MNS-15-060, Fifth 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)

Fifth 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)

ML15253A198
Person / Time
Site:	Mcguire, McGuire
Issue date:	08/26/2015
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, MNS-15-060
Download: ML15253A198 (26)

Text

Steven D. Capps

• DUKE Vice President McGuire Nuclear Station ENERGY. Duke Energy MG01VP 1 12700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.4805 f: 980.875.4809 Steven.Capps@duke-energy.cem 10 CFR 50.4 August 26, 2015 Serial: MNS-15-060 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17

Subject:

Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated March 12, 2012 (Agencywide 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-A, dated August 2012 (ADAMS Accession No. ML12242A378).

4. Duke Energy's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated October 29, 2012 (ADAMS Accession No. ML12307A023).

5. McGuire Nuclear Station Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order EA-12-049),

dated February 28, 2013 (ADAMS Accession No. ML13063A185). /.s

United States Nuclear Regulatory Commission August 26, 2015 Page 2

6. McGuire Nuclear Station 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 28, 2013 (ADAMS Accession No. ML13254A204).

7. McGuire Nuclear Station 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. ML14073A462).

8. McGuire Nuclear Station 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 (ADAMS Accession No. ML14253A188).

9. McGuire Nuclear Station 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) Dated February 26, 2015, (ADAMS Accession No. ML15075A016).

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 (OIP) 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 initial status report regarding mitigation strategies at the Oconee, McGuire and Catawba Nuclear Stations. Reference 5 provided the OIP for MNS.

Reference I requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.

The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, 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.

United States Nuclear Regulatory Commission August 26, 2015 Page 3 This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact George Murphy at (980) 875-5715.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 26, 2015.

Sincerely,

Enclosure:

MNS Fifth Six-Month Status Report in Response to Order EA-12-049

United States Nuclear Regulatory Commission August 26, 2015 Page 4 xc:

V.M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1 257 John Boska, Project Manager (0MB)

U.S. Nuclear Regulatory Commission One White Flint North, Mailstop O-8G9A 11555 Rockville Pike Rockville, MD 20852-2738 G. E. Miller, Project Manager (CNS & MNS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station Justin Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

ENCLOSURE MNS FIFTH SIX MONTH STATUS REPORT IN RESPONSE TO ORDER EA-12-049

MNS Fifth FLEX Six Month Status Report in Response to Order EA 12-049 1 Introduction McGuire developed an Overall Integrated Plan (QIP) (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049. The OIP was submitted to the NRC on February 28, 2013. The first six-month update was provided to the NRC on August 28, 2013 (Reference 3 in Section 8). The second six-month update was provided to the NRC on February 27, 2014 (Reference 5 in Section 8). The third six-month update was provided to the NRC on August 27, 2014 (Reference 6 in Section 8). The fourth six-month update was provided to the NRC on February 26, 2015 (Reference 7 in Section 8). This enclosure provides an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, that occurred during the period from February 1,2015 to July 31, 2015 (hereafter referred to as "the update period").

2 Milestone Accomplishments Unit 1 is considered in compliance with NRC Order EA-12-049 as of November 15, 2014 (Reference 13 in Section 8).

The following Unit 2 milestones were completed during the update period:

• Complete Engineering Change Package and Plan Work Orders Page 1 of 21

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.

Revised Target Activity Target Unit 1 Milestones Completion Stus Cmlio Date Date Complete Engineering Change Package and Plan 03/20/2014 Complete NA Work Orders Receive all portable FLEX equipment 05/20/2014 Complete NA Transmit results of Phase 2 staffing study 05/20/2014 Complete NA Complete all FSGs, AOPs, EOPs, OPs 10/31/2014 Complete NA Complete training for all FSGs, AOPs, EOPs, OPs 09/20/2014 Complete NA Complete all Maintenance Procedures 09/20/2014 Complete NA Begin Outage (1 EOC23) Fall 2014 Complete NA Storage Plan - Reasonable Protection Facilities Fall 2014 Complete NA Complete _____ _____

