ONS-2015-098, Fifth 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)

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Fifth 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)
ML15247A068
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 08/26/2015
From: Batson S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ONS-2015-098
Download: ML15247A068 (15)
v • d • e


Text

DUKEScott L.Batson Vice President ENERGYOconee Nuclear Station Duke Energy ONOIVP [7800 Rochester Hwy ONS-201 5-098 Seneca, SC 29672 o: 864.873.3274

f. 864.873. 4208 Scott.Batson@duke-energy.com August 26, 2015 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:

Fifth 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 Strategiesfor Beyond-Design-Basis External Events, dated March 12, 2012 (Accession No. ML12054A735).
2. Oconee Nuclear Station's Overall IntegratedPlan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order EA-12-049), dated February 28, 2013 (Accession No. ML13063A065).
3. Oconee Nuclear Station's FirstSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategiesfor Beyond-Design-basisExternal Events (Order Number EA-12-049), dated August 29, 2013 (Accession No. ML13246A009).
4. Oconee Nuclear Station's 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), dated February 28, 2014 (Accession No. ML14064A197).
5. Oconee Nuclear Station's Third 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),

(Accession No. ML14245A019).

6. Oconee Nuclear Station's Fourth 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 February 27, 2014 (Accession No. ML15063A027)
7. NEI 12-06, [Rev. 0], Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 (Accession No. ML12242A378).

I ONS-201 5-098 August 26, 2015 Page 2 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 status reports at six-month intervals.

Duke Energy has thus far submitted the OIP (Reference 2), and four six-month reports (References 3 to 6) for Oconee Nuclear Station. The purpose of this letter is to provide the fifth six-month status report. The enclosure provides updates related to compliance with NRC Order EA-12-049 and Nuclear Energy Institute (NEI) 12-06 (Reference 7) during the January 29, 2015 to July 28, 2015 update period.

This letter contains no new or revised Regulatory Commitments.

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 August 26, 2015.

Sincerely, Sct L ats~on Vice President Oconee Nuclear Station

Enclosure:

1. Oconee Nuclear Station, Fifth Six-Month Status Report for Order EA-1 2-049 (FLEX),

Units 1, 2, and 3.

ONS-201 5-098 August 26, 2015 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. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James R. Hall, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike, M/S O-8G9A Rockville, MD 20852-2746 Mr. Jeffery Whited (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ENCLOSURE1I Oconee Nuclear Station (ONS)

Fifth Six Month Status Report for Order EA-12-049 (FLEX),

Units 1, 2, and 3 Encl. Page 1 of 12

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

(Note: The referencesfor 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 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). The second six-month update was provided to the NRC on February 28, 2014 (Reference E18). The third six-month update was provided to the NRC on August 27, 2014 (Reference E28). The fourth six-month update was provided to the NRC on February 27, 2015 (Reference E29). This report constitutes the fifth 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 January 29, 2015 to July 28, 2015 (hereafter referred to as "the update period").

2) Milestone Accomplishments (during the update period)

The following milestone(s) were completed:

1. The fourth six month status report was submitted February 27, 2015.
3) Milestone Schedule Status The following represents the milestone status at 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 Completion Revised Target Milestone Date jActivity Status Completion Date Licensing Actions:

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 Complete Date Not Revised Submit 6 Month Update 3 Aug 2014 Complete Date Not Revised Submit 6 Month Update 4 Feb 2015 Complete Date Not Revised Submit 6 Month Update 5 Aug 2015 This Submittal 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 Modifications:

Develop Modifications Aug 2016 Started Date Not Revised Encl. Page - 2 of 12

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

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

Target

,Completion* f Revised Target Milestone Date * .. Activity Status j Completion Date Procurement: '

Identify Significant Material/Equipment Sept 2013 Complete Date Not Revised Material/Equipment Date Revised for Units 1

________________________________________ ___________ ______________ ISchedule Implementation Walkdowvns: - , * ,,: ,..

Conduct N-i Outage Walkdowns - U1 Nov 2014 Complete Date Not Revised Conduct N-i Outage Walkdowns - U2 Nov 2013 Complete Date Not Revised Conduct N-i Outage Walkdowns - U3 May 2014 Complete Date Not Revised Conduct Implementation Walkdowns -Ul Oct 2016 Not Started Date Not Revised Conduct Implementation Walkdowns - U2 Oct 2015 Not Started Date Not Revised Conduct Implementation Walkdowns - U3 April 2016 Not Started Date Not Revised Stffing: _____

Conduct Staffing Analysis [July 2016 Complete Date Not Revised Training:,,, .. .. ..

