HNP-15-006, 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 (Order Number EA-12-049)

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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 (Order Number EA-12-049)
ML15055A101
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 02/23/2015
From: Waldrep B
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, HNP-15-006
Download: ML15055A101 (22)
v • d • e


Text

Benjamin C. Waldrep Vice President Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2000 February 23, 2015 Serial: HNP-15-006 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Progress, Inc., (Duke Energy)

Shearon Harris Nuclear Power Plant (HNP), Unit 1 Docket No. 50-400 Renewed License Number NPF-63

Subject:

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 (Order Number EA-12-049)

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, (Agency-wide Documents Access and Management System (ADAMS) Accession No. 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 No. ML12229A174)
3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

4. Duke Energy Letter, Carolina Power and Light Company and Florida Power Corporations 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 Number EA-12-049), dated October 29, 2012, (ADAMS Accession No. ML12307A021)
5. 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, (ADAMS Accession No. ML13112A020)
6. Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013, (ADAMS Accession No. ML13239A359)
7. Duke Energy Letter, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014, (ADAMS Accession No. ML14072A051)

U.S. Nuclear Regulatory Commission Serial HNP-15-006 Page2

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 25, 2014, (ADAMS Accession No.ML14241A115)

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

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the Duke Energy initial status report regarding mitigation strategies. Reference 5 provided the Duke Energy overall integrated plan for HNP.

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, 7, and 8 provided the first, second, and third six-month status reports, respectively for Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed 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 Mr. David H. Corlett, Regulatory Affairs Manager, at 919-362-3137.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 23, 2015.

Sincerely,

U.S. Nuclear Regulatory Commission Serial HNP-15-006 Page 3

Enclosure:

Fourth Six-Month Status Report (Order EA-12-049) Shearon Harris Nuclear Power Plant, Unit 1, Docket No. 50-400, Renewed License Number NPF-63 cc: Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Ms. M. Barillas, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II Mr. S. R. Monarque, NRC Japan Lessons-Learned Project Manager, HNP

U.S. Nuclear Regulatory Commission Serial HNP-15-006, Enclosure SERIAL HNP-15-006 ENCLOSURE FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049)

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63

U.S. Nuclear Regulatory Commission Page 1 of 18 Serial HNP-15-006 Enclosure 1 Introduction Duke Energy Progress, Inc., (Duke Energy) developed an Overall Integrated Plan (OIP)

(Reference 1), for the Shearon Harris Nuclear Power Plant (HNP), Unit 1, documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference 3). The Overall Integrated Plan was submitted to the NRC on February 28, 2013. The first six-month update was provided to the NRC on August 28, 2013 (Reference 2). The second six-month update was provided to the NRC on February 28, 2014 (Reference 17). The third six-month update was provided to the NRC on August 25, 2014 (Reference 19). 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 July 28, 2014, to January 29, 2015 (hereafter referred to as the update period).

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

1) Submit Third Six-Month Update
2) Develop Modifications
3) Conduct Staffing Analysis
4) Install Offsite Delivery Pad 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. 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.

Revised Target Completion Activity Target Milestone Date Status Completion Date Date Not Submit Integrated Plan February 28, 2013 Complete Revised Date Not 6-Month Status Update August 28, 2013 Complete Revised Date Not Conduct N-1 Outage Walkdowns November 2013 Complete Revised Date Not Identify Significant Material/Equipment February 2014 Complete Revised Date Not 6-Month Status Update February 28, 2014 Complete Revised

U.S. Nuclear Regulatory Commission Page 2 of 18 Serial HNP-15-006 Enclosure Revised Target Completion Activity Target Milestone Date Status Completion Date Develop Strategies / Playbook with March 2015 Started April 2015 Regional Response Center (RRC)

Develop Training Program September 2014 Started April 2015 Date Not 6-Month Status Update August 28, 2014 Complete Revised Date Not Develop Modifications October 2014 Complete Revised Conduct Implementation Walkdowns December 2014 Started April 2015 Material / Equipment Procurement /

December 2014 Started April 2015 Delivery Date Not Conduct Staffing Analysis November 2014 Complete Revised Implement Training May 2015 Started April 2015 Date Not Install Offsite Delivery Pad February 2015 Complete Revised Date Not 6-Month Status Update February 28, 2015 Started Revised Develop FLEX Strategy Guidelines Date Not March 2015 Started (FSGs) Revised Date Not Develop Maintenance Procedures March 2015 Started Revised Date Not Implement Modifications May 2015 Started Revised Date Not Implementation Complete May 2015 Not Started Revised 4 Changes to Compliance Method The following summarizes the changes to the compliance method as documented in the Overall Integrated Plan (Reference 1) since the last six-month update period (numbering sequence is a continuation of the last six-month update).

