ML15259A387

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Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051
ML15259A387
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 10/06/2015
From: Boska J
Japan Lessons-Learned Division
To: Batson S
Duke Energy Carolinas
Boska J, NRR/JLD, 415-2901
References
EA-12-049, EA-12-051, TAC MF0782, TAC MF0783, TAC MF0784, TAC MF0785, TAC MF0786, TAC MF0787
Download: ML15259A387 (19)
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 6, 2015 Mr. Scott Batson Site Vice President Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672

SUBJECT:

OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - REPORT FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0782, MF0783, MF0784, MF0785, MF0786, AND MF0787)

Dear Mr. Batson:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A065 - not publicly available, security related information), Duke Energy Carolinas, LLC (Duke, the licensee) submitted its OIP for Oconee Nuclear Station, Units 1, 2, and 3 (Oconee) in response to Order EA-12-049. By letters dated August 29, 2013, February 28, 2014, August 27, 2014, February 27, 2015, and August 26, 2015 (ADAMS Accession Nos. ML13246A009, ML14064A196, ML14245A018, ML15063A027, and ML15247A068, respectively), the licensee submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Oconee interim staff evaluation (ISE) dated February 10, 2014 (ADAMS Accession No. ML13365A258), and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13086A095), the licensee submitted its OIP for Oconee in response to Order EA-12-051. By letter dated June 21, 2013 (ADAMS Accession No. ML13171A301), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 19, 2013, August 26, 2013, February 28, 2014, August 27, 2014, February 27, 2015, and August 26, 2015 (ADAMS Accession Nos.

ML13207A413, ML13242A009, ML14064A197, ML14245A019, ML15063A028, and

S. Batson ML15247A069, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review led to the issuance of the Oconee ISE and RAI dated November 1, 2013 (ADAMS Accession No. ML13298A696). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion took place prior to declarations of compliance for Oconee.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Oconee from July 20-23, 2015, per the audit plan dated June 10, 2015 (ADAMS Accession No. ML15160A664). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on a successful path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, review of staging and deployment of offsite equipment, and review of installation details for SFPI equipment.

The enclosed audit report provides a summary of the activities for the onsite audit portion.

Additionally, this report contains an attachment listing all open audit items currently under NRC staff review.

S. Batson If you have any questions, please contact me at 301-415-2901 or by e-mail at John.Boska@nrc.gov.

Sincerely, OL~ ri~

.@(n P. Beska, Senior Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos.: 50-269, 50-270, and 50-287

Enclosure:

Audit report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS AND RELIABLE SPENT FUEL POOL INSTRUMENTATION DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION. UNITS 1, 2. AND 3 DOCKET NOS. 50-269, 50-270. AND 50-287 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range SFP levels to support effective prioritization of event mitigation and recovery actions in the event of a BDBEE. The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A065 - not publicly available, security related information), Duke Energy Carolinas, LLC (Duke, the licensee) submitted its OIP for Oconee Nuclear Station, Units 1, 2, and 3 (Oconee) in response to Order EA-12-049. By letters dated August 29, 2013, February 28, 2014, August 27, 2014, February 27, 2015, and August 26, 2015 (ADAMS Accession Nos. ML13246A009, ML14064A196, ML14245A018, ML15063A027, and ML15247A068, respectively), the licensee submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders Enclosure

that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Oconee interim staff evaluation (ISE) dated February 10, 2014 (ADAMS Accession No. ML13365A258), and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13086A095), the licensee submitted its OIP for Oconee in response to Order EA-12-051. By letter dated June 21, 2013 (ADAMS Accession No. ML13171A301), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 19, 2013, August 26, 2013, February 28, 2014, August 27, 2014, February 27, 2015, and August 26, 2015 (ADAMS Accession Nos.

ML13207A413, ML13242A009, ML14064A197, ML14245A019, ML15063A028, and ML15247A069, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review led to the issuance of the Oconee ISE and RAI dated November 1, 2013 (ADAMS Accession No. ML13298A696). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at Oconee from July 20-23, 2015, per the audit plan dated June 10, 2015 (ADAMS Accession No. ML15160A664). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on a successful path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, review of staging and deployment of offsite equipment, and review of installation details for SFPI equipment. The audit's onsite portion took place prior to declarations of compliance for Oconee.

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented; the resulting site-specific Overall Program Documents (OPDs) and Final Integrated Plans (FIPs); and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination using the Nuclear Energy Institute (NEI) developed guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August 2012 (ADAMS Accession No. ML12242A378), as endorsed, by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) 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'" (ADAMS Accession No. ML12229A174). For Order EA-12-051, the staff will make a safety determination using the NEI developed guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC ISG JLD-ISG-2012-03 "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," (ADAMS Accession No. ML12221A339) as providing one acceptable means of meeting the order requirements. Should the licensee propose an alternative strategy for compliance, additional staff review will be required to evaluate the alternative strategy in reference to the applicable order.

