ONS-2014-029, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

ML14064A196
Person / Time
Site:	Oconee
Issue date:	02/28/2014
From:	Batson S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ONS-2014-029
Download: ML14064A196 (11)

Text

DU KE Scott L. Batson Vice President ENERGY, Oconee Nuclear Station Duke Energy ONO IVP 17800 RochesterHwy Seneca, SC 29672 o: 864.873.3274 ONS-2014-029 f. 864.873. 4208 Scott.Batson@duke-energy.com February 28, 2014 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55

Subject:

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

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, (Accession No. ML12054A735).

2. Oconee Nuclear Station's Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated February 28, 2013.

3. Oconee Nuclear Station's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-basis External Events (Order Number EA-12-049), dated August 29, 2013.

Ladies and Gentlemen, On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to Duke Energy which was immediately effective and directed Duke Energy to develop guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. The Order required that, following NRC's issuance of its final Interim Staff Guidance (ISG), Duke Energy would submit an Overall Integrated Plan (OIP), followed by a status report at six-month intervals following the OIP submittal.

Duke Energy has thus far submitted the OIP (Reference 2) and the first six-month update (Reference 3) for Oconee Nuclear Station. The purpose of this letter is to provide the second six-month status report. The enclosure provides updates related to OIP changes, if any, for the six-month period following the first six-month reporting period.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments. 4i,.-

'United States Nuclear Regulatory Commission ONS Second Six-Month Status Report (Order EA-12-049)

February 28, 2014 Page 2 Should you have any questions regarding this submittal, please contact David Haile with Oconee Regulatory Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 28, 2014.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station

Enclosure:

Oconee Nuclear Station, Second Six-Month Status Report for Order EA-12-049 (FLEX),

Units 1,2, and 3.

'United States Nuclear Regulatory Commission ONS Second Six-Month Status Report (Order EA-12-049)

February 28, 2014 Page 3 cc:

Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Eric Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Richard Guzman, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8C2 Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ENCLOSURE

[8 pages including cover]

Oconee Nuclear Station (ONS)

Second Six Month Status Report for Order EA-1 2-049 (FLEX),

Units 1, 2, and 3 Encl. Page - 1

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

1) Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference El) to Duke Energy which required the development of guidance and strategies related to mitigation of a beyond-design-basis external event. The Order required each plant to issue an Overall Integrated Plan (OIP) pursuant to the NRC's Interim Staff Guidance (ISG)

(Reference E2) which endorsed, with clarifications and exceptions, the industry guidance document, NEI 12-06 (Reference E3). The Order also required that update reports on progress or change to the OIP be submitted every six months.

An Overall Integrated Plan (Reference E4) was developed based on the diverse and flexible strategies (FLEX) from NEI 12-06 (Reference E3) in response to NRC Order EA-12-049 and was submitted to the NRC on February 28, 2013. The first six-month update was provided to the NRC on August 29, 2013 (Reference E5). This report constitutes the second six-month update, and reports milestone accomplishments, changes to the compliance method or schedule, or any need for relief/relaxation, and the basis, which occurred during the period from July 31, 2013 to January 28, 2014 (hereafter referred to as "the update period").

2) Milestone Accomplishments (during the update period)

The following milestone(s) were completed:

1. The first six month status report was submitted August 29, 2013.

2. Significant Materials/Equipment necessary to implement current strategies have been identified. Thus, completing this milestone.

3. Based on current strategies, the N-1 Outage Walkdowns for Oconee Unit 2 were deemed as not necessary. Thus, that milestone is considered to have been completed.

3) Milestone Schedule Status The following represents the milestone status for the end of the update period. The table reflects updates to the milestone table in Attachment 2 of the Overall Integrated Plan. It provides the status of each activity, and whether the target completion date has changed.

Note: The dates are planning dates, and are subject to change as design and implementation details are developed. Revised target completion dates are not expected to impact the implementation date(s) of the Order.

Target Was Target Milestone Completion Activity Completion Date

-Date Status Revised Licensing Actions: I Submit Overall Integrated Plan Feb 2013 Complete Date Not Revised Submit 6 Month Update 1 Aug 2013 Complete Date Not Revised Submit 6 Month Update 2 Feb 2014 This Submittal Date Not Revised Submit 6 Month Update 3 Aug 2014 Not Started Date Not Revised Submit 6 Month Update 4 Feb 2015 Not Started Date Not Revised Submit 6 Month Update 5 Aug 2015 Not Started Date Not Revised Submit 6 Month Update 6 Feb 2016 Not Started Date Not Revised Submit 6 Month Update 7 Aug 2016 Not Started Date Not Revised Encl. Page - 2

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

Target Activity Was Target Milestone Completion Status Completion Date

._ _ _ _Date SauRevised M odifications: - -I - Started Develop Modifications Aug 2016 Started Date Not Revised Procurement:

Identify SignificantI Material/Equipment Sept 2013 Complete Date Not Revised Material/Equipmentjt Material/Equipment May 2015 Started Date Not Revised Procurement/Delivery Implementation Walkdowns:

