CNS-15-080, 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)

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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)
ML15240A066
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/26/2015
From: Henderson K
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-15-080, EA-12-049
Download: ML15240A066 (24)
v • d • e


Text

Kelvin Henderson I~~.DUKE

ENERGY Vice President Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road York, SC 29745 o: 803.701.4251 f: 803.701.3221 10 CFR 50.4 August 26, 2015 CNS-1 5-080 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Renewed License Numbers NPF-35 and NPF-52

Subject:

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-1 2-049)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated March 12, 2012, (ADAMS Accession No. MLI12054A735).
2. NRC Interim Staff Guidance JLD-ISG-201 2-01, Compliance with Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174).
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378).
4. Duke Energy'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 (Order EA-12-049), dated October 29, 2012 (ADAMS Accession No. MLI12307A023).
5. Catawba Nuclear Station Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order EA-1 2-049), dated February 28, 2013.
6. Catawba Fourth Six-Month Report in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order EA-12-049), dated February 26, 2015 (ADAMS Accession No. ML15061A124).

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United States Nuclear Regulatory Commission Page 2 August 26, 2015 Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (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 I required submission of an initial status report 60 days following issuance of the final interim staff guidance (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 (Reference 3) with clarification and exceptions identified in Reference 2. Reference 4 provided the initial status report regarding mitigation strategies at the Oconee, McGuire and Catawba Nuclear Stations. Reference 5 provided the Catawba OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6 provides the fourth six-month status report for Catawba.

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 letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact Cecil Fletcher at (803) 701-3622.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 26, 2015.

Sincerely, Kelvin Henderson Vice President, Catawba Nuclear Station

Enclosure:

Fifth Six-Month Status Report Response (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1 and 2, Docket Nos. 50-413 and 50-41 4, Renewed License Nos. NPF-35 and NPF-52

United States Nuclear Regulatory Commission Page 3 August 26, 2015 XC:

V.M. McCree, Regional Administrator U. S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1 257 D.H. Dorman, Director, Office of Nuclear Reactor Regulation US. Nuclear Regulatory Commission One White Flint North, Mailstop 13-HI6M 11555 Rockville Pike Rockville, MD 20852-2738 Juan Uribe Project Manager, NRR/JLD/JHMB One White Flint North, Mail Stop O-13F10 11555 Rockville Pike Rockville, Maryland 20852-2738 G.E. Miller U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 G.A. Hutto NRC Senior Resident Catawba Nuclear Station Justin Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

ENCLOSURE Page 1 CNS Fifth Sixth Month status Report (Order EA-12-049)

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

CATAWBA NUCLEAR STATION (CNS), UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 RENEWED LICENSE NOS. NPF-35 AND NPF-52

ENCLOSURE Page 2 CNS Fifth Sixth Month Status Report (Order EA-12-049) 1 Introduction Catawba Nuclear Station (CNS) developed an Overall Integrated Plan (Reference 1 in Section 8),

documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference 2 in Section 8). The Overall Integrated Plan (OIP) was submitted to the NRC on February 28, 2013. This enclosure provides an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, that occurred during the period from January 28, 2015 to July 29, 2015 to (hereafter referred to as "the update period").

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

1) Fourth Six-Month Status Report for Catawba Nuclear Station, Units I and 2 was submitted on February 26, 2015.
2) Unit 2 EC Implementation (2EOC20).
3) SAFER National Response Centers Operational.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed from that stated in Attachment 2 of the OIP. The dates are planning dates 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.

Target Revised Milestone Completion Activity Status Completio Date Date Date Not Submit 60 Day Initial Status Report Oct 20.12 Complete Revised Submit Overall Integrated Plan Feb 2013 Complete Raevised First 6 Month Status Update Aug 2013 Complete Date Not Revised Second 6 Month Status Update Feb 2014 Complete Date Not Revised Date Not Third 6 Month Status Update Aug 2014 Complete Revised

ENCLOSURE Page 3 CNS Fifth Sixth Month Status Report (Order EA-12-049)

~Revised Target Activity Target Milestone Completion Status Completion Date Date Date Not Fourth 6 Month Status Update Feb 2015 Complete Revised Develop Engineering Changes (ECs) Jul 2015 Complete Date Revised Develop Strategies Sep 2015 Started Date Revised Purchase Equipment Oct 2015 Started Date Revised Develop Equipment PMs Oct 2015 Started Date Revised Feb 2015 (U2) Dt o Develop Guidelines Started Dt o Oct205 UIRevised Develop Training Sep 2015 Started Date Revised Implement Training Oct 2015 Started Date Revised Staffing 12-01 Phase II Nov 2014 Complete Date Not Revised Communications Integrated Plan May 2015 Complete DaeviNot EC Implementation (On-Line) Oct 2015 Started Date Revised Unit 1 EC Implementation (1 EOC22) Dec 2015 Not StartedReid Date Not Unit 2 EC Implementation (2EOC20) Mar 2015 Complete Date Not Revised Site Implementation Complete Date Not Dec 2015 Not StartedReid SAFER National Response Centers Fb21CopeeDate Not Operational Fb21CopeeRevised

ENCLOSURE Page 4 CNS Fifth Sixth Month Status Report (Order EA-12-049) 4 Changes to Compliance Method The following summarizes the changes to the compliance method or strategies as documented in the Overall Integrated Plan (Reference 1 in Section 8) or previous 6 Month Updates (References 3, 4, 5, and 6 in Section 8). These changes do not impact Catawba Nuclear Stations compliance with NEI 12-06.

