BSEP 14-0133, First Six Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

First Six Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

ML14364A029
Person / Time
Site:	Brunswick
Issue date:	12/17/2014
From:	William Gideon Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0133, EA-13-109
Download: ML14364A029 (8)

Text

William R. Gideon

~DUKE Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 December 17, 2014 Serial: BSEP 14-0133 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 First Six Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA 109)

References:

1. NRC Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," dated September 1, 1989, ADAMS Accession Number ML031140220.

2. NRC Order Number EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012, ADAMS Accession Number ML12056A043.

3. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013, ADAMS Accession Number ML13130A067.

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated November 14, 2013, ADAMS Accession Number ML13304B836.

5. NRC Acknowledgement of NEI 13-02 Phase 1 OIP Template, dated May 14, 2014, ADAMS Accession Number ML14128A219.

6. NEI 13-02, "Industry Guidance for Compliance with Order EA-1 3-109," Revision 0, Dated November 2013.

7. Duke Energy Letter, "Phase 1 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 26, 2014. ADAMS Accession Number ML14191A687.

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (i.e., Reference 3) to Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Reference 3 was immediately effective and directed BSEP to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of Reference 3.

A/5'3

U.S. Nuclear Regulatory Commission Page 2 of 3 Reference 3 required submission of an Overall Integrated Plan (OIP) pursuant to Section IV, Condition D. Reference 4 endorsed industry guidance document NEI 13-02, Revision 0 (i.e.,

Reference 6) with clarifications and exceptions. Reference 7 provided the Brunswick Steam Electric Plant OIP.

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

This letter contains no regulatory commitments.

If you have any questions regarding this report, please contact Mr. Lee Grzeck, Manager -

Regulatory Affairs, at (910) 457-2487.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 17, 2014.

Sincerely, William R. Gideon SWR/swr

U.S. Nuclear Regulatory Commission Page 3 of 3

Enclosure:

Six Month Status Update Report for the Implementation of Order EA-1 3-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc (with enclosure):

U.S. Nuclear Regulatory Commission ATTN: Mr. Bill Dean, Director, Office of Nuclear Reactor Regulation 11555 Rockville Pike Rockville, MD 20852-2738 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: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop 08B3) (Electronic Copy Only)

Washington, DC 20555-0001 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0

ENCLOSURE SIX MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF ORDER EA 109, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS" BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS.1 AND 2 DOCKET NOS.50-325 AND 50-324 RENEWED LICENSE NOS.DPR-71 AND DPR-62 Name Signature Date Preparer: Bob Ginsberg Fukushima Response Verifier: Leunis van Eeden 42//6 Fukushima Response Approver: Mike Weber Fukushima Response Manager

Brunswick Steam Electric Plant's Six Month Status Update Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (Reference 1 in Section 8) documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation, and the basis, if any.

2 Milestone Accomplishments The following milestone has been completed since the development of the Overall Integrated Plan (Reference 1), and is current as of December 1, 2014.

• Submit Overall Integrated Plan.

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

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

Milestone Target Activity Comments Completion Status (include date Date changes in this column)

Hold preliminary/conceptual design meeting. Jun. 2014 Complete. Date not revised.

Submit Overall Integrated Plan. Jun. 2014 Complete. Date not revised.

Submit 6 Month Status Report. Dec. 2014 Started. Date not revised.

Submit 6 Month Status Report. Jun. 2015 Not started. Date not revised.

Storage Plan. TBD Not started. Date not revised.

Staffing analysis completion. TBD Not started. Date not revised.

Long term use equipment acquisition TBD Not started. Date not revised.

timeline.

Submit 6 Month Status Report. Dec. 2015 Not started. Simultaneous with Phase 2 OIP.

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Brunswick Steam Electric Plant's Six Month Status Update Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" Milestone Target Activity Comments Completion Status (include date Date changes in this column)

Unit 2 Design Engineering On- Mar. 2016 Not started. Date not revised.

site/Complete.

Submit 6 Month Status Report. Jun. 2016 Not started. Date not revised.

Operations Procedure Changes Developed. Dec. 2016 Not started. Date not revised.

Site Specific Maintenance Procedure Dec. 2016 Not started. Date not revised.

Developed.

Submit 6 Month Status Report. Dec. 2016 Not started. Date not revised.

Training Complete. Feb. 2017 Not started. Outage start date moved up to February 2017.

Unit 2 Implementation Outage. Feb. 2017 Not started. Outage start date moved up to February 2017.

Procedure Changes Active. Mar. 2017 Not started. Date not revised.

Unit 2 Walk Through Mar. 2017 Not started. Date not revised.

Demonstration/Functional Test.

Unit 1 Design Engineering On- Mar. 2017 Not started. Date not revised.

site/Complete.

Submit 6 Month Status Report. Jun. 2017 Not started. Date not revised.

Submit 6 Month Status Report. Dec. 2017 Not started. Date not revised.

Unit 1 Implementation Outage. Feb. 2018 Not started. Outage start date moved up to February 2017.

Unit 1 Walk Through Mar. 2018 Not started. Date not revised.

Demonstration/Functional Test.

Submit Completion Report. May 2018 Not started. Date not revised.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 Overall Integrated Plan (Reference 1).

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Brunswick Steam Electric Plant's Six Month Status Update Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 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 from Overall Integrated Plan and Interim Staff Evaluation The following table provides a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status 1 Evaluate, design, and implement missile protection as required Evaluation started.

for the HCVS piping external to the reactor building.

2 Finalize location of the Remote Operating Station (ROS). Started.

3 Finalize and design means to address flammable gases in the Started.

HCVS.

4 Evaluate location of FLEX DG for accessibility under severe Started.

accident conditions.

5 Develop procedures for BDBEE and severe accident vent Not started.

operation (load shedding, power supply transfer, and vent valve operation from the Main Control Room and ROS), vent support functions for sustained operation and portable equipment deployment (FLEX DG supply to the 24/48VDC battery system, and makeup to the nitrogen backup system). 24/48VDC 6 Confirm suppression pool heat capacity. Initial results from GE Started.

report 0000-0165-0656-RO for BSEP indicate the suppression pool reaches the heat capacity temperature limit (HCTL) in 2.11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />.

7 Finalize location of supplemental N2 bottle connection. Not started.

8 Establish programs and processes for control of HCVS Not started.

equipment functionality, out-of-service time, and testing.

9 Confirm wetwell vent capacity is sufficient at the containment Started.

design pressure (62 psig). Existing calculation 0D12-0009 calculates a wetwell vent capacity at the primary containment pressure limit (PCPL, 70 psig).

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Brunswick Steam Electric Plant's Six Month Status Update Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. Duke Energy Letter, "Phase 1 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-1 3-109)," dated June 26, 2014. ADAMS Accession Number ML14191A687

2. NRC Order Number EA-1 3-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013. (Accession No. ML13130A067)

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