HNP-13-080, 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)
| ML13239A359 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/27/2013 |
| From: | Kapopoulos E Duke Energy Corp |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-12-049, HNP-13-080 | |
| Download: ML13239A359 (11) | |
Text
Ernest J. Kapopoulos, Jr.
Vice President Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2502 10CFR50.4 August 27, 2013 Serial: HNP-13-080 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400
Subject:
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)
References:
- 1. 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. ML12056A045)
- 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. 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)
Ladies and Gentlemen:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company. Reference 1 was immediately effective and directs Duke Energy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling,
Serial HNP-13-080 Page 2 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. Reference 4 provided the Duke Energy initial status report regarding mitigation strategies. Reference 5 provjc;led the Duke Energy overall integrated plan for Harris Nuclear Plant.
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. The purpose of this letter is to provide the first 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 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. If you have any questions regarding this report, 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 [
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Sincerely,~~~
Ernest J. Kapopoulos, Jr.
Enclosure:
First Six Month Status Report (Order EA-12-049) cc:
Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Mr. W. L. Cox Ill, Section Chief, North Carolina DENR Mr. A. Hon, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II Mr. E. J. Leeds, NRC Director, Office of Nuclear Reactor Regulation Mr. S. R. Jones, NRR/DSS/SBPB, NRC Ms. J. A. Kratchman, NRRIJLD/PMB, NRC
SERIAL: HNP-13-080 ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
Serial HNP-13-080 Page 2 of 9 Enclosure 1
Introduction Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company, developed an Overall Integrated Plan (Reference 2), for the Shearon Harris Nuclear Power Plant, Unit 1, (HNP) documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference 1). The Overall Integrated Plan 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 February 28, 2013, to July 30, 2013 (hereafter referred to as the update period).
2 Milestone Accomplishments The following milestones were completed during the update period:
- 1)
Submitted Integrated Plan 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.
Milestone Target Completion Date Activity Status Revised Target Completion Date Submit Integrated Plan February 28, 2013 Complete Date Not Revised 6 Month Status Update August 28, 2013 Started Date Not Revised Conduct N-1 Outage Walkdowns November 2013 Not Started Date Not Revised Identify Significant Material/Equipment January 2014 Started Date Not Revised 6 Month Status Update February 28, 2014 Not Started Date Not Revised Develop Strategies / Playbook w/RRC March 2014 Not Started Date Not Revised Develop Training Program March 2014 Not Started Date Not Revised 6 Month Status Update August 28, 2014 Not Started Date Not Revised Develop Modifications October 2014 Started Date Not Revised
Serial HNP-13-080 Page 3 of 9 Enclosure Milestone Target Completion Date Activity Status Revised Target Completion Date Conduct Implementation Walkdowns December 2014 Started Date Not Revised Material / Equipment Procurement /
Delivery December 2014 Not Started Date Not Revised Conduct Staffing Analysis December 2013 Revised January 2015 Implement Training February 2015 Not Started Date Not Revised Install Offsite Delivery Pad February 2015 Not Started Date Not Revised 6 Month Status Update February 28, 2015 Not Started Date Not Revised Develop FLEX Strategy Guidelines (FSGs)
March 2015 Not Started Date Not Revised Develop Maintenance Procedures March 2015 Not Started Date Not Revised Implement Modifications May 2015 Not Started Date Not Revised Implementation Complete May 2015 Not Started Date Not Revised 4
Changes to Compliance Method The following summarizes the changes to the compliance method as documented in the Overall Integrated Plan (OIP) (Reference 1).
- 1)
Change: HNPs OIP stated the Dedicated Shutdown Diesel Generator (DSDG) would be hardened and protected to provide power to Motor Control Center (MCC) 1D23 (Figure 26
& 27) (Modification Open Item #40). HNP determined hardening the DSDG will not be performed, therefore the DSDG will not be used as a credited power source for FLEX (Evaluation Open Item #65).
Justification: A FLEX power source aligned to MCC 1D23 will serve as the credited supply.
Open Item #44 implements this change.
Documentation: Open Item #40 will not be implemented and has been cancelled.
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.
Serial HNP-13-080 Page 4 of 9 Enclosure
- 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 the original OIP submitted on February 28, 2013. The table under Section 6.b. provides a list of open items that were added after February 28, 2013. The table under 6.c. provides a list of open items related to the Draft Safety Evaluation.
- a. Open Items Documented in the Overall Integrated Plan.
