/or support safety functions.

Identifymethods and strategy(ies) utilized to achieve coping times.Per the guidance given in NEI 12-06, FLEX strategies must be capable of execution underthe adverse conditions (unavailability of installed plant lighting, ventilation, etc.) expectedfollowing a BDBEE resulting in an ELAP/LUHS.

A calculation has been performed toevaluate ventilation concerns for areas where Phase 2 FLEX strategy activities areperformed.

Results of the calculation have concluded that temperatures remain withinacceptable limits in these areas based on conservative input heat load assumptions andwith no additional actions being taken to reduce heat load or to establish either active orpassive ventilation (e.g., portable fans, open doors, etc.). Therefore, no Phase 3 actionsare required to maintain equipment operation or personnel habitability.

Details:F5.3.1 -Provide a brief Confirm that procedure/guidance exists or will be developed todescription of support implementation with a description of the procedure

/Procedures

/ Strategies strategy/guideline.

I Guidelines No procedures/strategies are required to maintain any Phase 3equipment operation or personnel habitability following anELAP/LUHS event.F5.3.2 -Identify List modifications necessary for phase 3modifications No ventilation related modifications are required for any phaseof the ELAP/LUHS response.

F5.3.3 -Key Parameters List instrumentation credited or recovered for this copingevaluation.

No key ventilation parameters have been identified for anyphase of the ELAP/LUHS response since no ventilation strategy is required to maintain acceptable equipment andpersonnel environments.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 2Page 19 of 19F5 -Safety Functions Support (Ventilation)

F5.3 -PWR Portable Equipment Phase 3F5.3.4 -Deployment Conceptual DesignStrategy Modifications Protection of connections

a. Identify Strategy including how the equipment will bedeployed to the point of use.There is no requireddeployment of supplemental ventilation equipment in theELAP/LUHS copingstrategies.

No additional compensatory cooling measures areexpected to be necessary, other than those identified for the upper level of theMSVH. However, fordefense in depth, theoperating staff willperiodically monitor areatemperatures to insurehabitability and equipment survivability conditions areacceptable.

Additional natural convection flowpaths or portable ventilation fans and/or stand alone ACunits may be utilized if thearea temperature measurements indicateunacceptable increasing trends.Identify modifications No ventilation relatedmodifications are needed tosupport the implementation of any ELAP/LUHS copingstrategies.

Identify how the connection is protected No ventilation relatedconnections are needed tosupport the implementation of any ELAP/LUHS copingstrategies.

Notes:The information provided in this section is based on the following reference(s):

-Calculation ME-0973, Evaluation of Room Air Temperatures Following ExtendedLoss of All AC Power (ELAP), Revision

0.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Formal Responses to October 2013Audit Questions Surry Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 1 of 15Response to October 2013 Audit Questions Surry Power StationBackground By letter dated February 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML1 3063A1 81), Virginia Electric and Power Company(Dominion) submitted an Overall Integrated Plan (OIP) in response to the March 12,2012, U.S. Nuclear Regulatory Commission (NRC) Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (Order Number EA-12-049; ADAMS Accession No. ML12056A045) for SurryPower Station Units 1 and 2, which is consistent with NEI 12-06.The NRC staff has reviewed the February 28, 2013 OIP submittal and determined thatthe following information is needed to complete its technical review.NRC Audit Question No. 1NEI 12-06, Section 5.3.1, Protection of FLEX Equipment states in part:2. Large portable FLEX equipment such as pumps and power supplies should besecured as appropriate to protect them during a seismic event (i.e., Safe ShutdownEarthquake (SSE level)).3. Stored equipment and structures should be evaluated and protected from seismicinteractions to ensure that unsecured and/or non-seismic components do not damagethe equipment.

The licensee's plan did not provide sufficient information to address the securing oflarge portable equipment to protect them during a seismic event or to ensure unsecured and/or non-seismic components do not damage the equipment during a seismic eventas required by NEI 12-06, Section 5.3.1, consideration (2) and (3).Provide additional details to demonstrate conformance to NEI 12-06, Section 5.3.1,considerations 2, and 3.Dominion

Response

The BDB Storage Building will have tie downs integrated into the floor slab. These tiedowns will be used to secure any equipment that is not considered stable to ensure thestored BDB equipment remains protected from damage during a seismic event.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 2 of 15Additionally, the fire protection and HVAC systems are being seismically installed.