1) Chanqe: Some of the Deployment Conceptual Design and Deployment Conceptual Modification sections in the OIP only make reference to the National SAFER Response Center (NSRC) located in Memphis Tennessee. There are actually two NSRCs that can supply Phase 3 resources to Catawba, the NSRC-M for the Memphis location and NSRC-P for the Phoenix location.

Justification: The final approved SAFER Response Plan for Catawba lists both the Memphis and Phoenix NSRC locations as available Phase 3 resources.

Documentation: Reference SAFER Response Plan for Catawba Nuclear Station, Rev. 2 dated 2/1 0/1 5.

2) Changqe: Page 56 of 94 in the OIP states the following: Portable fans that are intrinsically safe (explosion proof) will be placed in vital battery rooms when the batteries are being charged to ensure hydrogen accumulation does not exceed flammability limits. Current air flow from the battery rooms is around 110 cfm and each 8 inch FLEX fan is capable of moving approximately 600 cfm of air. The new strategy will place a single fan in the stairwell doorway on the Unit 2 side of the vital battery rooms and open additional doors/pathways to ensure the temperature and hydrogen concentration in the vital battery rooms and adjacent area remain within acceptable limits.

3)

Justification: An HVAC/Gothic analysis performed by Zachry confirms that the Ventilation strategy described above for the vital battery rooms and adjacent area is viable.

Documentation: Reference CNC-121 1.00-00-0146 Rev. 0 (Gothic Analysis for Extended Loss of All AC Power (ELAP/FLEX).

ENCLOSURE Page 5 CNS Fifth Sixth Month Status Report (Order EA-12-049)

4) Changqe: The PWR Portable Equipment Phase 2 table on Page 64 of 94 in the OlP only lists 2.5", 5", and 6" Fire Hose. The current mitigation strategies also make use of 3" Fire Hose. The table also lists (3) 12 Volt DC Fuel Transfer Pumps which were part of the original equipment purchase but are not credited in any strategies.

.Justification: Use of 3" Fire Hose for many of the mitigation strategies was more economical and manpower friendly than using larger diameter hose. Flow modeling verified that use of 3" Fire Hose was acceptable for the different strategies that use this size hose. A diesel driven fuel transfer pump mounted on a trailer with a 500 gallon tank was chosen as the method to transfer diesel fuel between safety related underground storage tanks and the various pieces of Flex equipment. As such, the 12 Volt DC Fuel Transfer Pumps are no longer required.

Documentation: Reference calculations CNC-1223.02-00-0025 (Flow Model of SNSWP to CA Connections Phase 2 FLEX Strategies), CNC-1223.02-00-0028 (Flow Model for U2 NI Portable Pump Injection to RCS Phase 2 & 3 FLEX Strategies), and the various Flex Support Guidelines (FSGs).

5) Changqe: The sketch of the Portable Pump Location at Ultimate Heat Sink on Page 78 of 94 in the OIP has been revised based on a change in the design.

Justification: The design of the Standby Nuclear Service Water Pond (SNSWP, aka Ultimate Heat Sink) Portable Pump access structure was revised from a sea wall type design to a boat ramp type design. The revised sketch shows the final as built configuration.

Documentation: Reference ECl 10731.

ENCLOSURE Page 6 CNS Fifth Sixth Month Status Report (Order EA-12-049)

6) Chan~qe: Change No. 8 in the Fourth Six Month Update to the OIP stated the following:

Per discussion with CNS and MNS Engineering, Safety Analysis, Westinghouse, and MPR it was determined that a new pressure breakdown orifice will be requiredin each of the Reactor Coolant Pump (RCP) No. 1 seal leak off lines, upstream of the existing flow orifice.

Westinghouse has conservatively provided an assumed worst case pressure of 2045 psia at the No. 1 seal outlet following an Extended Loss of All AC Power (ELAP) event. The new pressure breakdown orifice is needed to prevent damage/degradationto the existing flow orifice because of excessive delta P. Additional piping stress and support analysis will also be performed once the new temperature/pressureprofile is determined to ensure all of the associatedseal leak off line components retain their pressure boundary function.

The actual Engineering Change to resolve this issue did not install a new pressure breakdown orifice. Instead, the existing flow element orifice plate was replaced with one having a thicker profile that could withstand the 2045 psia pressure requirement.

Justification: All of the analyses related to an ELAP assume the leak rate from the RCP No. 1 seal is 21 gpm or less. To ensure this assumption remains valid, a more robust flow element orifice plate is being installed in the RCP No. 1 seal leak off line for each pump.