Regional Response Center in place 10/19/2014 Complete NA Revised Target Activity Target Unit 2 Milestones Completion Status Completion Date Date Complete Engineering Change Package and Plan 03/20/2015 Complete Date Not Work Orders Revised Receive all portable FLEX equipment 05/20/2015 Complete NA Transmit results of Phase 2 staffing study 05/20/2015 Complete NA Complete all FSGs, AOPs, EOPs, OPs 06/20/2015 Started 09/20/2015 Date Not Complete training for all FSGs, AOPs, EOPs, OPs 09/20/2015 StartedReid Date Not Complete all Maintenance Procedures 09/20/2015 StartedReid Date Not Begin Outage (2EOC23) Fall 2015 Not Started Reid Page 2 of 21

TargetRevised Uni 2MiestnerCmpetio Activity Target Uni 2 iletonDatmpeto Status Completion Date Date Storage Plan - Reasonable Protection Facilities Summer Complete Fall 2014 Complete* 2015 Regional Response Center in place 10/11/2015 Complete NA

• Facility construction (three buildings) is complete. Unit 1 compliance was met with the completion and loading of the first two buildings in Fall 2014. Unit 2 compliance with Order EA-12-049 will be met with the loading of the remaining building.

4 Changes to Compliance Method

1) Change: The OIP for McGuire (Reference 1) identified that a modification would be implemented to provide assured air to the Turbine Driven Auxiliary Feed Water Pump (TDAFWP) flow control valves and the Steam Generator (SG) Pressure Operated Relief Valves (PORVs) during Extended Loss of AC Power (ELAP) Phase 1 response to allow these valves to be operated from the Control Room until a source of FLEX makeup air can be provided in Phase 2. In lieu of this, manual action is currently credited for the Unit 1 Phase 1 ELAP response, as identified in the McGuire Third Six-month update (Reference 6). The ELAP Phase I Assured Air modification will be completed during the Unit 2 RFO in fall 2015 for both Units, eliminating the associated temporary manual actions currently in place for the Unit 1, Phase 1 response.

Justification: Upon implementation of the Mitigating Strategies Order on Unit 2, the air supply to the TDAFWP flow control valves and SG PORVs will be assured via completion of the plant modification, allowing remote control of these components on both units from the Control Room per the McGuire OIP.

Documentation: Open Item #1

2) Change: The OIP for McGuire (Reference 1), and ISE Confirmatory Item 3.2.4.10.A, identified that the vital batteries would last for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of an ELAP event (assuming dc load stripping per ELAP response procedure). A revision to the original analysis that incorporated recent vendor extended discharge test data shows the vital batteries will last a minimum of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> when starting the ELAP event at only 80%

capacity (limited as required per existing guidance). Response procedures will be revised accordingly to reflect the need for recovery of the vital battery chargers within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> in lieu of the currently stated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Justification: ELAP response procedural guidance (EP/1(2)/A/5000/ECA-0.0) prioritizes Phase 2 deployment of the FLEX electrical distribution system (FSG-20) and the subsequent recovery of the vital battery chargers (FSG-4). The time margin between the calculated station battery run-time for Phase I response and the expected deployment time for FLEX equipment to repower the battery chargers is approximately 3-4 hours.

The McGuire vital batteries are procedurally maintained above the required assumed capacity of 80%.

Documentation: Open Item #52 Page 3 of 21

5 Need for RelieflRelaxation and Basis for the RelieflRelaxation McGuire expects to comply with the Order implementation date and no relief/relaxation is required at this time contingent on the following:

• Resolution of issues regarding RCP #1 seal leak-off flow rates and leak-off piping integrity, as identified in NSAL 14-1, Revision 1.

6 Open Items The following sections provide tables summarizing the status of the Open Items:

• Section 6.a provides the open items identified in the original OIP submitted on February 28, 2013.

• Section 6.b provides a list of open items that were added after February 28, 2013.