Conduct N-1 Outage Nov 2014 Not Started Date Not Revised Walkdowns - U1 Conduct N-1 Outage Nov 2013 Complete Date Not Revised Walkdowns - U2 Conduct N-1 Outage May 2014 Not Started Date Not Revised Walkdowns - U3 Conduct Implementation Oct 2016 Not Started Date Not Revised Walkdowns - U 1 Conduct Implementation Oct 2015 Not Started Date Not Revised Walkdowns - U2 Conduct Implementation April 2016 Not Started Date Not Revised Walkdowns - U3 Staffing:

Conduct Staffing Analysis July 2016 Not Started Date Not Revised Training:

Develop Training program - UI July 2016 Not Started Date Not Revised Develop Training program - U2 July 2015 Not Started Date Not Revised Develop Training program - U3 Jan 2016 Not Started Date Not Revised Implement Training - U1 Oct 2016 Not Started Date Not Revised Implement Training - U2 Oct 2015 Not Started Date Not Revised Implement Training - U3 April 2016 Not Started Date Not Revised Procedures:

Develop FLEX Supporting June 2016 Started Date Not Revised Guidelines (FSGs)

Develop Maintenance Procedures June 2016 Not Started Date Not Revised Regional Response Centers:

Develop Strategies/Playbook with April 2015 Started Date Not Revised RRC Install Offsite Delivery Pad March 2015 Not Started Date Not Revised Encl. Page - 3

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8) 1 Target Was Target Milestone Completion status Completion Date

- Date SRevised Implementation:

Implement Modifications - U1 Nov 2016 Not Started Date Not Revised Implement Modifications - U2 Nov 2015 Not Started Date Not Revised Implement Modifications - U3 May 2016 Not Started Date Not Revised

4) Changes to Compliance Method No changes to compliance methods that are alternatives to NEI 12-06 were made.

5) Need for Relief and Basis for the Relief Duke Energy Carolinas, LLC (Duke Energy), Oconee Nuclear Station, Units 1, 2, and 3 anticipates meeting the Order implementation date and no relief is required at this time.

6) Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary status of the Open Items. The table under Section 6.a.

provides the open items identified in the original OIP submitted on February 28, 2013. The table under Section 6.b. provides a list of open items that were added after February 28, 2013.

The table under 6.c. provides a list of open items related to the Interim Staff Evaluation (ISE).

a) Open Items Documented in the Overall Integrated Plan Overall Integrated Plan Open Items Status

1. Revised PMP HMR51 Analysis In Progress: 2.1 Flood Re-analysis Completed - Pending NRC Approval

2. Max flood level on site 'after modifications' In Progress: 2.1 Flood Re-analysis Completed - Pending NRC Approval

3. Deployment Path Program Not Started

4. Procedures and FSGs Started

5. FLEX Equipment Programmatic Control Started

6. Personnel Training Not Started

7. FLEX Basis Document Started

8. Configuration Control Not Started

9. RRC Started

10. Cooldown Analysis Started

11. ADV Survivability and Accessibility Not Started

12. Load Shed Analysis Not Started

13. Hydraulic Analysis for Pump Flow Not Started (Intake Canal to SGs)

Encl. Page - 4

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

Overall Integrated Plan Open Items Status

14. Fuel Oil Consumption Not Started

15. Hydraulic Analysis for Pump Flow Not Started (CTP-1 to SGs)

16. Water in embedded CCW lines & Hydraulic Not Started Analysis for Pumping Configuration

17. PSW Modification (EC 91877) Started

18. Alternate FLEX Connections Modification Started (SG Makeup)

19. Breaking Siphons in Embedded CCW Started Piping

20. Instrumentation Repower Started (Alternate Repower Strategy)

21. FLEX Equipment Storage Started

22. Portable Power Distribution Started (Primary Repower Strategy)

23. Long term SG and SFP Makeup Started

24. Hydrogen Buildup Analysis Started

25. BWST Tap Analysis and Modification Started (RCS Makeup)

26. Containment Analysis Started

27. Hydraulic Analysis for Pump Flow Not Started (CTP-1 to SFPs & Intake Canal to SFPs)

28. Robustness of SFP Refill Lines Completed: Validated SFP Refill Lines are installed as QA-1 and are seismically robust. (References E6 & E7)

29. Lighting Evaluation Not Started

30. Communication Assessment Started

31. NEI 12-01 Staffing Study Started

32. HVAC Analysis Started b) Open Items added after February 28th, 2013 Open Items Status

33. Evaluate changes to the RCSMU FLEX Strategy recommended by independent audit to eliminate the SSF RCMUP repower strategy Started and implement train specific diesel powered pump strategies (primary and alternate). I _I Encl. Page - 5

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

Open Items Status

34. Evaluate changing the alternate repower FLEX strategy to enhance deployment times by utilizing a small 120 VAC portable diesel generator (approximately 6000 watts) deployed on the Turbine Building deck to provide 120 VAC feeds to connections in the control room and cable room to repower the key instrumentation parameters.