AUDIT ACTIVITIES The onsite audit was conducted at the Oconee facility from July 20, 2015, through July 23, 2015. The NRC audit team staff was as follows:

Title Team Member Organization Team Lead/Project Manager John Beska NRR/JLD Technical Support - Electrical Prem Sahay NRR/JLD Technical Support - Reactor Joshua Miller NRR/DSS Systems Technical Support- Reactor Laura Okruhlik NRR/JLD Systems Technical Support - Balance of Plant On Yee NRR/JLD Technical Support - SFPI KhoiNguyen NRR/JLD The NRC staff executed the onsite portion of the audit per the three part approach discussed in the audit plan, to include conducting a tabletop discussion of the site's integrated mitigating strategies (MS) compliance program, a review of specific technical review items, and discussion of specific program topics. Activities that were planned to support the above included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.

AUDIT

SUMMARY

1.0 Entrance Meeting (July 20, 2015)

At the audit entrance meeting, the NRC staff audit team introduced itself followed by introductions from the licensee's staff. The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule.

2.0 Integrated Mitigating Strategies Compliance Program Overview Per the audit plan and as an introduction to the site's program, the licensee provided a presentation to the NRC audit team describing the site's strategies to meet the NRC orders.

The licensee reviewed its strategy to maintain core cooling, containment, and SFP cooling in the

event of an ELAP, and the plant modifications being done in order to implement the strategies.

Also reviewed was the design and location of the storage facilities for the FLEX equipment, the interface with the National Strategic Alliance for FLEX Emergency Response (SAFER)

Response Centers (NSRC) including staging areas, the SFP level indication modification, the modifications planned to enhance emergency communications, and procedural enhancements such as development of FLEX guidelines (FGs).

3.0 Onsite Audit Technical Discussion Topics Based on the audit plan, and with a particular emphasis on the Part 2 "Specific Technical Review Items," the NRC staff technical reviewers conducted interviews with licensee technical staff, site walk-downs, and detailed document review for the items listed in the plan. Results of these technical reviews and any additional review items needed from the licensee are documented in the audit item status table in Attachment 3, as discussed in the Conclusion section below.

3.1 Reactor Systems Technical Discussions and Walk-Downs The NRC staff met with licensee staff to discuss the amount of leakage from the reactor coolant pump (RCP) seals, and the use of the Standby Shutdown Facility (SSF) to initially respond to the event. The auxiliary service water (ASW) pump in the SSF will be used to maintain level in all steam generators (SGs) for reactor decay heat removal using a water supply from the ultimate heat sink (UHS). Water will be injected into the RCP seals to cool them and to add water to the reactor coolant system (RCS) using the SSF diesel generator (DG) to power the SSF reactor coolant makeup (RCMU) pumps, which are located in the reactor containment buildings. The RCMU pumps take suction from the spent fuel pools. A portable FLEX SG makeup pump that can add water to all six SGs and three portable FLEX RCS makeup pumps (one per unit) will be stored in the FLEX storage building (FSB), along with one backup (N+1) pump for SG makeup and one backup (N+1) pump for RCS makeup. The NRC staff reviewed the analysis and flow calculations along with applicable procedures. The NRC staff reviewed the licensee's strategy for utilizing raw water sources (such as Lake Keowee), including water filtration and monitoring of core parameters to ensure adequate cooling. The NRC staff also walked down the licensee's strategies and reviewed plant procedures for implementing the core cooling and makeup strategies.

3.2 Electrical Technical Discussions and Walk-Downs

a. The NRC staff walked down the battery rooms and reviewed the proposed strategies for hydrogen control and temperature control. The NRC staff reviewed the licensee response to audit questions and the summary of results and the conclusion in calculation OSC-11253, Attachment E, for hydrogen concentration in the battery rooms. The licensee's calculation determined that hydrogen will be maintained at or below 0.37% by volume in each battery room. When asked by the NRC staff, the licensee provided additional information that the Oconee criteria is below the 4% explosive limit for hydrogen concentration in the battery rooms and that a conservative 2% acceptance criteria is applied. Since the licensee's calculation shows that the hydrogen concentration by volume is much less than the acceptance criteria, no mitigation strategy

will be required. Based on the above, the NRC Staff has no further questions on hydrogen control. This item is closed.