8) Change: The FLEX Diesel Generators are pre-staged in the HNP Unit 2B Diesel Bay.

During the onsite audit in December 2014, the NRC concluded that pre-staging of the FLEX Diesel Generators is an alternative approach to NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0 (Reference 5), which describes the use of portable equipment.

Justification: HNP agrees with the NRCs position that use of pre-staged FLEX Diesel Generators constitutes an alternative to NEI 12-06, Revision 0. The use of pre-staged FLEX Diesel Generators allows re-energizing critical plant electrical loads more quickly

U.S. Nuclear Regulatory Commission Page 3 of 18 Serial HNP-15-006 Enclosure and efficiently than the use of portable generators that would have to be transferred from the FLEX storage building.

The FLEX Diesel Generators are stored in a Category 1, safety-related structure designed to adequately withstand all external events with multiple access paths that will remain clear after the initiating event. The FLEX Diesel Generators have been pre-staged to provide a significant reduction in the amount of large portable equipment required to be transported and setup, in the first hours following a beyond-design-basis external event. Pre-staging provides a level of efficiency that ensures the timeline for implementation of the HNP FLEX electrical support configuration. The strategy also minimizes risk by utilizing robust equipment that is located within a Category 1, safety-related structure that is adequately protected from all external events. The opportunity to improve response times, simplify required manual actions, and to utilize robust equipment in robust locations justifies the consideration of this strategy.

Documentation: A detailed justification for the consideration of this strategy will be provided in a position paper and posted on the HNP Fukushima Response ePortal prior to implementation.

9) Change: HNP has two FLEX Buildings. The first building is the HNP Unit 2 Emergency Diesel Generator Building that is a Category 1, safety-related structure designed to provide protection from the applicable site-specific severe external events. The second building is a commercial metal building constructed to North Carolina building codes. All N and N+1 equipment that directly performs a FLEX mitigating function is stored in the HNP Unit 2 Emergency Diesel Generator Building with one exception. The spare (N+1)

Emergency Service Water (ESW) pump is stored in the commercial metal building.

During the onsite audit in December 2014, the NRC concluded that the use of the commercial building is an alternative to NEI 12-06, Revision 0, which describes the storage of FLEX equipment.

Justification: HNP agrees with the NRCs position that the FLEX ESW pump (N+1 equipment) stored in the commercial metal building, in conjunction with equipment stored in the Seismic Category 1 storage building (N), constitutes an alternative to NEI 12-06, Revision 0, which describes the storage of FLEX equipment.

Documentation: A description of this strategy and the equipment out of service/unavailability limits will be provided in a paper and posted on the HNP Fukushima Response ePortal prior to implementation.

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

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 Reference 1 submitted on February 28, 2013. The table under Section 6.b. provides a list of open items that were added after July 28, 2014. The table under 6.c. provides a list of open items related to the Interim Staff Evaluation (ISE).

U.S. Nuclear Regulatory Commission Page 4 of 18 Serial HNP-15-006 Enclosure

a. Open Items Documented in the Overall Integrated Plan.

Overall Integrated Plan Open Item Status 1 Analysis to determine expected duration of TDAFW pump Complete operation under ELAP conditions 2 Staging analysis timeline of FLEX feedwater pump and plant Complete specific pump analysis at chosen FLEX injection points and water sources specifically for HNP 3 Determine highest rate of RCS cooldown with only one SG Complete PORV 4 Determine if B.5.b connections 1AF-173/174/175 are Complete adequately sized to meet SG feedwater requirements from decay heat (not credited) 5 Determine how much time the CST can be relied upon for Complete 6 Projected Inventory usage for RCS and SGs Started 7 Determine the amount of SG inventory needed for the first 72 Complete hours per cooldown strategy in PA-PSC-0965 8 Determine any adverse effects from using borated water from Complete RWST in Steam Generators 9 Determine HNP specific FLEX FW pump capacity Complete requirements (discharge pressure and flow) 10 A FLEX/ELAP staffing analysis needs to be performed for all Complete coping Strategies (Reference 20) 11 Calculation needed to determine the cooling flow Started requirements beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in SAMG-CA-002 in Mode 5 and 6 12 RCS boron concentration and boration in gallons to maintain Started inventory control and core cooling in regards to keeping the core subcritical with RCS cooldown strategy in PA-PSC-0965 Att. 3 13 RWST is partially exposed to tornado missiles and analysis Complete will need to be done to determine the volume that can be credited (Reference 12) 14 Analysis to determine HNP specific high pressure make up Complete pump minimum performance rating necessary to support FLEX coping strategies 15 Analysis to determine if the ASI pump can meet the HNP Canceled minimum high pressure makeup requirements Analysis to determine HNP specific Modes 5 and 6 FLEX Started pump capacity requirements for RCS low pressure Injection 16 Analysis needed to confirm RCS Depressurization via Started Reactor Vessel Head Vents will be effective 17 Analysis of BAT and RWST during ELAP without heat tracing Complete during cold weather conditions 18 Determine if RCS venting is needed Started 19 Analysis to determine minimum pump performance rating to Complete support ESW delivery to all FLEX usage point simultaneously and prevent pump run-out