Thelighting,

conduits, electrical, and fire detection are not being seismically installed but areconsidered insignificant and not able to damage BDB equipment.

NRC Audit Question No. 2NEI 12-06, Section 5.3.3, identifies that four procedural interface considerations shouldbe addressed.

Considerations 2 and 3 states:2. Consideration should be given to the impacts from large internal flooding sources thatare not seismically robust and do not require ac power (e.g., gravity drainage from lakeor cooling basins for non-safety-related cooling water systems).

Another example (not stated in NEI 12-06) is a turbine building flooding event coupledwith an ELAP that is a challenge to mitigate.

The 96" circ water headers are not ratedfor withstanding a seismic event. Recent nearby seismic activity, at North Anna, hasexceeded predicted SSE levels. The emergency switchgear room is in the basementwith a doorway with a small dike to separate it from the turbine building.

The majority ofsump pumps will be lost upon a loss of AC.3. For sites that use ac power to mitigate ground water in critical locations, a strategy toremove this water will be required.

The licensee's plan did not contain any information in regards to seismic hazardsassociated with large internal flooding sources that are not seismically robust and do notrequire ac power; or the use of ac power to mitigate ground water in critical locations.

Provide information to address considerations 2 and 3 above and how your proposedmitigation strategy will cope with a worse case turbine building flooding event during anELAP.Dominion

Response

Regarding NEI 12-06, Section 5.3.3, Consideration 2, fire protection water piping andother water system piping within the plant, including flooding sources that are notseismically robust and do not require ac power, were evaluated during the Individual Plant Examination for External Events (IPEEE) as potential seismic event inducedflooding sources.

The results of this evaluation concluded that seismic-induced leakagefrom these systems would not result in flooding that adversely affected safe-shutdown equipment.

Additionally, in response to a 2004 NRC inspection finding and unresolved issue (IR2004-006, URI 2004006-001, Letter No.04-322 dated May 21, 2004), Dominionperformed a detailed evaluation of a Turbine Building/Emergency Switchgear Room Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 3 of 15internal flooding scenario caused by a seismic event. The evaluation considered anearthquake magnitude sufficient to result in seismic loadings equivalent to twice thedesign basis earthquake (2xSSE).

Flooding from Circulating Water (CW) and ServiceWater (SW) system sources were evaluated due to the potential for gravity flow to theTurbine Building from the CW Intake Canal in the event of piping or component failuresin these systems.

The evaluation determined that the risk of internal flooding due tofailure of the SW/CW system components under this scenario was acceptably small.NRC Inspection Report 2005-002, (Letter No.05-285 dated 4/19/05),

documented theresolution of this finding and closed the URI. In addition, the high confidence of lowprobability of failure (HCLPF) values calculated for the evaluated structures andcomponents indicate that the definition of a "robust design" in NEI 12-06 is met suchthat these components would not be assumed to fail for an ELAP/LUHS.

Therefore, mitigation strategies to cope with Turbine Building internal flooding resulting from non-seismically robust components during an ELAP are not required to be developed.

Regarding NEI 12-06, Section 5.3.3, Consideration 3; as described in Updated FinalSafety Analysis Report (UFSAR) Section 15.5.1.3, non-safety-related pumps areinstalled to remove subsurface seepage water collected from beneath the Containment structure preventing water levels from reaching the top of the Containment base matand exerting hydrostatic pressure on the top of the mat liner. In the event thatgroundwater would rise to the site finished ground grade level at Elevation 26-6" meansea level, flotation of the Containment is not credible.

Therefore, Surry does not rely onac power to mitigate ground water in critical locations.