Develop Training program - Ul July 2016 Started Date Not Revised Develop Training program - U2 July 2015 Complete Date Not Revised Develop Training program - U3 Jan 2016 Started Date Not Revised Implement Training - U1 Oct 2016 Started Date Not Revised lInpiement Training - U2 Oct 2015 Started Date Not Revised Implement Training - U3 April 2016 Started Date Not Revised Procedures: ': , *,

Develop FLEX Guidelines (FGs) June 2016 Started Date Not Revised Develop Maintenance Procedures June 2016 Started Date Not Revised Rgona Response Centes:o ",  :* * '

Develop Strategies/Playbook with RRC April 2015 Complete Date Not Revised Complete Install Offsite Delivery Pad March 2015 (Installation not August 2015

____________ required)

Implementation: _________________

Implement Modifications - Ul Nov 2016 Started Date Not Revised Implement Modifications - U2 Nov 2015 Started Date Not Revised Implement Modifications - U3 May 2016 Started Date Not Revised Endl. Page - 3 of 12

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

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

4) Changes to Compliance Method During the July 2015 NRC Onsite Audit, it was discussed that the Atmospheric Dump Valves (ADVs) are rugged but not located in a structure protected from all beyond design-basis external events. Therefore, the NRC Auditors' perspective was that crediting ADV operation should be considered an alternate approach to NEI 12-06. Oconee acknowledges this position.

Justification is provided in OSC-11383 Attachment 10 (Reference E25) with respect to why the use of the ADVs is acceptable.

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 Section 6.a.

provides the open items identified in the original OIP submitted on February 28, 2013. The table Section 6.b* provides a list of open items that were added after February 28, 2013 through the end of the update period. The table Section 6.c. provides a list of open and confirmatory items related to the Interim Staff Evaluation (ISE) (Reference El19). The table Section 6.d.

addresses any generic concerns (No new generic issues were identified during this update period).

a) Open Items Documented in the Overall Integrated Plan S Overall integrated Plan open Items Status

1. Revised PMP HIMR5 1 Analysis Tracked by ONS NTM 01935875-01.
  • Closed during NRC July 2015 Audit.
2. Max flood level on site 'after modifications' Tracked by ONS NTM 01935875-02.

Closed during NRC July 2015 Audit.

3. Deployment Path Program Tracked by ONS NTM 01935875-03.

Closed during NRC July 2015 Audit.

4. Procedures and FSGs Tracked by ONS NTM 01935 875-04.

Closed during NRC July 2015 Audit*

5. FLEX Equipment Programmatic Control Takdb N T 13 7-5 Closed during NRC July 2015 Audit.
6. Personnel Training Tracked by ONS NTM 01935875-06.

Closed during NRC July 2015 Audit.

7. FLEX Basis Document Tracked by ONS NTM 01935875-07.

Closed during NRC July 2015 Audit.

8.Cofigrtio Control Tracked by ONS NTM 0 1935875-08.

oniguaionClosed during NRC July 2015 Audit.

9. RR~C Tracked by ONS NTM 01935875-09.

Closed during NRC July 2015 Audit.

10. Coldon AnaysisTracked by ONS NTM 10.

nalsisClosed oolown during NRC July0 1935875-10.

2015 Audit.

11. ADV Survivability and Accessibility Tracked by ONS NTM 01935875-11.

Closed during NRC July 2015 Audit.

