BSEP 17-0110, Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

ML17354A248
Person / Time
Site:	Brunswick
Issue date:	12/20/2017
From:	William Gideon Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 17-0110, EA-13-109
Download: ML17354A248 (16)

Text

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 December 20, 2017 Serial: BSEP 17-0110 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 NRC Docket Nos. 50-325 and 50-324 Seventh Six-Month Status Report 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 Number EA-13-109)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13143A321.

2. NRC Interim Staff Guidance JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated November 14, 2013, ADAMS Accession Number ML133048836.

3. NRC Interim Staff Guidance 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 Operation under Severe Accident Conditions, Revision 0, dated April 30, 2015, ADAMS Accession Number ML15104A118.

4. NEI 13-02, Industry Guidance for Compliance With Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation -Under Severe Accident Conditions, Revision 1, dated April 2015, ADAMS Accession Number ML151138318.

5. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Duke Energy's Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109),

dated June 17, 2013, ADAMS Accession Number ML13191A567.

6. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Phase 1 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 Number EA-13-109), dated June 26, 2014, ADAMS Accession Number ML14191A687.

7. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, First Six-Month Status Report 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 Number EA-13-109), dated December 17, 2014, ADAMS Accession Number ML14364A029.

U.S. Nuclear Regulatory Commission Page 2 of 4

8. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Second Six-Month Status Report 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 Number EA-13-109), dated June 25, 2015, ADAMS Accession Number ML15196A035.

9. Duke Energy Letter, BSEP, Unit Nos. 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 Number EA-13-109), dated December 11, 2015, ADAMS Accession Number ML16020A064.

1O. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Fourth Six-Month Status Report 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 Number EA-13-109), dated June 28, 2016, ADAMS Accession Number ML16190A111.

11. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Fifth Six-Month Status Report 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 Number EA-13-109), dated December 15, 2016, ADAMS Accession Number ML16365A007.

12. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Sixth Six-Month Status Report 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 Number EA-13-109}, dated June 19, 2017, ADAMS Accession Number ML17171A383.

13. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4467 and MF4468}, dated March 10, 2015, ADAMS Accession Number ML15049A266.

14. NRC Letter, 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) (GAG Nos. MF4467 and MF4468}, dated August 17, 2016, ADAMS Accession Number ML16223A725.

Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (i.e., Reference 1) to Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. Reference 1 was immediately effective and directs all boiling water reactors (BWRs) with Mark I and Mark II containments to take certain actions to ensure that these facilities have a hardened containment venting system (HCVS) to support strategies for controlling containment pressure and preventing core damage following an event that causes a loss of heat removal systems, such as an Extended Loss of AC Power (ELAP),

while ensuring the venting functions are also available during severe accident (SA) conditions.

BSEP, Unit Nos. 1 and 2, have Mark I containments. Specific requirements are outlined in of Reference 1.

U.S. Nuclear Regulatory Commission Page 3 of 4 Reference 1 required submission of an Overall Integrated Plan (OIP) by June 30, 2014, for Phase 1 of the Order, and an 01 P by December 31, 2015, for Phase 2 of the Order. The interim staff guidance (i.e., References 2 and 3) provides direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 (i.e., Reference 4), with clarifications and exceptions identified in Reference 3.

Reference 5 provided the Duke Energy initial status report regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 provided the BSEP, Units 1 and 2, Phase 1 OIP. References 7 and 8 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for BSEP, Units 1 and 2, respectively.

Reference 9 provided both the third six-month status report for Phase 1 of the Order pursuant to Section IV, Condition D.3, of Reference 1, and the OIP for Phase 2 of the Order pursuant to Section IV, Condition D.2 of Reference 1, for BSEP, Units 1 and 2, in a combined Phase 1 and Phase 2 OIP. Reference 1O provided the fourth six-month status report, Reference 11 provided the fifth six-month status report, and Reference 12 provided the sixth six-month status report pursuant to Section IV, Condition D.3 of Reference 1 for BSEP, Units 1 and 2.

The purpose of this letter is to provide the seventh six-month status report pursuant to Section IV, Condition D.3 of Reference 1 for BSEP, Units 1 and 2. This six-month status report provides the updates for both Phase 1 and Phase 2 OIP implementation including Phase 1 OIP open items, Phase 1 Interim Staff Evaluation (ISE) open items contained in Reference 13, and Phase 2 NRG ISE open items contained in Reference 14.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

I declare under penalty of perjury that the foregoing is true and correct. Executed on Siz:jj December 20, 2017.

William R. Gideon

Enclosure:

Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

U.S. Nuclear Regulatory Commission Page 4 of 4 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWFN 883) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRG Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only)

P.O. Box 29510 Raleigh, NC 27626-0510

Enclosure Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Seventh Six-Month Status Report 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 Number EA-13-109)

Enclosure BSEP 17-0110 Page 1 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109) 1 Introduction Note: References are provided in Section 10 of this enclosure.