The thicker orifice plate has been verified via analysis to remain intact and have insignificant deformation under the higher assumed pressure requirement of 2045 psia.

Thermal Hydraulic, piping, and support analyses have also been performed at this higher pressure to verify that components downstream of the RCP No. 1 seal leak off outlet connection do not fail and create the possibility for leak rates greater than 21 gpm.

Documentation: Open Item 96 and ECs 114658 (Unit 2) and 115165 (Unit 1).

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

ENCLOSURE Page 7 CNS Fifth Sixth Month Status Report (Order EA-12-049)

6. Open Items The following tables provide a summary status of the Open Items. The table under Section 6.a.

provides the Open Items identified in Attachment 5 of the original OIP submitted on February 28, 2013 and in the first, second, third, and fourth six month status reports (References 1, 3, 4, 5 and 6 in Section 8). The table under Section 6.b. provides a list of Open Items that were added after January 28, 2015. The table under 6.c. provides a list of Open Items related to the Interim Staff Evaluation (ISE). The table under 6.d. provides a list of Confirmatory Items related to the Interim Staff Evaluation (ISE).

a. Open Items Documented in the Overall Integrated Plan, the First Six Month Status Report, the Second Six Month Status Report, the Third Six Month Status Report, and the Fourth Six Month Status Report.

Item Overall Integrated Plan Open Item Status Disconnect all non-critical loads from vital batteries. Activity to Complete 1 be validated in conjunction with associated procedure changes. See Corrective Action 25 in PIP C-12-2291._______

Provide pumping capacity to control level in TDAFWP pit Complete 2 sump. Additional analysis required to verify adequate pump 2 head exists to overcome potential Turbine Building flooding.

See Corrective Action 26 in PIP C-12-2291._______

Provide pumping capacity to control level in TDAFWP pit Started 3 sump. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 27 in PIP C 2291.

Recharge communication system and satellite phone system. Complete 4 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 28 in PIP C 2291.

Align charging to Channel A and D Vital Batteries. Activity to Started 5 be validated in conjunction with associated procedure changes. See Corrective Action 29 in PIP C-I12-2291.

Align portable injection pump from Refueling Water Storage Complete Tank to Safety Injection System to provide Reactor Coolant System makeup and boration. Approximate time suggested by 6 PWROG to provide negative reactivity addition and maintain margin to criticality. Site specific analysis will need to be performed to establish actual time. See Corrective Action 30 in PIP C-12-2291._______

Align portable injection pump from Refueling Water Storage Started Tank to Safety Injection System to provide Reactor Coolant 7 System makeup and boration. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 31 in PIP C-i12-2291.

Provide portable lighting (beyond head and hand lamps and Started installed battery lighting). Activity to be validated in 8 conjunction with associated procedure changes. See Corrective Action 32 in PIP C-12-2291.

ENCLOSURE Page 8 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status Install portable fans in Control Room and Battery Rooms. Complete Time based on engineering judgment. Analysis will determine the need and timing for ventilation. See Corrective Action 33 in PIP C-I12-2291.

Install portable fans in Control Room and battery rooms. Started 10 Activity to be validated in conjunction with associated 10 procedure changes. See Corrective Action 34 in PIP C ____ ___ 2291.

Connect diesel driven Hale Pump through Essential Service Started Water piping to Spent Fuel Pool skimmer loop to provide a means to make up to the SEP without entering the SEP area.

Activity to be validated in conjunction with associated procedure changes. See Corrective Action 35 in PIP C ____ ___ 2291.

Open Spent Fuel Pool bay doors. Activity to be validated in Started 12 conjunction with associated procedure changes. See Corrective Action 36 in PIP C-I12-2291.

Align diesel driven Hale Pump to supply Essential Service Started 13 Water supply header from UHS. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 37 in PIP C-i12-2291.

Align diesel driven Hale Pump to supply second diesel driven Started 14 Hale Pump to feed SGs. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 38 in PIP C-12-2291.

Re-power H2 igniters. Activity to be validated in conjunction Started 15 with associated procedure changes. See Corrective Action 39

________in PIP C-i12-2291.

Align charging to Channel B and C Vital Batteries. Activity to Started 16 be validated in conjunction with associated procedure changes. See Corrective Action 40 in PIP C-12-2291.

17 Isolate the Cold Leg Accumulators. Activity to be validated in Started conjunction with associated procedure changes. See Corrective Action 41 in PIP C-12-2291.

18 Evaluate need to provide freeze protection for Complete instrumentation located in Doghouses and yard. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is based on engineering judgment. Evaluation will be performed to determine actual action time. See Corrective Action 42 in PIP C-12-2291.

19 Evaluate need to provide freeze protection for Complete instrumentation located in Dog houses and yard. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 43 in PIP C-12-2291.

20 Isolate Instrument Air to Containment. Activity to be validated Started in conjunction with associated procedure changes. See Corrective Action 44 in PIP C-12-2291.

