ML16223A725

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Events) CAC Nos. MF4467 and MF4468)

ML16223A725
Person / Time
Site:	Brunswick
Issue date:	08/17/2016
From:	Jessie Quichocho Japan Lessons-Learned Division
To:	William Gideon Duke Energy Progress
References
CAC MF4467, CAC MF4468, EA-13-109
Download: ML16223A725 (24)

Text

UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 17, 2016 Mr. William R. Gideon Site Vice President Brunswick Steam Electric Plant 8470 River Rd. SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - INTERIM STAFF EVALUATION RELATING TO OVERALL INTEGRATED PLAN IN RESPONSE TO PHASE 2 OF ORDER EA-13-109 (SEVERE ACCIDENT CAPABLE HARDENED VENTS) (CAC NOS. MF4467 AND MF4468)

Dear Mr. Gideon:

By letter dated June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13143A334). By letter dated December 11, 2015 (ADAMS Accession No. ML16020A064 ), Duke Energy Progress, Inc. (Duke, the licensee), submitted its third six-month status report of the implementation of the Commission order with Regard to Requirements for Reliable Hardened Vents (EA-13-109). The letter also included the Overall Integrated Plan (OIP) for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP) in response to Phase 2 of Order EA-13-109. The focus of the Phase 2 Interim Staff Evaluation (ISE) is to document the NRC staff's review of the information provided for implementation of Phase 2 requirements of Order EA-13-109. The new information provided related to Phase 1 of the order and open items identified in the staff's ISE on Phase 1 will be addressed separately. Any changes to the compliance method will be reviewed as part of the ongoing audit process.

The licensee's OIP for BSEP appears consistent with the guidance found in Nuclear Energy Institute (NEI) 13-02, Revision 1, endorsed, in part, by the NRC's Japan Lessons-Learned Project Directorate (JLD) Interim Staff Guidance (ISG) JLD-ISG-2015-01, as an acceptable means for implementing the requirements of Phase 2 of Order EA-13-109. This conclusion is based on satisfactory resolution of the open items detailed in the enclosed interim staff evaluation. This evaluation only addressed consistency with the guidance. Any plant modifications will need to be conducted in accordance with plant engineering change processes, the licensing basis, and the Commission's regulations.

W. Gideon If you have any questions, please contact Brian E. Lee, Project Manager, at 301-415-2916 or at Brian.Lee@nrc.gov.

Sincerely, s ie F. Quichocho, Chief ontainment and Balance of Plant Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosure:

Interim Staff Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 INTERIM STAFF EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER EA-13-109 PHASE 2, MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS DUKE ENERGY PROGRESS, INC.

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By letter dated June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC, the Commission) issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" [Reference 1].

The order requires licensees to implement its requirements in two phases. In Phase 1, licensees of boiling-water reactors (BWRs) with Mark I and Mark II containments are required to design and install a venting system that provides venting capability from the wetwell during severe accident conditions. In Phase 2, licensees of BWRs with Mark I and Mark II containments are required to design and install a venting system that provides venting capability from the drywell under severe accident conditions, or, alternatively, those licensees shall develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. As required by Order EA- 13-109, Duke Energy Progress, Inc. (Duke, the licensee) submitted its Overall Integrated Plan (OIP) for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP, Brunswick) for Phase 1 on June 26, 2014 [Reference 2]. The NRC staff's evaluation of the licensee's OIP for implementation of Phase 1 requirements was provided in the staff's interim staff evaluation (ISE) for Phase 1 on March 10, 2015 [Reference 3].

This ISE focuses on the staff's review of the information provided for implementation of Phase 2 requirements of Order EA-13-109. Phase 2 of Order EA-13-109 requires that BWRs with Mark I and Mark II containments have either a vent path from the containment drywell or a strategy that Enclosure

makes it unlikely that venting would be needed from the drywell before alternate, reliable containment heat removal and pressure control is reestablished. The second phase is not required to be installed concurrently with the first phase. The second phase shall be implemented no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.

By letter dated December 11, 2015 [Reference 4], Duke provided its OIP for BSEP in compliance with Section IV, Condition D. 2 of Order EA-13-109. The OIP describes the licensee's currently proposed modifications to systems, structures, and components, new and revised guidance, and strategies that it intends to implement in order to comply with the requirements of Phase 2 of Order EA-13-109. The OIP also includes the third 6-month update for Phase 1 of the order in accordance with Section IV, Condition D. 3 of Order EA-13-109. As stated above, this ISE will focus on the staff's review of information provided in the OIP related to implementation of requirements for Phase 2 of the order. In specific areas where Phase 1 requirements are associated with the Phase 2 strategy, it is addressed in this ISE.

2.0 REGULATORY EVALUATION

Following the events at the Fukushima Dai-ichi nuclear power plant on March 11, 2011, the NRC established a senior-level agency task force referred to as the Near-Term Task Force (NTTF). The NTTF was tasked with conducting a systematic and methodical review of the NRC regulations and processes and determining if the agency should make improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this review, the NTTF developed a set of recommendations, documented in SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan," dated July 12, 2011

[Reference 5]. These recommendations were enhanced by the NRC staff following interactions with stakeholders. Documentation of the NRC staff's efforts is contained in the Commission's staff requirements memorandum (SRM) for SECY-11-0124, "Recommended Actions to be Taken without Delay from the Near-Term Task Force Report," dated September 9, 2011

[Reference 6], and SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned," dated October 3, 2011 [Reference 7].

