HNP-14-086, 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)

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)

ML14241A115
Person / Time
Site:	Harris
Issue date:	08/25/2014
From:	Dufner J Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, HNP-14-086
Download: ML14241A115 (23)

Text

John D. Dufner DUKE Plant Manager Harris Nuclear Plant SENERGY.

5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2000 August 25, 2014 Serial: HNP-14-086 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:

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)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, 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. 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)

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)

Ai -s

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Page 2 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 (CP&L). 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. Reference 6 provided the first six-month status report for HNP. Reference 7 provided the second six-month status report for HNP. The purpose of this letter is to provide the third 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 August 25, 2014.

Sincerely, John D. Dufner

Enclosure:

Third 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

U.S. Nuclear Regulatory Commission Serial HNP-14-086, Enclosure SERIAL HNP-14-086 ENCLOSURE THIRD 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-14-086 Enclosure Page 1 of 20 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 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). These enclosures provide an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, that occurred during the period from January 28, 2014, to July 28, 2014 (hereafter referred to as "the update period").

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

1) Submitted Second Six-Month Update

2) Identified Significant Material/Equipment 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.

Target Revised Milestone Completion Activity Status Target Date Completion Date February 28, Complete Date Not Submit Integrated Plan 2013 Revised August 28, Complete Date Not 6 Month Status Update 2013 Revised Conduct N-1 Outage Walkdowns November Complete Date Not 2013 Revised Identify Significant Material/Equipment January 2014 Complete February 2014 6 Month Status Update February 28, Complete Date Not 2014 Revised Develop Strategies / Playbook w/RRC March 2014 Started March 2015 Develop Training Program March 2014 Started September 2014

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 2 of 20 Target Revised Milestone Completion Activity Status Target Date Completion Date 6 Month Status Update August 28, Started Date Not 2014 Revised Date Not Develop Modifications October 2014 Started Revise Revised December Date Not Conduct Implementation W alkdowns 2014 Started Revise 2014 Revised Material / Equipment Procurement /

December Started Date Not Delivery 2014 Revised November Conduct Staffing Analysis January 2015 Started 2014 2014 Implement Training February 2015 Started May 2015 Date Not Install Offsite Delivery Pad February 2015 Not Started Revise Revised 6 Month Status Update February 28, Not Started Date Not 2015 Revised Develop FLEX Strategy Guidelines March 2015 Started Date Not (FSGs)

Revised Date Not Develop Maintenance Procedures March 2015 Not Started Revise Revised Date Not Implement Modifications May 2015 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) since the last six-month update period (numbering sequence is a continuation of the last six-month update).

7)

ChanQe: Confirmatory Open Item 3.2.1.5.A, Reference 16 states that HNP will add RWST and BAT level instrumentation to Essential Equipment List by updating Attachment 6 of the OIP.

Justification: During discussions with the NRC staff regarding instrumentation included on the Essential Equipment List (Attachment 6 of the OIP) HNP agreed to the addition of refueling water storage tank (RWST) and boric acid tank (BAT) level instrumentation for availability of use during a beyond design basis external event (BDBEE.) HNP has updated Attachment 6 of the OIP which is updated to the e-portal (Open Item #85 has been completed). An updated Attachment 6 is included at the end of this enclosure.

Documentation: Confirmatory Open Item 3.2.1.5A, Open Item #85 has been completed.

U.S. Nuclear Regulatory Commission Page 3 of 20 Serial HNP-14-086 Enclosure 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 Shearon Harris Unit 1 will incorporate the guidance provided in the Westinghouse position paper entitled "Westinghouse Response to NRC Generic Request for Additional information (RAI) on Boron Mixing in support of the Pressurizer Water Reactor Owners Group (PWROG)"

(ADAMS Accession Number ML13235A135) with the following clarifications:

1. The required timing for providing borated makeup to the primary system should consider conditions with no reactor coolant system leakage and with the highest applicable leakage rate for the reactor coolant pump seals and unidentified reactor coolant system leakage.

2. For the condition associated with the highest applicable reactor coolant system leakage rate, two approaches have been identified, either of which is acceptable to the staff:

a. Adequate borated makeup should be provided such that the loop flow rate in two phase natural circulation does not decrease below the loop flow rate corresponding to single-phase natural circulation.

b.