ENCLOSURE Page 9 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 21 Align portable diesel driven Hale Pump to Containment Spray Complete connection. Contingency to be available if required to reduce Containment temperature. Modification of an existing B.5.b Strategy. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 45 in PIP C-I12-2291.

22 Align RRC diesel generator to power installed Containment Complete Spray pumps. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 46 in PIP C-I12-2291.

23 Arrangements with local transportation businesses and Complete Regional Response Centers will need to be established to ensure personnel and equipment can reach the site considering extensive damage to surrounding infrastructure (roads, bridges, etc.). See Corrective Action 47 in PIP C 2291.

24 Additional sump pumps need to be specified, purchased, and Complete placed in critical rooms and floor elevations in the Auxiliary building to mitigate/control internal flooding. See Corrective Action 48 in PIP C-12-2291.

25 Develop adequate procedural and administrative guidance to Started implement mitigation strategies and supporting activities during Phase 1, 2, and 3. See Corrective Action 49 in PIP C-12-2291.

26 Provide SIG Makeup via CA TDP with static RC/RN suction Started supply - Procedural guidelines and ECR 6139 and 6140.

See Corrective Action 7 and 19 in PIP C-I12-2291.

27 A site specific Building Specification will be written that details Complete the storage facility design requirements and ECR 5979 will design and construct the facilities. See Corrective Action 12 in PIP C-12-2291.

28 Add appropriate FLEX equipment to the site Periodic Complete Maintenance (PM) program. See Corrective Action 50 in PIP C-i12-2291.

29 Develop a Document for the FLEX program. See Corrective Complete Action 51 in PIP C-i12-2291.

30 Determine if Engineering Change program documents or Complete checklists need to be revised to include verification that the modification does not impact the FLEX program. See Corrective Action 52 in PIP C-12-2291.

31 Develop applicable training programs to support the FLEX Started strategies and supporting activities. Training will be provided once programs are in place. Corrective Action 53 in PIP C-12-2291 has been closed to the Needs and Evaluation Database (NED). NED 13-02758 has been initiated and assigned for processing.

ENCLOSURE Page 10 ONS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 32 Develop flow model calculations to support the various FLEX Complete strategies and document the available static water volume in

________RN/CA piping. See Corrective Action 20 in PIP C-12-2291.

33 Provide RN supply header hose connections in the yard and Complete in the pumphouse for portable pump to fill/pressurize RN system - ECR 5976 and 5977. See Corrective Action 9 and 10 in PIP C-i12-2291.

34 Provide primary CA piping connections for S/G Makeup via Started portable pump (ECR 5980 and 5981). See Corrective Action 13 and 14 in PIP C-I12-2291.

35 Provide MCC cable plug in connections for various loads Started (ECR 6047 and 6048). See Corrective Action 75 and 76 in PIP C-I12-2291.

36 Provide primary and alternate RCS makeup and injection Started connections (ECR 5983 and 5984). See Corrective Action 15

_______and 16 in PIP C-I12-2291.

37 Purchase high pressure and low pressure RCS injection Complete pumps. See Corrective Action 54 in PIP C-i12-2291.

38 Provide seismically qualified connection on the FD piping to Complete access diesel fuel in safety related underground storage tanks (ECR 5985 and 5988). See Corrective Action 17 and 18 in PIP C-12-2291.

39 Purchase portable diesel fuel transfer pump and storage Complete

________tank. See Corrective Action 55 in PIP C-I12-2291.

40 Provide access road to the SNSWP for the portable diesel Complete pump (ECR 5978). See Corrective Action 11 in PIP C 2291.

41 An analysis is needed to determine whether or not Complete venting/letdown is required when providing borated water injection. See Corrective Action 56 in PIP C-12-2291.

42 An analysis is needed to determine if containment spray for Complete temperature/pressure control is not required over the long term. See Corrective Action 57 in PIP C-i12-2291.

43 Provide redundant SFP Level Instruments per NRC Order - Started EC1 09413 and 109414. See Corrective Action 4 and 5 in PIP C-I12-2205._______

44 Determine lighting requirements via Corrective Action 31 in Complete PIP C-11-6867.

45 Determine lighting requirements and implement as needed Complete via Corrective Action 24 in PIP C-12-2291.

46 Determine long term environmental conditions in the Control Complete Room and CA Pump room via Corrective Action 13 in PIP C-11-6867. This evaluation will be part of Corrective Action 33 in PIP C-i12-2291.

47 Ensure that an appropriate inventory of portable hand-held Complete satellite phones, spare batteries, and chargers, is available for use by the Emergency Response Organization. See

________CorrectiveAction_7_inPIPC-12-2195._______

ENCLOSURE Page 11 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 48 Evaluate and purchase, if necessary, additional portable Complete radios, spare batteries, and chargers to ensure required communications links are fully established. Corrective Action 8 in PIP C-12-2195.