Overall Integrated Plan Open Item Status 1
Analysis to determine expected duration of TDAFW pump operation under ELAP conditions Started 2
Staging analysis timeline of FLEX feedwater pump and plant specific pump analysis at chosen FLEX injection points and water sources specifically for HNP Started 3
Determine highest rate of RCS cooldown with only one SG PORV Started 4
Determine if B.5.b connections 1AF-173/174/175 are adequately sized to meet SG feedwater requirements from decay heat (not credited)
Started 5
Determine how much time the CST can be relied upon for Started 6
Projected Inventory usage for RCS and SGs Started 7
Determine the amount of SG inventory needed for the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per cooldown strategy in PA-PSC-0965 Started 8
Determine any adverse affects from using borated water from RWST in Steam Generators Started 9
Determine HNP specific FLEX FW pump capacity requirements (discharge pressure and flow)
Started 10 A FLEX/ELAP staffing analysis needs to be performed for all coping strategies Not Started 11 Calculation needed to determine the cooling flow 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 Started 12 RCS boron concentration and boration in gallons to maintain inventory control and core cooling in regards to keeping the core subcritical with RCS cooldown strategy in PA-PSC-0965 Attachment 3 Started 13 RWST is partially exposed to tornado missiles and analysis will need to be done to determine the volume that can be credited Started 14 Analysis to determine HNP specific high pressure make up pump minimum performance rating necessary to support FLEX coping strategies Started 15 Analysis to determine if the ASI pump can meet the HNP minimum high pressure makeup requirements. Analysis to determine HNP specific Modes 5 and 6 FLEX pump capacity requirements for RCS low pressure injection Started 16 Analysis needed to confirm RCS Depressurization via Reactor Vessel Head Vents will be effective Started 17 Analysis of BAT and RWST during ELAP without heat tracing during cold weather conditions Started 18 Determine if RCS venting is needed Started 19 Analysis to determine minimum pump performance rating to support ESW delivery to all FLEX usage point simultaneously and prevent pump run-out Started
Serial HNP-13-080 Page 5 of 9 Enclosure Overall Integrated Plan Open Item Status 20 Analysis to determine HVAC requirements for operating installed and temporary equipment under ELAP conditions for maintaining reliable operation Started 21 Habitability analysis needed for local manual control of SG PORVs in the Steam Tunnel under ELAP conditions Started 22 Habitability analysis for local manual control of TDAFW pump at RAB 236 elevation Started 23 Analysis needed for loss of HVAC on TDAFW equipment Started 24 Calculation to determine power consumption assuming all HVAC is provided by portable blower units to support selection of FLEX generator size Started 25 Analysis to determine total fuel consumption rates of all FLEX equipment Not Started 26 Calculation to determine pounds of boron versus RWST tank level percent to achieve desired boron concentration Started 27 Detailed analysis of consequences from performing a DC deep load shed.
Specifically to determine what equipment is still needed to carry-out FSG coping functions. Instrument loops and etc.
Not Started 28 Detailed calculation needed to validate the coping time that will be added to Station Batteries to provide needed margin to the plants installed equipments coping time Not Started 29 Analysis of the affects of AUX Reservoir water being used for heat removal Started 30 Analysis of FLEX pump suction strainer sizes to any downstream FLEX flow path clearances.
Not Started 31 Containment Pressure & Temperature Analysis at extended time periods (is containment spray needed as a coping action?)
Started 32 Hydrogen production & removal in Battery Rooms Not Started 33 Seismic analysis of lighting fixtures and analysis of lighting needs in the plant during ELAP Started 34 Analysis needed to determine portable power and pump needs for selected FLEX strategies Started 35 Analysis to determine expected length of time for FLEX equipment to operate under extended ELAP conditions based on operation condition Started 36 Analysis to provide delivery path to equipment from Fuel Oil Storage Tanks and FLEX Storage Facility Not Started 37 Determine impact of internal plant flooding events Not Started 38 Boil off analysis of Spent Fuel Pool during full core offload immediately following a full core offload, determine length of coping time without any make-up to SFP immediately following full core offload Not Started 39 Analysis to determine any radiological affects to the public by using contaminated water sources for feedwater use to the Steam Generators Started 40 Modification - Harden/Protect Dedicated Shutdown Diesel Generator to provide power to MCC 1D23.
Canceled (Change 1) 41 Modification - Seismically upgrade the Alternate Seal Injection System to serve as one coping strategy to provide High Pressure RCS injection Not Started 42 Modification - Add an Alternate Seal Injection pump 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 Not Started
Serial HNP-13-080 Page 6 of 9 Enclosure Overall Integrated Plan Open Item Status 43 Modification - Protect and seismically upgrade MCC 1D23 and all connections/distribution. Provides power to Safety Related Battery Chargers and the Alternate Seal Injection System Not Started 44 Modification - FLEX Generator(s) electrical connections at:
- 1A3-SA 480V Bus (Pri)
- 1B3-SB 480V Bus (Pri)
- Primary & Alternate 480 VAC distribution/ control for FLEX pumps, FLEX outlets for lighting, ventilation, etc Not Started 45 Modification - Modify control power circuits for A & B SG PORVs to be powered from Instrument Buses SI, SII, or SIV. Modification provides the ability to control steaming/RCS cooldown Not Started 46 Modification - Add FLEX pump suction and discharge connection points to the AFW system upstream of Motor Driven AFW flow control valves.