If loop flow during two-phase natural circulation has decreased below the single phase natural circulation flow rate, then the mixing of any borated primary makeup added to the reactor coolant system is not to be credited until one hour after the flow in all loops has been restored to a flow rate that is greater than or equal to the single-phase natural circulation flow rate.

3.

In all cases, credit for increases in the reactor coolant system boron concentration should be delayed to account for the mixing of the borated primary makeup with the reactor coolant system inventory. Provided that the flow in all loops is greater than or equal to the corresponding single-phase natural circulation flow rate, the staff considers a mixing delay period of one hour following the addition of the targeted quantity of boric acid to the reactor coolant system to be appropriate.

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 January 28, 2014. The table under 6.c. provides a list of open items related to the Interim Safety Evaluation (ISE).

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 Completed ELAP conditions 2

Staging analysis timeline of FLEX feedwater pump and plant specific Completed 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 Completed 4

Determine if B.5.b connections 1AF-1 73/174/175 are adequately sized to Completed meet SG feedwater requirements from decay heat (not credited)

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 4 of 20 Overall Integrated Plan Open Item Status 5

Determine how much time the CST can be relied upon for Completed 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 Completed cooldown strategy in PA-PSC-0965 8

Determine any adverse effects from using borated water from RWST in Started Steam Generators 9

Determine HNP specific FLEX FW pump capacity requirements Completed (discharge pressure and flow) 10 A FLEX/ELAP staffing analysis needs to be performed for all coping Started Strategies 11 Calculation needed to determine the cooling flow requirements beyond the Started 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 inventory Started 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 will need to be Completed 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 15 Analysis to determine if the ASI pump can meet the HNP minimum high Canceled pressure makeup requirements (Change 2)

Analysis to determine HNP specific Modes 5 and 6 FLEX pump capacity Started requirements for RCS low pressure Injection 16 Analysis needed to confirm RCS Depressurization via Reactor Vessel Started Head Vents will be effective 17 Analysis of BAT and RWST during ELAP without heat tracing during cold Started weather conditions 18 Determine if RCS venting is needed Started 19 Analysis to determine minimum pump performance rating to support ESW Completed delivery to all FLEX usage point simultaneously and prevent pump run-out 20 Analysis to determine HVAC requirements for operating installed and Started temporary equipment under ELAP conditions for maintaining reliable Operation 21 Habitability analysis needed for local manual control of SG PORVs in the Started Steam Tunnel under ELAP conditions 22 Habitability analysis for local manual control of TDAFW pump at RAB 236 Started Elevation 23 Analysis needed for loss of HVAC on TDAFW equipment Started 24 Calculation to determine power consumption assuming all HVAC is Completed provided by portable blower units to support selection of FLEX generator Size 25 Analysis to determine total fuel consumption rates of all FLEX equipment Completed 26 Calculation to determine pounds of boron versus RWST tank level percent Completed to achieve desired boron concentration 27 Detailed analysis of consequences from performing a DC deep load shed.

Started Specifically to determine what equipment is still needed to carry-out FSG coping functions. Instrument loops and etc.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 5 of 20 Overall Integrated Plan Open Item Status 28 Detailed calculation needed to validate the coping time that will be added Started 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 FLEX Completed flow path clearances 31 Containment Pressure & Temperature Analysis at extended time periods Started (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 the Started 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 to Started operate under extended ELAP conditions based on operation condition 36 Analysis to provide delivery path to equipment from Fuel Oil Storage Started Tanks and FLEX Storage Facility 37 Determine impact of internal plant flooding events Started 38 Boil off analysis of Spent Fuel Pool during full core offload immediately Started 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 Generator to Canceled provide power to MCC 1 D23 (Change 1) 41 Modification - Seismically upgrade the Alternate Seal Injection System to Canceled serve as one coping strategy to provide High Pressure RCS injection (Change 2) 42 Modification - Add an Alternate Seal Injection pump discharge path to the Canceled CVCS charging header. Add an alternate suction path to the Alternate (Change 2)

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 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:

Started

• 1A3-SA 480V Bus (Pri)

• 1B3-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 be Design-Started powered from Instrument Buses SI, SII, or SIV. Modification provides the Implementation-ability to control steaming/RCS cooldown Not Started 46 Modification - Add FLEX pump suction and discharge connection points to Design-Started

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 6 of 20 Overall Integrated Plan Open Item Status the AFW system upstream of Motor Driven AFW flow control valves.