As directed by the Commission's SRM for SECY-11-0093 [Reference 8], the NRC staff reviewed the NTTF recommendations within the context of the NRC's existing regulatory framework and considered the various regulatory vehicles available to the NRC to implement the recommendations. SECY-11-0124 and SECY-11-0137 established the NRC staff's prioritization of the recommendations based upon the potential safety enhancements.

On February 17, 2012, the NRC staff provided SECY-12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami" [Reference 9], to the Commission, including the proposed order to implement the installation of a reliable hardened containment venting system (HCVS) for Mark I and Mark II containments. As directed by SRM-SECY-12-0025 [Reference 10], the NRC staff issued Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents" [Reference 11], which required licensees to install a reliable HCVS for Mark I and Mark 11 containments.

While developing the requirements for Order EA-12-050, the NRC acknowledged that questions remained about maintaining containment integrity and limiting the release of radioactive materials if the venting systems were used during severe accident conditions. The NRC staff presented options to address these issues for Commission consideration in SECY-12-0157, "Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments" [Reference 12]. In the SRM for SECY-12-0157

[Reference 13], the Commission directed the staff to issue a modification to Order EA-12-050, requiring licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." The NRC staff held a series of public meetings following issuance of SRM SECY-12-0157 to engage stakeholders on revising the order. Accordingly, by letter dated June 6, 2013, the NRC issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions."

Order EA-13-109, Attachment 2, requires that BWRs with Mark I and Mark II containments have a reliable, severe-accident capable HCVS. This requirement shall be implemented in two phases. In Phase 1, licensees of BWRs with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the wetwell during severe accident conditions. Severe accident conditions include the elevated temperatures, pressures, radiation levels, and combustible gas concentrations, such as hydrogen and carbon monoxide, associated with accidents involving extensive core damage, including accidents involving a breach of the reactor vessel by molten core debris. In Phase 2, licensees of BWRs with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the drywell under severe accident conditions, or, alternatively, those licensees shall develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions.

On November 12, 2013, the Nuclear Energy Institute (NEI) issued NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 0 [Reference 14] to provide guidance to assist nuclear power reactor licensees with the identification of measures needed to comply with the requirements of Phase 1 of the HCVS order. On November 14, 2013, the NRC staff issued Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG)

JLD- ISG-2013-02, "Compliance with Order EA-13-109, 'Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions'" [Reference 15], endorsing, in part, NEI 13-02, Revision 0, as an acceptable means of meeting the requirements of Phase 1 of Order EA-13-109, and published a notice of its availability in the Federal Register (FR) (November 25, 2013, 78 FR 70356). As required by the order, the licensee submitted its OIP for BSEP for Phase 1 on June 26, 2014. As stated above, the NRC staff issued its ISE for implementation of Phase 1 requirements on March 10, 2015

[Reference 3].

On April 23, 2015, the NEI issued NEI 13-02, "Industry Guidance for Compliance with Order EA- 13-109," Revision 1 [Reference 16] to provide guidance to assist nuclear power reactor licensees with the identification of measures needed to comply with the requirements of Phase 2 of Order EA-13-109. On April 29, 2015, the NRC staff issued JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA-13-109, 'Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions"' [Reference 17],

endorsing, in part, NEI 13-02, Revision 1, as an acceptable means of meeting the requirements of Phase 2 of Order EA-13-109, and published a notice of its availability in the FR (May 7, 2015, 80 FR 26303). Licensees are free to propose alternate methods for complying with the requirements of Order EA-13-109.

By letter dated May, 27, 2014 [Reference 18], the NRC notified all BWR Mark I and Mark II licensees that the staff will be conducting audits of the implementation of Order EA-13-109.

This letter described the audit process to be used by the staff in its review of the information contained in licensee's submittals in response to Phase 1 of Order EA-13-109. The staff is using a similar process for its review of the information submitted for implementation of Phase 2 requirements of the order.

3.0 TECHNICAL EVALUATION

Brunswick is a dual General Electric BWR, each unit having an independent reactor building and a Mark I primary containment system. To implement the Phase 1 HCVS requirements of Order EA-13-109, the licensee plans to upgrade the venting capability from the containment wetwells to provide reliable, severe accident capable hardened vents to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions.

To implement the Phase 2 (alternate strategy) requirements, the licensee plans to provide (i) a capability for severe accident water addition (SAWA), which will include combination of permanently installed and portable equipment to provide a means to add water to the reactor pressure vessel (RPV) following a severe accident and monitor system and plant conditions and (ii) a severe accident water management (SAWM) strategy and guidance for controlling the water addition to the RPV for the sustained operating period. The OIP describes evaluations of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. In addition, the OIP describes programmatic changes that include procedures, training, drills, and maintenance for SAWA and SAWM actions.

3.1 GENERAL INTEGRATED PLAN ELEMENTS AND ASSUMPTIONS 3.1.1 Evaluation of Extreme External Hazards Extreme external hazards for BSEP were evaluated in its OIP in response to Order EA-12-049 (Mitigation Strategies) [Reference 21 ]. In the BSEP ISE relating to Mitigation Strategies

[Reference 20], the NRC staff documented an analysis of BSEP's extreme external hazards evaluation. The following extreme external hazards screened in: Seismic, External Flooding, Extreme Cold - Ice only, High Wind, Extreme High Temperature. The following extreme external hazards screened out: Extreme Cold - except for Ice. The NRC staff's review confirmed that the licensee's approach described in the Brunswick OIP in response to Order EA-12-049 (Mitigation Strategies) [Reference 19], is consistent with the guidance found in NEI 12-06 [Reference 27], as endorsed by JLD-ISG-2012-01 [Reference 28], and that the requirements of Order EA-12-049 will be met for screening of the extreme external hazards if these requirements are implemented as described.

