ML14072A051

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

ML14072A051
Person / Time
Site:	Harris
Issue date:	02/27/2014
From:	O'Connor S T Duke Energy Corp, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, HNP-14-016
Download: ML14072A051 (17)

Text

Sean T. O'Connor DUKER General Manager ENERGY, Nuclear Engineering Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.3140 February 27, 2014 10 CFR 50.4 Serial: HNP-14-016 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:

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)

References:

1. NRC Order Number EA-1 2-049, Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, (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. 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 Corporation'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 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) 4 si U.S. Nuclear Regulatory Commission Page 2 of 2 Serial HNP-14-016 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 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 (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 Shearon Harris Nuclear Power Plant, Unit 1 (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. Reference 6 provided the first six-month status report for HNP. The purpose of this letter is to provide the second 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 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 27, 2014.Sincerely, Sean T. O'Connor

Enclosure:

Second 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 Mr. A. Hon, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure SERIAL HNP-14-.016 ENCLOSURE SECOND 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 Serial HNP-14-016 Enclosure Page 1 of 12 1 Introduction Duke Energy Progress, Inc., (Duke Energy) developed an Overall Integrated Plan (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 Status Report was provided to the NRC on August 28, 2013 (Reference 2). 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 31, 2013 to January 28, 2014 (hereafter referred to as "the update period").2 Milestone Accomplishments The following milestones were completed during the update period: 1)2)Submitted First Six-Month Update Conducted N-1 Outage Walkdowns 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 A.iviy A,.Target 1pj1t!4o5

.. .ta.us 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 Identify Significant Material/Equipment January 2014 Started February 2014 Date Not 6 Month Status Update February 28, 2014 Started Revise Revised Date Not Develop Strategies

/ Playbook w/RRC March 2014 Started Revise Revised Marc 201 StatedSeptember Develop Training Program March 2014 Started 2014 Date Not 6 Month Status Update August 28, 2014 Not Started Revise Revised U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 2 of 12 Cempp~onDafe

• Stau~ CRnpemtiod"Date Date Not Develop Modifications October 2014 Started Revise Revised Date Not Conduct Implementation Walkdowns December 2014 Started Revise Revised Material / Equipment Procurement

/ Date Not Delivery December 2014 Started Revised Conduct Staffing Analysis January 2015 Not Started Previously Revised Date Not Implement Training February 2015 Started Revise Revised Date Not Install Offsite Delivery Pad February 2015 Not Started Revise Revised Date Not 6 Month Status Update February 28, 2015 Not Started Revise Revised Develop FLEX Strategy Guidelines Date Not (FSGs) March 2015 Started Revised Date Not Develop Maintenance Procedures March 2015 Not Started Revise Revised Date Not Implement Modifications May 2015 Not Started Revise Revised Date Not Implementation Complete May 2015 Not Started Revise 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: (Previously reported in First Six-Month Update) Reference 1 stated the Dedicated Shutdown Diesel Generator (DSDG) would be hardened and protected to provide power to Motor Control Center (MCC) 1 D23 (Figures 26 & 27) (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 (Open Item #65).Justification:

A FLEX power source aligned to MCC 1 D23 will serve as the credited supply.Open Item #44 implements this change.Documentation:

Open Item #40 will not be implemented and has been canceled.2) Change: Reference 1 stated that components powered from MCC 1 D23 would be used in support of mitigation strategies by powering equipment necessary for FLEX operations (Alternate Seal Injection (ASI) pump, ASI tank, power source from MCC 1 D23 to the Safety Related battery chargers) (Open Item #65). These components will no longer be used as part of HNP's FLEX strategy for BDBEEs (Open Item #40, 41, 42, & 43 are U.S. Nuclear Regulatory Commission Page 3 of 12 Serial HNP-14-016 Enclosure canceled).

The FLEX electrical distribution network provides the required primary and alternate means of powering safety related battery chargers without reliance on the ability to power this equipment from MCC 1D23.Justification:

RCS makeup and boration strategy can be met by utilizing two portable high pressure makeup pumps, thereby eliminating the need to utilize the ASI system (Open Item #14 & Open Item #48).Documentation:

Reference 5, Section 3.2.2 (13) directs the use of portable equipment to extend plant coping capability.

Additionally, Section 3.2.2 states: In order to assure reliability and availability of the FLEX equipment required to meet these capabilities, the site should have sufficient equipment to address all functions at all units on-site, plus one additional spare, i.e., an N+ 1 capability, where "N" is the number of units on-site. ... The N+1 capability applies to the portable FLEX equipment described in Tables 3-1 and 3-2 (i.e., that equipment that directly supports maintenance of the key safety functions).

Open Item #65 is complete and Open Items #40, 41, 42, & 43 are canceled.

