ONS-2015-023, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML15063A027
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 02/27/2015
From: Batson S
Duke Energy Carolinas, Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ONS-2015-023
Download: ML15063A027 (16)
v • d • e


Text

Scott L. Batson Vice President

ENERGY, Oconee Nuclear Station Duke Energy ONOIVP I 7800 Rochester Hwy ONS-2015-023 Seneca, SC 29672 o: 864.873.3274
f. 864.873.4208 Scott.Batson@duke-energy.com February 27, 2015 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55

Subject:

Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (Accession No. ML12054A735).
2. Oconee Nuclear Station's 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 (Accession No. ML13063A065).
3. Oconee Nuclear Station's 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 29, 2013 (Accession No. ML13246A009).
4. Oconee Nuclear Station's 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 28, 2014 (Accession No. ML14064A197).
5. Oconee Nuclear Station's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 27, 2014 (Accession No. ML14245A019).
6. NEI 12-06, [Rev. 0], Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 (Accession No. ML12242A378).

-A S/

ONS-2015-023 February 27, 2015 Page 2 Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to Duke Energy which was immediately effective and directed Duke Energy to develop 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. The Order required that, following NRC's issuance of its final Interim Staff Guidance (ISG), Duke Energy would submit an Overall Integrated Plan (OIP), followed by status reports at six-month intervals.

Duke Energy has thus far submitted the OIP (Reference 2), and three six-month reports (References 3, 4, and 5) for Oconee Nuclear Station. The purpose of this letter is to provide the fourth six-month status report. The enclosure provides updates related to compliance with NRC Order EA-12-049 and Nuclear Energy Institute (NEI) 12-06 (Reference 6) during the July 29, 2014 to January 28, 2015 update period.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact David Haile with Oconee Regulatory Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 27, 2015.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station

Enclosure:

1. Oconee Nuclear Station, Fourth Six-Month Status Report for Order EA-12-049 (FLEX),

Units 1, 2, and 3.

ONS-2015-023 February 27, 2015 Page 3 cc:

Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James R. Hall, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike, M/S O-8G9A Rockville, MD 20852-2746 Mr. Jeffery Whited (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ENCLOSURE1 Oconee Nuclear Station (ONS)

Fourth Six Month Status Report for Order EA-12-049 (FLEX),

Units 1, 2, and 3 Encl. Page 1 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

1) Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference El) to Duke Energy which required the development of guidance and strategies related to mitigation of a beyond-design-basis external event. The Order required each plant to issue an Overall Integrated Plan (OIP) pursuant to the NRC's Interim Staff Guidance (ISG)

(Reference E2) which endorsed, with clarifications and exceptions, the industry guidance document, NEI 12-06 (Reference E3). The Order also required that update reports on progress or change to the OIP be submitted every six months.

An Overall Integrated Plan (Reference E4) was developed based on the diverse and flexible strategies (FLEX) from NEI 12-06 in response to NRC Order EA-12-049 and was submitted to the NRC on February 28, 2013. The first six-month update was provided to the NRC on August 29, 2013 (Reference E5). The second six-month update was provided to the NRC on February 28, 2014 (Reference E18). The third six-month update was provided to the NRC on August 27, 2014 (Reference E28). This report constitutes the fourth six-month update, and reports milestone accomplishments, changes to the compliance method or schedule, or any need for relief/relaxation, and the basis, which occurred during the period from July 29, 2014 to January 28, 2015 (hereafter referred to as "the update period").

2)

Milestone Accomplishments (during the update period)

The following milestone(s) were completed:

1. The third six month status report was submitted August 27, 2014.
2. Based on current strategies, the N-1 Outage Walkdowns for Oconee Unit 1 were deemed as not necessary. Thus, that milestone is considered to have been completed.
3)

Milestone Schedule Status The following represents the milestone status at the end of the update period. The table reflects updates to the milestone table in Attachment 2 of the Overall Integrated Plan. It provides the status of each activity, and whether the target completion date has changed.

Note: The dates are planning dates, and are subject to change as design and implementation details are developed. Revised target completion dates are not expected to impact the implementation date(s) of the Order.