3.1.2 Assumptions In its OIP, the licensee stated that it has adopted a set of generic assumptions associated with Order EA-13-109 Phase 1 and Phase 2 actions. The NRC staff reviewed the information in the OIP and determined that the set of generic assumptions appear to establish a baseline for HCVS evaluation consistent with the guidance found in NEI 13-02, Revision 1, as endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable method to implement the requirements of Order EA-13-109.

The NRC staff's review noted that there were no plant-specific assumptions added, only slightly modified, for implementation of Phase 2 requirements of the order in the OIP. The NRC staff reviewed the information in the OIP and determined that the modifications to the plant specific assumptions for BSEP do not appear to create any deviations from the guidance found in NEI 13-02, as endorsed, in part, by JLD-ISG-2015-01 as an acceptable method to implement the requirements of Order EA-13-109 Compliance Timeline and Deviations In Part 1 of its OIP, the licensee stated that compliance will be attained with no known deviations to the guidelines included in JLD-ISG-2013-02, JLD-ISG-2015-01, and NEI 13-02 for each phase. Specifically, the OIP noted that the HCVS will be comprised of installed and portable equipment and operating guidance. For compliance with Phase 1 requirements of the order, the severe accident wetwell vent will be a permanently installed vent from the suppression pool. For compliance with Phase 2 requirements of the order, strategies for the use of SAWA and SAWM will include a combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and guidance for controlling the water addition to the RPV for the sustained operating period. The OIP states that the current compliance schedule for Phase 2 is in the 1st Quarter of 2018 for Unit 1 and in the 1st Quarter of 2019 for Unit 2. The OIP also noted that if deviations are identified at a later date, then the deviations will be communicated in a future 6-month update following identification.

Brunswick's implementation schedule complies with the requirements of the order, and neither Duke nor the NRC staff has identified any deviations. Therefore, the NRC staff concludes that, if implemented, as described, it appears BSEP will attain compliance with Phase 2 of Order EA-13-109 with no known deviations to the guidance found in NEI 13-02, endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable method to implement the requirements of Order EA-13-109.

3.2 BOUNDARY CONDITIONS FOR WETWELL VENT As documented in the ISE for implementation of Phase 1, dated March 10, 2015 [Reference 3],

the NRC staff determined that the licensee's approach to boundary conditions for wetwell vent, if implemented as described in Section 3.2 and pending acceptable resolution of open items, appears to be consistent with the guidance found in NEI 13-02, endorsed in part, by JLD-ISG-2013-02 as an acceptable means for implementing the requirements of Order EA-13-109. For the staff's complete analysis of the boundary conditions for wetwell vent, see referenced ISE.

Any new information included in the 6-month updates related to implementation of Phase 1 requirements of the order will be addressed separately.

3.3 BOUNDARY CONDITIONS FOR EA-13-109 Order EA-13-109, Attachment 2, Section B states that licensees with BWRs with Mark I and Mark II containments shall either:

(1) design and install a HCVS, using a vent path from the containment drywell, that meets the requirements of Section 8.1, or (2) develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell before alternate reliable containment heat removal and pressure control is established that meets the requirements in Section 8.2.

In its OIP, the licensee confirmed that they will be using Option 8.2 of EA-13-109 (SAWA and SAWM; or 545 degrees Fahrenheit (°F) severe accident drywell vent with SAWA). Therefore, the licensee used the OIP template found in NEI letter dated September 28, 2015 [Reference 23], and endorsed in NRC letter dated October 8, 2015 [Reference 26], as guidance to structure its OIP submittal. Both SAWM and severe accident drywell vent require the use of SAWA and may not be done independently. As a result, the HCVS actions under Part 2 of the licensee's OIP apply to Part 3 of the OIP, which includes the SAWA section and two subsections (SAWM and severe accident drywell vent, respectively). In Attachment 2.1.C of the licensee's OIP, additional plant-specific information is provided to support SAWA and SAWM actions.

3.3.1 Sequence of Events (SOE)

Order EA-13-109, Sections B.2.1, 8.2.2, and B.2.3 state that:

2.1 The strategy making it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions shall be part of the overall accident management plan for Mark I and Mark 11 containments.

2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation.

In accordance with the requirements of Order EA-13-109, the operation of the HCVS using SAWA will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1 of the OIP and in Section 3.1.1 above. These include: Seismic, External Flooding, Extreme Cold - Ice only, High Wind, Extreme High Temperature. The licensee noted in its OIP, that initial operator actions will be completed by plant personnel and will include the capability for remote-manual initiation from the HCVS control station (either the main control room or the remote operating station (ROS)).

The licensee developed timelines (see attachments 2A, SOE Timeline - HCVS and 2.1.A, Sequence of Events Timeline - SAWA and SAWM), of the OIP for SAWA and SAWM) to identify required operator response times and actions. The timelines are an expansion of A of the OIP and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as the SAWA flowrate is adjusted for Option B.2 (SAWM) of Order EA-13-109. The licensee also indicated in its 01 P, that the timelines are appropriate for both in-vessel and ex-vessel core damage conditions. A list of manual actions needed to be performed by the plant personnel are noted in Table 3.1 of the OIP. The licensee stated that all operator actions, either from the primary operating station (POS) or the ROS will be evaluated for expected radiological and temperature conditions using the guidance provided in NEI 13-02 and HCVS-FAQ [Frequently Asked Questions]-12 [Reference 23].