U.S. Nuclear Regulatory Commission Page 5 of 18 Serial HNP-15-006 Enclosure Overall Integrated Plan Open Item Status 20 Analysis to determine HVAC requirements for operating Complete installed and temporary equipment under ELAP conditions for maintaining reliable Operation 21 Habitability analysis needed for local manual control of SG Complete PORVs in the Steam Tunnel under ELAP conditions 22 Habitability analysis for local manual control of TDAFW pump Complete at RAB 236 Elevation 23 Analysis needed for loss of HVAC on TDAFW equipment Complete 24 Calculation to determine power consumption assuming all Complete HVAC is provided by portable blower units to support selection of FLEX generator size 25 Analysis to determine total fuel consumption rates of all FLEX Complete equipment 26 Calculation to determine pounds of boron versus RWST tank Complete level percent to achieve desired boron concentration 27 Detailed analysis of consequences from performing a DC Started deep load shed. Specifically to determine what equipment is still needed to carry-out FSG coping functions. Instrument loops and etc.

28 Detailed calculation needed to validate the coping time that Started will be added to Station Batteries to provide needed margin to the plants installed equipments coping time 29 Analysis of the effects of AUX Reservoir water being used for Complete heat removal 30 Analysis of FLEX pump suction strainer sizes to any Complete downstream FLEX flow path clearances 31 Containment Pressure & Temperature Analysis at extended Started time periods (is containment spray needed as a coping action?)

32 Hydrogen production & removal in Battery Rooms Complete 33 Seismic analysis of lighting fixtures and analysis of lighting Started needs in the plant during ELAP 34 Analysis needed to determine portable power and pump Started needs for selected FLEX strategies 35 Analysis to determine expected length of time for FLEX Started equipment to operate under extended ELAP conditions based on operation condition 36 Analysis to provide delivery path to equipment from Fuel Oil Complete Storage Tanks and FLEX Storage Facility 37 Determine impact of internal plant flooding events Complete 38 Boil off analysis of Spent Fuel Pool during full core offload Complete immediately following a full core offload, determine length of coping time without any make-up to SFP immediately following full core offload 39 Analysis to determine any radiological affects to the public by Started using contaminated water sources for feedwater use to the Steam Generators

U.S. Nuclear Regulatory Commission Page 6 of 18 Serial HNP-15-006 Enclosure Overall Integrated Plan Open Item Status 40 Modification - Harden/Protect Dedicated Shutdown Diesel Canceled Generator to provide power to MCC 1D23 41 Modification - Seismically upgrade the Alternate Seal Canceled Injection System to serve as one coping strategy to provide High Pressure RCS injection 42 Modification - Add an Alternate Seal Injection pump Canceled discharge path to the CVCS charging header. Add an alternate suction path to the Alternate Seal Injection pump from the RWST and BAT. Provides alternate injection paths to the RCS while also providing a larger inventory source 43 Modification - Protect and seismically upgrade MCC 1D23 Canceled and all connections/distribution. Provides power to Safety-related Battery Chargers and the Alternate Seal Injection System 44 Modification - FLEX Generator(s) electrical connections at: Started

  • Primary & Alternate 480 VAC distribution/ control for FLEX pumps, FLEX outlets for lighting, ventilation, etc 45 Modification - Modify control power circuits for A & B SG Design-Started PORVs to be powered from Instrument Buses SI, SII, or SIV. Implementation-Started Modification provides the ability to control steaming/RCS cooldown 46 Modification - Add FLEX pump suction and discharge Design-Started connection points to the AFW system upstream of Motor Driven AFW flow control valves. Modification will provide Implementation-AFW flow control and the ability to provide inventory to the Started Steam Generators from portable pumps 47 Modification - Modify MDAFW FCVs control power circuit. Design-Started Install key switch jumper in to simulate a Motor Driven Auxiliary Feedwater pump breaker closed. ARP 19A (SA) R2 Implementation-terminal 119 & 120. Provides 125 V DC power to Started ARP19A(SA) and instrument bus SI for the purpose of operators controlling feedwater flow to the Steam Generators from the MCB 48 Modification - Add FLEX RCS suction and discharge Design-Started connection points to CVCS on A & B train. Provides the Implementation-capability to inject inventory (borated) from a FLEX pump to Started the RCS from the BAT or RWST 49 Modification - Add FLEX pump discharge connection points Design-Started to the Emergency Service Water system. Provides a pressurized water source to CST, RAB & FHB Fire Protection Implementation-SSE hose station headers, and Spent Fuel Pools Started

