BSEP 15-0044, Second 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)

Second 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)

ML15196A035
Person / Time
Site:	Brunswick
Issue date:	06/25/2015
From:	William Gideon Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 15-0044, EA-1 3-109, TAC MF4467, TAC MF4468
Download: ML15196A035 (10)

Text

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~'ENERGY. Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 June 25, 2015 Serial: BSEP 15-0044 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001

Subject:

Brunswick Steam Electric Piant (BSEP), Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Second 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-1 3-1 09)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA.-1 3-109, Issuance of Orderto Modify Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13143A321.

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

3. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, 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 (OrderNumber EA-13-109), dated June 26, 2014, ADAMS Accession Number ML14191A687.

4. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, 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 (OrderNumber EA-13-109), dated December 17, 2014, ADAMS Accession Number ML14364A029.

5. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of OrderEA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4467 and MF4468), dated March 10, 2015, ADAMS Accession Number ML15049A266.

6. NEt 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 0, November 12, 2013, ADAMS Accessio~n Number ML13316A853.

U.S. Nuclear Regulatory Commission Page 2 of 3 Ladies and Gentlemen:

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

Reference 1 required submission of an Overall Integrated Plan (OIP) pursuant to Section IV, Condition D. Reference 2 endorsed industry guidance document NEI 13-02, Revision 0 (i.e.,

Reference 6) with clarifications and exceptions. Reference 3 provided the Brunswick Steam Electric Plant OIP.

References 1 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 second six-month status report pursuant to Section IV, Condition D, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the submittal of the first six-month status report (i.e., Reference 4),

including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, 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 June 25, 2015.

William R. Gideon

Enclosure:

Brunswick Steam Electric Plant (BSEP), Second Six-Month Status Report for the Implementation of Order EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1 257 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 OWEN 8B3) (Electronic Copy Only) 11555 Roc*kville 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 Chair - North Carolina Utilities Commission PoO. Box 29510 Raleigh, NC 27626-0510

ENCLOSURE Brunswick Steam Electric Piant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1 Introduction Brunswick Steam Electric Piant (BSEP) developed an Overall Integrated Plan (i.e., Reference 2 to this enclosure) 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 Order Number EA-13-109 (i.e. Reference i to this enclosure). This enclosure provides the second 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 milestones have been completed since the development of the Overall Integrated Plan, and is current as of June 1, 2015.

0 Submit Overall Integrated Plan.

S Submit 6-Month Status Report (i.e., December 2014).

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.

Holdicates a change since Targt6 Hodpreliminary/conceptual design meeting.

Tontomm Jun. 2014 Complete. Date not revised.

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

Submit 6 Month Status Report. Dec. 2014 *Complete. Date not revised.

Submit 6 Month Status Report. Jun. 2015 *Started. Date not revised.

Storage Plan. TBD Not started. Date not revised.

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

Page 1 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-1 09, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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Milestorie ' ,- C:,Ohmpletcirn  :-A-ii" (Incluide ate

• Indicates a change since last 6 month update.

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

Simultaneous with Submit 6 Month Status Report. Dec. 2015 Not started. Pae2OP Unit 2 Design Engineering On-site/Complete. Mar. 2016 Not started. Date not revised.

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 Dc 06 Ntsatd aentrvsd Developed. Dc 06 Ntsatd aentrvsd Submit 6 Month Status Report. Dec. 2016 Not started. Date not revised.

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

Outage start date Unit 2 Implementation Outage. Feb. 2017 Not started. 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-site/Complete. Mar. 2017 Not started. Date not revised.

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

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

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

Page 2 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

'... . - Milestone..

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tavtus.÷ . ...- ' och: e<:.,ang es) j-:" *

• Indicates a change since last 6 month update.

Unit 1 Walk Through Mr 08 Ntsatd aentrvsd Demonstration/Functional Test. Mr 08 Ntsatd aentrvsd 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 (i.e., Reference 2 to this enclosure).

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 tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) (i.e., Reference 3 to this enclosure) and the status of each item.

• lIndicates a change since last 6 month update.

1 Evaluate, design, and implement missile protection as required *Complete.

for the HCVS piping external to the reactor building.

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

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

HCVS.