The NRC staff reviewed the three cases contained in the SOE timeline for use of the HCVS

[Attachment 2A of the OIP] and compared it with the information contained in the guidance document NEI 13-02, Revision 1, and determined that the three cases appropriately bound the conditions for which the HCVS is required. The three cases are: (1) successful FLEX implementation with no failure of reactor core isolation cooling (RCIC); (2) late failure of RCIC leading to core damage; and (3) failure of RCIC to inject at the start of the event. The timelines accurately reflect the progression of events as described in the BSEP Mitigation Strategies OIP

[Reference 21], SECY-12-0157 [Reference 12], and NUREG-1935, State-of-the-Art Reactor Consequence Analyses [Reference 22]. The NRC staff also reviewed the SOE timeline -

• SAWA/SAWM [Attachment 2.1.A of the OIP] and determined that the appropriate actions are identified for which the SAWA/SAWM is required and are consistent with the generic guidance provided in NEI 13-02, Revision 1.

The NRC staff reviewed the licensee discussion on the SOEs identified in the OIP against the guidance in NEI 13-02 and confirmed that the identified items appear to be appropriately derived from the timelines developed in Attachment 2.1.A of the OIP, consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01. The timeline establishes when electrical power and Order EA-12-049 actions are needed to support the strategies for Order EA-13-109, Phase 1, and Phase 2; and when to initiate SAWA flow to the RPV.

3.3.2 Boundary Conditions for SAWA Order EA-13-109, Sections B.2.2, and B.2.3 state that:

2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation.

3.3.2.1 SAWA Manual and Time Sensitive Actions Table 3.1 of the OIP provides a list of SAWA manual actions, which are time sensitive. These manual actions include establishing HCVS capability, making several electrical and mechanical connections in order to initiate water injection to the RPV, and monitoring of SAWA indications.

These time sensitive manual actions are expected to be performed within 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> from the loss of injection systems due to a severe accident and to support the strategies and actions needed for Phase 1 and Phase 2 requirements of Order EA-13-109. These actions will also support the SAWA flow to the RPV in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The time sensitive actions to be completed within the reactor building will be evaluated per guidance in NEI 13-02 and HCVS-FAQ-12 [Reference 23]. Time constraints for operator actions and their bases including their validation will be completed per guidance in NEI 13-02 and HCVS-FAQ-13 [Reference 23].

The SAWA flow path will use the same path and equipment as the FLEX primary injection flow path, but without the need to run any hoses inside the reactor building. All equipment and connections are remote from the HCVS vent pipe and so are protected by intervening structures and distance from the radiation from the vent pipe. The path is as follows:

• Hose connection at the condensate storage tank (CST) that is protected from all applicable external hazards

• FLEX suction hose from the CST to the FLEX (SAWA) pump that is stored in the FLEX storage building

• FLEX (SAWA) pump that is stored in the FLEX storage building

• FLEX discharge hose from the FLEX (SAWA) pump to the reactor building core bore connection at the reactor building wall and reachable at ground level

• Through the core bore to a manual valve located inside the reactor building

• Through a pipe, two manual valves and a check valve to the reactor water cleanup (RWCU) return line

• Via RWCU return, reactor core isolation cooling (RCIC) and main feed to the RPV

• SAWA flow rate will be monitored via a flow meter mounted on the FLEX (SAWA) pump skid.

• SAWA flow rate can be controlled by throttling valves on the FLEX (SAWA) pump skid The licensee noted that preliminary evaluations of conditions to ensure that operating personnel can safely access and operate controls and support equipment for SAWA equipment and connections external to protected buildings have been performed. These evaluations indicate that personnel can complete the initial and support activities without exceeding the ERO-allowable dose for equipment operation or site safety standards.

Open Item: Licensee to confirm through analysis the temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

The NRC staff reviewed the SAWA Manual Actions (Table 3.1 of the OIP), as well as time sensitive SAWA actions and found that the components required for manual operation appear to be in areas that are readily accessible to plant operators, and do not require extensive operator actions to operate the SAWA system. Additionally, the manual actions minimize the time

operators need to spend at the SAWA monitoring locations during system operation under severe accident conditions. The NRC staff reviewed the SAWA manual and time sensitive actions against the guidance in Section 6.1 and Attachment I of NEI 13-02, Revision 1

[Reference 16], and confirmed that these actions appear to consider minimizing the reliance on operator actions and be timely taken. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.2.2 SAWA Severe Accident Operation The SAWA operating requirements during a severe accident were developed using guidance provided in NEI 13-02, Section 4 and Appendix I. The guidance indicates that a maximum water addition flow of 500 gallons per minute (gpm) is sufficient for SAWA. The guidance also indicates that the time to establish water addition capability is expected to be less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Plant connection points and portable equipment satisfying the requirements of Order EA-12-049 may be credited by providing actions necessary to deploy and maintain equipment that can be performed under the thermal and radiological conditions that exist during a severe accident.

The SAWA flow path should contain backflow prevention to minimize the possibility of combustible gases, and the backflow of hot and radioactive fluids from exiting containment through the SAWA system.

In its OIP, the licensee stated that their strategy for SAWA assumes loss of reactor injection at the onset of the event. The SAWA capability will be available within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and will use existing and portable equipment. The OIP also noted that the SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids, gases, and potentially flammable conditions by inclusion of backflow prevention. Specifically, the BSEP SAWA injection flow path utilizes the RWCU and the main feedwater system to add water to the RPV.

The OIP states that the main feedwater containment isolation check valves prevent any backflow from the RPV to the SAWA connection.

As part of SAWA operation, the OIP described the SAWA actions that will be required for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and coping details for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation. The OIP indicated that SAWA operation is the same for the full period of sustained operation. The SAWA system shall be capable of providing a RPV injection rate of 300 gpm within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a loss of all RPV injection following an extended loss of all alternating current (ac) power (ELAP)/Severe Accident. The SAWA system shall meet the design characteristics of the HCVS with the exception of the dedicated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power source. Hydrogen mitigation is provided by the presence of a backflow prevention device in the SAWA flow path as described above, which is consistent with the guidance found in Section 1.1.4.4 of NEI 13-02, Revision 1.