NRC Audit Question No. 3As discussed in NEI 12-06, Section 5.3.3, the following four procedural interface considerations should be addressed:

Seismic studies have shown that even seismically qualified electrical equipment can beaffected by beyond-design-basis seismic events. In order to address theseconsiderations, each plant should compile a reference source for the plant operators that provides approaches to obtaining necessary instrument readings to support theimplementation of the coping strategy.

This reference source should include controlroom and non-control room readouts and should also provide guidance on how andwhere to measure key instrument readings at Containment penetrations, whereapplicable, using a portable instrument (e.g., a Fluke meter). Such a resource could beprovided as an attachment to the plant procedures/guidance.

Guidance should includecritical actions to perform until alternate indications can be connected and on how tocontrol critical equipment without associated control power.The licensee's plan did not contain any information in regards to any plans forconforming to the following parts of consideration 1 above:

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 4 of 15a) The development of procedure/guidelines on critical actions to perform untilalternate indications can be connected (measure);

andb) The development of procedures/guidelines on how to control criticalequipment without control power.Please provide a discussion of your plans to conform to the above considerations.

Dominion

Response

a) FLEX Support Guideline (FSG) 7, "Loss of Vital Instrumentation or Control Power," isbeing developed to enable plant personnel to obtain instrument readings locally in theevent that instrument power is disabled.

The guideline will indicate the location wherereadings can be obtained and include conditions required to access the areas neededto get the readings, special tools and equipment needed, etc. Portable meters will beused to display an electrical output which will be compared to a conversion chartincluded in the guideline to determine the converted parametric value of the readout.Key instrumentation required to implement the FLEX strategies can be accessed usingthis method.Development,

training, and implementation of FSGs are included in OIP Open Item #7,which will be completed by September 2014 as stated in the OIP Six-month StatusReport submitted in August 2013.b) Critical plant equipment credited for implementation of FLEX strategies do not relyon control power for operation.

Existing emergency procedures provide guidance formanual start of the turbine driven AFW pump if the pump does not automatically start.Guidance for local manual operation of the SG PORVs for steam release is beingdeveloped and will be included in procedures for response to an ELAP.NRC Audit Question No. 4As discussed in NEI 12-06, Section 8.2.1 all sites should consider the temperature ranges and weather conditions for their site in storing and deploying their equipment consistent with normal design practices.

All sites outside of Southern California,

Arizona, the Gulf Coast and Florida are expected to address deployment for conditions of snow, ice, and extreme cold. NEI 12-06, Section 8.2.1, further specifies that all siteslocated North of the 35th Parallel should provide the capability to address extremesnowfall with snow removal equipment.

Finally, all sites except for those within Level 1and 2 of the maximum ice storm severity map contained in Figure 8-2 should addressthe impact of ice storms.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 5 of 15The licensee's screening for hazards due to snow, ice and extreme cold fails to providereasonable assurance that the licensee has appropriately screened in the need toaddress deployment for conditions of ice because the plan does not discuss thehazards of ice in the determination of extreme external hazards.Provide a discussion on the external hazards of ice in the appropriate screening sectionof the plan.Dominion

Response

The Surry UFSAR does not provide historical data on ice storms in the sitecharacterization and, therefore, was not included in Section A.1 of the 0IP. Ice stormscan occur at Surry Power Station and may cause hazardous travel and downed treeswhich may block the site access road and possibly deployment haul paths. The stationmaintains a supply of ice melting chemicals and the equipment to deploy the chemicals as a matter of routine site safety. If an ice storm causes access route issues due todowned trees and icy conditions, two tractors and a front-end loader will be available tohelp clear debris and ice from roadways.

The BDB Storage Building is located adjacentto the site but is outside of the site Protected Area. Therefore, the distances for haulingequipment to the designated deployment locations is relatively short and the assumed 2hour duration for the clearing of haul paths remains reasonable.

Icing of the Discharge Canal and the deployment of the BDB High Capacity pump isaddressed in the response to Audit Question

1. 14.The impact of extreme cold and icy conditions on deployed distribution hoses and BDBequipment is addressed by heat tracing as discussed in the response to Audit Question#8.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 6 of 15NRC Audit Question No. 7NEI 12-06, Section 3.2.2 guideline (3) states:Plant procedures/guidance should specify actions necessary to assure that equipment functionality can be maintained (including support systems or alternate method) in anELAP/LUHS or can perform without ac power or normal access to the UHS.Cooling functions provided by such systems as auxiliary building cooling water, servicewater, or component cooling water may normally be used in order for equipment toperform their function.

