BSEP 14-0005, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14073A451
Person / Time
Site:	Brunswick
Issue date:	02/28/2014
From:	Hamrick G Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0005, EA-12-049
Download: ML14073A451 (15)

Text

DUKE George T. Hamrick Vice President ENERGY. Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 50.4 Serial: BSEP 14-0005 February 28, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Progress, Inc. (Duke Energy)

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 Renewed License Nos. DPR-71 and DPR-62

Subject:

Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML12054A735

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

4. CP&L and FPC to NRC, CarolinaPower& Light Company and Florida Power Corporation'sInitial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (OrderNumber EA-12-049), dated October 29, 2012, ADAMS Accession Number ML12307A021

5. CP&L to NRC, Overall IntegratedPlan in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (OrderNumber EA-12-049), dated February 28, 2013, ADAMS Accession Number ML13071A559

6. Duke Energy Letter, FirstSix-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated August 20, 2013, ADAMS Accession Number ML13248A447 Ars!

U.S. Nuclear Regulatory Commission Page 2 of 3 Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (i.e., Reference 1) to Duke Energy. Reference 1 was immediately effective and directs Duke Energy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (i.e., Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (i.e., Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Duke Energy initial status report regarding mitigation strategies at the Brunswick and Robinson Steam Electric Plants and the Shearon Harris Nuclear Power Plant.

Reference 5 provided the Duke Energy OIP for Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first six-month status report for BSEP. The purpose of this letter is to provide the second six-month status report, pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments and no revision to existing regulatory commitments.

Should you have any questions regarding this submittal, please contact Lee Grzeck, Manager-Regulatory Affairs, at (910) 457-2487.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 28, 2014.

Sincerely, George T. Hamrick

U.S. Nuclear Regulatory Commission Page 3 of 3

Enclosure:

Second Six-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 Events, Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 cc:

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Siva P. Lingham (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Ms. Jessica A. Kratchman (Mail Stop OWFN 9D2) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

ENCLOSURE SECOND SIX-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 EVENTS BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. I AND 2 DOCKET NOS. 50-325 AND 50-324 RENEWED LICENSE NOS DPR-71 AND DPR-62 Page 1 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure BSEP Second Six-Month Status Report I Introduction Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)

(i.e, Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049. The OIP was submitted to the NRC on February 28, 2013.

The first six month update was submitted to the NRC on August 20, 2013 (i.e., Reference 2 of this enclosure). This enclosure provides an update of milestone accomplishments, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, ifany, that occurred during the period between July 31, 2013, and January 28, 2014, hereafter referred to as the "update period."

2 Milestone Accomplishments The following milestones were completed during the update period:

0 Completed and submitted First Six Month Status Report.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates and subject to change as design and implementation details are developed.

The revised milestone target completion dates are not expected to impact the Order implementation date.

MlsoeTarget Activity Status Revised Completion Date Completion Date Submit 60 Day Status Report 10/29/12 Complete Date Not Revised Submit Overall Integrated 2/28/13 Complete Date Not Revised Implementation Plan Submit 6 Month Status Report 8/30/13 *Complete Date Not Revised Perform Staffing Analysis Phase 1 11/29/13 Complete Date Not Revised of NEI 12-01 Page 2 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure Target Completo Activity Status Revised eCompletion Date Completion Date Submit 6 Month Status Report 2/28/14 *Started Date Not Revised Develop Unit 2 Modification *3/30/15 Engineering Change (EC) 3/27/14 Started Unit 2 Modifications will Packages, including Storage be completed and ready Facility to exit RFO B222R1 Perform station-specific analysis following generic BWROG FLEX 3/30/14 Started *8/15/14 implementation analysis review (Open Item 19)

Develop Strategies/Contract with 4/1/14 Started *8/15/14 Regional Response Center (RRC)

Submit 6 Month Status Report 8/29/14 Not Started Date Not Revised SAT Process for Training (Unit 2) 1/27/14 Started *07/24/14 SAT Process for Training (Unit 1) 1/26/15 Not Started Date Not Revised Develop Training Plan (Unit 2) 07/27/14 Started Date Not Revised Develop Training Plan (Unit 1) 07/26/15 Not Started Date Not Revised Procure Equipment (Unit 2) 11/27/14 Started Date Not Revised Procure Equipment (Unit 1) 11/26/15 Started Date Not Revised

• Milestone deleted.