35. Validate the 10' assumed inundation level discussed in the OIP

[Assumption #8] is still conservative with respect to the Defense in Completed: CAP Depth Modifications analyzed in OIP reference 48 (which used a (Reference E8) slightly modified model run) and the credited CAL model run in OIP reference 14.

36. Perform raw water fouling analysis for core cooling and heat Started removal.

37. Evaluate freeze protection requirements in areas of the plant that Not Started contain equipment used in FLEX strategies.

38. Evaluate and establish a technical basis for use of non-safety Started related, installed equipment credited for mitigating an ELAP event.

c) Interim Staff Evaluation d) Generic Concerns The following summarizes ONS's review of five generic issues:

1. Electric Power Research Institute (EPRI) Report 3002001785, Use of Modular Accident Analysis Program(MAAP) in Support of Post-Fukushima Applications (Reference E9).

• The Oconee mitigating strategy is evaluated using RELAP5 and RETRAN for the NSSS response, and FATHOMS and GOTHIC for the containment response.

2. Electric Power Research Institute (EPRI) Report 3002000623 entitled "Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment" (Reference E10).

• ONS intends to follow EPRI Report 30002000623 in the development of maintenance and testing programs for equipment acquired in response to Mitigation Strategies Order EA-12-049 unless otherwise justified.

Encl. Page - 6

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

3. Westinghouse report entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG)" (Reference E12).

The Oconee mitigating strategy is evaluated using RELAP5 and RETRAN for the NSSS response, and FATHOMS and GOTHIC for the containment response.

4. Nuclear Energy Institute (NEI) position paper on mitigation strategies in shutdown and refueling modes (Reference E14).

• It is Oconee's intent to abide by the NEI position paper for shutdown and refueling modes.

5. Nuclear Energy Institute (NEI) position paper addressing battery life which has been endorsed by the NRC staff (Reference E16).

• For FLEX strategy planning purposes (resource allocation, debris removal, Phase 2 deployment, etc.) for T=0 events, the SSF will be relied on for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Phase 1 or one third of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> SSF design mission time. All instrument readings required to support the ELAP cool down are available in the SSF during this Phase 1 time period. This will allow time to deploy the primary repower strategy to repower the vital battery chargers and associated busses without performing additional load shedding. This approach eliminates resources required to perform additional load shedding activities on all 3 units in the T+2 to T+3 hour timeframe in which many critical activities are underway and eliminates potential unanticipated interactions created by load shed activities. Based on the above, the station vital batteries will be available for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after loss of power.

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

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

El. NRC Order Number EA-1 2-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents, dated March 12, 2012, (Accession No. ML12054A735).

E2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation strategiesfor Beyond-Design-Basis ExternalEvents, dated August 29, 2012 (Accession No. ML12229A174).

E3. NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 (Accession No. ML12242A378).

E4. Duke Energy Letter, Oconee Nuclear Station, Units 1, 2, and 3 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (OrderNumber EA-12-049)," dated February 2 8 th, 2013.

E5. Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Encl. Page - 7

ENCLOSURE: ONS SECOND SIX-MONTH STATUS REPORT: ORDER EA-12-049 (FLEX)

(Note: The references for this Enclosure are listed in Section 8)

Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049),

dated August 29, 2013 E6. Flow Diagram - Unit 1 & 2 Spent Fuel Cooling System (104A-1.1, Revision 53).

E7. Flow Diagram, Unit 3 Spent Fuel Cooling System (104A-3.1, Revision 48).

E8. ONS 2013 Corrective Action Program document - 8140 E9. EPRI Report 3002001785; "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications," dated June 2013 (Accession No. ML13190A201).

E10. EPRI Report 3002000623; "NuclearMaintenanceApplications Center: Preventive Maintenance Basis for FLEX Equipment," dated September 2013 (Accession No. ML13276A573).

El 1. NRC Letter endorsing EPRI Report 3002000623, dated October 7, 2013 (Accession No. ML13276A224)

E12. Westinghouse Report "WestinghouseResponse to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactorOwners Group (PWROG), "dated September 25, 2013, (withheld from public disclosure for proprietary reasons).

E13. NRC Letter endorsing Westinghouse Report; "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG), dated October 7, 2013 (Accession No. ML13276A555)

E14. Nuclear Energy Institute (NEI) position paper entitled "PositionPaper: Shutdown!

Refueling Modes," dated September 18, 2013 (Accession No. ML13273A514)

E15. NRC Letter endorsing NEI Position Paper "Shutdown/Refueling Modes," dated September 30, 2013 (Accession No. ML13267A382)

E16. Nuclear Energy Institute (NEI) White Paper entitled "BatteryLife Issue," dated August 21, 2013 (Accession No. ML13241A186)

E17. NRC Letter - "Battery Life White Paper Endorsement," dated September 16, 2013 (Accession No. ML13241A188).

Encl. Page - 8