• Section 6.c provides a list of open items related to the Interim Staff Evaluation (ISE) received on January 16, 2014.

• Section 6.d provides a list of open items related to the NRC Audit Report received on October 9, 2014.

Unit 2 designators have been added to the Open Item descriptions where appropriate since unit 1 is in compliance with the Order.

Page 4 of 21

Section 6.a. Open Items Documented in the Overall Integrated Plan.

Note: items marked with an asterisk (*) are designed and awaiting implementation.

Note: items marked with a double asterisk (**) have been completed during this update period.

Overall Integrated Plan Open Item Status 1 Implement (Units 1 and 2) plant modification: Assured Air to the TDAFWP FCVs and SG PORVs (Current Unit 1 Started*

configuration is based on 3rd Six Month Update Change #2) 2 Implement (Unit 2) plant modification: Satd Assured Water Supply to the TDAFWPs Satd 3 Implement (Unit 2) plant modification: SEP Satd Wide-Range Level Instrumentation 4 Implement plant modification: UHF Completed Communication System Upgrades 5 Implement (Unit 2) plant modification: Started*

Process Connections 6 Implement (Unit 2) plant modification:

Permanent Connections for Portable Started*

Electrical Equipment 7 Implement plant modification: FLEX Storage Completed Facilities 8 Implement (Unit 2) plant modification:

Submersible Ground Water Sump PumpCoped 9 Implement (Unit 2) plant modification: FLEX Satd Strategy Implementation 10 Implement (Unit 2) plant modification: "B" Satd RN to CA Pump Suction Re-route 11 Implement plant modification: Install Emergency Hardhat Light Storage Boxes Completed and Hardhat Hooks 12 A staffing Phase 2 study will be performed in accordance with NEI 12-0 1 to verify that a-Il actions can be taken in accordance with the timeline. Time constraints shown in Completed Attachment IA will be validated to be reasonable as the strategy is finalized.

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13 An analysis was performed in Duke Energy Calculation MCC-1 223.31-00-0012 that indicates that flooding will not occur for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This analysis will be revisedCoped to demonstrate that this time remainsCoped unaffected even if potential sources of water from Auxiliary Building or Turbine Building flooding are conSidered.

14 A calculation will be performed to demonstrate that sufficient negative reactivity can be added through use of a pump and a reactor coolant system vent Completed path to achieve xenon free cool down in accordance with the PWROG FSG guidelines.

15 Complete vital battery area room hydrogen accumulation calculation (see open item Completed.

1. 48 for heat up calculation) to determine if Description of this Open Item revised portable fans or HVAC units may be per Open Item 48 required, and timeframe for deployment.

16 Complete a calculation to determine when elevated interior doghouse temperatures adversely impact the FLEX strategy and to Completed evaluate methods for mitigation.

17 An evaluation will be performed to determine how long raw water can be used to supply SGs without excessively affecting SG capability to remove heat and provideCoped steam to the TDAFW pump. This will helpCoped determine when Phase 3 equipment may be needed to assist in providing cleaner water sources.

18 MNS will evaluate the need to provide freeze protection for critical instrumentation Completed and exposed FLEX connections.

19 Methods will be initiated to circulate and cool air in lower containment sub compartments to prevent any adverse impact on critical instrumentation. The response time is based on engineering judgment and will be confirmed by analysis. Completed Page 6 of 21

20 Deployment routes will be established and are expected to be utilized to transport FLEX equipment to the deployment areas.

The identified paths and deployment areas will be accessible during all modes of Completed operation. This deployment strategy will be included within an administrative program in order to keep pathways clear or actions to clear the pathways.

21 MNS will implement programmatic controls in accordance with NEI 12-06. Procedures and guidelines will be reviewed and revisedCoped and/or generated as required to addressCoped additional programmatic controls as a result of FLEX requirements.

22 Equipment associated with FLEX mitigation strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration Completed control in accordance with NEI 12-06 Section 11.1.