Evaluate location of FLEX Diesel Generator (DG) for accessibility Started.

under Severe Accident conditions.

Page 3 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions power supply transfer, and vent valve operation from the main 5 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).

Confirm suppression pool heat capacity. Initial results from GE *Complete.

report 0000-0165-0656-RO for BSEP indicate the suppression 6pool 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.

8Establish programs and processes for control of HCVS *Started.

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

Confirm Wetwell vent capacity is sufficient at the containment Started.

design pressure (62 psig). Existing calculation 0012-0009 calculates a wetwell vent capacity at the primary containment pressure limit (PCPL, 70 psig).

• Indicates a change since last 6 month update.

Make available for NRC staff audit the site specific controlling *Add ISE Open Item.

1document for HCVS out of service and compensatory measures. Not started.

Page 4 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions HCVS has the capacity to vent the steam/energy equivalent of Not started.

one percent of licensed/rated thermal power (i.e., unless a lower value is justified), and that the suppression pool and the HCVS 2 together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

Make available for NRC staff audit confirmation of the time it *Add ISE Open Item.

3takes the suppression pool to reach the heat capacity Not started.

temperature limit during extended loss of AC power (ELAP) with RCIC in operation.

Make available for NRC staff audit a description of the final ROS *Add ISlE Open Item.

4location. Not started.

Make available for NRC staff audit documentation that *Add ISlE Open Item.

5 demonstrates adequate communication between the remote Not started.

HCVS operation locations and the HCVS decision makers during ELAP and severe accident conditions.

Provide a description of the final design of the HCVS to address *Add ISlE Open Item.

6 hydrogen detonation/deflagration. Not started.

Make available for NRC staff audit seismic and tornado missile *Add ISlE Open Item.

7final design criteria for the HCVS stack. Not started.

Make available for NRC staff audit documentation of the HCVS *Add ISlE Open Item.

8 nitrogen pneumatic system design including sizing and location. Not started.

Make available for NRC staff audit documentation of HCVS *Add ISE Open Item.

9incorporation into the FLEX diesel generator loading calculation. Not started.

Make available for NRC staff audit an evaluation of temperature *Add ISlE Open Item.

10 and radiological conditions to ensure that operating personnel Not started.

can safely access and operate control and support equipment.

Page 5 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Interim Stdff Evaluation (ISE) Phas~ 1 Open Items Sfatus

• Indicates a chanae since last 6 month uodate.

Make available for NRC staff audit descriptions of all *Add ISE Open Item.

11 instrumentation and controls (existing and planned) necessary to Not started.

implement this order including qualification methods.

Clarify whether the seismic reliability demonstration of *Add ISE Open Item.

instruments, including valve position indication, vent pipe Not started.

12temperature instrumentation, radiation monitoring, and support 12system monitoring will (be) via methods that predict performance described in IEEE-344-2004 or provide justification for using a different revision of the standard.

Make available for NRC staff audit a justification for not *Add ISE Open Item.

13 monitoring HCVS system pressure as described in NEI 13-02. Not started.

Make available for NRC staff audit the descriptions of local *Add ISE Open Item.

conditions (temperature, radiation and humidity) anticipated Not started.

during ELAP and severe accident for the components (valves, 14 instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

Make available for NRC staff audit documentation of an *Add ISE Open Item.

evaluation verifying the existing containment isolation valves, Not started.

15 relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

Provide a description of the strategies for hydrogen control that *Add ISE Open Item.

16 minimizes the potential for hydrogen gas migration and ingress Not started.

into the reactor building or other buildings.

Page 6 of 7

ENCLOSURE Brunswick Steam Electric Plant (BSEP),

Second Six-Month Status Report for the Implementation of Order EA-1 3-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 7 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 3-109, Issuance of Ord/er to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13143A321.

2. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Phase 1 Overall Integrated Plan in Response to June 6, 2013, Commission OrderModifying 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.

3. NRC Letter, Brunswick Steam Electric Plant, Units 1 and2 2- Interim Staff Evaluation Relating to Overall IntegratedPlan in Response to Phase 1 of OrderEA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4467 and MF4468), dated March 10, 2015, ADAMS Accession Number ML15049A266.

Page 7 of 7