Completed (Reference E25, Att. 3)

12. Load Shed Analysis Tracked by ONS NTM 01935875-12.

____________________________________Closed during NRC July 2015 Audit.

Endl. Page - 4 of 12

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

(Note." The referencesfor this Enclosure are listed in Section 8)

Overall Integrated Plan Open Items Status Completed (Reference E22)

13. ydruli Pup Fow Intae Cnalto ~s)Analysis results are acceptable.

fo Anlysi 13.Hydaulc nalsisfo Pup Fow(InakeCaal o Ss)Tracked by ONS NTM 01935875-13.

Closed during NRC July 2015 Audit.

Completed (Reference E25, Att. 4)

14. Fuel Oil Consumption Tracked by ONS NTM 01935875-14.

Closed during NRC July 2015 Audit.

Completed (Reference E22)

15. ydruli AnaysiFlw (TP-1to ~s) fo Pum Analysis results are acceptable.

15.Hydaulcor umpFlo Aalyis (CP-1to ~s) Tracked by ONS NTM 01935875-15.

Closed during NRC July 2015 Audit.

16. Water in embedded CCW lines & Hydraulic Analysis for Completed (Reference E26)

Pumping Con figuration Tracked by ONS NTM 01935875-16.

Closed during NRC July 2015 Audit.

Completed

17. PSW Modification (EC 91877) Tracked by ONS NTM 01935875-17.

Closed during NRC July 2015 Audit.

Completed (Reference E23)

18. Alternate FLEX Connections Modification (SG Makeup) Tracked by ONS NTM 01935875-18.

Closed during NRC July 2015 Audit.

Tracked by ONS NTM 01935875-19.

19. Breaking Siphons in Embedded CCW Piping Closed during NRC July 2015 Audit.

20.Insrumntaio Reowe (Aterat Reowe Statey) Tracked by ONS NTM 01935875-20.

20. nstumetaton epoer Altrnae Rpowr Sratgy) Closed during NRC July 2015 Audit.

21 FEX quimentStoageTracked by ONS NTM 01935875-21.

21.____FLEX ___Equipment______Storage_____Closed during NRC July 2015 Audit.

22.Porabl PwerDisriutin (riaryRepwe Statey)Tracked by ONS NTM 0 1935875-22.

22.Porabl istibuion(Prmar Poer Reowe Stater)Closed during NRC July 2015 Audit.

23.adongSP ermSG MaeupTracked by ONS NTM 0 1935875-23.

23.adongSP ermSG MaeupClosed during NRC July 2015 Audit.

Completed

24. Hydrogen Buildup Analysis (Reference E27: Sect. 3.14 and Att. E)

Tracked by ONS NTM 0 1935875-24.

______________________________________Closed during NRC July 2015 Audit.

25. BWST Tap Analysis and Modification (RCS Makeup) Tracked by ONS NTM 01935875-25.

Closed during NRC July 2015 Audit.

26. Containment Analysis Tracked by ONS NTM 01935875-26.

Closed during NRC July 2015 Audit.

27. Hydraulic Analysis for Pump Flow (CTP-1 to SFPs & Tracked by ONS NTM 01935875-27.

Intake Canal to SFPs) Closed during NRC July 2015 Audit.

Completed (References E6 & E7)

Validated SFP Refill Lines are installed

28. Robustness of SFP Refill Lines as QA-1 and are seismically robust Tracked by ONS NTM 01935875-28.

Closed during NRC July 2015 Audit.

29. ightng EaluaionTracked by ONS NTM 0 1935875-29.
29. ightng EaluaionClosed during NRC July 2015 Audit.
30. AsessentTracked ommnictio by ONS NTM 0 1935875-30.
30. AsessentClosed ommuicaton during NRC July 2015 Audit.

Endl. Page - 5 of 12

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

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

Overall Integrated Plan Open Items Status Tracked by ONS NTM 01935875-3 1.