Figures 26 &27 have been updated and are attached.3) Change: Reference 1 stated that a non-seismic line connected to the Condensate Storage Tank (CST) would be upgraded to seismic qualification increasing the credited CST volume (Open Item #5). HNP has determined that protected alternate water sources can be used to meet SG feedwater requirements (Open Item #59).Justification:

The limiting event for CST feedwater inventory is a seismic event. Protected alternate water sources (e.g. RWST and RMWST) are available to ensure an adequate feedwater supply is maintained in support of mitigation strategies following a seismic event. Open Item #64 has been completed.

Documentation:

Open Item #59 will not be implemented and has been canceled.4) Change: Reference 1 stated that a planned modification to install Light Emitting Diode (LED) lamps in the Self-Contained DC Emergency Lighting units would extend the coping time associated with the emergency lights (Open Item #58). Alternate methods, such as flashlights, helmet lights, and/or portable lights powered from the FLEX distribution network will be employed in support of mitigation strategies (Open Item #57). Open Item#58 has been canceled.Justification:

Sufficient alternate lighting will be available for all FLEX initiating events (Open Item #33).Documentation:

Open Item #58 has been canceled.5) Change: Reference 1 designates 28 Figures that depict the mitigation strategies.

In response to questions by the Staff, updated figures have been developed for Figures 1, U.S. Nuclear Regulatory Commission Page 4 of 12 Serial HNP-14-016 0, 11, 12 & 13. In addition, two new figures, 29 & 30, have been created to provide clarity in support of Fuel Pool make-up strategies.

Justification:

Based on discussions with the Staff, the above referenced drawings were updated or created to provide clarity associated with mitigation strategies listed in Reference 1.Documentation:

Updated Figures 1, 10, 11, 12 & 13 associated with Reference 1 and new Figures 29 & 30 are attached.6) Change: Reference 1 states on pages 18, 28, 41, & 51 of 103 that "The FLEX equipment storage location has not yet been decided." HNP will locate FLEX equipment directly supporting mitigation strategies within the 2A-SA Emergency Diesel Generator (EDG) bay, a Seismic Category I structure.

Additionally, FLEX equipment not required to be fully protected from all external events will be located in a new commercial structure as depicted on updated Figure 1. (Open Item #36, revised Open Item #56, & new Open Item#80)Justification:

Storage of FLEX equipment will meet the requirements of Reference 5 Section 2.3 in that "...FLEX mitigation equipment should be stored in a location or locations such that it is reasonably protected such that no one external event can reasonably fail the site FLEX capability.

Reasonable protection can be provided for example, through provision of multiple sets of portable on-site equipment stored in diverse locations or through storage in structures designed to reasonably protect from applicable external events." Documentation:

FSAR 3.8.4.1, Reference

5. (Open Item #36, revised Open Item #56, &new Open Item #80)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 HNP confirms that the FLEX strategy station battery run-time will be calculated in accordance with the IEEE-485 methodology using manufacturer discharge test data applicable to the licensee's FLEX strategy as outlined in the NEI white paper on Extended Battery Duty Cycles (Reference 7, 13). Based on preliminary calculations, the time margin between the calculated station battery run-time for the FLEX strategy and the expected deployment time for FLEX equipment to supply the DC loads is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.HNP will incorporate the supplemental guidance provided in Reference 8, 14 entitled"Shutdown/Refueling Modes" (ADAMS Accession No. ML13273A514) to enhance the shutdown risk process and procedures. (New Open Item #82)

U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 5 of 12 Electric Power Research Institute (EPRI) Report 3002000623 (Reference 9, 15) entitled"Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment,".

HNP will follow Reference 15 in the development of maintenance and testing programs for equipment acquired in response to Mitigation Strategies Order EA-12-049.(ADAMS Accession No. ML13276A573) (New Open Item # 84)The NRC have recently endorsed 2 other Generic Issues associated with FLEX: 1. Use of the MAAP4 computer code in simulating the Extended Loss of AC Power (ELAP)event for Boiling Water Reactors (BWR) was endorsed for BWRs. PWRs that wish to use MAAP4 must provide additional justification.

HNP is a Westinghouse PWR and does not plan to utilize MAAP4. (ADAMS Accession No. ML13275A318)

2. Westinghouse report entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG)" specific to Combustion Engineering PWRs. HNP is a Westinghouse PWR and therefore this generic resolution is not applicable. (ADAMS Accession No. ML13276A555)

