BSEP 15-0063, Fifth 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)

Fifth 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)

ML15246A034
Person / Time
Site:	Brunswick
Issue date:	08/26/2015
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 15-0063, EA-12-049
Download: ML15246A034 (12)

Text

@ KEN RY DUKEwilliam R. ,ideon.

Vice President Brunswick Nuclear Plant Southport, NC 28461 o: 910.457.3698 August 26, 2015 Serial: BSEP 15-0063 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 Fifth 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-Basis External 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, Order Modifying 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. Duke Energy Letter, Carolina Power & 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-Basis External Events (Order Number EA-12-049), dated October 29, 2012, ADAMS Accession Number ML12307A021

5. Duke Energy Letter, Overali IntegratedPlan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),

dated February 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 Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),

dated August 20, 2013, ADAMS Accession Number ML13248A447

U.S. Nuclear Regulatory Commission Page 2 of 4

7. Duke Energy Letter, Second Six-Month Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2014, ADAMS Accession Number ML14073A451

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

dated August 28, 2014, ADAMS Accession Number ML14254A176 9.. Duke Energy Letter, Fourth Six-Month Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2015, ADAMS Accession Number ML15084A156

10. Duke Energy Letter, Notification of Full Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA- 12-05 1, "Orderto Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation"for BSEP, Unft 2, dated June 3, 2015, ADAMS Accession Number ML15173A013 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (i.e.,

Reference 1) to Duke Energy Progress, Inc. (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 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 initial status report regarding mitigation strategies at the Brunswick, Robinson, and Shearon Harris Nuclear Power Plants. Reference 5 provided the OIP for the 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.

References 6, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports respectively, for BSEP.

The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, 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 status report also includes an update to milestone accomplishments that confirms full compliance with Order EA-12-049, for BSEP, Unit 2 (i.e., Reference 10).

This letter contains no new regulatory commitments.

U.S. Nuclear Regulatory Commission Page 3 of 4 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 August 26, 2015.

Sincerely, -

William R. Gideon

Enclosure:

Fifth 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), Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2

U.S. Nuclear Regulatory Commission Page 4 of 4 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 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWEN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWEN 883) (Electronic Copy Only) 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 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

ENCLOSURE FIFTH 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)

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 Page 1 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 1 Introduction Note: References are provided in Section 7 of this enclosure.

Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)

(Reference 1) 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 (Reference 2). The second six-month update was submitted to the NRC on February 28, 2014 (Reference 3). The third six-month update was submitted to the NRC on August 28, 2014 (Reference 4). The fourth six-month update was submitted to the NRC on February 27, 2015 (Reference 5). 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 January 28, 2015, and July 28, 2015, hereafter referred to as the "update period."This status report also includes an update to milestone accomplishments that confirms full compliance with Order EA-12-049, for BSEP, Unit 2 (Reference 6).

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

, Develop Strategies/Contract with Regional Response Center (RRC)

• SAT Process for Training (Unit 1)

• Develop Training Plan (Unit 1)

• Procure Equipment (Unit 2)

• Create Maintenance Procedures (Unit 2)

• Procedure changes incorporating response strategies (Unit 2)

• Implement Training (Unit 2)

• Submit Six-Month Status Report (i.e., Fourth Six-Month Status Report)

• Unit 2 Implementation Outage

• Implement Modifications (Unit 2)

• Submit Completion Report (Unit 2) (i.e., BSEP, Unit 2, full compliance with Order EA-12-049) 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.

Page 2 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

• Indicates a change since last 6 month update.

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 1/91 opeeDt o eie of NEI 12-01 Submit 6 Month*Status Report 2/28/14 Complete Date Not Revised Develop Unit 2 Modification 3/30/15 Unit 2 Engineering Change (EC) 3/71 opee Modifications will be Packages, including Storage 3/71 opee completed and ready to Facility exit RFO B222R1 Perform station-specific analysis following generic BWROG FLEX 33/4Cmlt /11 implementation analysis review (Open Item 19)

Develop Strategies/Contract with *February *Cmlt*DeRvid Regional Response Center (RRC) 2015*Cmlt*DeRvid Submit 6 Month Status Report 8/29/14 Complete Date Not Revised SAT Process for Training (Unit 2) 01/27/14 Complete 10/31/14 SAT Process for Training (Unit 1) 1/26/15 *Complete 06/25/2015d t 10/31/14 Unit 2 Training Plan Deveop lan Unirainng

2) 7/2/14 ompete continues to be revised Deveop lan Unirainng

2) 7/2/14 ompete due to large amount of Operator training in 2014.

Develop Training Plan (Unit 1) 07/26/15 *Complete Date Not Revised 02/26/2015 Procure Equipment (Unit 2) 11/27/14 *Complete Permanent Storage Building not available Page 3 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

"; "' :",,Milestoneo ' Completion Activity Status L* Rev ised**;. =

__________,__,__....._______ Date Completion Date

• • Indicates a change since last 6 month update.

until Middle of January

___2015 ___ ____

Procure Equipment (Unit 1) 11/26/15 Started Date Not Revised Create Maintenance Procedures 012/5* mlee31/05 (Unit 2)012/5Copee0//05 CraeManeanePocdrs 01/26/16 *Started Date Not Revised (Unit 1)

Procedure Changes incorporating 012/5*opee0/521 response strategies (Unit 2)012/5Copee31/05 Procedure Changes incorporating 01/26/16 *Started Date Not Revised response strategies (Unit 1)

Implement Training (Unit 2) 02/27/15 *Complete Date Not Revised Submit 6 Month Status Report 2/27/15 Complete Date Not Revised Outage Start Date Unit 2 Implementation Outage March 2015 *Complete .moved up to.