Brunswick performed a site specific evaluation to justify the use of a lower initial SAWA flow rate of 300 gpm. This initial flow rate will be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of all RPV injection following an ELAP/Severe Accident and will be maintained for four hours before reduction to the wetwell vent preservation flow rate. The licensee used the Modular Accident Analysis Program (MAAP) Version 5.02 to perform this evaluation.

Open Item: Licensee to provide the site-specific MAAP evaluation that establishes the initial SAWA flow rate.

The NRC staff reviewed the SAWA severe accident operation against the guidance in Section 4 and Appendix I to NEI 13-02, Revision 1 and determined that if operated as described in the BSEP OIP, this strategy appears to be able to maintain the temperature in the drywell less than 545 °F in an ELAP scenario. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA 109.

3.3.2.3 Equipment Locations/Controls/Instrumentation The licensee used the guidance provided in NEI 13-02, Section 1.1.6 in selecting the equipment locations, controls, and instrumentation. The ingress and egress paths were evaluated for the expected severe accident conditions for the sustained operating period. Severe accident conditions include temperature, humidity, and radiation. The equipment has been evaluated to remain operational throughout the period of sustained operation. Personnel exposure and environmental conditions for operation of SAWA equipment has also been evaluated per plant safety guidelines. In its OIP, the licensee stated that electrical equipment and instrumentation will be powered from the existing station batteries, and from ac distribution systems that are powered from the generators used in support of Order EA-12-049 requirements.

In its OIP, the licensee provided information regarding how electrical equipment and instrumentation will be powered to monitor the required parameters during the sustained period of operation. The parameters to be monitored as noted in the OIP table include:

• Drywell Pressure

• Suppression Pool Level

• SAWA Flow The NRC staff reviewed the information provided regarding power sources for the electrical equipment and instrumentation and finds it acceptable. The OIP also stated that equipment and instrumentation will be evaluated to perform for the sustained operating period under the expected radiological and temperature conditions.

Open Item: Licensee to demonstrate how instrumentation and equipment being used for SAWA and supporting equipment is capable to perform for the sustained operating period under the expected temperature and radiological conditions.

The OIP also stated that SAWA components and connections external to protected buildings have been protected against the screened-in hazards of Order EA-12-049 for the station.

Regarding component qualifications, the OIP stated that the SAWA permanently installed equipment shall meet the same qualifications as for the wetwell operation during severe accident conditions. The OIP further stated that temporary and portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06.

At BSEP, the SAWA pumps and hoses are stored in the FLEX storage building, which is protected from all the screened-in external hazards.

The NRC staff reviewed the equipment locations, controls, and instrumentation that are described for SAWA monitoring and control against the guidance in Appendix I to NEI 13-02, Revision 1 and, confirmed that they are consistent. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA 109.

3.3.2.4 SAWA Procedures/Guidelines In its OIP, the licensee stated that the procedures and guidelines in support of SAWA implementation are captured by the emergency operating procedure (EOP) network as a means of water injection to the RPV when RPV level is not being maintained by other systems.

Procedure EOP-01-FSG-07 and -02 are stated to contain guidance for deployment/connection and specific pump operation respectively. The OIP states that the procedures are the same as for the FLEX strategy, with the exception of using a hard pipe connection instead of a hose inside the reactor building.

The NRC staff reviewed the BSEP OIP section which describes elements and action items in support of SAWA implementation. The staff agrees that the information provided will support completing the SAWA procedures and guidelines in support of SAWA implementation. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.3 Boundary Conditions for SAWA/SAWM Order EA-13-109, Attachment 2, requirement A.1.2.1 requires the HCVS to have the capacity to vent the steam/energy equivalent of one percent of the licensed/rated thermal power and be able to restore and maintain containment pressure below the primary containment design pressure and the primary containment pressure limit. This was identified in the OIP for Phase 1.

Order EA-13-109, Attachment 2, requirement B.2.2 requires that the licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions. Requirement A.1.2.1 provides assurance the HCVS has sufficient capacity to prevent containment failure as a result of over pressurization. Maintaining the availability of the wetwell vent makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions.

Guidance document NEI 13-02, Revision 1, as endorsed, in part, by NRC guidance JLD-ISG-2015-01, states that the preservation of the wetwell vent path, which is accomplished by managing the water addition flow rate to the extent that the wetwell vent line remains available until other means of severe accident coping are available is termed Severe Accident Water Management (SAWM).

In NEI 13-02, Revision 1, also states that there are three approaches for demonstrating a successful SAWM strategy that constitute a reliable containment venting strategy that makes it

unlikely that a licensee would need to vent from the containment drywell before alternate reliable containment heat removal and pressure control is reestablished.