23 Installed structures, systems and components pursuant to 10 CFR 50.63(a) will continue to meet augmented guidelines Completed of Regulatory Guide (RG) 1.155, Station Blackout.

24 The unavailability of equipment and applicable connections that directly perform a FLEX mitigation strategy will be managedCoped using plant equipment control guidelinesCoped developed in accordance with NEI 12-06 Section 11.5.

25 Programs and processes will be established (Unit 2) to ensure that personnel proficiency in the mitigation of beyond-design-basis Completed events is developed and maintained in accordance with NEI 12-06 Section 11.6.

26 The FLEX strategies and basis will be maintained in overall FLEX basis documents.

Completed Page 7 of 21

27 Existing plant configuration control documents will be modified to ensure that changes to the plant design, physical plant layout, roads, buildings, and miscellaneous Completed structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06 Section 11.8.

28 Training will be initiated through the Systematic Approach to Training (SAT) process. Training will be developed and provided to all involved plant personnel Unit 1 Completed based on any procedural changes or new procedures developed to address and Unit 2 Started identify FLEX activities. Applicable training will be completed prior to the implementation of FLEX.

29 The industry will establish two Regional Response Centers (RRCs) to support Completed utilities during beyond-design-basis events.

30 The N+I FLEX storage facilities will be designed in accordance with ASCE 7-10, Minimum Design Loads for Buildings and Other Structures. The FLEX storage facilities will be designed in accordance with ASCE 7-10, to withstand the maximum anticipated hurricane and tornado winds asCoped outlined in NEI 12-06. The FLEX buildings will be located in accordance with NEI 12-06 Section 7.3.1 to prevent damage to more than one of the three facilities due to tornado missiles.

31 FLEX storage facilities will be located above any potential site flood level, and/or the effects of localized flooding will be Completed evaluated in the FLEX facility design and equipment deployment.

32 Debris removal/remediation equipment and procedures will be provided to support Completed FLEX equipment deployment.

33 Snow and ice removal/remediation equipment and procedures will be provided to support FLEX equipment deployment.

Completed Page 8 of 21

34 FLEX equipment will be capable of operation under extreme temperatures, and suitably maintained to ensure standby readiness. FLEX storage facilities will beCoped designed to accommodate maximum snow and ice loading. FLEX storage facilities will be vented to maintain acceptable temperature.

35 An evaluation will be performed to ensure that the 300 gpm pump is capable of adequate flow and pressure to support feed Completed and bleed core cooling in typical Mode 5 and Mode 6 configurations.

36 Since the overall FLEX strategy is aimed at preventing core damage, the engineering change process will drive out an evaluation to prioritize operator actions associated with containment isolation as time allows. For example, the containment isolations to the Completed Containment Ventilation Unit Condensate Drain Tank (VUCDT) will be closed first since this path connects containment atmosphere directly to the Auxiliary Building.

37 An analysis will be performed to validate that containment spray for temperature/pressure control is not required over the long term. If the long term containment analysis determines that containment temperature and/or pressure will reach unacceptable levels over the long Completed term, connections will be installed for containment spray mitigating strategies and will be used with the portable diesel driven pumps to supply water from the UHS to the connections located in the Auxiliary Building.

38 Fans in containment that circulate air will be restored as required to cool the cubicle areas and to prevent the increase in temperature from having an adverse impact on essential instrumentation. The Completed engineering change process will drive out an evaluation to determine the appropriate timing of these actions.

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39 Evaluate other long term strategies for cooling containment such as circulating the Completed air volume in the annulus.

40 In order to prevent or mitigate this inevitability [i.e., vital battery depletion]:

1. Portable power distribution equipment will be used to repower the vital batteries, or

2. An alternate strategy to deploy portable generators and cables will be developed to directly reestablish power to the power Completed supplies in the 7300 cabinets thereby re-powering the instrumentation loops, or

3. An alternate strategy to utilize hand held instruments will be developed to tap into the instrument loops locally to monitor essential parameters.