Procure Additional FLEX Milestone labeled Equipment (Unit 2) 'Procure Equipment (Unit 2)' is all inclusive.

• Milestone deleted.

Procure Additional FLEX 11/26/15 *Delete Milestone labeled Equipment (Unit 1) 'Procure Equipment (Unit 1)' is all inclusive.

Create Maintenance Procedures 01/27/15 Not Started Date Not Revised (Unit 2)

Create Maintenance Procedures 01/26/16 Not Started Date Not Revised (Unit 1)

Procedure Changes incorporating 01/27/15 *Started Date Not Revised response strategies (Unit 2)

Procedure Changes incorporating 01/26/16 Not Started Date Not Revised response strategies (Unit 1)

Page 3 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure Milestone Target Activity Status Revised Milestone _ Completion Date Completion Date Implement Training (Unit 2) 02/27/15 Started Date Not Revised Implement Training (Unit 1) 02/26/16 Not Started Date Not Revised Submit 6 Month Status Report 2/27/15 Not Started Date Not Revised Unit 2 Implementation Outage March 2015 Not Started Date Not Revised

• 3/30/16 Develop Unit 1 Modification EC 3/26/15 Not Started Unit 1 Modifications will Packages be completed and ready to exit RFO B121R1 Submit 6 Month Status Report 8/31/15 Not Started Date Not Revised Implement Modifications (Unit 2) April 2015 Not Started Date Not Revised Implement Modifications (Unit 1) April 2016 Not Started Date Not Revised Submit 6 Month Status Report 2/29/16 Not Started Date Not Revised Unit 1 Implementation Outage March 2016 Not Started Date Not Revised Submit Completion Report (Unit 2) April 2015 Not Started Date Not Revised Submit Completion Report (Unit 1) April 2016 Not Started Date Not Revised Submit 6 Month Status Report 8/31/16 Not Started Date Not Revised

• Indicates a change since last 6 month update.

4 Changes to Compliance Method The following summarizes changes that were made during the second update period to the strategies as documented in the OIP (i.e., Reference 1 of this enclosure) or the changes that were provided by Reference 2 of this enclosure. These changes do not impact BSEP's compliance with NEI 12-06.

1) Change: The OIP identified a modification to the Reactor Core Isolation Cooling/High Pressure Coolant Injection (RCIC/HPCI) suction line at the Condensate Storage Tank (CST).

This modification would have facilitated alignment of the Clean Water Storage Tank (CWST) to the RCIC system suction. This modification will not be implemented.

Justification: NEI 12-06 requires a primary and alternate connection point for Core Cooling.

BSEP has identified the Suppression Pool and the clean water storage tank as its primary and alternate connection points, respectively. The OIP discusses taking suction from the CST, to maintain core cooling, if it is available following the Beyond-Design-Basis-External-Event (BDBEE). The modification was reviewed and determined to be an enhancement for Page 4 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure operations personnel. The removal of this modification from the scope of work to be performed does not impact BSEP's ability to meet the guidance contained within NEI 12-06.

Documentation: No additional documentation is required.

2) Change: The OIP identified a modification to an abandoned Auxiliary Steam Line which would be used to support core and spent fuel pool cooling during Phases 2 and 3. This line, which was to provide a path from outside Secondary Containment (Reactor Building) to inside Secondary Containment, will no longer be used. Instead, BSEP will perform a core bore on the East wall of Secondary Containment to facilitate the following objectives: primary connection for the core cooling supply line and primary connection for the spent fuel pool cooling supply line. A single supply line will penetrate Secondary Containment and split into two separate lines once inside. Each interior line will be capable of ensuring proper distribution of required makeup water for Core Cooling and Spent Fuel Pool (SFP) Cooling.

Strategy for Primary Connection for Core Cooling: A FLEX pump, of sufficient capacity and discharge head, will be deployed to the general area of the CWST. Discharge hoses will be deployed from the pump to the exterior East wall of each Reactor Building (RB) and connected to the new primary connection point. In each RB, hoses will be deployed from the interior connection of this penetration to a new connection point at the drywell personnel access roof. The hose will be connected to a hard pipe that will be connected to an existing flange on the Reactor Water Cleanup (RWCU) return line on top of the Drywell access. An isolation valve at the RWCU return line will be manually opened to supply cooling water to the reactor vessel through the "B" feedwater injection line.