Open Item: Licensee to demonstrate that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

In its OIP, the licensee indicated that SAWM can be maintained >7 days without the need for a drywell vent to maintain pressure below Primary Containment Pressure Limit, which meets the criteria for the first approach identified in NEI 13-02, Revision 1. The NRC staff reviewed the boundary conditions for SAWNSAWM against the guidance in Appendix C. 7 to NEI 13-02, Revision 1, and confirmed that under this approach, no detail concerning plant modifications or procedures is necessary in the licensee's OIP with respect to how alternate containment heat removal will be provided. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.3.1 Basis for SAWM Time Frame In NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 it states that SAWM will lead to an HCVS Stable State for the drywell and wetwell for at least 7 days from the start of the ELAP as shown in Figures C-2 through C-6 of the guidance document. Figures C-2 through C-6 of NEI 13-02, Revision 1, which are based on a representative BWR-4 with Mark I containment using MAAP 5.02, demonstrate that SAWA and SAWM in conjunction with the wetwell vent, can stabilize containment parameters and prevent containment failure even with a delay in water injection that results in core debris breaching the reactor vessel for the representative plant. In addition, the wetwell vent is effective in removing non-condensable gases from containment, including any hydrogen generated by the core oxidation and the core-concrete interaction. The licensee states in its OIP that BSEP is performing a site-specific evaluation, as discussed above in Section 3.3.2.2, which will demonstrate acceptable performance comparable to the reference plant in guidance document NEI 13-02 figures C-2 through C-6.

Instrumentation that will be utilized to implement the SAWM strategy includes drywell pressure, suppression pool level, and SAWA flow. The OIP states that modifications are planned such that these indications will be initially powered by station batteries and then by the FLEX (EA 049) generator. The diesel generator (DG) will provide power throughout the sustained operation period (7 days).

The OIP states that suppression pool level indication will be maintained throughout the sustained operation period, so the HCVS remains in-service. The time to reach the level at which the wetwell vent must be secured is >7 days using SAWM flowrates. Procedures will be developed that control the suppression pool level in the indicating range. The instruments to monitor pressure in the drywell will also be maintained to assist in determining how effectively the core is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which the SAWM flowrate should be adjusted (up or down) using suppression pool level and drywell pressure as controlling parameters to remove the decay heat from the containment.

The NRC staff reviewed the basis for the SAWM time frame against the guidance in Appendix C to NEI 13-02, Revision 1 and, confirmed that they are consistent. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.3.2 SAWM Manual and Time Sensitive Actions Table 3.1.B of the OIP provides a list of SAWM manual actions. The time sensitive SAWM actions include: (1) initiate actions to maintain the wetwell vent capability by lowering injection rate, while maintaining the cooling of the core debris; and (2) monitor SAWM critical parameters while ensuring the severe accident wetwell vent remains available.

The NRC staff reviewed the SAWM Manual Actions (Table 3.1.B of the OIP) and time sensitive SAWM actions, and found that the components required for manual operation appear to be in areas that are readily accessible to plant operators, and do not require extensive actions to facilitate the SAWM strategy. Additionally, the manual actions appear to minimize the time operators need to spend at the SAWM monitoring locations during system operation under severe accident conditions. The NRC staff reviewed the SAWA manual and time sensitive actions against the guidance in Section 6.1 and Attachment C of NEI 13-02, Revision 1

[Reference 16], and confirmed that these actions appear to consider minimizing the reliance on operator actions. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.3.3 SAWM Severe Accident Operation Order EA-13-109 Attachment 2, Sections B.2.2 and B.2.3 state that:

2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation.

The licensee anticipates that SAWM will only be used in severe accident events based on presumed failure of plant injection systems, as directed by the plant severe accident mitigation guidelines (SAMGs). Attachment 2.1.D of the OIP provides language for SAWM that will be incorporated into the site SAMGs.

The SAWA capability will be established as described above in Section 3.2.2. The SAWM strategy will use the installed instrumentation to monitor and adjust the flow from the SAWA equipment to control the pump discharge to deliver flowrates applicable to the SAWM strategy.

Once the SAWA initial flow rate has been established for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the flow will be controlled while monitoring drywell pressure and suppression pool level. The SAWM flowrate will be

controlled to maintain containment parameters and preserve the wetwell vent path. The SAWA equipment is expected to be capable of injection for the period of sustained operation.

The SAWM flow strategy will be the employed until alternate reliable containment heat removal and pressure control is reestablished (which is not expected to exceed 7 days). The SAWM flow strategy uses the SAWA flow path and no additional modifications are being made for SAWM.

The instrumentation necessary to employ the SAWM strategy shall be capable of monitoring the containment parameters of drywell pressure and suppression pool level to provide information to operators to assist them in determining how SAWA injection rates should be controlled, until alternate containment decay heat/pressure control is established. The SAWA equipment is expected to be capable of injection for the period of sustained operation (7 days).

The NRC staff reviewed the SAWM severe accident operation, specifically the expected SAWA flow rates from initiation of SAWA, the expected suppression pool water level response, the suppression pool freeboard, and the minimum permitted flow rate for containment protection. It was determined that under this water management strategy, sufficient water will be supplied to reduce thermal challenges to the containment so that the containment capability remains intact, and in addition, water flow rate can be optimized, when appropriate, in order to avoid compromising the wetwell vent path. The NRC staff reviewed the SAWM severe accident operation against the guidance in Appendix C to NEI 13-02, Revision 1 and determined that, if operated, as described, this strategy may be used in an ELAP scenario to mitigate core damage. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.3.3.4 Equipment Locations/Controls/Instrumentation The SAWM control location is the same as the SAWA control location. The OIP indicates the SAWA flowrate is provided at the pump trailer by an installed flow instrument qualified to operate under the expected environmental conditions. The injection flowrate is controlled by a manual valve located on the FLEX pump skid. Suppression pool level and drywell pressure are read in the control room using indicators powered by the FLEX diesel generator installed under Order EA-12-049. These indications are used to control SAWM flowrate to the RPV.

Open Item: Licensee to demonstrate that there is adequate communication between the main control room (MCR) and the operator at the FLEX manual valve during severe accident conditions.