I IBrunswick Steam Electric Plant (BSEP) developed an G>verall lntegrated Plan (OIP) (i.e.,

Reference 1) documenting the installation of a Hardened Containment Vent System (HCVS) in response to NRC Order EA-13-109 (i.e., Reference 2). The OIP was submitted to the NRC on June 6, 2014. The first six-month update was submitted to the NRC on December 17, 2014 (i.e., Reference 4). The second six-month update was submitted to the NRC on June 25, 2015 (i.e., Reference 5). Reference 6 provided both the third six-month update for Phase 1 of the Order and the OIP for Phase 2 of the Order, for BSEP, Units 1 and 2, on December 11, 2015.

The fourth six-month update was submitted to the NRC on June 28, 2016 (i.e., Reference 7).

The fifth six-month update was submitted to the NRC on December 15, 2016 (i.e., Reference 8).

The sixth six-month update was submitted to the NRC on June 19, 2017 (i.e., Reference 9).

This enclosure provides an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, for both Phase 1 and Phase 2 OIP implementation that occurred during the period between June 20, 2017, and December 14, 2017, hereafter referred to as the update period.

2 Milestone Accomplishments The following Phase 1 milestones were completed during the update period:

- (Phase 1 and 2 combined update) Submit 6-Month Status Report The following Phase 2 milestones were completed during the update period:

- (Phase 1 and 2 combined update) Submit 6-Month Status Report

Enclosure BSEP 17-0110 Page 2 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109) 3 Milestone Schedule Status The following provides an update to the Milestone Schedule of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are dev~loped. I The revised milestone target completion dates do not impact the order implementation date.

Target Completion Comments and Phase 1 Milestone Schedule Date Activity Status Date Changes

• Indicates a change since last 6-month update Hold preliminary/conceptual design Jun.2014 Complete Date not revised.

meeting.

Submit Overall Integrated Plan. Jun.2014 Complete Date not revised.

Submit 6 Month Status Report. Dec.2014 Complete Date not revised.

Submit 6 Month Status Report. Jun.2015 Complete Date not revised.

Submit 6-Month Status Report. Dec.2015 Complete Simultaneous with Phase 2 OIP.

U2 Design Engineering On- Jun.2016 Complete Date not revised.

site/Complete.

Storage Plan. Dec. 2016 Complete Date not revised.

Staffing analysis completion. Dec.2016 Complete Date not revised Long term use equipment Dec.2016 Complete Date not revised.

acquisition timeline.

Submit 6-Month Status Report. June 2016 Complete Date not revised.

Operations Procedure Changes Dec.2016 Complete Date not revised.

Developed.

Site Specific Maintenance Dec.2016 Complete Date not revised.

Procedure Developed.

Submit 6-Month Status Report. Dec. 2016 Complete Date not revised.

Training Complete. Feb.2017 Complete Date not revised.

U2 Implementation Outage. Mar. 2017 Complete Date not revised.

Procedure Changes Active. Mar. 2017 Complete Date not revised.

Enclosure BSEP 17-0110 Page 3 of 11

. Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Target Completion Comments and Phase 1 Milestone Schedule Date Activity Status Date Changes

• Indicates a change since last 6-month update U2 Walk Through Mar. 2017 Complete I Date not revised.

1 Demonstration/Functional Test.

U1 Design Engineering Mar. 2017 Complete Date not revised.

On-site/Complete.

Submit 6-Month Status Report. Jun.2017 Complete Date not revised.

Submit 6-Month Status Report. Dec. 2017 *Complete Date not revised.

U1 Implementation Outage. Feb. 2018 *Started Date not revised.

U1 Walk Through Mar. 2018 Not Started Date not revised.

Demonstration/Functional Test.

Submit Completion Report. May 2018 Not Started Date not revised.

Target Completion Comments and Phase 2 Milestone Schedule Date Activity Status Date Changes

• Indicates a change since last 6-month update Hold preliminary/conceptual Oct. 2015 Complete Date not revised.

design meeting.

Submit Overall Integrated Dec. 2015 Complete Third 6-month Implementation Plan. update included Phase 2 OIP (i.e.,

Reference 6).

Submit 6-Month Status Report. Jun.2016 Complete Date not revised.

Submit 6-Month Status Report. Dec. 2016 Complete Date not revised .

Submit 6-Month Status Report. Jun.2017 Complete Date not revised .

U1 Design Engineering On- Mar. 2017 Complete Date not revised.

site/Complete.

Submit 6-Month Status Report. Dec.2017 *Complete Date not revised.

Operations Procedure Changes Mar. 2018 Started Date not revised.

Developed.

Enclosure BSEP 17-011 O Page 4 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Target Completion Comments and Phase 2 Milestone Schedule Date Activity Status Date Changes

• Indicates a change since last 6-month update Site Specific Maintenance! Mar. 2018 Started Datb not revised.