Strategy for Primary Connection for SFP Cooling: A FLEX pump, of sufficient capacity and discharge head, will be deployed to the general area of the CWST. Discharge hoses will be deployed from the pump to the exterior East wall of each Reactor building and connected to the new primary connection point. In each RB, hoses will be deployed from the interior connection for this penetration to a new connection point to the "B" loop RHR Fuel Pool Cooling Assist line. An isolation valve in the SFP cooling system will be manually opened to supply cooling water to the SFP through the "B" RHR Fuel Pool Cooling Assist line.

Justification: NEI 12-06 requires that at least one connection point of FLEX equipment only involves access through seismically robust structures. The Auxiliary Steam Line was chosen due to availability. During detailed design, it was determined the Auxiliary Steam Line would be challenged to meet the seismic requirements outlined in NEI 12-06. A core bore has been identified as the most efficient method to provide the primary connection point for both Core Cooling and SFP Cooling, and will be protected from all applicable external hazards.

Documentation: Open Item 10 will track completion of this item, and Open Item 1 will track demonstration of deployment path acceptability.

3) Change: The OIP identified a modification to the abandoned Supplemental Spent Fuel Pool Cooling line in support of cooling the spent fuel pool during Phases 2 and 3. This line, which was to provide a path from outside Secondary Containment (RB) to inside Secondary Containment, will no longer be used. Instead, BSEP will pull hoses from our FLEX pump through the RB air lock doors to the 117' elevation. These hoses will either fill the SFP or provide the required spray to the SFP. This approach, which has been established as our Page 5 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure alternate connection point for SFP Cooling, is currently documented as one of BSEP's B.5.b strategies for filling the SFP.

Justification: NEI 12-06 requires an alternate connection point for SFP makeup. During detailed design reviews it was determined that Table C-3, of NEI 12-06, acknowledges the use of hoses to fill the SFP meets the guidance in NEI 12-06.

Documentation: Open Item 9 will track completion of this item and Open Item 1 will track demonstration of deployment path acceptability.

4) Change: The OIP discussed, in multiple locations, the use and modifications of Severe Accident Mitigation Alternative (SAMA) diesel generators. The OIP will be modified to reflect the use of newly procured FLEX diesel generators instead of the SAMA diesel generators.

Justification: Detailed design evaluations determined that the existing SAMA diesel generators could not be protected from all applicable hazards as identified in NEI 12-06. A qualified building, providing protection from all applicable hazards, will be built. New FLEX diesel generators (i.e., approximately 500 kW, 480 VAC), capable of re-powering key equipment and instruments utilized in FLEX strategies, will be procured and pre-staged within the new FLEX diesel generator storage building.

Documentation: No additional documentation is required.

5) Change: The OIP identified a modification, in support of DC Power Management, which required pre-staging two 400 kW generators and maintaining a +1 generator in the FLEX Storage Building. The modification included an external connection point for the +1 generator.

The modification will now pre-stage two 500 kW generators, but the requirement for a third generator has been removed from BSEP's plan. The connection point originally planned for the N+1 diesel generator will continue to be installed, but will be designated for the Regional Response Center (RRC) generator.

Justification: NEI 12-06 identifies that electrical diversity can be accomplished by providing a primary and alternate method to repower key equipment and instruments utilized in FLEX strategies. During detailed analysis, it was determined that a single 500 kW generator can repower the key equipment and instruments needed for both BSEP units. Each 500 kW generator has sufficient margin to supply both units' Division II Battery Chargers, thereby maintaining DC distribution to the key equipment. One 500kW generator will satisfy the N requirement for both BSEP units and the second 500 kW generator will satisfy the +1 requirement for BSEP.

Documentation: Open Item 9 will track completion of this item and Open Item 1 will track demonstration of deployment path acceptability.