b. The licensee stated that Oconee does not plan to use a de battery load shed strategy because the SSF system will be used to power the de loads for the mitigating strategy for Phases 1 and 2 and is expected to power the de loads for up to 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />.
c. The NRC staff reviewed and approved the use of the existing installed SSF diesel generator for Phase 1 and 2 and for up to 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> of coping (in the non-flood strategy) as an alternative to NEI 12-06, Rev. 0, in the NRC Interim Staff Evaluation (ISE) Report (ADAMS Accession No. ML13365A258) in February 2014.
d. The NRC staff walked down electrical connection points and locations for the FLEX DGs. Three portable FLEX DGs (one for each unit, 500 kW, 600 Vac) are stored in the FSB, along with one backup (N+1) DG. These FLEX DGs are stored with enough diesel fuel for several hours of operation, and will be refueled after that. The NRC staff also reviewed the licensee's use of smaller portable FLEX DGs, 6 kW, 120/240 Vac, stored in the FSB which will be used to repower important plant equipment. The staff reviewed the summary of results and the conclusion of the licensee's load and sizing calculations for the FLEX generators and did not identify any issues. Subsequent to the audit visit, the licensee reported that a change has been made to use a larger 10 kW 120/240 Vac portable DG for the alternate repower strategy. The increased capacity will allow one 10 kW DG per unit to supply the needed loads, with one additional 10 kW DG for the backup (N+1) equipment. All four 1OkW DGs are stored in the FSB. The licensee plans to continue to store several of the 6kW, 120/240 Vac DGs in the FSB. One of the portable 6 kW DGs (one DG for all three Units) will continue to be used as part of the primary repower strategy with one 6 kW DG as the backup (N+1). The other 6 kW DGs will be available to provide power for FLEX support related functions (portable lighting and ventilation).
e. During the site audit, the licensee stated that the temperature ratings on the procurement specifications of the Phase 2 and Phase 3 portable FLEX DGs bound the historical average maximum site temperatures (105 °F) and therefore the licensee concluded that the FLEX DGs are designed for the environment where they will operate.
f. The NRC Staff discussed the qualification of electrical equipment inside containment with the licensee staff. The licensee provided a response stating that the equipment in the containment is qualified for 284 °F for the loss-of-coolant accident (LOCA) and for 32 days post-accident. The ELAP temperature profile in the containment after shutdown showed that it can go up to 284 °F and 59.0 psig in about 60 hours2.5 days <br />0.357 weeks <br />0.0822 months <br /> and then will level off. Therefore the equipment will remain qualified for the ELAP peak temperature and will not exceed the equipment qualification temperature for 30 days (refer to calculation OSC-8064). The licensee also provided temperature profiles for both the LOCA and the ELAP event. The licensee confirmed that the qualification of electrical equipment in the containment will remain bounded for the ELAP event out to approximately 30 days, which would envelop a significant recovery phase period also. Based on above, the

NRC staff has no further questions on the qualification of electrical equipment inside containment.

g. The NRC staff reviewed the licensee's response and evaluation of an issue identified by the NRC staff regarding the ability to successfully recharge the station batteries after they reached a fully depleted state and if the batteries would be able to supply power.

The licensee's response stated that the battery chargers at Oconee are designed to automatically restart after a loss of power event and will, depending on the amount of battery discharge, go into "current limit" mode until the connected battery has recharged enough to self-limit the amount of current it is drawing from the charger. Going into current limit mode is normal and occurs after every battery discharge test is performed.

Although discharge tests are performed periodically on the batteries and they would be expected to recharge successfully from a depleted state, there is a possibility that a given battery may not be recoverable after an extended period of being fully discharged.

Based on the above, the licensee committed to changing its mitigation strategy. The licensee will add actions to the Blackout Tab in procedure EP/1/A/1800/001 to initiate a procedure to isolate the station batteries until power can be restored to the battery chargers. Subsequent to the audit visit, the licensee reported that this would be accomplished by shedding all loads on the vital de buses (1 DCA and 1DCB for Unit 1).

The licensee will also shut down the vital inverters (1 DIA, 1DIB, 1DIC, and 1DID for Unit

1) which are powered by the batteries and supply loads such as the instrument panels, by opening the inverter input and output breakers. Analogous steps will be added to the Unit 2 and Unit 3 procedures. The battery chargers' input and output breakers will remain closed so that the chargers will restart automatically when power is restored.

These actions will be completed after declaration of an ELAP (approx. T +2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />) and before T +4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> (which is the current Station Blackout coping limit).