U.S. Nuclear Regulatory Commission Page 7 of 18 Serial HNP-15-006 Enclosure Overall Integrated Plan Open Item Status 50 Modification - Add quick connect connection point at 4 inch Design-Complete flanges downstream of valves 2DFO-262 and 2 DFO-280.

Allows connection of a FLEX pump to transfer fuel oil from Implementation-the Fuel Oil Storage Tanks to support fuel delivery to Started operating FLEX equipment 51 Modification - Install enhanced Spent Fuel Pool level Started indication. Refer to NTTF 7.1 52 Modification - Verify seismic qualification or seismically Design-Started upgrade piping bounded by valves 1CT-23, 1SF-10, 2SF-10, and 1SF-193. Allows HNP to credit Spent Fuel Make-up from the RWST via the installed Fuel Pool Cooling Pumps which Implementation-are being powered from a FLEX generator. Also allows HNP Not Started to credit ESW Emergency Makeup to Spent Fuel Pools 53 Modification - Add quick connects at tank locations to support Design-Started transfer of water using a FLEX transfer pump. This allows filling of the Refuel Water Storage Tank from the Reactor Make-up Water Storage Tank, and CST from the Condenser Implementation-Hotwell, Demineralized Water Storage Tank, Filtered Water Started Storage Tank, and Refuel Water Storage Tank 54 Modification - Add FLEX connection points to the Canceled Containment Spray System. Abates high pressure/high temperature conditions inside containment 55 Modification -Add temporary power cables and connection Started points at select MOV MCC breaker/control cubicles. Provides the ability to perform a one-time stroke of valves that are needed to be repositioned in an ELAP event 56 Modification - Structure(s) built to house and protect FLEX Started generators and equipment 57 Modification - Install FLEX distribution network to power Started FLEX equipment (pumps, ventilation, lighting, power outlets, and temporary power to MOVs) 58 Modification - Upgrade the installed in-plant emergency DC Canceled lighting packs with Light Emitting Diode bulbs. This will significantly extend the operating time of the lights installed in the plant 59 Modification - Seismically qualify/upgrade the Condenser Canceled Hotwell Transfer Suction Piping and add isolation valve. This will significantly increase the credited volume of the Condensate Storage Tank 60 Develop a procedure to take local reading in containment Complete electrical penetration, PIC, or RVLIS for all required readings 61 Contract for offsite fuel delivery Complete 62 Contract for Demineralized Water Processing Skid or tanker Complete delivery 63 Perform an analysis to determine the amount of volume for Complete the RMWST that can be credited

U.S. Nuclear Regulatory Commission Page 8 of 18 Serial HNP-15-006 Enclosure Overall Integrated Plan Open Item Status 64 Evaluate to determine that a modification can be Complete implemented with reasonable assurance of success to seismically upgrade the condensate transfer pump suction line penetration to the CST and estimated total CST inventory we can credit. In the current configuration 238K gallons is credited as available and protected (Tank-0020) 65 Evaluate to determine that a modification can be Complete implemented with reasonable assurance of success considering economic feasibility to harden (seismic, flood &

missile protect) the DSDG, MCC 1D23, ASI Pump, ASI Tank, associated system piping and all electric connections/distribution and instrumentation 66 FLEX 4.2 Programmatic Controls - Implement programmatic Started controls for review, revision and/or generation of procedures and guidelines as required to address additional programmatic controls as a result of FLEX requirements 67 FLEX 4.2 Programmatic Controls - Implement programs and Started processes to assure personnel proficiency in the mitigation of beyond-design-basis external events in accordance with NEI 12-06 68 FLEX 4.2 Programmatic Controls - Establish FLEX Started Strategies and basis in an overall FLEX Basis Document 69 FLEX 4.2 Programmatic Controls - Modify existing plant Started configuration control procedures to ensure that changes to the plant design, physical layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX Strategies IAW NEI 12-06, Section 11.8 70 FLEX 4.2 Programmatic Controls - Training will be initiated Started through the Systems Approach to Training (SAT) Process.