41 An analysis was completed to demonstrate that adequate control room cooling would be available if action was taken to openCoped various doors at around 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after theCoped event occurs. This action will be incorporated into procedures.

42 An evaluation will be performed to determine diesel fuel, gasoline and two-Coped cycle oil requirements for Phase 1 and Phase 2 portable equipment.

43 Analysis will be performed to determineCoped commodities requirements.Coped 44 Evaluate SEP to ensure predicted makeup water dilution rates in the Spent Fuel PoolsCoped for the coping strategies described hereinCoped are bounded.

45 Analysis will be performed to determine radiation protection equipment Completed requirements.

46 These instruments [i.e., Essential Instrumentation and Vital l&C] will be used in the FSGs in accordance with the PWROG guidance. Setpoint uncertainty analyses will be developed in accordance Completed with PWROG guidance.

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47 A portable battery pack with inverter is also being evaluated for use. The battery pack would be rapidly deployed for use to close the CLA motor-operated valves (MOVs) outside of containment penetration without Completed reliance on the valve's limit or torque switches or the

'valve's relay circuitry.

Section 6.b. Open Items added after February 28, 2013 First Six Month Update Status New Open Items 48 Complete vital battery area room heatup calculation to determine if portable fans or HVAC units may be required, and the Completed timeframe for deployment. (Reference open item 15) 49 To facilitate the Phase 2 FLEX mitigation response, the high and low pressure make-up pumps for the Reactor Coolant System for each Unit are currently planned to be pre-staged in the Auxiliary Building, near the FLEX connection points. As these areas are within a Category I seismic structure, no Completed spares will be stored in the FLEX buildings for deployment, since "N"pieces of FLEX equipment are already deployed and protected. Per NEI 12-06 guidance, this equipment will be evaluated for seismic ruggedness.

50 Access to connection points for the Phase 2 FLEX mitigation response will be through the north end of the McGuire Auxiliary Building, an area which is not seismically designed.

Section 5.3.2 part 2 of the NEI 12-06 Guidance Document states: "At least one connection point of FLEX equipment will onlyCoped require access through seismically robust oled structures. This includes both the connection point and any areas that plant operators will have to access to deploy or control the capability." Evaluate Auxiliary Building access points for possible qualification of seismic ruggedness.

Page 11 of 21

51 Reference 01 #30. NEI 12-06 Guidance clarification documented in NEI FLEX Guidance Inquiry no. 2013-07 identifies that FLEX buildings designed for hurricane wind speeds and using diverse locations per Completed Section 7.3.1 part (c) are protected from both tornado and hurricane generated missiles.

Validate strategy with NEI.

Second Six Month Update New Open Items Status 52 McGuire to confirm that the FLEX strategy station battery run-time was 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. The detailed licensee calculations, supporting vendor discharge test data, FLEX strategy battery load profile, Completed and other inputs/initial conditions required by IEEE-485 will be available on the licensee's web portal for documents and 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 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

53 See ISE Open Item 3.2.1.8.A. The PWROG submitted to NRC a position paper, dated August 15, 2013, which provides test data regarding boric acid mixing under single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those Completed for which boric acid mixing data is available.

McGuire to confirm its intent to abide by the generic approach discussed above, and address the clarifications in the NRC endorsement letter dated January 8, 2014.

54 NEI submitted the EPRI Report 3002000623 entitled "Nuclear Maintenance Applications Center: Preventative Maintenance Basis for FLEX Equipment" on October 23, 2013. Completed McGuire to confirm its intent to abide by the generic approach discussed above in Page 12 of 21

developing FLEX equipment maintenance and testing programs.

55 See ISE Confirmatory Item 3.2.1.7.A.

McGuire to confirm that the guidance in NEI position paper, "Position Paper:

Shutdown/Refueling Modes," will be followed Completed in the Mitigation Strategies for BOBEEs occurring during Shutdown/Refueling Modes.