Based on the above actions to prevent complete discharge of the batteries, FG/X/A/1900/020, "FLEX Electrical Distribution," is being revised to verify proper operation of the battery chargers and to add actions to return specified de loads and the vital inverters to service when re-energizing the battery chargers from the Phase 2 portable re power system in the T + 18 hours0.75 days <br />0.107 weeks <br />0.0247 months <br /> to T +24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> timeframe. The licensee stated that in the meantime, the SSF DG will continue to supply power to the SSF battery charger, SSF inverters and SSF loads starting from T=15 minutes and onward per Oconee procedure AP/O/A/1700/025. The licensee provided a Nuclear Task Management Tracking No. 01938086-01 to revise procedure FG/X/A/1900/020 ('X' is the Unit number) as discussed above. Based on the above, this item is closed.

3.3 SFPI Technical Discussions and Walk-Downs The NRC staff walked down instrument, transmitter, electronics, and display locations for the SFP level instrumentation, along with the associated cable runs. The NRC staff also reviewed the available calibration, maintenance and test procedures for the SFP level instrumentation.

3.4 Other Technical Discussion Areas and Walk-Downs

a. The NRC staff toured the locations where the FLEX equipment would be located or stored (for portable equipment). The staff walked down equipment haul routes from the storage locations to the designated deployment sites, and walked down haul routes from designated staging areas for equipment that will be delivered from the NSRC.
b. The NRC staff walked down the FLEX strategies for core cooling, reactor coolant system inventory, SFP inventory, and containment cooling functions. This included the usage of the portable FLEX pumps, hose routing and connection points (primary and alternate).
c. The NRC staff reviewed the strategy that will be implemented by the licensee to refuel the portable diesel-powered FLEX equipment. The NRC staff reviewed the instructions for refueling the equipment, as well as the equipment needed to perform the refueling.

Additionally, the staff reviewed the licensee's procedures for ensuring adequate fuel quality.

d. The licensee's cooldown strategy relies on operation of the SG atmospheric dump valves (ADVs). The NRC staff reviewed the capability to operate the ADVs during an extended loss of alternating current (ac) power (ELAP).
e. The NRC staff reviewed the licensee's plans to ensure adequate communications, lighting, personnel access, and equipment access, to successfully implement the strategies. The staff interviewed plant personnel responsible for these areas, and observed lighting and communication needs during plant walkdowns.

4.0 Exit Meeting (July 23, 2015)

The NRC staff audit team conducted an exit meeting with licensee staff following the closure of onsite audit activities. The NRC staff highlighted items reviewed and noted that the results of the onsite audit trip will be documented in this report. There were eight FLEX issues and one SFPI issue open at the conclusion of the audit and they were discussed at the exit meeting.

After returning to the office, the NRC audit team added one additional item for further review.

This is item 20-E, on the qualification of the SSF RCMU pumps. See Attachment 3 for additional information.

CONCLUSION The NRC staff completed all three parts of the onsite audit plan. Each audit item listed in Part 2 of the plan was reviewed by NRC staff members while on site. In addition to the list of NRC and licensee onsite audit staff participants in Attachment 1, Attachment 2 provides a list of documents reviewed during the onsite audit portion.

In support of the continuing audit process, as the licensee proceeds towards orders compliance for this site, Attachment 3 provides the status of all open audit review items that the NRC staff is evaluating in anticipation of issuance of a combined safety evaluation (SE) for both the MS and SFPI orders. The five sources for the audit items referenced below are as follows:

a. Interim Staff Evaluation (ISE) Open Items (Ols) and Confirmatory Items (Cls)
b. Audit Questions (AQs)
c. Licensee-identified Overall Integrated Plan (OIP) Open Items (Ols)
d. SFPI Requests for Additional Information (RAls)
e. Additional information needed to support the SE The attachments provide audit information as follows:
a. Attachment 1: List of NRC staff and licensee staff audit participants
b. Attachment 2: List of documents reviewed during the onsite audit
c. Attachment 3: MS/SFPI SE Audit Items currently under NRC staff review (licensee input needed as noted)

While this report notes the completion of the onsite portion of the audit per the audit plan dated June 10, 2015, the ongoing audit process continues, as per the letters dated August 28, 2013, and March 26, 2014, to all licensees and construction permit holders for both orders.

Additionally, while Attachment 3 provides a list of currently open items, the status and progress of the NRC staff's review may change based on licensee plan changes, resolution of generic issues, and other NRC staff concerns not previously documented. Changes in the NRC staff review will be communicated in the ongoing audit process.