It may be necessary to provide an alternate means for supportsystems that require ac power or normal access to the UHS, or provide a technical justification for continued functionality without the support system.For permanently installed equipment used to support FLEX strategies, the licensee hasprovided insufficient information to provide reasonable assurance that the strategies and guidelines developed pursuant to the plan will comply with NEI 12-06, Section3.2.2, guideline (3).The licensee is requested to provide a discussion as to whether equipment functionality can be maintained in regards to cooling functions for permanent equipment used tosupport FLEX strategies.

Dominion

Response

Permanently installed plant equipment used to support core cooling and heat removal,RCS inventory

control, and Spent Fuel Pool (SFP) cooling FLEX strategies do notrequire cooling support systems, such as component cooling water and service water,to perform their required functions.

NRC Audit Question No. 8NEI 12-06, Section 3.2.2, guideline (12) states:Plant procedures/guidance should consider loss of heat tracing effects for equipment required to cope with an ELAP. Alternate steps, if needed, should be identified tosupplement planned action.Heat tracing is used at some plants to ensure cold weather conditions do not result infreezing important piping and instrumentation systems with small diameter piping.Procedures/guidance should be reviewed to identify if any heat traced systems arerelied upon to cope with an ELAP. For example, additional condensate makeup may besupplied from a system exposed to cold weather where heat tracing is needed to ensure Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 7 of 15control systems are available.

If any such systems are identified, additional backupsources of water not dependent on heat tracing should be identified.

The licensee plan did not address the loss of heat tracing in the integrated plan. Thelicensee screened in for extreme cold, ice and snow and thus there is a need for thelicensee to address loss of heat tracing affects on FLEX strategies.

Provide a discussion on the effects of the loss of heat tracing in regards to the effectsfor equipment required to cope with an ELAP, including alternate steps, if needed, tosupplement planned actions.Dominion

Response

Heat trace is used to provide two protection functions:

-Heat trace is used to maintain highly concentrated soluble boron solutions abovethe temperature where the soluble boron will precipitate out of solution.

-Heat trace is also used to protect piping systems and components from freezing inextreme cold weather conditions.

The FLEX strategies that have been developed do not depend on highly concentrated soluble boron solutions.

The FLEX strategies will use borated water sources with boronconcentrations below 4000 PPM; therefore, boron precipitation is not expected to occur.Additionally, the FLEX strategies have been developed to protect piping systems andcomponents from freezing.

Commercially available Heat Tape and insulation rolls willbe maintained in the BDB Storage Building for use on piping systems and components that will be used during an ELAP event where freezing is a concern in extreme coldweather conditions.

In addition, major components being procured for FLEX strategies are being provided with cold weather packages and small electrical generators to powerthe heat tape circuits, as well as protect the equipment from damage due to extremecold weather and to help assure equipment reliability.

In addition, the Emergency Condensate Storage Tank level instrument tubing credited for BDB and subject tofreezing conditions in an ELAP will be protected with the use of heat lamps which canbe powered from small generators that have been procured for FLEX strategies or fromthe small generators that will be included as part of the large BDB pump skids beingpurchased.

Equipment used for the mixing of borated water in the portable Boric Acid Batch Tankswill include components such as an agitator and a tank heater to facilitate completedissolution of the boric acid crystals.

FLEX Strategies will provide guidance for mixingto maintain concentrations below the solubility limit corresponding to freezingtemperatures.