49 Ensure that portable communications equipment (i.e., Complete satellite phones, radios, and diesel generators) are stored in a manner such that maximizes survivability from applicable external events per NEI 12-01, Section 4.5. Corrective Action 9 in PIP C-i12-2195.

50 Ensure that programmatic controls are established for Complete communications equipment (i.e., portable satellite phones, radios, small generators) to ensure availability and reliability, including the performance of periodic inventory checks and operability testing per NEI 12-01, Section 4.8.. Also, provide training on the locations and use of communications systems and equipment (NEI 12-01, Section 4.11). Corrective Action 10 in PIP C-i12-21 95.

51 Ensure that arrangements are in place with communications Complete service providers to utilize their emergency services as described in NEl 12-01, Section 4.10. Corrective Action 12 in PIP C-I12-2195.

Purchase debris removal equipment that is also capable of Complete 52 towing all FLEX equipment. See Corrective Action 58 in PIP C-12-2291.

53 Provide additional portable FLEX equipment such as pumps, Complete air compressors, and generators to be purchased with specific identifiers/labels maintained in the Equipment Data Base (EDB). See Corrective Action 59 in PIP C-i12-2291.

54 Develop periodic surveillance procedures and Operator Complete rounds to verify that all FLEX equipment is in its proper storage location and not degraded. See Corrective Action 60 in PIP C-I12-2291.

55 Develop Regional Response Center Playbook. See Complete Corrective Action 61 in PIP C-12-2291.

56 Complete staffing studies and ensure adequate personnel will Complete be available to support the FLEX mitigation strategies and associated activities. See Corrective Action 7 in PIP C 4953.

57 Develop procedural guidelines to use handheld instruments Started tied into local in plant components to monitor essential parameters. See Corrective Action 62 in PIP C-12-2291.

58 Develop procedural guidelines to disconnect normal power Started supplies and attach alternate power cables from disconnect devices and portable generators for select components. See Corrective Action 63 in PIP C-12-2291._______

59 Develop procedural guidelines to deploy and install lighting in Started required areas. See Corrective Action 24 and 32 in

____ ___ PIP C-i12-2291._______

ENCLOSURE Page 12 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 60 Determine if Phase 3 ventilation needs (RRC equipment, Complete additional procedural guidelines, etc.) are required. See Corrective Action 64 in PIP C-I12-2291.

61 Determine if Mobile Boration will be required from the RRC Complete during Phase 3. See Corrective Action 65 in PIP C-i12-2291.

62 Determine if portable lighting will be required from the RRC Complete during Phase 3. See Corrective Action 66 in PIP C-I12-2291. _______

63 Determine if portable fans/ducting will be required from the Complete RRC during Phase 3. See Corrective Action 67 in PIP C 2291.

64 Determine Phase 3 requirements related to Radiation Complete Protection Equipment. See Corrective Action 68 in PIP C 2291.

65 Determine Phase 3 requirements related to Commodities Complete such as food and water. See Corrective Action 69 in PIP C-12-2291.

Calculate diesel fuel consumption rates for the portable FLEX Complete equipment and compare that to the available fuel stored in 66 the Emergency Diesel Generator safety related underground storage tanks to determine if additional diesel fuel is needed from off-site resources during Phase 3. See Corrective Action 70 in PIP C-I12-2291.

67 Select and purchase Phase 3 debris clearing equipment Complete and/or transport vehicles if needed to move RRC equipment around the site. See Corrective Action 71 in PIP C-12-2291. _______

68 Implement Flood mitigation activities per Corrective Action Started Program (Ref. PIP C-1 2-0833).

69 Complete initial testing of FLEX mitigation equipment prior to Complete full implementation dates. See Corrective Action 72 in PIP C-12-2291.

70 Establish a Special Emphasis Code in the EDB and Work Complete Control program for FLEX equipment. See Corrective Action 73 in PIP C-12-2291.

71 Obtain and store any additional equipment in FLEX Storage Started Facilities or Category I buildings needed to aid in the connection of the RRC equipment to plant components. See Corrective Action 74 in PIP C-I12-2291.

72 Revise RP/0/A/5000/007 (Natural Disaster and Earthquake) Complete to move equipment at the SNSWP if flooding is imminent.

See Corrective Action 79 in PIP C-12-2291.

Formally evaluate/document potential deployment route Complete 73 concerns such as soil liquefaction discussed in NEI 12-06.

See Corrective Action 86 in PIP C-12-2291.

Document seismic qualification (robustness in accordance with Complete 74 NEI 12-06) of assured RN to KF make up piping on Unit 1.

See Corrective Action 87 in PIP C-12-2291.

Add new FWST low/high pressure borated water injection Complete 75 pump suction connection. See Corrective Action 83 and 84 in

_______PIP C-12-2291 (ECR-6787 and ECR-6788)_______

ENCLOSURE Page 13 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item ,Overall Integrated Plan Open Item Status Evaluate travel paths into the Auxiliary Building through non Complete 76 seismic structures. See Corrective Action 88 in PIP C 2291.