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 30, 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 Started under ELAP conditions 2 Staging analysis timeline of FLEX feedwater pump and plant Started 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 PORV Started 4 Determine if B.5.b connections 1AF-173/174/175 are adequately Started sized to meet SG feedwater requirements from decay heat (not credited)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 /> Started per cooldown strategy in PA-PSC-0965 8 Determine any adverse effects from using borated water from Started RWST in Steam Generators 9 Determine HNP specific FLEX FW pump capacity requirements Started (discharge pressure and flow)10 A FLEX/ELAP staffing analysis needs to be performed for all coping Not Started Strategies 11 Calculation needed to determine the cooling flow requirements Started 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 U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 6 of 12 Overall Integrated Plan Open Item Status 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 Attachment 3 13 RWST is partially exposed to tornado missiles and analysis will Completed need to be done to determine the volume that can be credited (Reference 12)14 Analysis to determine HNP specific high pressure make up pump Started minimum performance rating necessary to support FLEX coping strategies Analysis to determine if the ASI pump can meet the HNP minimum Canceled 15 high pressure makeup requirements. (Change 2)Analysis to determine HNP specific Modes 5 and 6 FLEX pump Started capacity requirements for RCS low pressure Injection 16 Analysis needed to confirm RCS Depressurization via Reactor Started Vessel Head Vents will be effective 17 Analysis of BAT and RWST during ELAP without heat tracing Started during cold weather conditions 18 Determine if RCS venting is needed Started 19 Analysis to determine minimum pump performance rating to support Started ESW delivery to all FLEX usage point simultaneously and prevent pump run-out 20 Analysis to determine HVAC requirements for operating installed Started and temporary equipment under ELAP conditions for maintaining reliable Operation 21 Habitability analysis needed for local manual control of SG PORVs Started in the Steam Tunnel under ELAP conditions 22 Habitability analysis for local manual control of TDAFW pump at Started RAB 236 Elevation 23 Analysis needed for loss of HVAC on TDAFW equipment Started 24 Calculation to determine power consumption assuming all HVAC is Started provided by portable blower units to support selection of FLEX generator Size 25 Analysis to determine total fuel consumption rates of all FLEX Started equipment 26 Calculation to determine pounds of boron versus RWST tank level Started percent to achieve desired boron concentration 27 Detailed analysis of consequences from performing a DC deep load Started 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 will be Not Started added to Station Batteries to provide needed margin to the plant's installed equipment's coping time 29 Analysis of the affects of AUX Reservoir water being used for heat Started removal 30 Analysis of FLEX pump suction strainer sizes to any downstream Started FLEX flow path clearances.

U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 7 of 12 Overall Integrated Plan Open Item Status 31 Containment Pressure & Temperature Analysis at extended time Started periods (is containment spray needed as a coping action?)32 Hydrogen production

& removal in Battery Rooms Started 33 Seismic analysis of lighting fixtures and analysis of lighting needs in Started the plant during ELAP 34 Analysis needed to determine portable power and pump needs for Started selected FLEX strategies 35 Analysis to determine expected length of time for FLEX equipment Started to operate under extended ELAP conditions based on operation condition 36 Analysis to provide delivery path to equipment from Fuel Oil Started Storage Tanks and FLEX Storage Facility 37 Determine impact of internal plant flooding events Not Started 38 Boil off analysis of Spent Fuel Pool during full core offload Started 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 using Started contaminated water sources for feedwater use to the Steam Generators 40 Modification

-Harden/Protect Dedicated Shutdown Diesel Canceled Generator to provide power to MCC 1 D23. (Change 1)41 Modification

-Seismically upgrade the Alternate Seal Injection Canceled System to serve as one coping strategy to provide High Pressure (Change 2)RCS injection 42 Modification

-Add an Alternate Seal Injection pump discharge path Canceled to the CVCS charging header. Add an alternate suction path to the (Change 2)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 1 D23 and all Canceled connections/distribution.

Provides power to Safety Related Battery (Change 2)Chargers and the Alternate Seal Injection System 44 Modification

-FLEX Generator(s) electrical connections at: Not Started* 1A3-SA 480V Bus (Pri)* 1 B3-SB 480V Bus (Pri)* 1A21-SA 480V MCC (Alt)* 1A31-SA 480V MCC (Alt)* 1B21-SB 480V MCC (Alt)* 1B31-SB 480V MCC (Alt)* 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 PORVs to Not Started be powered from Instrument Buses SI, SII, or SIV. Modification provides the ability to control steaming/RCS cooldown U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 8 of 12 Overall Integrated Plan Open Item Status 46 Modification

-Add FLEX pump suction and discharge connection Not Started 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 47 Modification

-Modify MDAFW FCVs control power circuit. Install Not Started 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 48 Modification

-Add FLEX RCS suction and discharge connection Not Started 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 49 Modification

-Add FLEX pump discharge connection points to the Not Started Emergency Service Water system. Provides a pressurized water source to CST, RAB & FHB Fire Protection SSE hose station headers, and Spent Fuel Pools 50 Modification

-Add quick connect connection point at 4 inch flanges Not Started downstream of valves 2DFO-262 and 2 DFO-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 51 Modification

-Install enhanced Spent Fuel Pool level indication.