Tavrget

_ tetion mpeflons a ie

~M~etoe.Dae Activity Dateg

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L icensing ;-Actions:

Submit Overall Integrated Plan Feb 2013 Complete Date Not Revised Submit 6 Month Update 1 Aug 2013 Complete Date Not Revised Submit 6 Month Update 2 Feb 2014 Complete Date Not Revised Submit 6 Month Update 3 Aug 2014 Complete Date Not Revised Submit 6 Month Update 4 Feb 2015 This Submittal Date Not Revised Submit 6 Month Update 5 Aug 2015 Not Started Date Not Revised Submit 6 Month Update 6 Feb 2016 Not Started Date Not Revised Submit 6 Month Update 7 Aug 2016 Not Started Date Not Revised Encl. Page - 2 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note. The references for this Enclosure are listed in Section 8)

T-arget M6~lif~catlon Develop Modifications Aug 2016 Started Date Not Revised

..Proc ulr In Identify Significant Material/Equipment Sept 2013 Complete Date Not Revised Material/Equipment Procurement/Delivery May 2015 Started Date Not Revised Impleniitatiw lh~,aikdo~wns:i Conduct N-I Outage Walkdowns - U1 Nov 2014 Complete Date Not Revised Conduct N-I Outage Walkdowns - U2 Nov 2013 Complete Date Not Revised Conduct N-I Outage Walkdowns - U3 May 2014 Complete Date Not Revised Conduct Implementation Walkdowns - U1 Oct 2016 Not Started Date Not Revised Conduct Implementation Walkdowns - U2 Oct 2015 Not Started Date Not Revised Conduct Implementation Walkdowns - U3 April 2016 Not Started Date Not Revised St g:

Conduct Staffing Analysis July 2016 Started Date Not Revised Training.:

Develop Training program - Ul July 2016 Started Date Not Revised Develop Training program - U2 July 2015 Started Date Not Revised Develop Training program - U3 Jan 2016 Started Date Not Revised Implement Training - U1 Oct 2016 Started Date Not Revised Implement Training - U2 Oct 2015 Started Date Not Revised Implement Training - U3 April 2016 Started Date Not Revised Procedures:

Develop FLEX Supporting Guidelines June 2016 Started Date Not Revised (FSGs)

June_2016 Started DateNotRevised Develop Maintenance Procedures June 2016 Not Started Date Not Revised Rtegio nirReSponse C e'ners;:

Develop Strategies/Playbook with RRC April 2015 Started Date Not Revised Install Offsite Delivery Pad March 2015 Started August 2015 Implementation::.

Implement Modifications - Ul Nov 2016 Started Date Not Revised Implement Modifications - U2 Nov 2015 Started Date Not Revised Implement Modifications - U3 May 2016 Started Date Not Revised Encl. Page - 3 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

4) Changes to Compliance Method No changes to compliance methods that are alternatives to NEI 12-06 were made.
5)

Need for Relief and Basis for the Relief Duke Energy Carolinas, LLC (Duke Energy), Oconee Nuclear Station, Units 1, 2, and 3 anticipates meeting the Order implementation date and no relief is required at this time.

6)

Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary status of the Open Items. The table Section 6.a.

provides the open items identified in the original OIP submitted on February 28, 2013. The table Section 6.b. provides a list of open items that were added after February 28, 2013 through the end of the update period. The table Section 6.c. provides a list of open and confirmatory items related to the Interim Staff Evaluation (ISE) (Reference E19). The table Section 6.d.

addresses any generic concerns (No new generic issues were identified during this update period).

a) Open Items Documented in the Overall Integrated Plan Overall Integrated Plan Open Items Statu's

1. Revised PMP IIMR51 Analysis In Progress: 2.1 Flood Re-analysis Completed - Pending NRC Approval In Progress: 2.1 Flood Re-analysis
2. Max flood level on site 'after modifications' Competed 2 Pend RC-apal Completed - Pending NRC Approval
3. Deployment Path Program Started
4. Procedures and FSGs Started
5. FLEX Equipment Programmatic Control Started
6. Personnel Training Started
7. FLEX Basis Document Started
8. Configuration Control Started
9. RRC Started
10. Cooldown Analysis Started
11. ADV Survivability and Accessibility Started
12. Load Shed Analysis Completed 12.__LoadShedAnalysis_

(Reference E25, Attachment 3)