The OIP also noted that the key parameters used for SAWM implementation are:

• Drywell Pressure

• Suppression Pool Level

• SAWA Flowrate The OIP states the drywell pressure and suppression pool level instruments are qualified to Regulatory Guide 1.97 requirements and are the same instruments used for the wetwell vent.

The SAWA flow instrumentation will be qualified for the expected environmental conditions when needed.

Open Item: Licensee to demonstrate the SAWM flow instrumentation qualification for the expected environmental conditions.

The NRC staff reviewed the equipment locations, controls, and instrumentation that are described for SAWM monitoring and control of the SAWA system and, determined that they appear to be reasonable. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.4 PROGRAMMATIC CONTROLS, TRAINING, DRILLS, AND MAINTENANCE 3.4.1 Programmatic Controls Order EA-13-109, Sections 3.1 and 3.2 state that:

3.1 The licensee shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power.

3.2 The licensee shall train appropriate personnel in the use of the HCVS.

The training curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power.

In Part 4 of its OIP, the licensee states that a site-specific program and procedures are being developed following the guidance provided in NEI 13-02, Sections 5, 6.1.2 and 6.1.3. These will address the use and storage of portable equipment including routes for transportation from the storage locations to deployment areas. In addition, procedures will be established for system operations when normal and backup power is available, and during ELAP conditions. The OIP also states that provisions will be established for out-of-service requirements of the HCVS and the compensatory measures. The OIP provided specific time frames for out-of-service requirements for the HCVS/SAWA functionality.

In its OIP, the licensee provides an overview of how programmatic controls and procedures will be developed for implementation of SAWA and SAWM strategy. The OIP also provides a list of key areas where either new procedures will be developed or existing procedures will be revised. The NRC staff reviewed the overall procedures and programs development process including the list of key components to be included and noted that, they appear to be consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. The NRC staff determined that procedure development appears to be in accordance with existing industry protocols. The provisions for out-of-service requirements appear to reflect consideration of the probability of an ELAP requiring severe accident venting and the consequences of a failure to vent under such conditions.

3.4.2 Training Order EA-13-109, Section 3.2 states that:

3.2 The licensee shall train appropriate personnel in the use of the HCVS. The training curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power.

In Part 4 of its OIP, the licensee stated that all personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receive necessary training. The training plan will be developed per the guidance provided in NEI 13-02, Section 6.1.3 and will be refreshed on a periodic basis as changes occur to the HCVS/SAWA/SAWM actions, systems, or strategies. In addition, training content and frequency will follow the systems approach to training process.

The BSEP OIP describes HCVS training requirements, which the NRC staff reviewed and confirmed are consistent with the guidance found in Section 6.1.3 of NEI 13-02, Revision 1 [Reference 16]. The systematic approach to the training process has been accepted by the NRC as appropriate for developing training for nuclear plant personnel.

The training plan appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.4.3 Drills Order EA-13-109, Section 3.1, states that:

3.1 The licensee shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power.

In Part 4 of its OIP, the licensee states that drills and exercise parameters will be developed and aligned with the guidance provided in NEI 13-06, "Enhancements to Emergency to Response Capabilities for Beyond Design Basis Accidents and Events" [Reference 24] and NEI 14-01, "Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents"

[Reference 25]. In addition, drills, tabletops, or exercises will be developed to use of HCVS/SAWA/SAWM system.

The BSEP OIP describes an approach to drills, which the NRC staff reviewed and confirmed is consistent with the guidance found in Section 6.1.3 of NEI 13-02, Revision 1 [Reference 16].

This approach appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

3.4.4 Maintenance Order EA-13-109, Section 1.2.13 states that:

1.2.13 The HCVS shall include features and provisions for the operation, testing, inspection and maintenance adequate to ensure that reliable function and capability are maintained.

For Phase 2 compliance requirements, Table 4-1 was revised to include testing and inspection requirements for SAWA components. The NRC staff reviewed Table 4-1 and found that it is consistent with Section 6.2.4 of NEI 13-02, Revision 1. Implementation of these testing and inspection requirements for HCVS and SAWA will ensure reliable operation of the systems.

In Part 4 of its OIP, the licensee states that the maintenance program will be developed following the guidance provided in NEI 13-02, Sections 5.4, and 6.2 and will utilize the standard Electric Power Research Institute industry preventive maintenance process for the maintenance calibration and testing for the HCVS/SAWA/SAWM components.

The BSEP OIP describes an approach to maintenance, which the NRC staff reviewed and confirmed is consistent with the guidance found in Sections 5.4 and 6.2 of NEI 13-02, Revision 1 [Reference 16]. The maintenance plan as described appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109.

4.0 OPEN ITEMS This section contains a summary of the open items identified to date as part of the staff's evaluation. Open items, whether NRC or licensee identified, are topics for which there is insufficient information to fully resolve the issue, for which the NRC staff requires clarification to ensure the issue is on a path to resolution, or for which the actions to resolve the issue are not yet complete. The intent behind designating an issue as an open item is to highlight items that the staff intends to review further. The NRC staff has reviewed the licensee's OIP for consistency with NRC policy and technical accuracy. The NRC and licensee identified open items have been identified in Section 3.0 and are listed in the table below. Furthermore, these open items have been communicated to the licensee during the May 3, 2016, teleconference between NRC staff and the licensee.

L.IS t 0 f 0 pen 1"tems Open Item Action ISE Section

1. Licensee to confirm through analysis, the temperature and Section 3.3.2.1 radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

2. Licensee to provide the site-specific MAAP evaluation that Section 3.3.2.2 establishes the initial SAWA flow rate.

3. Licensee to demonstrate how instrumentation and equipment Section 3.3.2.3 being used for SAWA and supporting equipment is capable to perform for the sustained operating period under the expected temperature and radioloqical conditions.

