ML13246A009
| ML13246A009 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/29/2013 |
| From: | Batson S Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049 | |
| Download: ML13246A009 (9) | |
Text
DUKE SCOTT L BATSON ENERGY..
Needo Duke En.,.y ONOIVP/ 7800 Rochster H"j Seneca, SC 29872 August 29, 2013 1 OCFR50.4 864.873-3274 884-873.4208 fax ScotBafsont@duke-enerw.om ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)
Oconee Nuclear Station (ONS), Unit Nos. 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 Renewed. License Nos. DPR-38, DPR-47, and DPR-55
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-1 2-049)
References:
- 1. NRC Order Number EA-1 2-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
- 2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance With Order EA-12-049, Order Modifying Licensees with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012
- 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
- 5. Oconee 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-12-049), dated February 28, 2013 On March 12, 2012, the NRC issued Order EA-12-049 (Reference 1) to Duke Energy.
Reference I 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.
Reference I required the submission of an Initial Status Report 60 days following Issuance of the NCR's Interim Staff Guidance (Reference 2), and the submission of an Overall Integrated Plan by February 28, 2013. Reference 2 endorses, with clarifications and exceptions, the industry guidance document, NEI 12-06 (Reference 3). Duke Energy provided the Initial Status Report for Catawba, McGuire, and Oconee Nuclear Power Stations (Reference 4) on
United States Nuclear Regulatory Commission ONS First Six-Month Status Report (Order EA-12-049)
August 29, 2013 Page 2 October 29, 2012 and the Overall Integrated Plan for Oconee Nuclear Station (Reference 5) on February 28, 2013.
Reference 1,Section IV, Condition C.2, also requires that status reports are to be submitted at six-month intervals, following the submittal of the Overall Integrated Plan. Reference 3 provides guidance for the status report content. This letter transmits Oconee's first six-month Status Report, which outlines the progress made since submittal of the Overall Integrated Plan.
This letter contains no new regulatory commitments.
If you have any questions regarding this report, please contact David Halie, Oconee Regulatory Affairs Group, at (864) 873-4742.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August 29, 2013.
Respectfully submitted, Scott L. Batson Vice President, Oconee Nuclear Station
Enclosure:
ONS - First Six-Month Status Report (Order EA-12-049), Units 1, 2, and 3.
United States Nuclear Regulatory Commission ONS First Six-Month Status Report (Order EA-1 2-049)
August 29, 2013 Page 3 xc:
V.M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Mr. Eric J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M 11555 Rockville Pike Rockville, MD 20852-2738 Richard Guzman, Project Manager (ONS)
U.S. Nuclear Regulatory Commission One White Flint North, Mailstop O-8C2 11555 Rockville Pike Rockville, MD 20852-2738 E. L. Crowe NRC Senior Resident Inspector Oconee Nuclear Station
ENCLOSURE ONS - FIRST SIX-MONTH STATUS REPORT (ORDER EA-12-049)
UNITS 1, 2, AND 3 Encl. Page - I
ENCLOSURE: ONS - FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
(Note: The reference list for this Enclosure is contained in Section 8)
- 1. Introduction Oconee Nuclear Station (ONS) developed an Overall Integrated Plan (Reference A),
documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference B). 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. Submit Overall Integrated Plan - Complete.
- 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 Activity Status Revised Target Completion Date Completion Date Submit Overall Integrated Plan Feb 2013 Complete Date Not Revised Submit 6 Month Updates:
Update 1 Aug 2013 Started Date Not Revised Update 2 Feb 2014 Not Started Date Not Revised Update 3 Aug 2014 Not Started Date Not Revised Update 4 Feb 2015 Not Started Date Not Revised Update 5 Aug 2015 Not Started Date Not Revised Update 6 Feb 2016 Not Started Date Not Revised Update 7 Aug 2016 Not Started Date ot Revised Modifications:.
Develop Modifications Aug 2016 Started Date Not Revised Procurement:
Identify Significant Sept 2013 Started Date Not Revised Material/Equipment Material/Equipment May 2015 Not Started Date Not Revised Procurement/Delivery End. Page-2
ENCLOSURE: ONS - FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
(Note: The reference list for this Enclosure is contained in Section 8)
MltoeTarget
- Revised Target:
Completion Date F
A Completion Date Implementation Walkdowns:
Conduct N-i Outage Nov 2014 Not Started Date Not Revised Walkdowns for U1 Conduct N-1 Outage Nov 2013 Not Started Date Not Revised Walkdowns for U2 Conduct N-I Outage May 2014 Not Started Date Not Revised Walkdowns for U3 Conduct Implementation Oct 2016 Not Started Date Not Revised Walkdowns for U1 Conduct Implementation Oct 2015 Not Started Date Not Revised Walkdowns for U2 Conduct Implementation April 2016 Not Started Date Not Revised Walkdowns for U3 Staffing:
Conduct Staffing Analysis July 2016 Started Date Not Revised Training:
Develop U1 Training program July 2016 Not Started Date Not Revised Develop U2 Training program July 2015 Not Started Date Not Revised Develop U3Training program Jan 2016 Not Started Date Not Revised Implement U1 Training Oct 2016 Not Started Date Not Revised Implement U2 Training Oct 2015 Not Started Date Not Revised Implement U3 Training April 2016 Not Started Date Not Revised Procedures:
Develop FLEX Supporting June 2016 Not Started Date Not Revised Guidelines (FSGs)_________________
Develop Maintenance June 2016 Not Started Date Not Revised Procedures:_..