56 McGuire to confirm viability of proposed long-term ELAP Phase 3 recovery strategy:

Modes 1-4: rely on passive ice condenser response and repowered containment/an nulus ventilation fan cooling to prevent Pressurizer/Steam Generator level indication reference legs from flashing during RCS cooldown/depressurization, and realign/restart RHR system (and support Completed systems). Manage containment pressure as necessary.

Modes 5-6: rely on passive ice condenser response and deploy portable FLEX pump within timeframe necessary to manage RCS boration/inventory. Manage containment pressure as necessary and realign/restart RHR system (and support systems).

Third Six Month Update Status New Open Items 57 NSAL 14-1: Upon completion of the vendor evaluation of the RCP seal leak-off flow with the installed Number 1 Seal Leak-off orifice, identify the path forward for meeting the FLEX Mitigation Strategy Analysis Completed assumptions based on the evaluated leak-off flow.

Fourth Six Month Update Status New Open Items None. N/A New Open Items added this Update Status None. N/A Page 13 of 21

Section 6.c. Secton ~c. Staff Evaluation* Open and Confirmatory Items Interim Interim Staff Evaluation Status Open Item 3.2.1.8.A The PWROG submitted to NRC a position paper, dated August 15, 2013, which provides test data regarding boric acid mixing under single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. Completed During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above.

The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

Interim Staff Evaluation Status Confirmatory Items 3.1 .1 .2.A Deployment of FLEX equipment - On page 57 of its Integrated Plan, in the chart identifying Pressurized Water Reactor (PWR) Portable Equipment Phase 2, the licensee lists (9) 9x12 trailers used to store Completed and deploy power equipment, but does not list tow vehicles. Confirm abilities to move FLEX equipment and the level of protection afforded the means to move.

3.1.1 .3.A Procedural interfaces, seismic - Confirm evaluation that shows time is available to deploy ground water sump pumps as needed in critical locations in addition to the vicinity of the TDAFW pump. Completed 3.1.1 .4.A Off Site Resources, seismic - Confirm development of the MNS playbook as well as identification of the local Assembly Area andCoped routes to the plant.

Page 14 of 21

3.1.3.1 .A Protection of FLEX equipment, high winds -

Site specific data to justify the assumed tornado width of 1200 feet will be required to confirm the final locations of the FLEX Completed storage facilities conform to NEI 12-06 guidance.

3.1 .5.2.A Deployment of FLEX equipment, high temperatures - Confirm that the storage facilities will be designed for extreme temperature ranges including concerns for Completed expansion of sheet metal, swollen door seals, etc.

3.2.1.A RCS Cooling and Heat Removal, and RCS Inventory Control Strategies - Justify the use of the analysis from Sections 5.2.1 and 5.2.2 of WCAP-1 7601-P by identifying and evaluating the important parameters and Completed assumptions demonstrating that they are representative of MNS and appropriate for simulating the ELAP transient.

3.2.1.1 .A Computer Code Used for ELAP Analysis -

Confirm that reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to Completed reflux condensation initiation. This includes specifying an acceptable definition for reflux condensation cooling.

3.2.1.2.A RCP seals - Confirm that the RCP seal initial maximum leakage rate used in the analysis is greater than or equal to the upper bound expectation for the ELAP event (21Coped gpm/seal) discussed in the PWROG whiteCoped paper addressing the RCP seal leakage for Westinghouse plants.

3.2.1.2.B RCP seals - 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 F before cooldown commences. Completed This is beyond the qualification temperature (550 degrees F) 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 Page 15 of 21

provided to justify that (1) the integrity of the associated 0-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.

3.2.1.2.C RCP seals - Ifthe seals are changed to the newly designed Generation 3 SHIELD seals, or non-Westinghouse seals, the acceptability of the use of the newly designed Generation 3 SHIELD seals, or non-Westinghouse seals Completed should be addressed, and the RCP seal leakages rates for use in the ELAP analysis should be provided with acceptable justification.

