RA-18-0258, (Bsep), Unit Nos. 1 and 2 - Ninth 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...

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(Bsep), Unit Nos. 1 and 2 - Ninth 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...
ML18354A907
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 12/19/2018
From: William Gideon
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RA-18-0258
Download: ML18354A907 (17)
v • d • e


Text

(_~ DUKE William R. Gideon Vice President ENERGY Bmnswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 December 19, 2018 Serial: RA-18-0258 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 No. 50-325 and 50-324 Ninth 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.
10. 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. Duke Energy Letter, 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), dated December 20, 2017, ADAMS Accession Number ML17354A248.
14. 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.
15. NRG 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.
16. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRG Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (GAG Nos. MF4467 and MF4468; EPID L-2014-JLD-0041), dated March 22, 2018, ADAMS Accession Number ML18068A627.
17. Duke Energy Letter, Brunswick Steam Electric Plant, Unit 1, Completion of Required Action for NRG Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated May 29, 2018, ADAMS Accession Number ML18149A523.

U.S. Nuclear Regulatory Commission Page 3 of 4

18. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Eighth 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 26, 2018, ADAMS Accession Number ML18177A458.

Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRG) 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 directed 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.

Reference 1 required submission of an Overall Integrated Plan (OIP) by June 30, 2014, for Phase 1 of the Order, and by December 31, 2015, for Phase 2 of the Order. The interim staff guidance (i.e., References 2 and 3) provided direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 4 endorsed industry guidance document NEI 13-02, Revision 1 with clarifications and exceptions identified in Reference 3. Reference 5 provided the Duke Energy initial status report. Reference 6 provided the BSEP, Units 1 and 2, Phase 1 OIP.

References 7, 8, 9, 10, 11, 12, 13, and 18 provided the first, second, third, fourth, fifth, sixth, seventh, and eighth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for BSEP, Units 1 and 2, respectively. Reference 9 and the six-month status reports thereafter, included both the six-month status report for Phase 1 of the Order pursuant to Section IV, Condition D.3, of Reference 1, and 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.

References 14 and 15 provide the NRG Interim Staff Evaluations relating to the Phase 1 OIP and Phase 2 OIP, respectively. Reference 16 provides the NRG Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRG Order EA-13-109.

Reference 17 provided the notification required by Item IV.D.4 of Order EA-13-109 that full compliance (i.e., Phase 1 and Phase 2) with the requirements described in Attachment 2 of the Order has been achieved for BSEP, Unit No. 1.

The purpose of this letter is to provide the ninth six-month status report pursuant to Section IV, Condition D.3 of Reference 1. 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 14, and Phase 2 NRG ISE open items contained in Reference 15, and Audit open item responses contained in Reference 16.

U.S. Nuclear Regulatory Commission Page 4 of 4 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 December 19, 2018.

  • Sincerely,
t;/,R. ~/p,e~_,J William R. Gideon

Enclosure:

Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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) 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. Dennis Galvin (Mail Stop OWFN 8B1A) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWFN 12D20) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC 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 RA-18-0258 Page 1 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 1O of this enclosure.

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 directed 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.

Reference 1 required submission of an Overall Integrated Plan (OIP) by June 30, 2014, for Phase 1 of the Order, and by December 31, 2015, for Phase 2 of the Order. The interim staff guidance (i.e., References 2 and 3) provided direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 4 endorsed industry guidance document NEI 13-02, Revision 1 with clarifications and exceptions identified in Reference 3. Reference 5 provided the Duke Energy initial status report. Reference 6 provided the BSEP, Units 1 and 2, Phase 1 01 P.

Reference 9 provided the BSEP, Units 1 and 2, Phase 2 OIP.

References 7, 8, 9, 10, 11, 12, 13, and 18 provided the first, second, third, fourth, fifth, sixth, seventh, and eighth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for BSEP, Units 1 and 2, respectively. Reference 9 and the six-month status reports thereafter, included the six-month status report for Phase 1 of the Order pursuant to Section IV, Condition D.3, of Reference 1, and 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.

References 14 and 1.5 provided the NRC Interim Staff Evaluation relating to the OIP in response to Phase 1, and Phase 2, respectively. Reference 16 provided the NRC Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRC Order EA-13-109.

Reference 17 provided the notification required by Item IV.D.4 of Order EA-13-109 that full compliance (i.e., Phase 1 and Phase 2) with the requirements described in Attachment 2 of the Order has been achieved for BSEP, Unit No. 1.

This enclosure provides the ninth six-month status report pursuant to Section IV, Condition D.3 of Reference 1. 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 14, and Phase 2 NRC ISE open items contained in Reference 15, and Audit open items responses contained in Reference 16.

Enclosure RA-18-0258 Page 2 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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)

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 30, 2018, and December 31, 2018, 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 RA-18-0258 Page 3 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 developed.

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

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

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

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

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

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

U2 Desion EnoineerinQ On-site/Complete. Jun.2016 Complete Date not revised.