Attachments:

1. NRC and Licensee Staff Onsite Audit Participants
2. Onsite Audit Documents Reviewed
3. MS/SFPI Audit Items currently under NRC staff review

Onsite Audit Participants NRC Staff:

John Boska NRR/JLD/JOMB Laura Okruhlik NRR/JLD/JERB Prem Sahay NRR/JLD/JERB KhoiNguyen NRR/JLD/JERB Joshua Miller NRR/JLD/JERB On Yee NRR/JLD/JCBB Stewart Bailey NRR/JLD David Nelson MTS (contractor)

Oconee Staff:

Dana Jones Manager, Fukushima Response David Garland Supervisor, Operations Support Jim Weir Lead Engineer, Fukushima Response Eddie Welch Principal Engineer, Fukushima Response Greg Saxon Lead Engineer, Fukushima Response David Haile Regulatory Assurance Rusty Childs Fukushima Response Team Laura Todd Fukushima Response Team Tom Loflin Fukushima Response Team Danny Staudt Fukushima Response Team Dean Hubbard Manager, Flooding Response Adam Johnson Fukushima Response Team Guy Levy Fukushima Response Team Jeff Thomas Corporate Fukushima Response Paul Guill Corporate Fukushima Response Eric Henshaw Corporate Safety Analysis Attachment 1

Documents Reviewed

  • OSC-619, Analysis for Use of Spent Fuel Pool Inventory for Standby Shutdown Facility, Revision 43.
  • OSC-1879, Seismic Evaluation of the Borated Water Storage Tank, Revision 4, August 22, 1995.
  • OSC-2509-ICC-0011, "Seismic Qualification for EC 105805 ROOO" (Calculation OSC-2509 revision to add weight to Panel 2AB3 IQF).
  • OSC-2509-ICC-0012, "Seismic Qualification for EC105806 ROOO" (Calculation OSC-2509 revision to add weight to Panel 3AB3A IQF).
  • OSC-8655, Maximum Turbine Building Flood Flow Rate Caused by Failure of a Condenser Inlet Pipe, Rev. 2.
  • OSC-8671, Auxiliary Building Flood Design Values, Rev. 4.
  • OSC-9595 - Protected Service Water System Hydraulic Model Appendix H: B5b Case Alignments, 8/13/14.
  • OSC -9648, Oconee Nuclear Station Units 1, 2 and 3 - Units 1, 2 and 3 BWST Tornado Missile Loading and Evaluation, Revision 1, October 29, 2009.
  • OSC-10937, Extended Loss of AC Power FLEX RELAP5 Analysis, Revision 2, 7/1/15.
  • OSC-11179, Portable RCS Makeup Pumps NPSH, Rev. 1.
  • OSC-11230, Non PSW Installed Auxiliary Building Electrical Equipment That Supports PSW-Temperature Rating Evaluations, Rev 1.
  • OSC-11232, Flow model for portable pump feeding Steam Generators through SSF ASW piping from CTP #1 or Intake Canal.
  • OSC-11253, Auxiliary Building GOTHIC Heat-Up Analysis - ELAP Event Cases, Revision 1.
  • OSC-11295, ELAP Containment Response Analysis, Revision 1, 7/20/15.
  • OSC-11329, FLEX Strategy Intermediate Cooling Hydraulic Calculation, rev. 0.
  • OSC-1134 7, ONS Permanent FLEX Storage Building Structural Analysis, Rev. 0.
  • OSC-11349, FLEX Spent Fuel Pool Makeup, rev. 0.
  • OSC-11358, U2 FLEX Primary and Alternate Strategy Electrical System Calculation, Revision 0.
  • OSC-11383, Revision 0, Attachment 1, Reliance time on the Standby Shutdown Facility (SSF) during an ELAP for a T=O Event, Revision 0, 7/9/15.
  • OSC-11383, Revision 0, Attachment 3, Performing a Deep Load Shed Analysis
  • OSC-11383, Revision 0, Attachment 4, Fuel Oil Evaluation.
  • OSC-11383, Revision 0, Attachment 5, Clarification of Applicable External Flooding at ONS, Revision 0, 6/12/15.
  • OSC-11383, Revision 0, Attachment 7, Calculation of Minimum Spare Hoses and Cables, Revision 0.
  • OSC-11383, Revision 0, Attachment 8, Portable Equipment Deployment Pathway Hazard Assessment, Revision 0.