6) Change: The OIP Attachment 1A, identified Action Item 4 as a "Time Constraint" action. The specific action states, "SAMA diesel generator started and loaded." The time constraint is identified as 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. The new action states, "FLEX diesel generator started and loaded."

The time constraint is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Justification: The 500 kW generators (as discussed in Change 5) are being referenced as Page 6 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure FLEX Diesel Generators with both the N and the +1 FLEX Diesel Generator being pre-staged.

The original action allowed for failure of the initial N SAMA diesel generator and the deployment of the +1 diesel generator. The mobilization time required for the +1 diesel generator (5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) is no longer a limiting condition. The revised strategy will facilitate re-powering the key equipment and instruments utilized in FLEX strategies by either the initial FLEX diesel generator or the +1 FLEX diesel generator and satisfies previously established Station Blackout requirement of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Documentation: Open Item 9 will track completion of this item and Open Item 1 will track demonstration of deployment path acceptability.

7) Change: The OIP, Attachment 1A, identified Action Item 5 as a "Time Constraint" action. The specific action states, "Deep load shedding is completed." The time constraint is identified as 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. This is no longer considered to be a "Time Constraint" action.

Justification: The original determination that this action was a "Time Constraint" action was based on extending the Phase 1 coping time for re-powering key equipment and instruments utilized in FLEX strategies from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 5.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Initially, this action was determined to be necessary to facilitate a failure of a SAMA diesel generator and the deployment of the +1 diesel generator. As discussed above in Change 6, the +1 FLEX diesel generator will be pre-staged; therefore, time delays associated with deployment no longer apply. DC power deep load shedding is no longer required as a strategy to extend coping time.

Documentation: Open Item 9 will track completion of this item.

8) Change: The OIP identified a modification, in support of DC Power Management, that would provide the means to connect the RRC supplied 4160 VAC generator to the existing 4160 VAC Emergency Busses during Phase 3. The modification will not be implemented.

Justification: NEI 12-06 requires the use of off-site equipment during Phase 3. During detailed design, BSEP evaluated the need for the 4160 VAC connection during the Phase 3 response.

To extend BSEP's coping time for Phase 2, a 480 VAC generator with sufficient capacity will maintain BSEP's ability to protect the core, containment integrity, and spent fuel. The removal of this modification from the scope of work to be performed does not impact BSEP's ability to meet the guidance contained within NEI 12-06.

Documentation: No additional documentation is required.

9) Change: The OIP, Attachment 1A, identified Action Item 8 as a "Time Constraint" action. The specific action states, "Align SAMA diesel generators to 480 VAC; power for MOVs, AC instruments, battery room fans, etc. (critical load 24/48 VDC battery chargers). N+1 SAMA diesel generator deployed and loaded, if necessary." The time constraint is identified as 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is no longer considered to be a "Time Constraint" action.

Justification: The original determination that this action was a "Time Constraint" action was based on BSEP's response to meet the guidance contained within EA-12-50, Reference 10 of this enclosure. EA-1 2-50 has been superseded by EA-1 3-109. EA-1 3-109, Reference 11 of this enclosure will not be implemented in conjunction with FLEX implementation. Actions to Page 7 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure re-power MOVs, AC instruments, battery room fans, etc. become contingency actions and will be performed when needed based on power availability.

Documentation: No additional documentation is required.

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

6 Open Items Generic Concerns The NRC has recently endorsed three Generic Issues associated with FLEX:

1. Electric Power Research Institute (EPRI) Report 3002001785, Use of ModularAccident Analysis Program(MAAP) in Support of Post-FukushimaApplications.

• BSEP will abide by this generic resolution

2. EPRI Report 3002000623, Nuclear MaintenanceApplications Center: Preventive Maintenance Basis for FLEX Equipment.

• BSEP will abide by this generic resolution

3. NEI position paper, Shutdown/Refueling Modes, to enhance the shutdown risk process and procedures.

• BSEP will abide by this generic resolution Plan Open Items The following tables provide a summary status of the Open Items. The table under Section 6a.

provides the open items that were previously identified in the original OIP submitted on February 28, 2013, and in the first six-month status report submitted in Reference 2 of this enclosure. The table under Section 6b. provides a list of open items that were added after July 30, 2013.

Page 8 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure Table 6a. Open Items Documented in the OIP.