4. Licensee to demonstrate that containment failure as a result of Section 3.3.3 overpressure can be prevented without a drywell vent during severe accident conditions.

5. Licensee to demonstrate that there is adequate Section 3.3.3.4 communication between the MCR and the operator at the FLEX pump durinQ severe accident conditions.

6. Licensee to demonstrate the SAWM flow instrumentation Section 3.3.3.4 qualification for the expected environmental conditions.

5.0

SUMMARY

As required by Order EA-13-109, the licensee has provided an 01 P for implementation of Phase 2 requirements of the order. The OIP describes how containment venting strategies will be developed and used to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits during a severe accident and loss of active heat removal capability. These strategies include use of SAWA equipment to inject water into the RPV and use of a SAWM strategy to control water injection and suppression pool level to ensure the HCVS wetwell vent will remain functional for removal of decay heat from containment during the prescribed period of sustained operation.

The NRC staff finds that the licensee's OIP for Phase 2 of Order EA-13-109 describes: plan elements and assumptions; boundary conditions; provisions for programmatic controls, training, drills and maintenance; and an implementation schedule that, subject to acceptable closure of the above open items, appear consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing Phase 2 requirements of Order EA-13-109.

6.0 REFERENCES

1. Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," June 6, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13143A321).

2. Letter from Duke Energy to NRC, "Brunswick Steam Electric Plant, Units 1 & 2 - Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 (Order EA-13-109)," dated June 26, 2014 (ADAMS Accession No. ML14191A687).

3. Letter from NRC to Duke Energy, "Brunswick Steam Electric Plant Units 1 and 2 -

Interim Staff Evaluation Related to Overall Integrated Plan in Response to Phase 1 of order EA-13-109 (Severe Accident Capable Hardened Vents)," dated March 10, 2015 (ADAMS Accession No. ML15049A266).

4. Letter from Duke Energy to NRC, "Brunswick Steam Electric Plant Units 1 and 2 -

Phase 1 and Phase 2 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order EA-13-109)," dated December 11, 2015 (ADAMS Accession No. ML16020A064).

5. SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan", (ADAMS Accession No. ML111861807).

6. SRM-SECY-11-0124, "Recommended Actions to be taken Without Delay from the Near-Term Task Force Report", (ADAMS Accession No. ML112911571 ).

7. SRM-SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned" (ADAMS Accession No. ML113490055).

8. SRM-SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions following the Events in Japan," August 19, 2011 (ADAMS Accession No. ML112310021 ).

9. SECY-12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," February 17, 2012 (ADAMS Accession No. ML12039A103).

10. SRM-SECY-12-0025," Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," March 9, 2012 (ADAMS Accession No. ML120690347).

11. Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 9, 2012 (ADAMS Accession No. ML12054A694).

12. SECY-12-0157, "Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments", November 26, 2012 (ADAMS Accession No. ML12325A704).

13. SRM-SECY-12-0157, "Consideration Of Additional Requirements For Containment Venting Systems For Boiling Water Reactors With Mark I And Mark II Containments",

March 19, 2013 (ADAMS Accession No. ML13078A017).

14. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109 (NEI 13-02 Rev.

0), BWR Mark I and II, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions." November 12, 2013 (ADAMS Accession No. ML13316A853).

15. Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard toReliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Rev. 0, November 14, 2013 (ADAMS Accession No. ML13304B836).

16. NEI 13-02, Rev. 1, "Industry Guidance for Compliance with Order EA-13-109," Revision 1, April 23, 2015 (ADAMS Accession No. ML15113B318).

17. Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condition," April 29, 2015 (ADAMS Accession No. ML15104A118).

18. Nuclear Regulatory Commission Audits Of Licensee Responses To Phase 1 of the Order [EA-13-109] to Modify Licenses With Regard To Reliable Hardened Containment Vents Capable Of Operation Under Severe Accident Conditions (ADAMS Accession No. ML14126A545).

19. Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", March 12, 2012 (ADAMS Accession No. ML12054A735).

20. Brunswick Steam Electric Plant, Units 1 and 2 - Interim Staff Evaluation Regarding Overall Integrated Plan in Response to Order EA-12-049 - Mitigation Strategies (TAC NOS. MF0975 AND MF0976) November 22, 2013 (ADAMS Accession No. ML13220A090).

21. Letter from Duke Energy to NRC, Brunswick,t Units 1 and 2, - 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 EA-12-049), dated February 28, 2013 (ADAMS Accession No. ML13071A559).

22. NUREG-1935, "State-of-the-Art Reactor Consequence Analyses (SOARCA)." Final Report (ADAMS Accession No. ML12332A058).

23. Letter from NRC to NEI, "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision 1, dated September 22, 2015, and FAQs 10, 11, 12, and 13 (ADAMS Accession No. ML15273A141 ).

24. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014.

25. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014.

26. Letter from NRC to NEI endorsing, "Hardened Containment Venting System (HCVS)

Phase 1 and 2 Overall Integrated Plan Template, Revision 1, dated October 8, 2015, and FAQs 10, 11, 12, 13 (ADAMS Accession No. ML15271A148).

27. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012.

28. Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events," dated August 29, 2012.

Principal Contributors: Bruce Heida Brian Lee Brett Titus Rajender Auluck Date: August 17, 2016

..* ML16223A725 *via email OFFICE NRR/JlD/JCBB/PM NRR/JlD/lA NRR/JlD/JOMB/PM NRR/JlD/JCBB/C NAME Blee Slent PBamford JQuichocho DATE 08/05/2016 08/16/2016 08/11/2016 08/17/2016