Implementation-Modification will provide AFW flow control and the ability to provide Not Started inventory to the Steam Generators from portable pumps 47 Modification - Modify MDAFW FCVs control power circuit. Install key Design-Started switch jumper in to simulate a Motor Driven Auxiliary Feedwater pump breaker closed. ARP 19A (SA) R2 terminal 119 & 120. Provides 125 V DC Implementation-power to ARP1 9A(SA) and instrument bus SI for the purpose of operators Not Started controlling feedwater flow to the Steam Generators from the MCB 48 Modification - Add FLEX RCS suction and discharge connection points to Design-Started CVCS on A & B train. Provides the capability to inject inventory (borated)

Implementation-from a FLEX pump to the RCS from the BAT or RWST Not Started 49 Modification - Add FLEX pump discharge connection points to the Design-Started Emergency Service Water system. Provides a pressurized water source to CST, RAB & FHB Fire Protection SSE hose station headers, and Spent Not Started Fuel Pools 50 Modification - Add quick connect connection point at 4 inch flanges Design-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 Implementation-fuel delivery to operating FLEX equipment Not Started 51 Modification - Install enhanced Spent Fuel Pool level indication. Refer to Started NTTF 7.1 52 Modification - Verify seismic qualification or seismically upgrade piping Design-Started bounded by valves 1 CT-23, 1SF-1 0, 2SF-1 0, and 1SF-1 93. Allows HNP to Design-Starte credit Spent Fuel Make-up from the RWST via the installed Fuel Pool Cooling Pumps which are being powered from a FLEX generator. Also Implementation-allows HNP to credit ESW Emergency Makeup to Spent Fuel Pools 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 Design-Started Storage Tank from the Reactor Make-up Water Storage Tank, and CST from the Condenser Hotwell, Demineralized Water Storage Tank, Filtered Implementation-Water Storage Tank, and Refuel Water Storage Tank Not Started 54 Modification - Add FLEX connection points to the Containment Spray Not Started System. Abates high pressure/high temperature conditions inside containment 55 Modification -Add temporary power cables and connection points at select Started 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 in; c

,.mplian.o to ASE7 10 to house and Started protect FLEX generators and equipment (Revised 12/10/13) 57 Modification - Install FLEX distribution network to power FLEX equipment Started (pumps, ventilation, lighting, power outlets, and temporary power to MOVs) 58 Modification - Upgrade the installed in-plant emergency DC lighting packs Canceled with Light Emitting Diode bulbs. This will significantly extend the operating (Change 4) time of the lights installed in the plant 59 Modification - Seismically qualify/upgrade the Condenser Hotwell Transfer Canceled Suction Piping and add isolation valve. This will significantly increase the (Change 3) credited volume of the Condensate Storage Tank

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 7 of 20 Overall Integrated Plan Open Item Status 60 Develop a procedure to take local reading in containment electrical 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 delivery Completed 63 Perform an analysis to determine the amount of volume for the RMWST Completed that can be credited 64 Evaluate to determine that a modification can be implemented with Closed reasonable assurance of success to seismically upgrade the condensate 12/9/13 transfer pump suction line penetration to the CST and estimated total CST (Change 3) 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 to 12/10/13 harden (seismic, flood & missile protect) the DSDG, MCC 1 D23, ASI (Change 2)

Pump, ASI Tank, associated system piping and all electric connections/distribution and instrumentation 66 FLEX 4.2 Programmatic Controls - Implement programmatic controls for Started 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 processes to Not Started 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 basis Not Started in an overall FLEX Basis Document 69 FLEX 4.2 Programmatic Controls - Modify existing plant configuration Not Started 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 70 FLEX 4.2 Programmatic Controls - Training will be initiated through the Started 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 the Started 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 Programs to Started 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 FLEX Started strategies 74 Initiate PMs and develop testing procedures to support FSG guidelines for Started FLEX equipment

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 8 of 20 Overall Integrated Plan Open Item Status 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, fuel, etc.)