This will ensure that boron precipitation does not occur during anextreme cold weather event.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 8 of 15NRC Audit Question No. 9Describe how electrical isolation will be maintained such that (a) Class 1E equipment isprotected from faults in portable/FLEX equipment and (b) multiple sources do notattempt to power electrical buses.Dominion

Response

(a) For permanently installed BDB equipment connections, connection hardware iseither procured/installed to the requirements of safety-related equipment or is isolatedfrom the class IE buses in accordance with the approved license basis for each unit.FLEX Support Guidelines (FSG-5) provides guidance for energizing a Class 1 E bususing portable generators consistent with NEI 12-06, Section 3.2.2. The BDB portablediesel generators will only be used when the Class 1 E Diesel Generators have beenisolated.

Each of the BDB portable diesel generators will be provided with outputelectrical protection (breakers, fuses, relays, etc.) that will provide protection for theoutput cables and the connection buses. Existing load circuit protection will be used forthe bus loads. Class 1 E equipment is protected by existing protection relaying.

TheFLEX re-powering strategies do not change any existing equipment protection scheme.(b) Electrical isolation to prevent simultaneously supplying power to the same bus fromdifferent sources will be administratively controlled.

FSG-5 ensures the breakers fromother potential supply sources are racked out and tagged before power is supplied tothe buses by the BDB portable diesel generators which are connected directly to theemergency buses for the 4160VAC tie-in and to permanently installed receptacles forthe 480VAC tie-in.NRC Audit Question No. 14NEI 12-06, Section 8.3.3 requires addressing procedural interfaces associated with asnow, ice and extreme cold hazard. The licensee indicates snow can occur at the site.The licensee does not discuss ice storms. Additionally, Surry experienced a severeicing event (1998?) where the James River iced over. The plant response was to try toget a tug boat to the Intake Structure to keep it functional.

However, circumstances deteriorated and circ water flow decreased to the point the delta T across the condenser was extremely high (100 degrees).

Ultimately, the discharge water heated the riverwater sufficiently to help the intake area.The licensee is requested to provide a discussion regarding the deployment andoperation of Phase-2 equipment during snow and ice conditions at the plant which leadto an ELAP. Provide a discussion on how the plant would respond using its mitigating strategy if an icing event such as the 1988 event would progress into an ELAP. Include Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 9 of 15discussion on assuring access to the UHS if both units were shutdown and no heatadded to Discharge Canal to melt ice.Dominion

Response

Ice storms and freezing conditions can occur at the Surry site. Deployment of Phase 2equipment under these conditions is discussed in the response to Audit Question

1. 4.As stated in the OIP Section A.1, freezing of the James River is unlikely due to itsbrackish nature. However, in the case of the event cited involving icing at the Low-Level Intake Structure, there would be no impact on FLEX strategies.

Neither the IntakeStructure nor the Intake Canal is involved in the strategy to provide core cooling withwater supplied by the BDB High Capacity pump.Suction for the BDB High Capacity pump will be taken from the Discharge Canal. TheBDB High Capacity pump and suction line with an inline floating strainer will bedeployed into the discharge when augmented staff arrives on-site at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or sooner.Some degree of warm water would be available in the Discharge Canal to preventfreezing even with both units shutdown.

However, in the event that ice was present onthe surface of the Discharge Canal, tools and equipment will be available in the BDBStorage Building to create an opening in the ice in order to drop the suction line andstrainer into the canal.NRC Audit Question No. 15There appears to be a single access road to the site. Please discuss the possibility ofan external event (hurricane, snow or ice storm, etc.) blocking the access road. Includein the discussion the ability to open the access road sufficiently to permit supplemental staff to arrive and deploy Phase-2 equipment.

Dominion

Response

The access road to Surry could become blocked due to debris or heavy snow; however,BDB equipment will include two John Deere 6125M Cab Tractors and one Caterpillar 924H Front-end Loader. These three pieces of equipment have buckets that arecapable of snow, ice, and debris removal and the front-end loader will have thecapability to clear large items of debris. The loader and tractors will be located in theBDB Storage Building to provide protection from external events.As stated in Dominion's NTTF Recommendation 9.3, Phase 1 Staffing Assessment dated April 29, 2013, if the access road cannot be cleared to support the arrival ofaugmented staff, an alternate staging location will be designated.