3.2.1 .3.A Decay Heat - Values of the following key parameters used to determine the decay heat should be specified and the adequacy of the values evaluated: (1) initial power level, (2) fuel enrichment, (3) fuel burn up, (4) effective full power operating days per fuel Completed 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.

3.2.1.4.A Initial Values for Key Plant Parameters and Assumptions - Confirm results and appropriate actions subsequent to Westinghouse supplying McGuire with additional information regarding the key plant Completed parameters and assumptions.

3.2.1 .7.A Confirm that MNS will abide by the generic resolution for shutdown and refueling Completed concerns.

3.2.3.A Containment Functions Strategies - Confirm completion of the long term containment Completed analysis and appropriate actions.

3.2.4.4.A Lighting and Communications - Confirmation will be required that upgrades to the site's communications systems have been Completed completed.

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3.2.4.6.A Ventilation for Equipment Cooling and Personnel Habitability - Room heat up response for specific MNS areas are completed but need to be evaluated by NRC Completed personnel. Confirm completion of evaluation and appropriate actions.

3.2.4.7.A Water Sources - Confirm that plant procedures specify that a flow path is promptly established for makeup flow to the steam generators and identify backup water sources in order of intended use; and that Completed plant procedures/guidance should specify clear criteria for transferring to the next preferred source of water.

3.2.4.8.A Electrical Power Sources - Confirm completion of Flex DG sizing calculation and Completed appropriate actions.

3.2.4.9.A Portable Equipment Fuel - Confirm completion of evaluation and appropriate actions to assess long-term FLEX equipment Completed fuel oil requirements.

3.2.4.1O.A The battery sizing calculation needs to be verified when revised to show that dc power for 2 of 4 channels can be maintained for 24 Completed hours without a charger in place.

3.2.4.1O.B Load Reduction to Conserve DC Power -

Confirm that ELAP procedures/guidance will direct operators to conserve dc power during Completed the event by stripping nonessential loads as soon as practical.

3.4.A Offsite Resources - Confirm NEI 12-06, Section 12.2, Guidelines 2 through 10 are Completed addressed with the RRC.

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Section 6.d. Sectio 6.d.

NRC Onsite Mitigating Strategies Audit Report Note: status of items marked "Pending" are industry issues in the process of being addressed by NRC or via the PWROG. Site-specific evaluation of these items has been completed.

Open Item # Audit Report Open Item Description Status , Off-Site Resources: The NRC staff Item ISE Cl requests that the licensee provide a copy Completed 3.1.1 .4.A of the playbook once it's finalized. , Lighting and Communications: The NRC Item ISE Cl requested that the licensee provide 3.2.4.4.A confirmation of the modifications to the Completed communications systems once completed. , Process Connections: The NRC staff Licensee requested that the licensee provide a Identified OIP summary of the plant modifications toCoped Open Item 5 implement the FLEX strategy for staffCoped review. , Containment Functions Strategies: The Item ISE CI licensee has provided a response to the 3.2.3.A question on the e-Portal; however, the Completed staff requests that the calculations be posted on the e-Portal. , Portable Equipment Fuel: Provide Item ISE CI information on the fuel quality from the 3.2.4.9.A trucks that will be onsite to initially refuel Completed FLEX equipment. , NOTRUMP Code: The staff performed a SE Review confirmatory ELAP analysis using Item 5 TRACE and is currently reviewing the results between TRACE and Pending Final Integrated NOTRUMP. In addition, the staff has Plan submittal requested a copy of the PWROG application of NOTRUMP white paper. , RCP Leakage Rate: The NRC staff SE Review understands that Westinghouse has Item 7 recently recalculated seal leak-off line pressures under loss of seal cooling events based on a revised seal leakage model and additional design-specific Pending Final Integrated information for certain plants. Please Plan submittal clarify whether the piping in your seal leak-off line is capable of withstanding the pressure predicted during an ELAP event according to the revised seal