Overall Integrated Plan Open Item Status

1. Perform a formal validation of FLEX deployment, connection, and action timelines after the procedural guidance is developed and related Not Started staffing study is completed.

2. Implement programmatic controls. Not Started

3. Develop plant equipment control guidelines, in accordance with NEI 12-06, Section 11.5, to manage the unavailability of equipment and Not Started applicable connections that directly perform a FLEX mitigation strategy.

4. Establish programs and process to assure personnel proficiency in the mitigation of beyond-design-basis events is developed and maintained Started in accordance with NEI 12-06, Section 11.6.

5. Maintain FLEX strategies in overall FLEX basis documents. Started

6. Modify existing plant configuration control procedures to ensure that changes to the plant design, physical plant layouts, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06, Section 11.8.

7. Complete applicable training prior to the implementation of FLEX. Started

8. Complete construction of FLEX Equipment Storage Building prior to the implementation of Started FLEX.

9. Develop BSEP procedures and programs to address storage structure requirements, deployment path requirements, and FLEX Started equipment requirements relative to the hazards applicable to BSEP.

10. Design FLEX equipment connection points (e.g.,

mechanical, pneumatic, and electrical) to Started withstand the applicable external hazards.

Page 9 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure Overall Integrated Plan Open Item Status 1 1. Perform study to validate Suppression Pool temperatures exceeding 220°F. Started

12. Develop site specific procedures or guidelines, utilizing the industry developed guidance from the Owners' Groups, EPRI, and NEI Task team, to Started address the criteria in NEI 12-06.

1 3. Modify the current HCVS in accordance with NRC Deleted. EA-12-050 superseded by of Oder o Moify Order EA-1 2-050, Issuance ofEA-1 3-109. Action to be tracked by Licenses with Regard to Reliable Hardened EA-13-109 response.

Containment Vents.

14. Complete SFP level instrumentation modifications per NRC Order EA 12-051, Issuance of Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

1 5. Develop deep load-shedding procedures to extend coping time for station batteries. Not Started

16. Modify procedures such that operator manual actions, in areas where habitability is a concern, occur early in the FLEX timeline, to the extent Not Started practical.

1 7. Revise procedures to open Reactor Building doors to provide a natural air circulation path. Not Started

18. Provide transportation equipment to move large skids/trailer-mounted equipment provided from off- Not Started site.

19. Review generic BWROG analysis of FLEX implementation and perform station-specific Started analysis (NEDC 33771P, Revision 1).

20. Develop a process/methodology to rupture the Wetwell Vent Disc with Containment pressure Not Started below 55 psi.

21. Develop a process/methodology to provide Clean Water Makeup to the CWST during Phase 3 response.

22. Develop guidance for obtaining local vital indications during a loss of DC in conjunction with an ELAP. This strategy will be available for Not Started appropriate plant personnel use in response to these failures.

Page 10 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure Table 6b. Open Items added after July 30, 2013 Overall Integrated Plan Open Item Status None Not applicable 7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. CP&L to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (Order Number EA-12-049), dated February 28, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13071A559

2. Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated August 20, 2013, ADAMS Accession Number ML13248A447

3. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, "Issuanceof Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, ADAMS accession Number ML12054A735

4. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation strategiesfor Beyond-Design-BasisExternal Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

5. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

6. CP&L and FPC to NRC, CarolinaPower& Light Company and FloridaPower Corporation's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderEA-12-049), dated October 29, 2012, ADAMS Accession Number ML12307A021

7. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 30, 2013, ADAMS Accession Number ML13267A382 Page 11 of 12

U.S. Nuclear Regulatory Commission Serial: BSEP 14-0005 Enclosure

8. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 3, 2013, ADAMS Accession Number ML13275A318

9. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 7, 2013, ADAMS Accession Number ML13276A224

10. NRC Order Number EA-1 2-050, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents, dated March 12, 2012, ADAMS Accession Number MLI12054A694

11. NRC Order Number EA-1 3-109, Issuance of Orderto Modify Licenses with Regard to Reliable Hardened Containment Vents Capableof Operation Under Severe Accident Conditions,dated June 6, 2013, ADAMS Accession Number ML13143A321 Page 12 of 12