Training will be developed and provided to all involved plant personnel based on any procedural changes or new procedures developed to address and identify FLEX activities. Applicable training will be completed prior to the implementation of FLEX 71 External Hazards for Structures - Structures to provide Started protection of the FLEX equipment will be constructed to meet the requirements identified in NEI 12-06, Section 11. The structures will be built prior to the FLEX implementation Date 72 External Hazards for Structures - Develop Procedures and Started Programs to address storage structure requirements, deployment path requirements, and FLEX equipment requirements relative to the External Hazards applicable to HNP 73 Purchase sufficient amounts of portable equipment to fulfill Started selected FLEX strategies 74 Initiate PMs and develop testing procedures to support FSG Started guidelines for FLEX equipment 75 Develop RRC playbook Started

U.S. Nuclear Regulatory Commission Page 9 of 18 Serial HNP-15-006 Enclosure Overall Integrated Plan Open Item Status 76 Determine RRC portable equipment requirements (water, Complete boron, etc.)

77 Determine Phase 3 equipment/commodities requirements Complete (food, fuel, etc.)

78 Convert to high capacity SAT phone batteries Complete 79 Modification - Modify SG PORV hydraulic pump motor MCC Started cubicles to provide for quick connection of a temporary FLEX power source 80 Update OIP submittal document for February 2014 Complete 81 RCP Leakage Calc tracking audit question #17 Started 82 Ensure Compliance with Shutdown Refuel Mode Position Started Paper 83 Determine which WCAP-17601-P Analyses Apply to HNP Started 84 Ensure Compliance with EPRI Report 3002000623 PM Basis Started for FLEX Equipment 85 Add RWST and BAT level instrumentation to Essential Complete Equipment List by updating Attachment 6 of the OIP.

86 Ensure compliance with NRC Battery Life Issue White Paper. Started

b. Open Items added after July 28, 2014 Overall Integrated Plan Open Item/Technical review gaps Status None NA
c. Draft Safety Evaluation The following table provides a summary status of the Open Items & Confirmatory Open Items from Reference 16.

Item # Description Status 3.2.1.8.C At the time the audit was conducted, the licensee had neither (1) committed to abide by the generic approach discussed above, including the additional conditions specified in the NRCs Complete endorsement letter, nor (2) identified an acceptable alternate approach for justifying the boric acid mixing assumptions in the analyses supporting its mitigating strategy. As such, resolution of this concern for HNP is needed.

U.S. Nuclear Regulatory Commission Page 10 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.1.1.2.A The Integrated Plan did not address NEI 12-06 Section 5.3.2, Deployment of FLEX Equipment considerations 4 (if power is required to move or deploy the equipment) and 5 (the means to move FLEX equipment should be provided that is also reasonably protected from the event). This information needs to be provided for review.

Response: Complete HNP plans on the use of a tractor outfitted with a front end loader and hitch to relocate FLEX equipment from the Seismic Category I EDG Building to coping strategy locations. The tractor will also be located in the EDG Building with a door capable of withstanding design wind/tornado loadings and missile impacts. This door will be manually operated as per consideration 4 of NEI 12-06 Section 5.3.2. Tracked by Open Item #72.

3.2.1.3.A The licensee was requested to address the applicability of assumption 4 from WCAP Section 4.2.1 Input Assumptions -

Common to All Plant Types on WCAP-17601, which states that Decay heat is per ANS 5.1-1979 + 2 sigma, or equivalent, and to provide a discussion regarding the following key parameters used to determine the decay heat: (1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days Complete per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics are based on the beginning of the cycle, middle of the cycle, or end of the cycle. If a different decay heat model is used, the licensee was also requested to address the specific model and the acceptability of the model. This Confirmatory Open Item is being tracked by Open Item #83.

3.2.4.10.C The licensee was requested to provide a detailed discussion on the loads that will be shed from the DC bus, the equipment location (or location where the required action needs to be taken), and the required operator actions needed to be performed and the time to Complete complete each action. The licensee was requested to explain which functions are lost as a result of shedding each load and discuss any impact on defense in depth and redundancy. This Item is being tracked by Open Item #27.

3.1.1.3.A Internal Plant Flooding events - Completion of analysis to determine Complete the impact of internal plant flood events.

3.1.1.4.A Off-Site Resources - Confirm RRC local staging area, evaluation of access routes, and method of transportation to the site. Tracked by Started Open Item #75.

U.S. Nuclear Regulatory Commission Page 11 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.1.4.2.A The licensee stated that the engineering evaluation required to support the modification identified in licensee-identified Open Item

  1. 49 will address configuration and operation of the FLEX equipment under extreme cold, snow, or ice conditions. Licensee-identified Open Item #49 should be reviewed during the 6-month update to ensure that the engineering evaluation was added to it. Complete

Response

Criteria to support configuration and operation of FLEX equipment under extreme cold, snow, or ice conditions is provided within the engineering evaluation.