Regional Response Centers:
Develop Strategies/Playbook with April 2015 Started Date Not Revised Install Offste Delivery Pad March 2015 Not Started Date Not Revised Implementation:
Implement U1 Modifications Nov 2016 Not Started Date Not Revised Implement U2 Modifications Nov 2015 Not Started Date Not Revised Implement U3 Modifications May 2016 Not Started Date Not Revised Encl. Page - 3
ENCLOSURE: ONS - FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
(Note: The reference list for this Enclosure is contained in Section 8)
- 4. Changes to Compliance Method No changes were made during the update period.
- 5. Need for RelileflRelaxation and Basis for the RelieflRelaxatlon ONS 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.
" Table 6a provides a status of the open items Identified In the original submittal of the Overall Integrated Plan (Reference A).
" Table 6b provides a status of open items which were added after submittal of the Overall Integrated Plan.
" Table 6c will provide a status of open items to address the Draft Safety Evaluation.
Table 6a: Open Items Documented In the Overall Integrated Plan.
Overall Integrated Plan Open Item Status 1-Revised PMP HMR51 Analysis In Progress: 2.1 Flood Re-analysis 1-__RevisedPMPHMR51_AnalysisCompleted, Pending NRC Approval 2-Max flood level on site (after modifications)
In Progress: 2.1 Flood Re-analysis Completed, Pending NRC Approval 3-Deployment Path Program Not Started 4-Procedures and FSGs Not Started 5-FLEX Equipment Programmatic Control Not Started 6-Personnel Training Not Started 7-FLEX Basis Document Not Started 8-Configuration Control Not Started 9-Regional Response Center (RRC) Playbook Started 10- Cooldown Analysis Started 11-ADV Survivability and Accessibility Not Started 12-Load Shed Analysis Not Started 13-Hydraulic Analysis for Pump Flow (Intake Canal to Not Started SGs) 14-Fuel Oil Consumption Not Started 15-Hydraulic Analysis for Pump Flow (CTP-1 to SGs)
Not Started 16-Water in embedded CCW lines & Hydraulic Analysis Not Started for Pumping Configuration 17-PSW Modification (EC 91877)
Started 18-Alternate FLEX Connections Modification (SG Makeup)
Started 19-Breaking Siphons in Embedded CCW Piping Started Encl. Page - 4
ENCLOSURE: ONS - FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
(Note: The reference list for this Enclosure is contained in Section 8)
Table 6a: Open Items Documented in the Overall Integrated Plan, Overall Integrated Plan Open Item Status 20- Instrumentation Repower Started (Alternate Repower Strategy) 21-FLEX Equipment Storage Started 22-Portable Power Distribution Started (Primary Repower Strt~egy) 23-Long term SG and SFP Makeup Started 24-Hydrogen Buildup Analysis Not Started 25-BWST Tap Analysis and Modification (RCS Makeup)
Started 26-Containment Analysis Started 27-Hydraulic Analysis for Pump Flow (CTP-1 to SFPs & Intake Canal to SFPs)
Not Started Completed: Validated SFP Refill 28-Robustness of SFP Refill Lines Lines are installed as QA-1 and are seismically robust (Reference C & D).
29-Lighting Evaluation Not Started 30- Communication Assessment Started 31-NEI 12-01 Staffing Study Started 32-HVAC Analysis Started Table 6b: Open Items added after February 28, 2013 Overall Integrated Plan Open Item Status 33-Evaluate changes to the RCSMU FLEX Strategy recommended by independent audit to eliminate the SSF RCMUP repower strategy and Started implement train specific diesel powered pump strategies (primary and alternate).
34-Evaluate changing the alternate repower FLEX strategy to enhance deployment times by utilizing a small 120 VAC portable diesel generator (approximately 6000 watts) deployed on the Turbine Building deck to Started provide 120 VAC feeds to connections In the control room and cable room to repower the key instrumentation parameters.
35-Validate the 10' assumed inundation level discussed in the OIP
[Assumption #8] is still conservative with respect to the Defense In Depth Not Started Modifications analyzed in 0IP reference 48 (which used a slightly modified model run) and the credited CAL model run in QIP reference 14.
36-Perform raw water fouling analysis for core cooling and heat removal.
Not Started Encl. Page - 5
ENCLOSURE: ONS - FIRST SIX MONTH STATUS REPORT (ORDER EA-12-049)
(Note: The reference list for this Enclosure is contained in Section 8)
Table 6c: Draft Safety Evaluation Open Items (A Draft Safety Evaluation has not yet been provided by the NRC).
Draft Safety Evaluation Open Item Status N/A N/A
- 7. Potential Draft Safety Evaluation Impacts A Draft Safety Evaluation has not yet been issued at this time.
- 8. References The following references support the updates to the Overall Integrated Plan described in this attachment.
A) Oconee Nuclear Station, 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 B) 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 C) OFD-104A-1.1, Spent Fuel Cooling System (Units 1 & 2), Revision 53.
D) OFD-104A-3.1, Spent Fuel Cooling System (Unit 3), Revision 48.
Encl. Page - 6