An analysis is needed to determine if there are any impacts to Complete FLEX strategies due to large internal flooding sources that are not seismically robust or that require AC power for isolation.

The analysis shall also consider the effects of ground water intrusion during an Extended Loss of All AC Power event. See Corrective Action 89 in PIP C-12-2291.

A Catawba specific shutdown margin calculation performed in Complete 78 accordance with PWROG guidance is required. See

________Corrective Action 90 in PIP C-I12-2291.

Westinghouse assistance is required to provide additional Complete 79 information related to seal leakage on the Catawba Reactor Coolant Pumps. See Corrective Action 91 in PIP C-I12-2291.

The number of Steam Generators and PORVs required for the Complete Low Pressure portable pump makeup FLEX strategy needs to 80 be validated and formally documented in a Catawba station calculation. See Corrective Action 92 in PIP C-12-2291.

Westinghouse assistance is needed to perform thermal Complete 81 hydraulic analyses to support plant specific decision making and provide justification for the duration of each phase. See Corrective Action 93 in PIP C-I12-2291.

Additional analyses is needed to evaluate whether Complete containment penetration seals and other equipment located 82 inside containment and used in the mitigation strategies are still functional based on the predicted temperatures and pressures during a Fukushima type event. See Corrective Action 94 in PIP C-12-2291.

Station controlled documents need to be created to capture Started 83 vendor reports related to generator machine capabilities to power the designated FLEX loads in Phase 2 and 3. See Corrective Action 95 in PIP C-12-2291.

Determine if any changes to WPM 602, NSD 403, or any other Complete site/fleet Shutdown/Refueling documents need to be revised to 84 comply with the position paper related to Shutdown Risk Management and Contingency Planning. See Corrective Action 96 in PIP C-12-2291.

Started Perform a seismic robustness evaluation of the proposed cable 85 "backbone" and it's associated components. See Corrective Action 97 in PIP C-12-2291.

Vendor data and system calculations needed to support FLEX Complete 86 response strategies involving low speed operation of Turbine-86 Driven CA (TDCA) Pumps in support of ELAP EOP setpoint 0.12 development. See Corrective Action 1 in PIP C-13-91 58.

ENCLOSURE Page 14 ONS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status Due to normal operational input to the TDCA pump pit sump Complete and having both TDCA pumps in simultaneous operation, 87 additional portable sump pumps, hoses, and associated equipment are required. See Corrective Action 15 in PIP C-11-6867.

A calculation is needed to support the validation of the Complete Fukushima Phase 3 strategy associated with providing core cooling via the portable pump feeding RN from the SNSWP, powering up one KC pump and one ND pump via the 4160 Volt portable generator from the Regional Response Center.

88 The calculation should determine whether or not adequate core cooling can be achieved with reduced RN flow rates assuming worst case SNSWP upper temperature limits and core decay heat loads when this Phase 3 strategy is put in service. See Corrective Action 98 in PIP C-12-2291.

As documented in Actual Corrective Action #8 in PIP C Complete 2291, EC1 10650 (Install New Fire Hydrant Near The SNSWP 89 For Flex Buildings & B.5.B) is to be cancelled. Complete actions to finalize cancellation of this Engineering See Corrective Action 101 in PIP 0-12-2291.

Ensure that hard copies of Procedures needed to support EP Complete and AP implementation (and any additional supporting 90 procedures identified by FLEX procedures) are accessible during a BDBEE causing an Extended Loss of All AC Power (ELAP greater than 4 hrs.). See Corrective Action 102 and 120 in PIP C-12-2291.

Review DPC-1552.08-00-0278, Appendix C. Determine which Complete operations procedures perform surveillances of the CLAs 91 boron concentrations. Make the necessary revisions using the basis provided by DPC-1552.08-00-0278, Appendix C. See Corrective Action 104 in PIP C-I12-2291.

Review DPC-1552.08-00-0278, Appendix C. Determine which Complete chemistry procedures perform surveillances of the CLAs boron 92 concentrations. Make the necessary revisions using the basis provided by DPC-1552.08-00-0278, Appendix C. See Corrective Action 105 and 121 in PIP C-12-2291.

Portions of the Flex equipment deployment paths will traverse Complete under existing power/transmission lines located on site. As such, guidance needs to be developed and placed in 93 procedures (FSG's) on how to use the deployment path if power/transmission lines and/or towers have fallen across the path. An evaluation on the impact to deployment and mitigation strategy timelines also needs to be documented.

_______See Corrective Action 106 in PIP C-12-2291._______

ENCLOSURE Page 15 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status NRC Audit question #44 asks about containment pressures Complete during an ELAP event. Based on the Rev. 2 draft of DPC-1552.08-00-0280 (Extended Loss of AC Power (ELAP) - Ice Condenser Containment Response with FLEX Mitigation 94 Strategies), containment pressures for Catawba Units I and 2 will exceed design pressures. Justification for operating above containment design pressures during an ELAP event needs to be addressed by engineering. See Corrective Action 119 in PIP C-12-2291.