3.2.1.A Section 3.2 of WCAP-17601 discusses the Pressurized Water Reactor Owners Group (PWROG)s recommendations that cover the following subjects for consideration in developing FLEX mitigation strategies: (1) minimizing RCP seal leakage rates; (2) adequate shutdown margin; (3) time initiating cooldown and depressurization; (4) prevention of the RCS overfill; (5) blind feeding an SG with a portable pump; (6) nitrogen injection from safety injection tanks (SITs), and (7) asymmetric natural circulation cooldown (NCC). The licensee should provide a discussion of their position on each of the recommendations discussed above for developing the FLEX mitigation strategies. Specifics of this discussion should include a listing of the recommendations that are Complete applicable to the plant, providing rationale for the applicability, addressing how the applicable recommendations are considered in the ELAP coping analysis, discussing the plan to implement the recommendations, and providing the rationale for each of the recommendations that are determined to be not applicable to the plant.

Tracked by Open Item #83. Identified in PWROG-14015-P, HNP is listed as a category 1 plant. Category 1 plants show a maximum No. 1 seal leak rate of 17.5 gpm which is below the generic value listed in WCAP-17601-P.

U.S. Nuclear Regulatory Commission Page 12 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.2.1.1.A During the audit process, the licensee was requested to specify which analysis performed in WCAP-17601-P, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," is being applied to HNP. Additionally, the licensee was requested to justify the use of that analysis by identifying and evaluating the important parameters and assumptions demonstrating that they are representative of your site and appropriate for simulating the ELAP transient. The licensee Complete responded by stating that a vendor resource will assist in determining which WCAP-17601-P analyses applies to HNP. The licensee was requested to include and update in the 6-month update.

Tracked by Open Item #83. As identified in PWROG-14015-P, HNP is listed as a category 1 plant. Category 1 plants show a maximum No. 1 seal leak rate of 17.5 gpm which is below the generic value listed in WCAP-17601-P.

3.2.1.1.B Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation. Provide an acceptable definition for reflux Complete condensation cooling.

Tracked by Open Item #83. PWROG-14015-P.

3.2.1.1.C The NRC staff noted that a plant specific ELAP containment atmosphere analysis using approved analytical tools must be performed to confirm no action is required to maintain containment and potentially affected instrumentation (licensee-identified Open Item #31). The NRC staff also noted that the SBO analyses discussed above used Modular Accident Analysis Program (MAAP)

Complete Version 3 for an analytical tool. Justification for the appropriateness of MAAP3 for containment analyses should be provided.

Response

HNP containment analysis is being performed under GOTHIC calculations. Tracked by Open Item #31.

U.S. Nuclear Regulatory Commission Page 13 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.2.1.2.A For the plants using Westinghouse RCPs and seals that are not the SHIELD shutdown seals, the RCP seal initial maximum leakage rate should be greater than or equal to the upper bound expectation for the seal leakage rate for the ELAP event (21 gpm/seal) discussed in the PWROG position paper addressing the RCP seal leakage for Westinghouse plants. If the RCP seal leakage rates used in the plant-specific ELAP analyses are less than the upper bound expectation for the seal leakage rate discussed in the position paper, justification should be provided. If the seals are Complete changed to non-Westinghouse seals, the acceptability of the use of non-Westinghouse seals should be addressed, and the RCP seal leakage rates for use in the ELAP analysis should be provided with acceptable justification.

Tracked by Open Item #81. As identified in PWROG-14015-P, HNP is listed as a category 1 plant. Category 1 plants show a maximum No. 1 seal leak rate of 17.5 gpm which is below the generic value listed in WCAP-17601-P.

3.2.1.2.B In some plant designs, such as those with 1200 to 1300 psia SG design pressures and no accumulator backing of the main steam system power-operated relief valve (PORV) actuators, the cold legs could experience temperatures as high as 580 degrees Fahrenheit before cooldown commences. This is beyond the qualification temperature (550 degrees Fahrenheit) of the O-rings used in the RCP seals. For those Westinghouse designs, a discussion of the information (including the applicable analysis and relevant seal leakage testing data) should be provided to justify that (1) the Complete integrity of the associated O-rings will be maintained at the temperature conditions experienced during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal used in the ELAP is adequate and acceptable.

Tracked by Open Item #81. As identified in PWROG-14015-P, HNP is listed as a category 1 plant. Category 1 plants show a maximum No. 1 seal leak rate of 17.5 gpm which is below the generic value listed in WCAP-17601-P.