Procedure Developed.

Training Complete. Feb.2018 Started Date not revised.

U1 Implementation Outage. Mar. 2018 *Started Date not revised.

Procedure Changes Active. Mar. 2018 Not Started Date not revised.

U1 Walk Through Mar. 2018 Not Started Date not revised.

Demonstration/Functional Test.

U2 Design Engineering On- Mar. 2018 Started Date not revised.

site/Complete.

Submit 6-Month Status Report. Jun.2018 Not Started Date not revised.

Submit 6- Month Status Report. Dec. 2018 Not Started Date not revised.

U2 Implementation Outage. Mar. 2019 Not Started Date not revised.

U2 Walk Through Mar. 2019 Not Started Date not revised .

Demonstration/Functional Test.

Submit Completion Report. Jul. 2019 Not Started Date not revised.

4 Changes to Compliance Method No changes to the Phase 1 or Phase 2 Overall Integrated Plan (i.e., Reference 6) have been made during this 6-month update period.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There are no changes to the need for relief/relaxation during this seventh update period. BSEP expects to comply with the order implementation date.

6 Open Items from Phase 1 Overall Integrated Plan and Phase 1 Interim Staff Evaluation Tables 6a and 6b provide a summary status of Open Items. Table 6a provides the open items that were previously identified in the original OIP (i.e., Reference 1) submitted on

Enclosure BSEP 17-0110 Page 5 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

June 26, 2014. Table 6b provides the open items that were previously identified in the Phase 1 Interim Staff Evaluation (ISE) (i.e., Reference 3). No new open items are identified or added during this update period.

Table 6a. Phase 1 Overall Integrated Plan Open Items I

Table 6a - Overall Integrated Plan Open Items

1. Open Item Status

• Indicates a change since last 6-month update 1 Evaluate, design, and implement missile protection as required for the Complete HCVS piping external to the reactor building.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

2 Finalize location of the Remote OperatinQ Station (ROS). Complete The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

3 Finalize and desiQn means to address flammable gases in the HCVS. Complete The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

4 Evaluate location of FLEX DG for accessibility under Severe Accident Complete conditions.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

5 Develop procedures for BDBEE and severe accident vent operation Complete (i.e., load shedding, power supply transfer, and vent valve operation from the Main Control Room and ROS), vent support functions for sustained operation and portable equipment deployment (FLEX DG supply to the 24/48 VDC battery system, and makeup to the nitrogen backup system).

The procedure chanQes are complete and issued.

6 Confirm suppression pool heat capacity. Initial results from GE report Complete 0000-0165-0656-RO for BSEP indicate the suppression pool reaches the heat capacity temperature limit (HCTL) in 2.11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

7 Finalize location of supplemental N2 bottle connection. Deleted The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

8 Establish programs and processes for control of HCVS equipment Complete functionality, out-of-service time, and testing.

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

9 Confirm Wetwell vent capacity is sufficient at the containment desiQn Complete

Enclosure BSEP 17-0110 Page 6 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Table 6a - Overall Integrated Plan Open Items

1. Open Item Status

• Indicates a change since last 6-month update pressure (62 psig). Existing calculation 0D12-0009 calculates a wetwell vent capacity at the primary containment pressure limit (PCPL, 70 psiQ). I The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

Table 6b. Interim Staff Evaluation Open Items (Phase 1)

Table 6b - Interim Staff Evaluation Open Items (Phase 1)

1. Open Item Status

• Indicates a change since last 6-month update 1 Make available for NRC staff audit the site-specific controlling document for Complete HCVS out of service and compensatory measures.

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

2 Make available for NRC staff audit analyses demonstrating that HCVS has Complete the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (i.e., unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

3 Make available for NRC staff audit confirmation of the time it takes the Complete suppression pool to reach the heat capacity temperature limit during ELAP with RCIC in operation.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

4 Make available for NRC staff audit a description of the final ROS location. Complete The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

5 Make available for NRC staff audit documentation that demonstrates Complete adequate communication between the remote HCVS operation locations and the HCVS decision makers during ELAP and severe accident conditions.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

Enclosure BSEP 17-011 O Page 7 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Table Sb- Interim Staff Evaluation Open Items (Phase 1)

1. Open Item Status

• Indicates a change since last 6-month update 6 Provide a description of the final design of the HCVS to address hydrogen Complete detonation and deflaoration. I The information was provided in the December 2016 Six-Month Status Report by letter

• dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

7 Make available for NRC staff audit seismic and tornado missile final design Complete criteria for the HCVS stack.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007) ..