Section 1 .4 in Attachment 1 of DPC-1 552.08-00-0280 Rev. 2 Complete provides Catawba specific Containment Acceptance Criteria.

Based on results in Rev. 2 of DPC-1552.08-00-0280, the following Acceptance Criteria item could be exceeded for a 95 short period of time: 1.4.2 Recovery to less than 21 2°F in the containment cubicles (i.e., SGs and Pzr) prior to RHR operation is desired, but not necessary. This Corrective Action should justify exceeding this Acceptance Criteria limit. See Corrective Action 122 in PIP C-I12-2291.

A new pressure breakdown orifice will be required in each of Started 96 the Reactor Coolant Pump (RCP) No.1 seal leak off lines upstream of the existing flow orifice (Ref. ECR 8527). See Corrective Action 1 in PIP C-I15-355.

b. Open Items added after January 28, 2015.

Item Overall Integrated Plan Open Item Status A process needs to be in place to monitor S/G deposition to Complete 97 ensure compliance with the Westinghouse Water Quality Analysis. See Corrective Action 123 in PIP C-12-2291.

Designate a SAFER Response Plan SPOC position and Complete 98 update NSD 117. See Corrective Action 125 in PIP C-I12-2291.

Generate additional EDB records for Flex equipment. See Complete Corrective Action 126 in PIP C-I12-2291.

Issue CNM 1203.03-0269.001 (new number assignment for Complete 10 this work) that assembles the operation and maintenance instruction manual for the Hale 3000 FLEX Pumps. See Corrective Action 127 in PIP C-12-2291.

Conduct a validation of the FLEX strategies in accordance with Complete 101 the NEI FLEX Validation Process. See Corrective Action 128 in PIP 0-12-2291.

This action is for the Nuclear Procedures Group to complete Complete 12 various OP procedures for the Unit 2 Fukushima Project to support the Unit 2 Validation and Verification. See Corrective Action 129 in PIP C-i12-2291.

ENCLOSURE Page 16 ONS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status This action is for the Operations Support Group to complete Complete 103 the Fukushima FLEX Procedures. See Corrective Action 130 in PIP C-12-2291.

This Corrective Action is to verify that the SAFER Response Complete Plan for Catawba Nuclear Station is incorporated into an 14 Administrative Procedure with the number CNSRP-1 612.03-

01. See Corrective Action 132 in PIP C-12-2291.

Add a step to the Unit 2 Controlling Procedure for Unit Complete Shutdown stating that "Prior to entering Loops Not Filled, 105 ensure FLEX equipment is pre-staged as required for shutdown conditions." See Corrective Action 130 in PIP C 2291.

Track and document FSGs and other procedures needed for Started 106 the Unit 1 FLEX order implementation. See Corrective Action 136 in PIP C-i12-2291.

OPT LOR supervisor to ensure all licensed operators have Complete 107 received training on specified Lesson Plans. See Corrective Action 140 in PIP C-12-2291.

OPT AO supervisor to ensure all Auxiliary Operators have Complete 108 received training on specified Lesson Plans/FAM. Guides.

See Corrective Action 141 in PIP C-i12-2291.

ILT supervisor to ensure all ILT15 candidates receive training Complete 109 on specified Lesson Plans. See Corrective Action 142 in PIP C-i12-2291.

ILT supervisor to ensure all ILT16 candidates receive training Complete 110 on specified Lesson Plans. See Corrective Action 143 in PIP C-12-2291.

Perform and document the Unit 1 flow modeling calculationsStre 111 associated with the validation of the Fukushima mitigation strategies. See Corrective Action 145 in PIP C-12-2291.

Started Ensure that hard copies of Procedures needed to support Unit 1 EP and AP implementation (and any additional supporting 12 procedures identified by FLEX procedures) are accessible 12 during a BDBE causing an extended loss of all AC power (greater than 4 hrs.). See Corrective Action 146 in PIP C 2291.

Complete This action is for transmitting the Initial Issue of Specification CNS-1465.00-00-0022 Revision 0, Design Basis Specification 13 for the "FLEX Program for NRC Order EA-1 2-049". See Corrective Action 147 in PIP C-12-2291.

ENCLOSURE Page 17 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status Calculation CNC-1223.02-00-0028, Rev. 1, for the NI system Started 14 flow model for FLEX has determined a recommended change to FLEX procedures FSG-08 for U1 and U2. See Corrective Action 150 in PIP 0-12-2291.

Issue CNM 1203.03-0270.001 (new number assignment for Started this work) that assembles the operation and maintenance 115 instruction manual for the Hale Medium Pressure FLEX Pumps (Model: HP300/450DJ-TC). See Corrective Action 151 in PIP C-I12-2291.

Issue CNM 1203.03-0271.001 (new number assignment for Started this work) that assembles the operation and maintenance 116 instruction manual for the Hale High Pressure FLEX Pumps (Model: HP40/1700DJ-TC). See Corrective Action 152 in PIP

________C-12-2291.

c. Interim Staff Evaluation Open Items (Item Number is associated with the section of the Technical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)

Item Interim Staff Evaluation Open Item Status Resolve the conflict between the need to pump the TDAFW Complete (Ref.