31. NEI 12-01 (Reference E24) Staffing Study Closed during NRC July 2015 Audit.

by ONS NTM

32. VACAnalsisTracked 32._____HVAC_____Analysis_________Closed during NRC July01935875-32.

2015 Audit.

b) Open Items added after February 2 8 th, 2013 Open Items Status

33. Evaluate changes to the RCSMU FLEX Strategy Completed (Reference E25 Att. 2) recommended by independent audit to eliminate the SSF Tracked by ONS NTM 01935875-33.

RCMVUP repower strategy and implement train specific diesel powered pump strategies (primary and alternate). Closed during NRC July 2015 Audit.

34. Evaluate changing the alternate repower FLEX strategy to enhance deployment times by utilizing a small 120 VAC portable diesel generator (approximately 6000 watts) Tracked by ONS NTM 01935875-34.

deployed on the Turbine Building deck to provide 120 Closed during NRC July 2015 Audit.

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 This item superseded by Open Item 40 to the Defense in Depth Modifications analyzed in OIP Tracked by ONS NTM 01935875-35.

Reference 48 (which used a slightly modified model run) Closed during NRC July 2015 Audit.

and the credited CAL model run in OIP reference 14.

36. Perform raw water fouling analysis for core cooling and Tracked by ONS NTM 01935875-36.

heat removal. Closed during NRC July 2015 Audit.

37. Evaluate freeze protection requirements in areas of the Tracked by ONS NTM 01935875-37.

plant that contain equipment used in FLEX strategies. Closed during NRC July 2015 Audit.

38. Evaluate and establish a technical basis for use of non- rce yOSNM0957-8 safety related, installed equipment credited for mitigating Closked duin ONRC July 201358Audit.

an ELAP event. Coe uigNCJl 05Adt

39. FLEX Strategy for Shutdown Modes: Determine what TrcebyNSTM095739 mods, procedures, equipment, etc. is needed to support a Coe uigNCJl 05Adt Shutdown Modes FLEX Strategy.
40. Clarification of Applicable External Flooding Hazard at Tracked by ONS NTM 0 1935875-40.

ONS. Closed during NRC July 2015 Audit.

c) Interim Staff Evaluation (ISE)

ISE Open Items Status

1. Provide a description and justification for the specific Tracked by ONS evaluation model(s) used in the ELAP analyses for Oconee NTM 01938086-02.

(ISE Open Item # 3.2.1.1 .A).

2. The licensee should either (1) develop a successful Completed mitigating strategy that does not rely on repowering the SSF RCMU (eeec 2 t.2 pumps following recession of floodwaters or (2) provide adequate Closed during NRC justification that the SSF RCMU pumps can reliably be repowered Jl 05Adt following recession of floodwaters (ISE Open Item # 3.2.1.6.A). Jl 05Adt Encl. Page - 6of 12

ONS FIFTH SIX-MONTFH E_+/-l.,_t.o.J~.2.*NTCLOSU*CTRE:* STATUS REPORT (ORDER EA-12-049) (FLEX)

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

ISE Open Items Status

3. Provide adequate basis that nitrogen from the core flood tanks will not Closed during NRC be injected into the reactor coolant system Jl 05Adt (ISE Open Item # 3.2.1.6.B). Jl 05Adt
4. When ffurther analyses are completed, the licensee should provide additional information that either supports a conclusion that Takdb N pressurizer relief or safety valves do not lift during the ELAP event or NM0988-3 that lifting of the valve(s), if it occurs, is acceptable (ISE Open Item # 3.2.1 .6.C).
5. Provide additional information demonstrating successfu~l mitigation of an ELAIP event involving an uncontrolled cooldown resulting from Takdb N consequential damage to the main steam system due to the severeNM01986-4 natural hazard that initiates the ELAP event (1SF Open Item # 3.2.1 .6.D).
6. Demonstrate that Oconee's approach for modeling boric acid mixing is consistent with a generically acceptable methodology or develop aClsdurnNR plant-specific technical basis to support the modeling assumptions for Culose d05uringNR bonic acid nixing in the FLAP analysis for Oconee Jl 05Adt (ISEOpen Item #_3.2.1.8.B). __________

ISE Confirmatory Items Status

1. Confi-rm that ONS's final FLEX equipment deployment routes include adequate consideration of potential soil liquefaction or other Closed during NRC conditions that could impede movement following a severe seismic or July 2015 Audit.

other BOB event (Confirmatory Item # 3.1.1.2.A).