U.S. Nuclear Regulatory Commission Page 14 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.2.1.2.C During the audit process, the licensee responded by stating that for items a, b, c and d, a vendor will assist HNP in addressing these items. For item e, HNP is not installing safe shutdown low leakage seals. For Item f, RCPs are Westinghouse model 93A with a Westinghouse 93ACS seal package. The licensee stated that a vendor will assist HNP in addressing whether or not the reactor coolant pump and seal combination complies with a seal leakage model described in WCAP-17601 and for Item g, HNP intends to conduct a symmetric cooldown in response to ELAP. A licensee-Complete identified Open Item has been generated to track items a, b, c, d, and f. The time table, details of licensees actions and Open Item number needs to be provided and updated in the 6-month status report.

Tracked by Open Items #81 & 83. As identified in PWROG-14015-P, HNP is listed as a category 1 plant. Category 1 plants show a maximum No. 1 seal leak rate of 17.5 gpm which is below the generic value listed in WCAP-17601-P.

3.2.1.5.A Confirm RWST and BAT level instrumentation is added to the Complete essential equipment list.

3.2.1.6.A The final SOE information when analyses have been completed, including the licensees validation that defined actions from the Complete FLEX strategies can be completed within the time constraints is needed for review.

3.2.1.8.A The licensee was requested to provide an assessment of the potential loss of effectiveness of the boron due the addition of debris with different minerals and chemicals.

Response

HNP has sufficient coping capabilities to ensure mitigation strategies are maintained greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (indefinite coping)

Complete in Modes 1-4. As provided in Reference 11, sufficient RWST volume exists to provide RCS make up in support of mitigation strategies. Additionally, HNP has accepted involvement in use of the Non-Generic Equipment procurement from the RRC under PO201343 for delivery of a Water Treatment skid as listed in Reference 16, Section 8.7 and Table 9-1. Tracked by Open Item

  1. 11 & 12.

3.2.1.8.B The licensee responded by stating that analyses addressing re-criticality is in progress and is tracked by licensee-identified Open Item #12 (Boration to keep core subcritical). When these calculations are completed, a summary report discussing the results Started of these analyses need to be made available for review.

Tracked by Open Item #12.

3.2.1.9.A Completion of analyses to determine adequate performance criteria of FLEX portable pumps to support the licensees phase 2 FLEX Complete strategies.

U.S. Nuclear Regulatory Commission Page 15 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.2.3.A The licensee was requested to provide the completed analysis of the ELAP containment response as specified in licensee-identified Open Item 33 (this should be 31) - Containment Pressure and Temperature Analysis at extended time periods when available, and to discuss whether or not the containment spray is needed as a coping action. The licensee stated that licensee-identified Open Started Item #31 is tracking completion of Containment analysis as stated.

Once the Containment analyses are completed, the licensee was requested to address the questions provided above and provide a summary report of the Containment Analysis for review.

Tracked by Open Item #31.

3.2.4.1.A Confirm completion of analyses demonstrating the expected Complete duration of TDAFW pump operation under ELAP conditions.

3.2.4.2.A Confirm analysis for loss of HVAC on TDAFW equipment.

Complete 3.2.4.2.B Confirm analysis of adequacy of the ventilation provided in the battery room to protect the batteries from the effects of extreme Complete high and low temperatures.

3.2.4.2.C Confirm analysis of battery room ventilation to prevent hydrogen Complete accumulation during charging batteries during Phase 2 and 3.

3.2.4.3.A Confirm analysis to evaluate the loss of heat tracing for equipment Complete required to implement licensee FLEX strategies.

3.2.4.4.A Confirm analysis of lighting needs throughout the plant during ELAP conditions.

Complete Tracked by Open Item #33.

3.2.4.4.B Communications. Confirm that upgrades to the sites Complete communications systems have been completed.

3.2.4.6.A The licensee responded by stating that HNP is performing an evaluation of the environmental conditions in various areas/compartments related to an ELAP event (licensee-identified Open Item #20). The results of the evaluation will be used to Complete determine if any speci"c actions are required to cope with extreme temperatures. These evaluations, once completed, need to be available for review.

3.2.4.7.A The licensee stated that HNP has determined not to pursue the CST non-seismic piping modification. As a result, only 238,000 gallons can be credited following a seismic event. The licensee was asked how long the CST can be relied upon assuming the reduced Complete water capacity. The licensee stated that licensee-identified Open Item #5 is being evaluated with vendor assistance. Completion of the analysis determines the amount of time that the CST can be relied upon. The results need to be available for review.