Started 78 Convert to high capacity SAT phone batteries Completed 79 Modification - Modify SG PORV hydraulic pump motor MCC cubicles to Started provide for quick connection of a temporary FLEX power source 80 Update OIP submittal document for February 2014 Completed 81 RCP Leakage Calc tracking audit question #17 Started 82 Ensure Compliance with Shutdown Refuel Mode Position Paper Started 83 Determine Which WCAP-1 7601-P Analyses Apply to HNP Started 84 Ensure Compliance with EPRI Report 3002000623 PM Basis for FLEX Started Equipment

b. Open Items added after January 28, 2014 Overall Integrated Plan Open Item Status 85 Add RWST and BAT level instrumentation to Essential Equipment List by Completed updating Attachment 6 of the OIP.

(Change 7) 86 Ensure compliance with NRC Battery Life Issue White Paper.

Started

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 NRC's endorsement letter, nor (2) identified an acceptable alternate approach for justifying Completed the boric acid mixing assumptions in the analyses supporting its (Section 6) mitigating strategy. As such, resolution of this concern for HNP is needed.

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

Completed 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.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 9 of 20 Item #

Description Status 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-1 7601, 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 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 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. Licensee-identified Open Item #27.

3.1.1.3.A Internal Plant Flooding events - Completion of analysis to determine the impact of internal plant flood events. Tracked by Open Item #37.

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.

3.1.4.2.A The licensee stated that the engineering evaluation required to support the modification identified in licensee-identified Open Item #49 will address configuration and operation of the FLEX equipment under extreme cold, snow, or ice conditions. Licensee-identified Open Item

1. 49 should be reviewed during the 6-month update to ensure that the engineering evaluation was added to it.

Completed

Response

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

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 10 of 20 Item #

Description Status 3.2.1.A Section 3.2 of WCAP-1 7601 discusses the 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 applicable to Started 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 PWR OG 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-1 7601 -P.

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 responded by stating that a vendor resource Started will assist in determining which WCAP-1 7601-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 PWR OG 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-1 7601 -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 Started condensation cooling.

Tracked by Open Item #83. PWR OG 14015-P.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 11 of 20 Item #

Description Status 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

1. 31). The NRC staff also noted that the SBO analyses discussed above used Modular Accident Analysis Program (MAAP) Version 3 for an analytical tool. Justification for the appropriateness of MAAP3 for Completed containment analyses should be provided.

Response

HNP containment analysis is being performed under GOTHIC calculations.

Tracked by Open Item #31.

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 changed to non-Westinghouse Started 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 PWR OG 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-1 7601 -P.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 12 of 20 Item #

Description Status 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 0-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 integrity Started 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 PWR OG 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.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-1 7601 and for Item g, HNP intends to conduct a symmetric cooldown in response to ELAP. A licensee-identified Open Item has Started been generated to track items a, b, c, d, and f. The time table, details of licensee's 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 PWR OG 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-1 7601-P.

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

Tracked by Open Item #10.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 13 of 20 Item #

Description Status 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) in Modes 1-4.

Completed As provided in Reference 12, 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 P0201343 for delivery of a Water Treatment skid as listed in Reference 18, Section 8.7 and Table 9-1.

Tracked by Open Item #11 & 12.

3.2.1.8.B The licensee responded by stating that analyses addressing recriticality 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 of these Started analyses need to be made available for review.

Tracked by Open Items #12.

3.2.1.9.A Completion of analyses to determine adequate performance criteria of FLEX portable pumps to support the licensee's phase 2 FLEX strategies.

Started Tracked by Open Item #14. Open Items #9 & #19 also support this analysis and are closed.

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 Item #31 is tracking Started 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 duration of TDAFW pump operation under ELAP conditions.

Completed Tracked by Open Item #1 and #30 which are now closed.

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

Started Tracked by Open Item #22 & #23.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 14 of 20 Item #

Description Status 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 high and low temperatures.

Started Tracked by Open Item #20.

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

Started Tracked by Open Item #32.

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

Started Tracked by Open Item #17.

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

Started Tracked by Open Item #33.

3.2.4.4.8 Communications. Confirm that upgrades to the site's communications systems have been completed.

Completed Tracked by Open Item #78 and is now closed.

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 determine if any specific actions are required to cope with extreme Started temperatures. These evaluations, once completed, need to be available for review.

Tracked by Open Item #20.