Not Started Refer to NTTF 7.1 52 Modification

-Verify seismic qualification or seismically upgrade Not Started piping bounded by valves 1CT-23, 1SF-1 0, 2SF-10, and 1SF-1 93.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 53

-Add quick connects at tank locations to support 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 Hotwell, Demineralized Water Storage Tank, Filtered Water Storage Tank, and Refuel Water Storage Tank (Revised -Connections made available without plant modifications) 54 Modification

-Add FLEX connection points to the Containment Not Started Spray System. Abates high pressure/high temperature conditions inside containment 55 Modification -Add temporary power cables and connection points at Started 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 U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 9 of 12 Overall Integrated Plan Open Item Status 56 Modification

-Structure(s) built,,, in .plian, to ASG. .7 1, to Started house and protect FLEX generators and equipment (Revised 12/10/13)57 Modification

-Install FLEX distribution network to power FLEX Not Started equipment (pumps, ventilation, lighting, power outlets, and temporary power to MOVs)58 Modification

-Upgrade the installed in-plant emergency DC lighting Canceled packs with Light Emitting Diode bulbs. This will significantly extend (Change 4)the operating time of the lights installed in the plant 59 Modification

-Seismically qualify/upgrade the Condenser Hotwell Canceled Transfer Suction Piping and add isolation valve. This will (Change 3)significantly increase the credited volume of the Condensate Storage Tank 60 Develop a procedure to take local reading in containment electrical Not Started penetration, PIC, or RVLIS for all required readings 61 Contract for offsite fuel delivery Not Started 62 Contract for Demineralized Water Processing Skid or tanker Not Started delivery 63 Perform an analysis to determine the amount of volume for the Not Started RMWST that can be credited 64 Evaluate to determine that a modification can be implemented with Closed reasonable assurance of success to seismically upgrade the 12/9/13 condensate transfer pump suction line penetration to the CST and (Change 3)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 implemented with Completed reasonable assurance of success considering economic feasibility 12/10/13 to harden (seismic, flood & missile protect) the DSDG, MCC 1 D23, (Change 2)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 Not 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 Strategies and Not Started basis in an overall FLEX Basis Document 69 FLEX 4.2 Programmatic Controls -Modify existing plant Not 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 lAW NEI 12-06, Section 11.8 U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Page 10 of 12 Overall Integrated Plan Open Item Status 70 FLEX 4.2 Programmatic Controls -Training will be initiated through Started 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 protection of Started 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 selected Started FLEX strategies 74 Initiate PMs and develop testing procedures to support FSG Started guidelines for FLEX equipment 75 Develop Regional Response Center (RRC) playbook Started 76 Determine Regional Response Center (RRC) portable equipment Started requirements (water, boron, etc.)77 Determine Phase 3 equipment/commodities requirements (food, Started fuel, etc.)78 Convert to high capacity SAT phone batteries Started 79 Modification

-Modify SG PORV hydraulic pump motor MCC Started cubicles to provide for quick connection of a temporary FLEX power source b. Open Items added after August 28, 2013 Overall Integrated Plan Open Item Status 80 Update OIP submittal document for February 2014 Started 81 RCP Leakage Calc tracking audit question #17 Started 82 Ensure Compliance with Shutdown Refuel Mode Position Paper Started 83 Determine Which WCAP-17601-P Analyses Apply to HNP Started 84 Ensure Compliance with EPRI Report 3002000623 PM Basis for Started FLEX Equipment Started c. Draft Safety Evaluation Draft Safety Evaluation Open Item I Status Draft SE has not been provided N/A 7 Potential Draft Safety Evaluation Impacts The NRC staff issued the Shearon Harris Nuclear Power Plant, Unit I -Interim Staff Evaluation Relating to the Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)

U.S. Nuclear Regulatory Commission Page 11 of 12 Serial HNP-14-016 Enclosure (TAC No. MF0874) (Reference

16) on February 12, 2014. The Interim Staff Evaluation was issued after the end of the update period covered by this status report. Therefore, the open item and confirmatory items identified in the Interim Staff Evaluation are not specifically addressed in this status report.8 References The following references support the updates to the Overall Integrated Plan described in this attachment.

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-1 2-049, Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, (ADAMS Accession No. ML12054A735)

4) NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with OrderEA-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 Corporation'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 Number 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. ML1 3276A224)

U.S. Nuclear Regulatory Commission Page 12 of 12 Serial HNP-14-016 1) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWR Owners Group, Program 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 I -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)

U.S. Nuclear Regulatory Commission Serial HNP-14-016 Enclosure Attachment SERIAL HNP-14-016 ENCLOSURE ATTACHMENT REVISED AND NEW FIGURES (9 Figures)

THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED: HNP-14-016 Revised Figures 1, 10 thru 13 26 and 27 29 and 30 WITHIN THIS PACKAGE...

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