From this location, personnel would be shuttled to the site via helicopter.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 10 of 15NRC Audit Question No. 27In the 6-month update, the licensee is changing their strategy from: installing manualoperators on the SG PORVs, to installing a backup air bottle system.Note that Surry already has a backup air bottle system for the PORVs that allow theoperators to operate the PORVs from the adjacent Containment spray room.The staff requests the licensee describe the new backup air bottle system and itsoperation (e.g., expected cycles),

include a discussion on where operators will berequired to operate this system and evaluate effects of the environmental conditions, noise, communications, heat, etc.Dominion

Response

Currently, the SG PORVs are equipped with an existing backup air bottle system thatallows for manual operation.

However, the existing backup air bottle system is locatedon the ground floor of the seismic Class I Containment Spray Pump House (CSPH),which is not tornado missile protected on two of its four walls and the ceiling.A new seismically-designed, tornado missile protected backup air bottle system will beinstalled in the Main Steam Valve House (MSVH) AFW pump room to allow manualcontrol of the SG PORVs. Check valves will be installed in the air supply tubing toisolate the new backup air bottle system from the existing backup air bottle system. Thecapacity of the new backup air system will be sufficient to support SG PORV manualoperation to respond to the ELAP event. The backup air system compressed air bottlescan be re-pressurized during event response, as necessary, using portable aircompressors that are included with the BDB response support equipment.

Steam flowthrough the SG PORVs will be controlled by manually throttling air pressure to the valveair operators from the location of the air bottles in AFW Pump Room.Brief access to the 55-foot elevation of the MSVH is required to align the backup airsystem in order to manually operate the SG PORVs. Normal access to the MSVH (viathe AFW pump room) is through the ground floor of the CSPH. In the event of tornado-generated missile damage to the CSPH that prevents normal access to the MSVH andAFW Pump Room, the MSVH can be alternately accessed through an exterior doorlocated on the 55-foot elevation.

If the MSVH permanently installed exterior buildingladders also experience tornado missile damage, portable ladders will be utilized foralternate accessibility.

Based on preliminary results of the loss of ventilation temperature transient analysis forthe upper elevation of the MSVH, the ambient temperature in the SG PORV area isexpected to be near the normal operating temperature once stabilized with either theexterior access door at the 55-foot elevation or the AFW pump room access door open Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 11 of 15to provide supplemental ventilation.

At normal operating temperatures, this area isroutinely accessed during plant operation; therefore, access during ELAP response isnot expected to be limited.

The ventilation analyses are the subject of OIP Open Item14 and are provided in the Six-Month Status Update which is included as Attachment 1of this letter.The loss of ventilation temperature transient analysis for the AFW pump room showsthat the ambient temperature in the room with the Turbine Driven Auxiliary Feedwater (TDAFW) pump operating remains below 120°F for the entire transient.

Although notexpected to be necessary during low outdoor temperature conditions, FSG procedures provide for supplemental space heating for the AFW pump room.During an ELAP, the associated noise level from the TDAFW pump in the AFW pumproom will be significant.

Steam flow through the SG PORVs will also generate asignificant level of noise when operating.

Consequently, communications with thecontrol room will be established using methods suitable for the high-noise environment.

Details of the communications plan are the subject of Surry OIP Open Item 18.NRC Audit Question No. 29The staff requests the licensee provide the discharge pressure of the procured FLEXpumps in order to meet their functions.

Discuss pump lift capacities, pump placements, and discharge flow paths, to assure FLEX pumps can get UHS water up to and into theplant piping systems.Dominion

Response

The FLEX strategies require the following BDB pumps: 1) the BDB High Capacity Pump(one common pump for both units, which lifts water from the UHS to supply both Units 1and 2 AFW pumps/systems and to supply SFP makeup for the dual unit Surry SFP); 2)the BDB AFW Pumps (one for each unit, which delivers flow to the SGs for decay heatremoval and RCS cool down); and 3) the BDB RCS Injection Pumps (one for each unit,which delivers borated water to the RCS for inventory makeup and reactivity controlwhen needed).