Storage Plan. Dec.2016 Complete Date not revised.

Staffing analysis completion. Dec.2016 Complete Date not revised.

Long term use equipment acquisition timeline. Dec.2016 Complete Date not revised.

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

Operations Procedure Changes Developed. Dec.2016 Complete Date not revised.

Site Specific Maintenance Procedure Developed. Dec. 2016 Complete Date not revised.

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

TraininQ 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.

U2 Walk Through Demonstration/Functional Test. Mar. 2017 Complete Date not revised.

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

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

Submit (seventh) 6-Month Status Report. Dec.2017 Complete Date not revised.

U1 Implementation Outaoe. Feb.2018 Complete Date not revised.

U1 Walk Through Demonstration/Functional Test. Mar. 2018 Complete Date not revised.

Submit Completion Report. May 2018 Complete Date not revised.

(Unit 1)

Enclosure RA-18-0258 Page 4 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 Activity Comments and Phase 2 Milestone Schedule Completion Date Status Date Changes

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

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

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

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

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

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

Submit (seventh) 6-Month Status Report. Dec. 2017 Complete Date not revised.

Operations Procedure Changes Developed. Mar. 2018 Complete Date not revised.

Site Specific Maintenance Procedure Developed. Mar. 2018 Complete Date not revised.

Training Complete. Feb.2018 Complete Date not revised.

U1 Implementation Outage. Mar. 2018 Complete Date not revised.

Procedure Changes Active. Mar. 2018 Complete Date not revised.

U1 Walk Through Demonstration/Functional Test. Mar. 2018 Complete Date not revised.

U2 Design Engineering On-site/Complete. Mar. 2018 Complete Date not revised.

Submit (eighth) 6-Month Status Report. Jun.2018 Complete Date not revised.

Submit (ninth) 6- Month Status Report. Dec. 2018 *Complete Date not revised.

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

U2 Walk Through Demonstration/Functional Test. Mar. 2019 Not Started Date not revised.

Submit Completion Report. (Unit 2) 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 9) 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 update period. BSEP expects to comply with the order implementation date.

Enclosure RA-18-0258 Page 5 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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)

6. Open Items from Phase 1 Overall Integrated Plan and Phase 1 Interim Staff Evaluation Phase 1 Open Items were identified in the Phase 1 OIP (i.e., Reference 6) and in the NRC Phase 1 Interim Staff Evaluation (ISE) (i.e., Reference 14). The following tables (Table 6a provides the Phase 1 OIP Open Items, and Table 6b provides the Phase 1 ISE Open Items) provide completion references and a summary of the closure action for Open Items not previously completed. No new open items are identified or added during this update period.

Table 6a

  • Overall Integrated Plan Open Items (Phase 1)
  1. Open Item Status
  • Indicates a change since last 6-month update 1 Evaluate, design, and implement missile protection as required for the HCVS piping Complete external to the reactor building.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

2 Finalize location of the Remote Operatino Station (ROS). Complete Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

3 Finalize and design means to address flammable oases in the HCVS. Complete Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

4 Evaluate location of FLEX DG for accessibility under Severe Accident conditions. Complete Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11).

5 Develop procedures for BDBEE and severe accident vent operation (i.e., load shedding, Complete 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 nitrooen backup system).

Information provided in the December 2017 Six-Month Status Report by letter dated December 20, 2017 (i.e.,

ADAMS Accession No. ML17354A248) (i.e., Reference 11).

6 Confirm suppression pool heat capacity. Initial results from GE report 0000-0165-0656-R0 Complete 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 />.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

7 Finalize location of supplemental N2 bottle connection. Deleted Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

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

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS

Enclosure RA-18-0258 Page 6 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 (Phase 1)

  1. Open Item Status
  • Indicates a change since last 6-month update Accession No. ML17171A383)(i.e., Reference 12).

9 Confirm Wetwell vent capacity is sufficient at the containment design pressure (62 psig). Complete Existing calculation 0D12-0009 calculates a wetwell vent capacity at the primary containment pressure limit (PCPL, 70 psiQ).

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 HCVS out of Complete service and compensatory measures.

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Closed per NRG Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 2 Make available for NRG staff audit analyses demonstrating that HCVS has the capacity to Complete 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.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 3 Make available for NRG staff audit confirmation of the time it takes the suppression pool to Complete reach the heat capacity temperature limit during ELAP with RCIC in operation.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRG Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 4 Make available for NRC staff audit a description of the final ROS location. Complete Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS

Enclosure RA-18-0258 Page 7 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 update Accession No. ML18068A627) (i.e., Reference 16) 5 Make available for NRC staff audit documentation that demonstrates adequate Complete communication between the remote HCVS operation locations and the HCVS decision makers during ELAP and severe accident conditions.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 6 Provide a description of the final design of the HCVS to address hydrogen detonation and Complete deflagration.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 7 Make available for NRC staff audit seismic and tornado missile final design criteria for the Complete HCVS stack.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 8 Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system Complete design including sizing and location.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 9 Make available for NRC staff audit documentation of HCVS incorporation into the FLEX Complete diesel generator loading calculation.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 10 Make available for NRC staff audit an evaluation of temperature and radiological Complete conditions to ensure that operating personnel can safely access and operate control and

Enclosure RA-18-0258 Page 8 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 update support equipment.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Open per NRG Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

BSEP performed a radiation dose calculation EC 412141 11 lntegrated Dose Calculation for Hardened Vent Remote Operating Station (ROS) - Fukushima11 which shows the integrated radiation dose due to HCVS operation will not inhibit operator actions needed to initiate and operate the HCVS during an ELAP with severe accident conditions. The integrated dose calculation is provided on the eportal for NRG review.