Completed

13. Hydraulic Analysis for Pump Flow (Intake Canal to SGs)

Analysis results are acceptable (Reference E22)

14. Fuel Oil Consumption Completed (Reference E25, Attachment 4)

Completed

15. Hydraulic Analysis for Pump Flow (CTP-1 to SGs)

Analysis results are acceptable (Reference E22)

Encl. Page - 4 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8) rallintegrated Planpen Items S.,

16. Water in embedded CCW lines & Hydraulic Analysis for Completed Pumping Configuration (Reference E26)
17. PSW Modification (EC 91877)

Completed

18. Alternate FLEX Connections Modification (SG Makeup)

Completed (Reference E23)

19. Breaking Siphons in Embedded CCW Piping Started
20. Instrumentation Repower (Alternate Repower Strategy)

Started

21. FLEX Equipment Storage Started
22. Portable Power Distribution (Primary Repower Strategy)

Started

23. Long term SG and SFP Makeup Started Completed
24. Hydrogen Buildup Analysis (Reference E27 Section 3.14 and Attachment E)
25. BWST Tap Analysis and Modification (RCS Makeup)

Started

26. Containment Analysis Started
27. Hydraulic Analysis for Pump Flow (CTP-1 to SFPs &

Started Intake Canal to SFPs)

Completed

28. Robustness of SFP Refill Lines Validated SFP Refill Lines are installed as QA-1 and are seismically robust (References E6 & E7)
29. Lighting Evaluation Not Started
30. Communication Assessment Started
31. NEI 12-01 (Reference E24) Staffing Study Started
32. HVAC Analysis Started b) Open Items added after February 2 8 th 2013 Open Items Status.
33. Evaluate changes to the RCSMU FLEX Strategy recommended by independent audit to eliminate the SSF Completed RCMUP repower strategy and implement train specific (Reference E25 Attachment 2) 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)

Started deployed on the Turbine Building deck to provide 120 VAC feeds to connections in the control room and cable room to repower the key instrumentation parameters.

Encl. Page - 5 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

VO""

'Ims Status

35. Validate the 10' assumed inundation level discussed in the OIP [Assumption #8] is still conservative with respect to the Defense in Depth Modifications analyzed in OIP This item superseded by Open Item 40 Reference 48 (which used a slightly modified model run) and the credited CAL model run in OIP reference 14.
36. Perform raw water fouling analysis for core cooling and Started heat removal.

37, Evaluate freeze protection requirements in areas of the plant that contain equipment used in FLEX strategies.

38, Evaluate and establish a technical basis for use of non-safety related, installed equipment credited for mitigating Started an ELAP event.

39, FLEX Strategy for Shutdown Modes: Determine what mods, procedures, equipment, etc. is needed to support a Started Shutdown Modes FLEX Strategy.

40, Clarification of Applicable External Flooding Hazard at Started ONS.

Interim Staff Evaluation (ISE)

" SF Open: Items Status

1. Provide a description and justification for the specific evaluation model(s) used in the ELAP analyses for Oconee (ISE Not Started Open Item # 3.2.1..A).
2. The licensee should either (1) develop a successful mitigating strategy that does not rely on repowering the SSF RCMU pumps following recession of floodwaters or (2) provide Completed adequate justification that the SSF RCMU pumps can reliably be (Reference E25 Attachment 2) repowered following recession of floodwaters (ISE Open Item #

3.2.1.6.A).

3. Provide adequate basis that nitrogen from the core flood tanks will not be injected into the reactor coolant system (ISE Open Not Started Item # 3.2.1.6.B).
4.

When further analyses are completed, the licensee should provide additional information that either supports a conclusion that pressurizer relief or safety valves do not lift during the ELAP Not Started event or that lifting of the valve(s), if it occurs, is acceptable (ISE Open Item # 3.2.1.6.C).

Encl. Page - 6 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

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5.

Provide additional information demonstrating successful mitigation of an ELAP event involving an uncontrolled cooldown resulting from consequential damage to the main steam system Started due to the severe natural hazard that initiates the ELAP event (ISE Open Item # 3.2.1.6.D).

6. Demonstrate that Oconee's approach for modeling boric acid mixing is consistent with a generically acceptable methodology or develop a plant-specific technical basis to support the Not Started modeling assumptions for boric acid mixing in the ELAP analysis for Oconee (ISE Open Item # 3.2.1.8.B).