Modification will provide AFW flow control and the ability to provide inventory to the Steam Generators from portable pumps Not Started 47 Modification - Modify MDAFW FCVs control power circuit. Install key switch jumper in to simulate a Motor Driven Auxiliary Feedwater pump breaker closed. ARP 19A (SA) R2 terminal 119 & 120. Provides 125 V DC power to ARP19A (SA) and instrument bus SI for the purpose of operators controlling feedwater flow to the Steam Generators from the MCB Not Started 48 Modification - Add FLEX RCS suction and discharge connection points to CVCS on A & B train. Provides the capability to inject inventory (borated) from a FLEX pump to the RCS from the BAT or RWST Not Started 49 Modification - Add FLEX pump discharge connection points to the Emergency Service Water system. Provides a pressurized water source to CST, RAB & FHB Fire Protection SSE hose station headers, and Spent Fuel Pools Not Started 50 Modification - Add quick connect connection point at 4 inch flanges downstream of valves 2DFO-262 and 2DFO-280. Allows connection of a FLEX pump to transfer fuel oil from the Fuel Oil Storage Tanks to support fuel delivery to operating FLEX equipment Not Started 51 Modification - Install enhanced Spent Fuel Pool level indication. Refer to NTTF 7.1 Not Started 52 Modification - Verify seismic qualification or seismically 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 are being powered from a FLEX generator. Also allows HNP to credit ESW Emergency Makeup to Spent Fuel Pools Not Started 53 Modification - Add quick connects at tank locations to support 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 Hotwell, Demineralized Water Storage Tank, Filtered Water Storage Tank, and Refuel Water Storage Tank Not Started
Serial HNP-13-080 Page 7 of 9 Enclosure Overall Integrated Plan Open Item Status 54 Modification - Add FLEX connection points to the Containment Spray System. Abates high pressure/high temperature conditions inside containment Not Started 55 Modification -Add temporary power cables and connection points at select MOV MCC breaker/control cubicles. Provides the ability to perform a onetime stroke of valves that are needed to be repositioned in an ELAP event Started 56 Modification - Structure(s) built in compliance to ASCE 7-10 to house and protect FLEX generators and equipment Not Started 57 Modification - Install FLEX distribution network to power FLEX equipment (pumps, ventilation, lighting, power outlets, and temporary power to MOVs)
Not Started 58 Modification - Upgrade the installed in-plant emergency DC lighting packs with Light Emitting Diode bulbs. This will significantly extend the operating time of the lights installed in the plant Not Started 59 Modification - Seismically qualify/upgrade the Condenser Hotwell Transfer Suction Piping and add isolation valve. This will significantly increase the credited volume of the Condensate Storage Tank Not Started 60 Develop a procedure to take local reading in containment electrical penetration, PIC, or RVLIS for all required readings Not Started 61 Contract for offsite fuel delivery Not Started 62 Contract for Demineralized Water Processing Skid or tanker delivery Not Started 63 Perform an analysis to determine the amount of volume for the RMWST that can be credited Not Started 64 Evaluate to determine that a modification can be 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)
Started 65 Evaluate to determine that a modification can be 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 Started 66 FLEX 4.2 Programmatic Controls - Implement programmatic controls for review, revision and/or generation of procedures and guidelines as required to address additional programmatic controls as a result of FLEX requirements Started 67 FLEX 4.2 Programmatic Controls - Implement programs and processes to assure personnel proficiency in the mitigation of beyond-design-basis external events in accordance with NEI 12-06 Not Started 68 FLEX 4.2 Programmatic Controls - Establish FLEX Strategies and basis in an overall FLEX Basis Document Not Started 69 FLEX 4.2 Programmatic Controls - Modify existing plant 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 Not Started
Serial HNP-13-080 Page 8 of 9 Enclosure Overall Integrated Plan Open Item Status 70 FLEX 4.2 Programmatic Controls - Training will be initiated 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 Not Started 71 External Hazards for Structures - Structures to provide 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 Started 72 External Hazards for Structures - Develop Procedures and Programs to address storage structure requirements, deployment path requirements, and FLEX equipment requirements relative to the External Hazards applicable to HNP Not Started 73 Purchase sufficient amounts of portable equipment to fulfill selected FLEX strategies Started 74 Initiate PMs and develop testing procedures to support FSG guidelines for FLEX equipment Started 75 Develop Regional Response Center (RRC) playbook Not Started 76 Determine Regional Response Center (RRC) portable equipment requirements (water, boron, etc.)
Started 77 Determine Phase 3 equipment/commodities requirements (food, fuel, etc.)
Not Started 78 Convert to high capacity SAT phone batteries Started 79 Modification - Modify SG PORV hydraulic pump motor MCC cubicles to provide for quick connection of a temporary FLEX power source Started
- b. Open Items added after February 28, 2013 Overall Integrated Plan Open Item Status None N/A
- c. Draft Safety Evaluation Draft Safety Evaluation Open Item Status Draft SE has not been provided N/A 7
Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
Serial HNP-13-080 Page 9 of 9 Enclosure 8
References The following references support the updates to the Overall Integrated Plan described in this attachment.
- 1)
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
- 2)
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)