Attachment 2

  • OSC-11383, Revision 0, Attachment 9, Atmospheric Dump Valve - Survivability and Accessibility (Seismic), Revision 0, 7/15/15.
  • OSC-11383, Revision 0, Attachment 10, Atmospheric Dump Valve - Survivability and Accessibility (Tornado, Wind & Missile), Revision 0, 7/15/15.
  • OSC-11383, Revision 0, Attachment 11, Oconee Mitigating Strategies Revised Sequence of Events Timelines, Revision 0, 7/9/15.
  • OSC-11383, Revision 0, Attachment 12, Beyond Design Basis External Events (BDBEE)

I Extended Loss of AC Power (ELAP) Communications Position Paper, Draft

  • OSC-11383, Revision 0, Attachment 13, FLEX Strategies Lighting Assessment, Draft
  • OSC-11383, Revision 0, Attachment 15, FLEX Mitigating Actions For Environmental Cooling, Revision 0, 7/10/15.
  • OSC-11383, Revision 0, Attachment 17, FSB Seismic Overturning.
  • OSC-11383, Revision 0, Attachment 17, FSB Seismic Interaction.
  • OSC-11383, Revision 0, Attachment 19, Technical Evaluation of Reactor Coolant Pump Seals during FLEX Events, Revision 0, 7/18/15
  • OSC-11383 Revision 0, Attachment 20, Revision 0: Use of Non-Safety Related Components in FLEX Mitigation Strategies.
  • OSC 11383, Revision 0, Attachment X, Seismic Stability Assessment of FLEX Equipment Stored in the FLEX Building, Draft
  • OSC-11431, FLEX Deployment Path Seismic Liquefaction Assessment For Foundation Input Response, Revision 0, March 16, 2015.
  • CN-CCOE-14-5, Rev. 0, "Supporting Chemistry Calculations for Alternate Cooling Source Usage During Extended Loss of All AC Power at Oconee Nuclear Power Station Units, 1, 2 and 3," September 2014.
  • CN-SEE-11-14-4, Rev. 0, "FLEX Alternate Cooling Impact Evaluation for Oconee Nuclear Station Replacement Once-Through Steam Generators," July 2014.
  • DAR-SEE-11-14-7, Rev. 0, "Evaluation of Alternate Coolant Sources for Responding to a Postulated Extended Loss of All AC Power Event at the Oconee Nuclear Station,"

Westinghouse Design Report, January 2015.

  • OSS-0176. 00-00-0005, Rev. 1, Design Basis Specification for the Permanent FLEX Storage Building (PFSB).
  • OSS-0218.00-00-0025, "Specification for the Installation of Field Run Cable Support Systems for ONS," Rev. 15.
  • OFD-104A-1.1 - Oconee Nuclear Station - Units 1 and 2 - Flow Diagram of Spent Fuel Cooling Diagram, Rev. 57.
  • OFD-104A-3.1 - Oconee Nuclear Station - Unit 3 - Flow Diagram of Spent Fuel Cooling Diagram, Rev. 49.
  • 0-0308C, "General Arrangement Auxiliary Building Hot Machine Shop-Spent Fuel Pool -

Plan-EL 838+0 - EL 844+0," Rev. 12.

  • 0-2308C, "General Arrangement Auxiliary Building Spent Fuel Pool Area - Plan-EL 838+0 & EL 844+0," Rev. 15.
  • 0-0702-B, Rev. 26, One line Diagram 4160V and 600VAC Essential Load Centers Auxiliary Power Systems, Standby Shutdown Facility.
  • 0-0703-K, Rev. 75, One line Diagram 600V and 208VAC Essential Motor Control Centers Auxiliary Power Systems, Standby Shutdown Facility.
  • 0-0703-L, Rev. 22, One line Diagram 208/120 and 120 VAC Power Panel Boards (Standby Shutdown Facility.)
  • 0-0706, Rev. 15, One line Diagram Essential SSF 125VDC Auxiliary Power Systems.
  • 0-0912-A, "Auxiliary Building Electrical Equipment Layout - Ventilation Room Below EL.

858 + O"," Rev. 20G.

  • 0-2912, "Auxiliary Building Electrical Equipment Layout - Ventilation Room Below EL.

858 + O"," Rev. 29A.