.IS onfirmatoqry Items Status

7. Confirm that ONS's final FLEX equipment deployment routes include adequate consideration of potential soil liquefaction or Not Started other conditions that could impede movement following a severe seismic or other BOB event (Confirmatory Item # 3.1.1.2.A).
8. Confirm that the licensee's reference source providing guidance for operators to obtain instrument readings under ELAP Not Started conditions adequately addresses the considerations in NEI 12-06, Section 5.3.3, consideration (1) (Confirmatory Item # 3.1.1.3.A).
9.

Confirm that the details for delivery and staging of off-site resources in the licensee's RRC playbook developed by the Not Started SAFER team and the utility are acceptable for all BDBEEs (Confirmatory Item # 3.1.1.4.A).

10. To show conformity with NEI 12-06, Section 6.2.3.2, consideration 2, confirm that persistent, prohibitive flooding Not Started levels will not occur at the ONS site (Confirmatory Item # 3.1.2.2.A).
11. Confirm that the final ELAP computer code analyses for core cooling, reactor coolant system inventory, shutdown margin, and containment integrity have acceptable methodology and Not Started assumptions and support the sequence of events timeline (Confirmatory Item # 3.2.1..B).
12. Reliance on the RELAP5/MOD2-Babcock & Wilcox (B&W) and RETRAN-30 codes in the ELAP analysis for B&W plants should be limited at the present time to the flow conditions prior Not Started to boiler-condenser cooling initiation. Confirm that the code is not used outside this range (Confirmatory Item # 3.2.1.1.C).
13. Confirm the means of isolating RCP seal return and RCS letdown in accordance with the Jocassee dam break procedure and the Not Started associated timeframe (Confirmatory Item # 3.2.1.2.A).

Encl. Page - 7 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

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14. Confirm that RCP seal temperature would be maintained at an acceptably low value by establishing injection flow to the RCP Not Started seals via the SSF RCMU pump within 20 minutes of event initiation (Confirmatory Item # 3.2.1.2.B).
15. Confirm there is justification for the assumed seal leakage rates for the Bingham RCPs with Sulzer seal assemblies Not Started (Confirmatory Item # 3.2.1.2.C).
16. Confirm there is justification for the assumed seal leakage rates for the Westinghouse 93-A RCPs with Flowserve N-9000 seals Not Started with the Abeyance feature (Confirmatory Item # 3.2.1.2.D).
17. Confirm that steam generator pressure indication will be available to support the cooldown directed by the ELAP mitigating strategy, or provide adequate basis that such indication is Started unnecessary even at average reactor coolant temperatures below 525 degrees Fahrenheit (Confirmatory Item # 3.2.1.5.A).
18. Confirm that the final containment analysis (open item 26) demonstrates that there will be no impact on the credited Not Started instrumentation (Confirmatory Item # 3.2.1.5.B).
19. When evaluations are completed, confirm that the survivability and performance of the atmospheric dump valves is adequate to Not Started support ONS's mitigation strategy (Confirmatory Item # 3.2.1.6.E).
20. Confirm that the analysis to determine Oconee's boration requirements in Phase 2 of the mitigating strategy provides Not Started acceptable results (Confirmatory Item # 3.2.1.8.A).
21. Confirm that the BWST design provides tornado missile protection to ensure a source of borated water Not Started (Confirmatory Item # 3.2.1.8.C).
22. Confirm the portable pump capability requirements and fuel requirements to implement Phase 2 and Phase 3 strategies Started (Confirmatory Item # 3.2.1.9.A).
23. Confirm acceptability of the SFP cooling strategy when it is Not Started completed (Confirmatory Item # 3.2.2.A).
24. Confirm that the results of the licensee's containment analysis beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are acceptable (ONS open item 26)

Not Started (Confirmatory Item # 3.2.3.A).

25. Confirm using the analysis of hydrogen buildup (open item 24),

that there will be no impact on the Phase 2 ventilation strategies Not Started (Confirmatory Item # 3.2.4.2.A).