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

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRG Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 12 Clarify whether the seismic reliability demonstration of instruments, including valve position Complete 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.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 13 Make available for NRG staff audit a justification for not monitoring HCVS system pressure Complete as described in NEI 13-02.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

Enclosure RA-18-0258 Page 9 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 update 14 Make available for NRC staff audit the descriptions of local conditions (i.e., temperature, Complete (FIP) radiation and humidity) anticipated during ELAP and severe accident for the components (e.g., valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Pending per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

The NRC staff reviewed the table provided on the eportal. The staff anticipates a similar table in the Final Integrated Plan (FIP) (i.e., on the docket) to close the item. The FIP will be provided with the Unit 2 Closeout (i.e., both Units closeout) submittal after completion of Unit 2 Phase 2 HCVS in March 2019.

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

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 16 Provide a description of the strategies for hydrogen control that minimizes the potential for Complete hydrogen gas migration and ingress into the reactor building or other buildings.

Information provided in the December 2016 Six-Month Status Report by letter dated December 15, 2016 (i.e.,

ADAMS Accession No. ML16365A007) (i.e., Reference 11 ).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

Enclosure RA-18-0258 Page 10 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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)

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 (i.e., Reference 9). The Phase 2 NRC Interim Staff Evaluation (ISE) Open Items (i.e., Reference 15) are addressed and documented in subsequent Order EA-13-109 six-month status reports and are considered complete pending NRC closure. Table 8 provides completion references for each ISE Phase 2 Open Item and a summary of the closure action for Open Items not previously completed.

Table 8 - Interim Staff Evaluation Phase 2 Open Items

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

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Open per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16).

See Phase 1 Open Item #10 response.

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

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 3 Licensee to demonstrate how instrumentation and equipment being used for SAWA and Complete (FIP) supporting equipment is capable to perform for the sustained operating period under the expected temperature and radiological conditions.

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Pending per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

The NRC staff reviewed the SAWA flow instrument qualifications for temperature and radiation. The staff

Enclosure RA-18-0258 Page 11 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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 8 - Interim Staff Evaluation Phase 2 Open Items

  1. Open Item Status
  • Indicates a change since last 6-month update anticipates a table in the Final Integrated Plan (FIP) (i.e., on the docket) to close the item. The (FIP will be provided with the Unit 2 Closeout (i.e., both Units closeout) submittal after completion of Unit 2 Phase 2 HCVS in March 2019.

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

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 5 Licensee to demonstrate that there is adequate communication between the MCA and the Complete operator at the FLEX pump during severe accident conditions.

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Closed per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16) 6 Licensee to demonstrate the SAWM flow instrumentation qualification for the expected Complete (FIP) environmental conditions.

Information provided in the June 2017 Six-Month Status Report by letter dated June 19, 2017 (i.e., ADAMS Accession No. ML17171A383) (i.e., Reference 12).

Pending per NRC Audit Report of ISE Open Item Responses by letter dated March 22, 2018 (i.e., ADAMS Accession No. ML18068A627) (i.e., Reference 16)

The NRC staff reviewed the SAWA flow instrument qualifications for temperature and radiation. The staff anticipates a table in the FIP (on the docket) to close the item. The Final Integrated Plan (FIP) will be provided with the Unit 2 Closeout (i.e., both Units closeout) submittal after completion of Unit 2 Phase 2 HCVS in March 2019.

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

No new ISE impacts are identified or added during this update period.

Enclosure RA-18-0258 Page 12 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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)

10. 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.
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.

Enclosure RA-18-0258 Page 13 of 13 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Ninth 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)

10. 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. Duke Energy Letter, 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), dated December 20, 2017, ADAMS Accession Number ML17354A248.
14. 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.
15. 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.
16. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRG Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (GAG Nos. MF4467 and MF4468; EPID L-2014-JLD-0041), dated March 22, 2018, ADAMS Accession Number ML18068A627.
17. Duke Energy Letter, Brunswick Steam Electric Plant, Unit 1, Completion of Required Action for NRG Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated May 29, 2018, ADAMS Accession Number ML18149A523.
18. Duke Energy Letter, BSEP, Unit Nos. 1 and 2, Eighth 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 26, 2018, ADAMS Accession Number ML18177A458.
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