3.2.4.7.B The licensee stated that credit for partial protection of the RWST from tornado missiles is pending further analysis. Confirm analysis Complete that determines the volume that can be credited for a borated water source from the RWST.

U.S. Nuclear Regulatory Commission Page 16 of 18 Serial HNP-15-006 Enclosure Item # Description Status 3.2.4.8.A Electrical Isolation - confirm administrative controls for alignment and operation of the FLEX distribution network will be provided to prevent energizing a bus from multiple sources. Started Tracked by Open Item #66.

3.2.4.9.A Completion of fuel consumption rate analyses that calculate the total fuel usage for each piece of FLEX equipment and thus determine if sufficient fuel with margin exists on-site until offsite Complete resources arrive for replenishment. Confirm FLEX equipment total fuel consumption rate.

3.2.4.9.B Confirm delivery path to equipment from fuel oil storage tanks and Complete FLEX storage facility.

3.2.4.10.A Confirm analysis of consequences from performing DC deep load shed and calculation needed to validate the coping time that will be added to station batteries to provide needed margin to the plants Complete installed equipments coping time.

Tracked by Open Item #27.

3.2.4.10.B The NRC staff concluded that the NEI position paper provides an acceptable approach for licensees to use in demonstrating that vented lead-acid batteries can be credited for durations longer than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The licensee was requested if HNP plans to comply with recommendations presented in the Nuclear Energy Institute (NEI) position paper entitled Battery Life Issue (ADAMS Accession No. ML13241A186 (position paper))?

Complete During the audit process, the licensee stated that HNP intends to comply with the NEI white paper entitled Battery Life Issue (ADAMS Accession No. ML13241A186) as endorsed by the NRC (ADAMS Accession No. ML13241A188). The licensee should provide a summary description of how HNP will conform to the NEI position paper. Tracked by Open Item #86.

3.2.4.10.D Confirm sizing calculations for the FLEX DGs to show that they can Complete supply the loads assumed in phase 2 and 3.

3.4.A Confirm information is provided on how conformance with NEI 12-06, Section 12.2 guidelines 2 through 10 will be met.

Started Tracked by Open Items #66, 71, 72, 73, 74, 75.

7 Potential Draft Safety Evaluation Impacts The NRC issued the Shearon Harris Nuclear Power Plant, Unit 1 - Interim Staff Evaluation Relating to the Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0874) (Reference 16) on February 12, 2014. The open item and confirmatory open items identified in the Interim Staff Evaluation are addressed in this report. There are no potential impacts to the Interim Staff Evaluation identified at this time.

U.S. Nuclear Regulatory Commission Page 17 of 18 Serial HNP-15-006 Enclosure 8 References The following references support the updates to the Overall Integrated Plan 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, (ADAMS Accession No. ML13112A020)
2) Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2013, (ADAMS Accession No. ML13239A359)
3) 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, 2012 (ADAMS Accession No. ML12054A735)
4) NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External Events, dated August 29, 2012. (ADAMS Accession No. ML12229A174)
5) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)
6) Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporations 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. ML12307A021)
7) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 16, 2013 (ADAMS Accession No. ML13241A188)
8) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 30, 2013 (ADAMS Accession No. ML13267A382)
9) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 3, 2013 (ADAMS Accession No. ML13275A318)
10) 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)
11) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, Program

U.S. Nuclear Regulatory Commission Page 18 of 18 Serial HNP-15-006 Enclosure Management Office Westinghouse Electric Company LLC, October 7, 2013 (ADAMS Accession No. ML13276A555)

12) HNP-C/FLEX-0001, Tornado Effects on RWST for FLEX NTTF 4.2 Coping Strategies, Revision 0
13) Extended Battery Duty Cycles Position Paper (ADAMS Accession No. ML13241A186)
14) Shutdown/Refueling Modes Position Paper (ADAMS Accession No. ML13273A514)
15) Nuclear Maintenance Application Center: Preventive Maintenance Basis for FLEX Equipment Position Paper (ADAMS Accession No. ML13276A573)
16) NRC Letter, Shearon Harris Nuclear Power Plant, Unit 1 - Interim Staff Evaluation Relating to the Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0874) dated February 12, 2014 (ML13364A214)
17) Duke Energy Letter, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014, (ADAMS Accession No. ML14072A051)
18) Areva Inc., Regional Response Center Technical Requirements (Document Number 51-9199717-007) dated January 30, 2014 (Draft)
19) 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 25, 2014, (ADAMS Accession No.ML14241A115)
20) Duke Energy Letter, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1,2, and 6 - Phase 2 Staffing Assessment, dated November 25, 2014
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