The placement of these pumps and the discharge flow paths are shownin Figures 1 and 2 of the Surry OIP. Additional figures are available in the OIP thatshow the BDB connection points in more detail.The BDB High Capacity Pump is a diesel driven Godwin HM130L pump which developsmore than 150 psid at 1200 gpm. The Godwin HM130L is equipped with a totallyautomatic self-priming system which can achieve suction lifts from a completely drycondition to 28 feet. The BDB High Capacity Pump will be placed such that the suctionnozzle is approximately 10 feet above the elevation of the UHS water level.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 12 of 15The BDB AFW Pump is a diesel driven Hale Model TBP50-M pump which developsapproximately 500 psid at 350 gpm. The Hale Model TBP50-M pump is equipped witha priming system and is guaranteed to have 10 foot lift capability with 20 feet of 6"suction hose and a suction strainer.

However, the BDB AFW pump is used in floodedsuction conditions in FLEX strategies with the suction being supplied by either thedischarge of the BDB High Capacity pump or the Emergency Condensate Storage Tank(ECST) which is the normal AFW water storage tank.A Dominion hydraulic calculation confirms the ability of the BDB High Capacity pump todeliver at least 300 gpm to the AFW pump/system of both units and at least 500 gpm tothe SFP with margin for pump placement.

The BDB RCS Injection Pump is a diesel driven Hydra-Cell Model T8045 positivedisplacement pump which develops over 2000 psig discharge pressure at 45 gpm. TheHydra-Cell Model T8045 pump has dry lift (self priming) capability of approximately 9feet. However, the BDB RCS Injection pump is used in flooded suction conditions inFLEX strategies with the suction being supplied by the RWST or the portable Boric AcidBatch Tank. Calculations documenting the RCS makeup hydraulic analysis have beencompleted.

NRC Audit Question No. 30The staff requests the licensee provide additional information on the continued operation of the TDAFW pump during an ELAP event.A) discuss dependency on DC, AC, and air on the pump and associated valve operators B) discuss reliability of continued operation with respect to steam moisture content(previously attributed to pump trips), steam trap operation; and do trip valves closestopping trap drainC) discuss operation of the steam admission valves; do they fail close on loss of DC ornitrogen, what measures need to be taken to ensure continued operation.

D) discuss affects of environment conditions on governor operation E) discuss whether the TDAFW pump and its support systems (e.g., exhaust andrecirculation) are robust as defined by NEI 12-06, Appendix A [such that it would meetthe guidance of NEI 12-06, Section 3.2.1.3, initial condition (6) and Section 3.2.1.4,boundary condition (4)] and the effect of their consequential failure if appropriate, including any operator actions required to preserve inventory.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 13 of 15Dominion

Response

As described in the Surry 0IP, Section B.1, the TDAFW pump automatically starts in theevent of an ELAP/LUHS event on the loss of offsite power condition and does notrequire AC or DC electrical power to provide AFW to the SGs.A) The TDAFW pump does not rely on AC or DC power, or on compressed air pressure, to function.

The TDAFW pump turbine is supplied with motive steam through twoparallel, normally closed air-operated valves. The valves fail open upon loss of DCpower and fail as-is upon loss of compressed air pressure.

DC power will be available at the initiation of the ELAP and these valves are expected to open as a result of theTDAFW pump start signal. The valves will remain open following ELAP DC loadstripping and will not be cycled open/closed to control the TDAFW pump. During anELAP, the TDAFW pump turbine steam flow will be controlled automatically by thegovernor valve or manually with the overspeed trip/throttle valve. Neither the TDAFWpump turbine governor valve nor the overspeed trip/throttle valve require electrical power or compressed air to function.

Therefore, continued operation of the TDAFW pump does not rely on AC or DC power,or on compressed air.B) The TDAFW pump turbine steam supply lines are designed with steam condensate traps in the low points of the lines for condensate removal.

The traps drain to the maincondenser through a common header that includes a normally open air operatedisolation trip valve. The steam trap common drain line isolation trip valve closes on aContainment isolation signal, which is concurrent with certain AFW pump start signals,and fails closed on loss of Instrument Air pressure.