Encl. Page - 8 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8) iS,.., *oiff*oirems i

S, tatus :

26. Confirm that the results of ONS's evaluation of building and area temperatures (licensee-identified open item 32), are acceptable to Not Started support the licensee's proposed ELAP mitigation strategies (Confirmatory Item # 3.2.4.2.B).
27. Confirm that the licensee's evaluation of freeze protection (ONS Not Started open item 37) is acceptable (Confirmatory Item # 3.2.4.3.A).
28. Confirm that the licensee's analysis of lighting (open item 29) is Not Started acceptable (Confirmatory Item # 3.2.4.4.A).
29. Confirm that upgrades to the site's communications systems have Not Started been completed (Confirmatory Item # 3.2.4.4.B).
30. Confirm that ONS's FLEX strategies with regard to protected and internal locked area access are acceptable Not Started (Confirmatory Item # 3.2.4.5.A).
31. Confirm that the use of non-safety related installed equipment (licensee's open item 38) is acceptable Not Started (Confirmatory Item # 3.2.4.7.A).
32. Confirm that the licensee's strategy for providing chemical treatment pond make up water at a rate of 700,000 gallons per Not Started day following a flooding event is acceptable. This is ONS Open Item 23 in the Integrated Plan (Confirmatory Item # 3.2.4.7.B).
33. Confirm that ONS's processes and procedures to prevent inappropriate interactions of portable electrical power sources with permanent plant equipment (ONS's open item 4) conforms to Not Started the guidance in NEI 12-06, Section 3.2.2, Guideline (13), or provides an acceptable alternative to that guidance (Confirmatory Item # 3.2.4.8.A).
34. Confirm that the licensee's FLEX generator sizing calculations/analysis and single line diagrams showing proposed Not Started connections of FLEX electrical equipment are acceptable (Confirmatory Item # 3.2.4.8.B).
35. Confirm that the licensee's fuel oil consumption analysis Completed (licensee's open item 14) is acceptable (Reference E25, Attachment 4)

(Confirmatory Item # 3.2.4.9.A).

36. Confirm the licensee has considered the coordination of SSF and portable equipment during a "T=0" event, explaining what criteria Completed will be used to determine when to switch from use of the SSF to (Reference E25, Attachment 1) use of portable equipment and to explain whether the SSF can be used beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Confirmatory Item # 3.2.4.9.B).

Encl. Page - 9 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

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37. Confirm that the licensee's analyses on load shedding (licensee's open item 12), and summaries of battery sizing calculations for Completed both seismic and flooding scenarios of ELAP are acceptable (Reference E25 Attachment 3)

(Confirmatory Item # 3.2.4.10.A).

38. Confirm that the licensee's implementation of maintenance and testing guidance for FLEX equipment is acceptable Not Started (Confirmatory Item # 3.3.1.A).
39. Offsite Resources - Confirm NEI 12-06 Section 12.2, Guidelines 2 through 10, are addressed with SAFER Not Started (Confirmatory Item # 3.4.A).

d) Generic Concerns The following summarizes ONS's review of six generic issues:

i. Electric Power Research Institute (EPRI) Report 3002001785, Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications and NRC endorsement (Reference E8 & Reference E17).

The Oconee mitigating strategy is evaluated using RELAP5 and RETRAN for the NSSS response, and FATHOMS and GOTHIC for the containment response.

ii. Electric Power Research Institute (EPRI) Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment and NRC endorsement (Reference E9 & Reference E10).

  • ONS intends to follow EPRI Report 30002000623 in the development of maintenance and testing programs for equipment acquired in response to Mitigation Strategies Order EA-12-049 unless otherwise justified.

iii. Westinghouse report, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG) and NRC endorsement (Reference EllI &

Reference E12).

  • The Oconee mitigating strategy is evaluated using RELAP5 and RETRAN for the NSSS response, and FATHOMS and GOTHIC for the containment response.

iv. Nuclear Energy Institute (NEI) position paper, Position Paper: Shutdown/Refueling Modes and NRC endorsement (Reference E13 & Reference E14).

  • It is Oconee's intent to abide by the NEI position paper for shutdown and refueling modes.