  • OM-201-3514.001, (Areva Report 32-9221238-000): "Qualifications for a Waveguide Type "B" Support and Horn End Assembly for AREVA Spent Fuel Pool Level Monitoring Instrumentation," Rev. 0.
  • OM-201-3515.001, (Areva Report 32-9221237-002): "Qualifications for a Waveguide Type "A" Support and Horn End Assembly for AREVA Spent Fuel Pool Level Monitoring Instrumentation," Rev. 2.
  • OM-201-3516.001, (Areva Report 32-9218496-002): "Qualification for a Standard Orthogonal Sensor Support for the AREVA Spent Fuel Pool Level Monitoring Instrumentation," Rev. 2.
  • OM-201-3517.001, (Areva Report 32-9220141-001): "ONS FLEX SFPLI- Power Control Panel and Digital Display Mounting and Anchorage Design for Units 1, 2 &3"," Rev. 1.
  • OM-201-3518.001, (Areva Report 32-9221347-001): "ONS SFPLI -Vega Waveguide Span Criteria, Standard Pipe Support Design and Anchorage Verification for Vega Waveguide Supports," Rev. 1.
  • OM-201-3520 (Areva Report 51-9202556-005): Qualification Analysis of VEGAPULS 62ER Through Air Radar.
  • OM-201-3544.001, Baldor Diesel Generator Operation
  • OM-201-3521 (Areva Report 66-00846-002): Test Report for VEGAPULS 62ER.
  • OM-201-3536 (Areva Report 51-9221032-000): Qualification Analysis for VEGA Waveguide Horn Cove.
  • OM-201-3541.001, One-line diagram for Unit 2 primary repower system.
  • OM-201-3543.001, Caterpillar C15 Generator Set Operation.
  • OM-201-3555.001, One-line diagram for Unit 2 alternate repower system.
  • DPM-1393.01-0009-001: Qualification Test Report of Weschler Meter (NTS No. 29553-92N), Rev.O.
  • SAFER 480V System - ONS Phase 3 One line (Electrical), Draft.
  • ONEl-0400-370 - ONS Units 1 and 2 Engineering Instructions: Loss of Spent Fuel Cooling Heat Up Times Due to Decay Heat, Rev. 1.
  • ONEl-0400-3701- ONS Unit 3 Engineering Instructions: Loss of Spent Fuel Cooling Heat Up Times Due to Decay Heat, Rev. 1.
  • EC 105805, Engineering Change for U1-U2 SFP Wide Range Level Instruments.
  • EC 105806, Engineering Change for U3 SFP Wide Range Level Instruments.
  • EC 113108, Engineering Change for U2 FLEX Electrical Connections.
  • EC 113109, Engineering Change for U2 FLEX Electrical Connections.
  • CSD-EG-ONS-1619.1000, Diverse and Flexible Coping Strategies (FLEX) Program Document - Oconee Nuclear Station, Draft.
  • Oconee Nuclear Station SAFER Response Plan, AREVA Document 51-9237989-001, 7/6/15.
  • AP/O/A/1700/010, Turbine Building Flood, Rev. 9.
  • AP/O/A/1700/025, Standby Shutdown Facility Emergency Operating Procedure
  • AP/O/A/1700/030, Plant Flooding, Rev. 20.
  • AP/1-2/A/1700/035: Loss of SFP Cooling And/Or Level).
  • AP/3/A/1700/035: Loss of SFP Cooling And/Or Level).
  • AP/O/A/1700/047, External Flood Mitigation, Rev 14, Draft.
  • EP/2/A/1800/001, Blackout, Draft.
  • FG/2/A/1900/001, Long Term RCS Inventory Control, Draft
  • FG/O/A/1900/003, Alternative Low Pressure Emergency Feedwater, Draft.
  • FG/O/A/1900/005, Initial Assessment and FLEX Equipment Staging, Draft.
  • FG/2/A/1900/007, Alternate Monitoring of Essential Instrumentation, Draft.
  • FG/2/A/1900/008, Alternative RCS Boration, Draft.
  • FG/2/A/1900/009, Low Decay Heat Temperature Control, Draft.
  • FG/2/A/1900/010, CFT lsolationNenting, Draft.
  • FG/1-2/A/1900/011, Alternative Spent Fuel Pool Cooling, Draft.
  • FG/3/A/1900/011, Alternative Spent Fuel Pool Cooling, Draft.
  • FG/2/A/1900/014, Unit 2 Shutdown RCS Makeup, Draft.
  • FG/2/A/1900/015, Containment Isolation and Closure, Draft.
  • FG/2/A/1900/020, Unit 2 FLEX Electrical Distribution, Draft.
  • IP/1-2/B/0220/001G3: Unit 1&2 Wide Range SFP Level Instrument Calibration Procedure
  • IP/3/B/0220/001 G3: Unit 3 Wide Range SFP Level Instrument Calibration Procedure
  • PT/2/A/0600/001, "Periodic Instrument Surveillance," Rev. 307, Draft.
  • PT/3/A/0600/001, "Periodic Instrument Surveillance," Rev. 312, Draft.

Mitigation Strategies/Spent Fuel Pool Instrumentation Safety Evaluation Audit Items:

Audit Items Currently Under NRC Staff Review, Requiring Licensee Input As Noted Audit Item Item Description Licensee Input Needed Reference Provide a description and justification for the specific No input needed at this time. The staff is reviewing ISE 01 3.2.1.1.A evaluation model(s) used in the ELAP analyses for the RELAP5 evaluation model used at Oconee.