8 Make available for NRC staff audit documentation of the HCVS nitrogen Complete pneumatic system desh:::in includino sizing and location.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

9 Make available for NRC staff audit documentation of HCVS incorporation Complete into the FLEX diesel generator loading calculation.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

10 Make available for NRC staff audit an evaluation of temperature and Complete radiological conditions to ensure that operating personnel can safely access and operate control and support equipment.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

11 Make available for NRC staff audit descriptions of all instrumentation and Complete controls (i.e., existing and planned) necessary to implement this order includino qualification methods.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

12 Clarify whether the seismic reliability demonstration of instruments, Complete including valve position indication, vent pipe temperature instrumentation, radiation monitoring, and support system monitoring will (be) via methods that predict performance described in IEEE-344-2004 or provide justification for using a different revision of the standard.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

13 Make available for NRC staff audit a justification for not monitoring HCVS Complete svstem pressure as described in NEI 13-02.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

Enclosure BSEP 17-0110 Page 8 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Table 6b - Interim Staff Evaluation Open Items (Phase 1)

1. Open Item Status

• Indicates a change since last 6-month uodate 14 Make available for NRC staff audit the descriptions of local conditions (i.e., Complete temperature, radiation and humidity) anticipated during ELAP and severe abcident for the components (e.g., valves, instrumentatioh, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of oerformina their functions durina ELAP and severe accident conditions.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

15 Make available for NRC staff audit documentation of an evaluation verifying Complete the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

16 Provide a description of the strategies for hydrogen control that minimizes Complete the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

The information was provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e., ADAMS Accession No. ML16365A007).

7 Interim Staff Evaluation (ISE) Impacts (Phase 1 only)

There are no new Phase 1 ISE impacts.

8 Open Items from Phase 2 Overall Integrated Plan and Phase 2 Interim Staff Evaluation There were no open items reported in the Phase 2 OIP submitted on December 11, 2015 (i.e.,

Reference 6). Table 8 provides the open items that were identified in the Phase 2 Interim Staff Evaluation (i.e., Reference 10).

Table 8 - Interim Staff Evaluation Phase 2 Open Items

1. Open Item Status

• Indicates a change since last 6-month uodate 1 Licensee to confirm through analysis, the temperature and Complete radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383J.

Enclosure BSEP 17-0110 Page 9 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containl'!lent Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109}

Table 8 - Interim Staff Evaluation Phase 2 Ooen Items

1. Open Item Status

• Indicates a change since last 6-month update 2 Licensee to provide the site-specific MAAP evaluation that establishes Complete the initial SAWA flow rate. I

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

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

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

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

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

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

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

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

• The information was provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383).

9 Interim Staff Evaluation (ISE) Impacts (Phase 2 only)

• Although not a change to the Phase 2 compliance method, the existing secondary containment isolation valve 2-FLEX-V5003 will serve a dual-purpose as the secondary containment isolation valve and take over flow control duties from valve 2-G31-V5013 during FLEX implementation. Valve 2-G31-V5013 is no longer required and will be removed from service.

The SAWA flow path description is changed as follows:

Page 8, Section 3.3.2. 1, Second Paragraph - 6th bullet states: "Through a pipe, two manual valves and a check valve to the reactor water cleanup (RWCU) return line" This changes to: "Through a pipe, one manual valve and a check valve to the reactor water cleanup (RWCU) return line"

Enclosure BSEP 17-0110 Page 10 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109) 1O References The following references support updates to the Phase 1 and Phase 2 Overall Integrated Plan described in this enclosure.

1. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Phase 1 Overalf 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 Number EA-13-109), dated June 26, 2014, ADAMS Accession Number ML14191A687.

2. Nuclear Regulatory Commission (NRC) Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013, Agencywide Documents Access and Management System (ADAMS) Accession Number ML13143A321.

3. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4467 and MF4468}, dated March 1o, 2015, ADAMS Accession Number ML15049A266.

4. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, First Six Month Status Report 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 Number EA-13-109), dated December 17, 2014, ADAMS Accession Number ML14364A029.

5. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Second Six Month Status Report 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 Number EA-13-109), dated June 25, 2015, ADAMS Accession Number ML15196A035.

6. Duke Energy Letter, BSEP, Unit Nos. 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 Number EA-13-109), dated December 11, 2015, ADAMS Accession Number ML16020A064.

7. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Fourth Six-Month Status Report 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 Number EA-13-109), dated June 28, 2016, ADAMS Accession Number ML 16190A11.

8. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Fifth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened

Enclosure BSEP 17-0110 Page 11 of 11 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Seventh Six-Month Status Report 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 Number EA-13-109)

Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 15, 2016, ADAMS Accession Number ML16365A007.

9. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Sixth Six-Month Status Report 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 Number EA-13-109), dated June 19, 2017, ADAMS Accession Number ML17171A383.

10. NRC Letter, 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) (GAG Nos. MF4467 and MF4468), dated August 17, 2016, ADAMS Accession Number ML16223A725.