The steam turbine that drives theTDAFW pump can operate on steam of any moisture

content, or on a steam /condensate

mixture, but can be subject to over speed trip on start-up when significant condensate is present in the inlet steam line. Since the steam traps are aligned to drainto the condenser during power operation prior to TDAFW pump start, insignificant moisture is expected to accumulate in the turbine steam supply lines. Consequently, significant condensate will not be introduced to the turbine on an automatic start.Further, the turbine governor controls initial startups such that the pump/turbine gradually ramps up to operating speed, which tends to gradually introduce any minimalcondensate that could potentially be in the steam supply lines to the turbine in acontrolled fashion as it comes up to speed. When the TDAFW pump/turbine is atnormal operating speed, the steam flow in the steam supply line will carry any smallamounts of non-drained water that might condense in the line through the steam supplyline to the turbine and thus tend to preclude condensate buildup in the steam supplyline. Thus, the design of the steam supply lines and steam trap system limits thepossibility of turbine trips due to excess condehsate in the steam supply lines.C) See response to A) above.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 14 of 15D) The TDAFW pump governor operation will not be adversely affected by theenvironmental conditions within the AFW pump room during an ELAP/LUHS.

ADominion calculation for the loss of ventilation transient temperature analysis showsthat the temperature in the ground level of the MSVH (AFW pump room) will remainbelow 1200F, which is below the qualification temperature of the governor.

Although notexpected to be necessary during low ambient temperature conditions, FSG-5 willprovide for supplemental space heating for the AFW pump room, such that TDAFWpump governor operation will not be affected.

E) The TDAFW pump and associated components (e.g., turbine exhaust and pumprecirculation piping, etc.) that support operation of the TDAFW pump are designed tomeet the current plant design basis for the applicable external hazards identified inSurry 0IP Section A.1. Thus, failures of the TDAFW pump and its support systems arenot postulated for BDB events.NRC Audit Question No. 37Discuss impact of injecting raw water through the main feedwater header on the "J"nozzles inside the steam generators.

Include filtering requirements.

Dominion

Response

The injection of raw water from the Surry Discharge Canal, following depletion of theEmergency Condensate Storage Tank (ECST) and the Emergency Condensate Makeup Tank (ECMT), would not occur until 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> after the event at the earliest andwill not affect the SG feedwater ring J-nozzles.

The J-nozzles are fabricated fromerosion resistant material (Inconel) and are of sufficient internal diameter to preventblockage.

The BDB High Capacity Pump, drawing raw water from the Surry Discharge Canal, includes strainers to prevent downstream pump damage, flow blockage, andexcessive sediment or debris accumulation.

Although the Surry Discharge Canal is the ultimate credited source of AFW supplybecause it will be available for all considered extreme events, other site water sourcesare expected to be used preferentially, if available.

These sources include the normalCondensate Storage Tanks, the main condenser

hotwell, and the Fire Protection System water storage tanks, which would provide a clean source of fresh water for SGinjection.

Studies are currently being performed by Westinghouse (SG supplier) to assess thelong-term effects of the use of available water sources on SG performance in responseto the ELAP/LUHS.

The study will result in a list of prioritized water sources.

The finalresults of the Westinghouse study are expected in March 2014 and will be provided in afuture Six-Month Update.

Serial No. 12-163EDocket Nos. 50-280/281 Order EA-12-049 Attachment 3Page 15 of 15NRC Audit Question No. 44Please clarify whether you plan to abide by the Nuclear Energy Institute position paperaddressing mitigating strategies in shutdown and refueling modes that is datedSeptember 18, 2013 (ADAMS Accession No. ML 13273A514),

and which has beenendorsed by the NRC staff (ADAMS Accession No. ML13267A382).

If not, pleaseclarify how mitigating strategies for shutdown and refueling modes will be addressed and provide justification for the planned approach.

Dominion

Response

Surry Power Station will abide by the Nuclear Energy Institute position paper entitled"Shutdown

/ Refueling Modes" addressing mitigating strategies in shutdown andrefueling modes that is dated September 18, 2013 and has been endorsed by the NRCstaff.