Oconee.

The licensee's analysis shows that the pressurizer When further analyses are completed, the licensee relief valves lift until feed flow is established to the should provide additional information that either SGs. The staff requests that the licensee make ISE 01 3.2.1.6.C supports a conclusion that pressurizer relief or safety available for audit a quantification of how much valves do not lift during the ELAP event or that lifting of water is lost from the RCS, and if there is two-the valve(s), if it occurs, is acceptable. phase flow through the reliefs, an evaluation of the capability of the reliefs to handle this flow.

Due to having no main steam isolation valves, and Provide additional information demonstrating steam lines that are exposed to tornado missiles, successful mitigation of an ELAP event involving an the NRC staff's judgment is that a guillotine break of ISE 01 3.2.1.6.D uncontrolled cooldown resulting from consequential a main steam line with no automatic feedwater damage to the main steam system due to the severe isolation signal should be postulated. The staff natural hazard that initiates the ELAP event. requests that the licensee make available for audit an analysis of this event.

Confirm that the final ELAP computer code analyses for core cooling, reactor coolant system inventory, None at this time. The staff is reviewing the ISE Cl 3.2.1.1.B shutdown margin, and containment integrity have computer codes used at Oconee.

acceptable methodology and assumptions and support the sequence of events timeline.

Attachment 3

Audit Item Item Description Licensee Input Needed Reference The RCP seal heats up until SSF RCMU pump flow Confirm that RCP seal temperature would be is established about 20 minutes after the ELAP maintained at an acceptably low value by establishing ISE Cl 3.2.1.2. B occurs. The staff requests that the licensee make injection flow to the RCP seals via the SSF RCMU available for audit an analysis of the temperatures pump within 20 minutes of event initiation.

reached in the RCP seal.

Confirm there is justification for the assumed seal No input needed at this time. The staff is reviewing ISE Cl 3.2.1.2.C leakage rates for the Bingham RCPs with Sulzer seal the information provided by the licensee.

assemblies.

Confirm there is justification for the assumed seal No input needed at this time. The staff is reviewing ISE Cl 3.2.1.2. D leakage rates for the Westinghouse 93-A RCPs with the information provided by the licensee and the Flowserve N-9000 seals with the Abeyance feature. vendor.

The staff requests that the licensee make available for audit an analysis of possible damage to the When evaluations are completed, confirm that the ADVs from seismic interaction or damage to main survivability and performance of the atmospheric dump steam branch lines from seismic interaction. The ISE Cl 3.2.1.6.E valves is adequate to support Oconee's mitigation staff also requests additional analysis and/or strategy. justification that exposed main steam piping and the ADVs will survive a beyond design basis high wind event, including wind-generated missiles.

Please provide the results for the selected methods, tests and analyses used to demonstrate the No input needed at this time. The staff is reviewing SFPI RAl-8-D qualification and reliability of the installed equipment in the information provided by the licensee.

accordance with the order requirements.

Please (1) state the ambient conditions (temperature, pressure, humidity) under which the SSF RCMU pumps are qualified or otherwise expected to function and provide a The staff requests that the licensee make available for basis, (2) state the expected conditions in containment during audit the analyses that show the conditions in SE 20-E the period when the functionality of the SSF RCMU pumps is containment and the qualification data for the SSF credited and provide a basis, and (3) confirm that the credit RCMU pumps.

taken for the SSF RCMU pumps under ELAP conditions is justified.

S. Batson If you have any questions, please contact me at 301-415-2901 or by e-mail at John.Boska@nrc.gov.

Sincerely, IRA/

John P. Beska, Senior Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos.: 50-269, 50-270, and 50-287

Enclosure:

Audit report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsRgn2MailCenter Resource JOMB R/F JBoska, NRR RidsNrrDorllpl2-1 Resource MHalter, NRR RidsNrrPMOconee Resource LGibson, NRR RidsNrrLASLent Resource AProffitt, NRR RidsAcrsAcnw_MailCTR Resource JHall, NRR ADAMS Accession No. ML15259A387 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JCBB/BC(A)*

NAME JBoska SLent BTitus DATE 9/23/2015 09/17/2015 9/23/2015 OFFICE NRR/JLD/JERB/BC(A)* NRR/JLD/JOMB/BC(A) NRR/JLD/JOMB/PM NAME Jlehning MHalter JBoska DATE 9/23/2015 9/23/2015 10/6/2015 OFFICIAL AGENCY RECORD

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