February 2015 Implement Modifications (Unit 2) April 2015 *Complete Date Not Revised Submit Completion Report (Unit 2) April 2015 *Complete Date Not Revised Develop Unit 1 Modification EC

• 161 tre Dt eie Packages___________________

Submit 6 Month Status Report 8/31/15 *Started Date Not Revised Implement Training (Unit 1) 02/26/16 *Started Date Not Revised Submit 6 Month Status Report 2/29/16 Not Started Date Not Revised

• Outage Start Date Unit 1 Implementation Outage *February Not Started moved up to 2016 February 2016 Implement Modifications (Unit 1) April 2016 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 Page 4 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 4 Changes to Compliance Method The following summarizes changes that were made during the fifth update period to the strategies as documented in the OIP (Reference 1 of this enclosure) or to the changes that were provided by Reference 2, 3, 4, and 5 of this enclosure. These changes do not impact BSEP's compliance with NEI 12-06.

There are no changes to the compliance method during this fifth update period.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There are no changes to the need for relief/relaxation during this fifth update period.

6 Open Items Generic Concerns None Plan Open Items Tables 6a and 6b provide a summary status of the Open Items. Table 6a provides the open items that were previously identified in the original OIP submitted on February 28, 2013, and in the first, second, third and fourth six-month status report submitted in Reference 2, 3, 4, and 5 of this enclosure. Table 6b provides a list of open items that were added after January 28, 2015.

Table 6a. Open Items Documented in the Overall Integrated Plan

' "!*,i*.*: Overall ve Intetgatd rated, Plan 0 en Item Statusii:i~~i*il:;;

s~ausi~i*!.,,,,*ii*** ::**,,

• Indicates a change since last 6 month update.

1. Perform a formal validation of FLEX deployment, *Completed connection, and action timelines after the procedural guidance is developed and related staffing study is completed.

2. Implement programmatic controls. *Completed

3. Develop plant equipment control guidelines, in *Completed accordance with NEI 12-06 Section 11.5, to manage the unavailability of equipment and applicable connections that directly perform a FLEX mitigation strategy.

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

5. Maintain FLEX strategies in overall FLEX basis *Completed documents.

Page 5 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

, Overall Integrated Plan 0pen Item I .... Status,:,

• Indicates a change since last 6 month update.

6. Modify existing plant configuration control procedures *Completed 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 *Completed (Unit 2) implementation of FLEX. *Started (Unit 1)

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

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

10. Design FLEX equipment connection points (e.g. Complete mechanical, pneumatic, and electrical) to withstand the applicable external hazards.

11. Perform study to validate Suppression Pool Complete temperatures exceeding 220°F.

12. Develop site specific procedures or guidelines, *Completed (Unit 2) utilizing the industry developed guidance from the *Started (Unit 1)

Owners' Groups, EPRI, and NEI Task team, to address the criteria in NEI 12-06.

13. Deleted Deleted

14. Complete SFP level instrumentation modifications per *Completed (Unit 2)

NRC Order EA 12-051, Issuance of Order to Modify *Started (Unit 1)

Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

15. Develop deep load-shedding procedures to extend Delete coping time for station batteries. 2nd 6-month update change #7.

Deep load shedding procedures are not required. Load shedding activities are contained in SBO-1 0.

16. Modify procedures such that operator manual actions, *Completed (Unit 2) in areas where habitability is a concern, occur early in *Started (Unit 1) the FLEX timeline, to the extent practical.

17. Revise procedures to open Reactor Building doors to *Completed (Unit 2) provide a natural air circulation path. *Sare (Unit 1)

18. Provide transportation equipment to move large *Completed skids/trailer-mounted equipment provided from off-site.

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

20. Develop a process/methodology to rupture the *Completed (Unit 2)

Wetwell Vent Disc with Containment pressure below *Sare (Unit 1) 55 psi.

21. Develop a process/methodology to provide Clean *Completed (Unit 2)

Water Makeup to the CST during Phase 3 response. *Started (Unit 1)

Page 6 of 8

uEoate.0 NUmBERh FIFTSI-MOndctH SaTU REPORTe(ORDERas Overall Integrated Plan Open Item

• I,- Status *.

Overall Integrated

• lndjcates Plana Open chanqeItem since last 6 month update. Status

22. Develop guidance for obtaining local vital indications *Completed (Unit 2) during a loss of DC in conjunction with an ELAP. This *Started (Unit 1) strategy will be available for appropriate plant personnel use in response to these failures.

23. Provide justification showing the Unit 1 CST & Unit 2 *Completed CST are robust from applicable external hazards.

24. Develop a DC power coping analysis lAW IEEE-485 *Completed and establish an appropriate coping time for FLEX response.

Table 6b. Open Items added after January 28, 2015 S.... ,OverallIntegrated Plan Open Item ... ... I.. ... *,, ,Status  :

No new open items durnn this fifth update period.

Page 7 of 8

FIFTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 7 References The following references support updates to the Overall Integrated Plan as described in this enclosure.

1. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated February 28, 2013, Agencywide Documents Access and Management System (ADAMS)

Accession Number ML13071A559

2. Duke Energy Letter, FirstSix-Month Status Report in Response to March 12, 2012, Commission OrderModifying 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. Duke Energy Letter, Second Six-Month Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA- 12-049), dated February 28, 2014, 'ADAMS Accession Number ML14073A451

4. Duke Energy Letter, Third Six-Month Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies

• for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated August 28, 2014, ADAMS Accession Number ML14254A176

5. Duke Energy Letter, Fourth 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 February 27, 2015, ADAMS Accession Number ML15084A156

6. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and OrderEA- 12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation"for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013

7. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML12054A735

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

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

10. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation'sInitial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012, ADAMS Accession Number ML12307A021 Page 8 of 8