3.1 .2.2.A pump pit before submergence at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and deploying NRC SE generators to power the sump pumps by 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See Tracker List)

Corrective Action 107 in PIP 0-12-2291.

Core Sub-Criticality - Confirm resolution of the generic concern associated with the modeling of the timing and uniformity of the Complete (Ref.

3.2.1 .8.A mixing of a liquid boric acid solution injected into the reactor DPC-1552.08-coolant system under natural circulation conditions potentially 0-28 involving two-phase flow. See Corrective Action 108 in PIP C- 0-28 12-2291.

d. Interim Staff Evaluation Confirmatory Items (Item Number is associated with the section of the Technical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)

Item Interim Staff Evaluation Confirmatory Item Status Seismic Deployment (applicable to all hazards deployment) -

since a final location for the building has been selected, formal Complete (Ref.

3112A evaluation of potential deployment routes and concerns such NRC SE 3.1..2.A as soil liquefaction can proceed. Confirm attributes of deployment routes, including liquefaction potential. SeeTrceLit Corrective Action 109 in PIP C-12-2291.

Procedural Interfaces- Seismic- Confirm completion of evaluation of potential internal Aux Building flooding and 3.1.1 .3.A appropriate actions and procurement of sump pumps. See Open Corrective Action 110 in PIP C-12-2291.

ENCLOSURE Page 18 CNS Fifth Sixth Month Status Report (Order EA-12-049)

Item Interim Staff Evaluation Confirmatory Item Status Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. This includes specifying an Complete (Ref.

3.2.1.1.A acceptable definition for reflux condensation cooling. Confirm NRC SE that the NOTRUMP code is used within the accepted limits. Tracker List)

See Corrective Action 111 in PIP C-I12-2291.

Westinghouse will be assisting CNS in providing further 3.2.1.3.A information regarding decay heat modeling. Evaluate for Complete (Ref.

applicability and implementation. See Corrective Action 112 in NCS PIP C-I12-2291. Tracker List)

Licensee will confirm that the final containment analysis validates that containment spray for temperature/pressure Complete (Ref.

3.2.3.A. control is not required over the long term, or will provide NRC SE procedures to cool the containment. See Corrective Action Tracker List) 113 in PIP C-12-2291.

Room temperature analyses being performed will provide a 3..41 A better idea of the environmental conditions expected during the Open 3.2.41 .A event. Confirm completion of analyses and appropriate actions. See Corrective Action 114 in PIP C-I12-2291.

Evaluations to address the needs for freeze protection are in 3.2.4.3.A progress. Confirm completion of evaluations and appropriate Open actions. See Corrective Action 115 in PIP C-I12-2291.

Confirm evaluations for additional lighting have been 3.2.4.4.A completed (licensee's open item 45 and 59), and appropriate Oe 3.2.4.4.B Confirm upgrades to the site's communication systems have NComlt (REf Offsite Resources- Confirm NEI 12-06 Section 12.2, Guidelines 3.4.A 2 through 10, are addressed with SAFER. See Corrective Open

________Action_118_inPIPC-12-2291._______

7 Potential 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 Overall Integrated Plan described in this attachment.

1) Catawba Nuclear Station, Unit Nos. 1 and 2, 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.

ENCLOSU RE Page 19 CNS Fifth Sixth Month Status Report (Order EA-12-049)

2) NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2013.
3) First Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1 and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.
4) Second Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units I and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.
5) Third Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1 and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.
6) Fourth Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1 and 2, Docket Nos. 50-413 and 50-41 4, Renewed License Nos. NPF-35 and NPF-52.
7) 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, dated August 29, 2012, 2012 (ADAMS Accession No. ML12229A174).
8) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX). Implementation Guide, Revision 0, dated August 2012
9) Duke Energy'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 (Order EA-1 2-049), dated October 29, 2012, (ADAMS Accession No. ML12307A023).
10) Catawba Nuclear Station, Units 1 and 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (Tac Nos. Mf1 162 and MfI1163), Dated February 6, 2014 (ADAMS Accession No. MLI13364A1 73).

11 ) 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 No. ML13267A382).

ENCLOSURE Page 20 CNS Fifth Sixth Month Status Report (Order EA-12-049)

12) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, Program Management Office Westinghouse Electric Company LLC, October 7, 2013, (ADAMS Accession No. ML13276A555).
13) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, Program Management Office Westinghouse Electric Company LLC, dated January 8, 2014, (ADAMS Accession No. ML13276A183).
14) 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 No. ML13275A318).
15) 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 16, 2013, (ADAMS Accession Nos.: (Pkg.)

ML13241A182, (NEI) ML13241A186, (Rsp.) ML13241A188).

16) 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 No.: ML13276A224).

ENCLOSURE Page 21 CNS Fifth Sixth Month Status Report (Order EA-1 2-049)

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