_____________ leakage model. If not, please discuss _______________

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any planned modifications to the seal leak-off piping design and the associated completion timeline. Alternately, please clarify that the seal leakage rate would remain in an acceptable range if the affected seal leak-off piping were to rupture. , RCP Leakage Rate: Please provide SE Review adequate justification for the seal Item 8 leakage rates calculated according to the Westinghouse seal leakage model that was revised following the issuance of NSAL-14-1. The justification should include a discussion of the following factors:

1. Benchmarking of the seal leakage model against relevant data from tests or operating events,

2. Discussion of the impact on the seal leakage rate due to fluid temperatures greater than 550°F resulting in increased Pending Final Integrated deflection at the seal interface, Plan submittal

3. Clarification whether the second-stage reactor coolant pump seal would remain closed under ELAP conditions predicted by the revised seal leakage model and a technical basis to support the determination, and,

4. Justification that the interpolation scheme used to compute the integrated leakage from the reactor coolant pump seals from a limited number of computer simulations (e.g., three) is realistic or conservative. , Battery Sizing Calculations: The staff Item ISE CI will complete a vendor audit of the Pending Final Integrated 3.2.4.10.A batteries. Plan submittal , Off-Site Resources: The NRC staff Item ISE CI discussed with the licensee its plan to 3.4.A address minimum capabilities of off-site resources, outlined in the 10 guidelines in NEI 12-06. The licensee indicated that the National SAFER Response Center generated a generic response to address the guidelines, and coordination Completed of McGuire strategies with the National SAFER Response Centers is ongoing.

During the onsite audit, the licensee provided a copy of the generic response and the NRC staff is still in the process of reviewing the document.

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Attachment 4, Loss of Heat Tracing Effects, NEI 12-06, AQ 35 Section 3.2.2, Guideline 12: The staff is currently reviewing the licensee's Completed response on the e-Portal.

Attachment 4, Shutdown and Refueling Modes: During Item ISE CI the onsite audit, the licensee provided a 3.2.1.7.A copy of the PWROG interim generic guidance that identified minimal coping Pending Final Integrated strategies for PWRs when an ELAP Plan submittal event occurs in a shutdown mode, and the NRC staff is still in the process of reviewing the document.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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

1. McGuire Nuclear Station Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order EA-12-049), dated February 28, 2013, (ADAMS Accession No. ML13063A185).

2. 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).

3. McGuire Nuclear Station, 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 28, 2013, (ADAMS Accession No. ML13254A204).

4. William B. McGuire Nuclear Station, Units 1 and 2--Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) dated January 16, 2014, (ADAMS Accession No. ML13338A421).

5. McGuire Nuclear Station, 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. ML14073A462).

6. McGuire Nuclear Station, 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, (ADAMS Accession No. ML14253A188).

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7. McGuire Nuclear Station, Fourth Six-Month StatUs Report in Responseto 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 26, 2015, (ADAMS Accession No. ML15075A016).

8. NSAL-14-1, Revision 1 "Impact of Reactor Coolant Pump No. 1 Seal Leakoff Piping on Reactor Coolant Pump Seal Leakage During a Loss of All Seal Cooling,"

dated September 9, 2014.

9. WCAP-17601-P, Revision 1 "Reactor Coolant System Response to ELAP for Westinghouse, Combustion Engineering and B&W NSSS Designs", January 2013, (ADAMS Accession No. ML13042A010).

10. NEI letter "EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern" dated August 27, 2013, (ML13241A186), and NRC endorsement letter dated September 16, 2013, (ADAMS Accession No. ML13241A188).

11. EP/I/A/5000/ECA-0.0, Revision 35.

12. McGuire Nuclear Station, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051, dated October 9, 2014, (ADAMS Accession No. ML14241A454).

13. Notification of Full Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and with Order EA-1 2-051, "Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" - McGuire Nuclear Station Unit 1, dated November 18, 2014, (ADAMS Accession No. ML14335A322).

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