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 water capacity. The licensee stated that licensee-identified Open Item #5 is Completed 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.

Tracked by Open Item #5 and is now closed.

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 that determines the volume that can be credited for a borated water source Completed from the RWST.

Tracked by Open Item #13 which is now closed.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 15 of 20 Item #

Description Status 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 resources arrive for Completed replenishment. Confirm FLEX equipment total fuel consumption rate.

Tracked by Open Item #25 which is now closed.

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

Started Tracked by Open Item #36.

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 plant's Started installed equipment's coping time.

Tracked by Open Item #27.

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

Completed Tracked by Open Item #24 which is now closed.

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, 76.

7 Potential Draft Safety Evaluation Impacts The NRC 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) (TAC No. MFO874) (Reference 16) on February 12, 2014. The open item and confirmatory open items identified in the Interim Staff Evaluation are addressed in this report.

U.S. Nuclear Regulatory Commission Page 16 of 20 Serial HNP-14-086 Enclosure 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-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 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 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 17 of 20 Serial HNP-14-086 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)

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 18 of 20 The following is a revised Attachment 6, Essential Instrumentation Table, to the Overall Implementation Plan (OIP) as discussed above in Section 4, Changes to Compliance Method.

This revised Attachment 6 replaces the Attachment 6 previously submitted in Reference 1 in its entirety.

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 19 of 20 Overall Integrated Plan: EA-12-049 ESSENTIAL INSTRUMENTATION TABLE INSTRUMENT CORE RCS INVENTORY PARAMETER INTUETCR CIVNOY CONTAINMENT FUEL POOL NUMBER(S)

COOLING CONTROL/BORATION RCS Hot Leg TE-413/TE-423/TE-433 X

Temperature (THOT)

RCS Cold Leg TE-41 O/TE-420/TE-430 X

Temperature (TcoLD)

RCS Wide Range PT-402 X

(WR) Pressure PT-403 X

SG Narrow Range LT-473/LT-483/LT-493 X

(NR) Level LT-474/LT-484/LT-494 X

LT-475/LT-485/LT-495 X

LT-476/LT-486/LT-496 X

SG Wide Range LT-477/LT-487/LT-497 X

(WR) Level Core Exit ICCM Train A X

Thermocouple ICCM Train B X

Temperatures Pressurizer Level LT-459/LT-460/LT-461 X

Reactor Vessel Level RVLIS Train A X

X Indicating System RVLIS Train B X

X (RVLIS)

Refueling Water LT-990/LT-991/LT-992/

X X

X Storage Tank LT-993 Boric Acid Tank LT-106/LT-161 X

X AFW Pump Flow FT-2050A/ FT-2050B/

X FT-2050C X

SG Pressure PT-474/PT-484/PT-494 X

PT-475/PT-485/PT-495 X

PT-476/PT-486/PT-496 X

CST Level LT-9010A X

LT-9010B X

U.S. Nuclear Regulatory Commission Serial HNP-14-086 Enclosure Page 20 of 20 Overall Integrated Plan: EA-12-049 ESSENTIAL INSTRUMENTATION TABLE INSTRUMENT CORE RCS INVENTORY PARAMETER INTUETCR CIVNOY CONTAINMENT FUEL POOL NUMBER(S)

COOLING CONTROL/BORATION 125 VDC Battery/DC EI-01EE-1798C1SAV X

X X

X Bus Voltage (local)

EI-01EE-1799D1SBV X

X X

X (local)

Safety Related EI-01EE-1798A1SAV X

X X

X Battery Charger (local)

Voltage EI-01EE-1798B1SAV X

X X

X (local)

EI-01EE-1799A1SBV X

X X

X (local)

EI-01EE-1799B2SBV X

X X

X (local)

Safety Related EI-01EE-1798A2SAV X

X X

X Battery Charger (local)

Amperage EI-01EE-1798B2SAV X

X X

X (local)

EI-01EE-1799A2SBV X

X X

X (local)

EI-01EE-1799B2SBV X

X X

X (local)

Neutron Flux Neutron Flux Monitoring X

NI-60 Neutron Flux Monitoring X

NI-61 Containment PT-950/PT-951/

X Pressure PT-952/PT-953 X

Fuel Pool Level TBD (Open Item #51)

X (Reference 38)