Encl. Page - 10 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note.- The references for this Enclosure are listed in Section 8)

v. Nuclear Energy Institute (NEI) white paper, Battery Life Issue and NRC endorsement (Reference E15 & Reference E16).
  • The SSF has a design basis mission time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ONS plans to utilize the SSF as long as it remains operational. After an ELAP is determined, ONS will utilize the SSF in a dual loop feed to cooldown to 240-250 degrees. ONS will simultaneously deploy Phase 2 equipment during this timeframe utilizing the priority established from our thermal-hydraulic analysis. All instrument readings required to support the ELAP cool down are available in the SSF during this Phase 1 time period. This will allow time to deploy the primary repower strategy to repower the vital battery chargers and associated busses without performing additional load shedding. This approach eliminates resources required to perform additional load shedding activities on all 3 units in the T+2, to T+3 hour timeframe in which many critical activities are underway and eliminates potential unanticipated interactions created by load shed activities.

Based on the above, the station vital batteries will be available for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after loss of power.

vi. Westinghouse position paper, Westinghouse Response to NRC Generic Request for Additional information (RAI) on Boron Mixing in support of the Pressurizer Water Reactor Owners Group (PWROG) and NRC endorsement (References E20 & E21).

  • Oconee Nuclear Station will address this generic issue in the ISE Open Item
  1. 3.2.1.8.B.
7)

Potential Interim Staff Evaluation Impacts There are no potential impacts from the Interim Staff Evaluation identified.

8)

References The following references support the updates to the Overall Integrated Plan described in this enclosure:

El.

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 (Accession No. ML12054A735).

E2.

NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-2-049, Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External Events, dated August 29, 2012 (Accession No. ML12229A174).

E3.

NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 (Accession No. ML12242A378).

E4.

Duke Energy Letter, Oconee Nuclear Station, Units 1,2 and 3 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 2 8th, 2013 (Accession No. ML13063A065).

E5.

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 29, 2013 (Accession No. ML13246A009).

E6.

Flow Diagram - Unit 1 & 2 Spent Fuel Cooling System (104A-1.1, Revision 53).

Encl. Page - 11 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

E7.

Flow Diagram - Unit 3 Spent Fuel Cooling System (104A-3.1, Revision 48).

E8.

EPRI Report 3002001785, Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications, dated June 2013 (Accession No. ML13190A201).

E9.

EPRI Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment, dated September 2013 (Accession No. ML13276A573).

E10. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock Vice President Nuclear Operations, dated October 7, 2013 (Accession No. ML13276A224).

El1. Westinghouse Report, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG), dated September 25, 2013 (Withheld from public disclosure).

E12. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Jack Stringfellow, PWR Owners Group, Program Management - Westinghouse, October 7, 2013 (Accession No. ML13276A555).

E13. NEI Position Paper, Shutdown/Refueling Modes, dated September 18, 2013 (Accession No. ML13273A514).

E14. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 30, 2013 (Accession No. ML13267A382).

E15. NEI White Paper, Battery Life Issues, dated August 21, 2013 (Accession No. ML13241A186).

E16. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 16, 2013 (Accession No. ML13241A188).

E17. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 3, 2013 (Accession No. ML13275A318).

E18. 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 28, 2014 (Accession No. ML14064A197).

E19. NRC letter from Jeremy S. Bowen, Mitigating Strategies Directorate (NRR), Mr. Scott Batson, Site Vice President Oconee Nuclear Station, dated February 10, 2014 (Accession No. ML13365A258).

E20. Westinghouse Position Paper, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in support of the Pressurizer Water Reactor Owners Group (PWROG), dated August 16, 2013 (Accession No. ML13235A135).

E21. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Jack Stringfellow, PWR Owners Group, Program Management - Westinghouse, dated January 8, 2014 (Accession No. ML13276A183).

E22. ONS Hydraulic Analysis Calculation - 11232.

E23. ONS Engineering Change Document - 113065.

Encl. Page - 12 of 13

ENCLOSURE: ONS FOURTH SIX-MONTH STATUS REPORT (ORDER EA-12-049) (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

E24. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012 (Accession No. ML12125A412).

E25. ONS Select Fukushima Related Technical Evaluations, Analyses, and Position Papers Calculation -11383.

E26. ONS FLEX Strategy Intermediate Cooling Hydraulic Calculation -11329.

E27. ONS Auxiliary Building GOTHIC Heat-Up Analysis - ELAP Event Cases - 11253.

E28. Duke Energy Letter, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated August 27, 2014 (Accession No. ML14245A019).

Encl. Page - 13 of 13

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