2. Confirm that the licensee's reference source providing guidance for operators to obtain instrument readings under FLAP conditions Closed during NRC adequately addresses the considerations in NEI 12-06, Section 5.3.3, July 2015 Audit.

consideration (1) (Confirmatory Item # 3.1.1.3 .A).

3. Confirm that the details for delivery and staging of off-site resources ClsdurnNR in the licensee's RRC playbook developed by the SAFER team and the ClsdurnNR utility are acceptable for all BDBFEs (Confirmatory Item # 3.1.1.4.A). July 2015 Audit.
4. To show conformity with NEI 12-06, Section 6.2.3.2, consideration 2, ClsdurnNR confirm that persistent, prohibitive flooding levels will not occur at the Julyse 205Aduit.NR ONS site (Confirmatory Item # 3.1.2.2.A). Jl 05Adt
5. Confirmn that the final ELMP computer code analyses for core cooling, reactor coolant system inventory, shutdown margin, and containment Tracked by ONS integrity have acceptable methodology and assumptions and support NTM 0 1938086-05.

the sequence of events timeline (Confirmatory Itemf# 3.2.1.1 .B).

6. Reliance on the RELAP5/MOD2- Babcock & Wilcox (B&W) and RETRAN-30 codes in the ELAP analysis for B&W plants should be Closed during NRC limited at the present time to the flow conditions prior to boiler-condenser cooling initiation. Confirmn that the code is not used outside July 2015 Audit.

this range (Confirmatory Item # 3.2.1.1 .C).

7. Confirm the means of isolating RCP seal return and RCS letdown in Closed during NRC accordance with the Jocassee dam break procedure and the associated Jl 05Adt timeframe (Confirmatory Item # 3.2.1.2.A). Jl 05Adt Encl. Page - 7of 12

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

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

ISE Confirmatory Items 'Status

8. Confirm that RCP seal temperature would be maintained at an acceptably low value by establishing injection flow to the RCP seals Tracked by ONS via the S SF RCMU pump within 20 minutes of event initiation NTM 01938086-06.

(Confirmatory Item # 3.2.1.2.B).___________

9. Confirm there is justification for the assumed seal leakage rates for the Takdb N Bingham RCPs with Sulzer seal assemblies NTMae 019808-07 (Confirmatory Item # 3.2.1.2.C). NTM__0193808__-07.
10. Confirm there is justification for the assumed seal leakage rates for the Takdb N Westinghouse 93-A RCPs with Flowserve N-9000 seals with the NM0988-8 Abeyance feature (Confirmatory Item # 3.2.1 .2.D). ___________
11. Confirm that steam generator pressure indication will be available to support the cooldown directed by the ELAP mitigating strategy, or Closed during NRC provide adequate basis that such indication is unnecessary even at Jl 05Adt average reactor coolant temperatures below 525 degrees Fahrenheit Jl 05Adt (Confirmatory Item # 3.2.1.5.A).
12. Confirm that the final containment analysis (open item 26)ClsdurnNR demonstrates that there will be no impact on the credited Julyse 205Adu it.N instrumentation (Confirmatory Item # 3.2.1 .5.B). Jl 05Adt
13. When evaluations are completed, confirm that the survivability and Tracked by ONS performance of the atmospheric dump valves is adequate to support NM0988-9 ONS's mitigation strategy (Confirmatory Item # 3.2.1 .6.E). ____________
14. Confirm that the analysis to determine Oconee's boration requirements Closed during NRC in Phase 2 of the mitigating strategy provides acceptable results Jl 05Adt (Confirmatory Item # 3.2.1.8.A). Jl 05Adt
15. Confirm that the BWST design provides tomnado missile protection to Closed during NRC ensure a source of borated water (Confirmatory Item # 3.2.1.8.C). July 2015 Audit.
16. Confirm the portable pump capability requirements and fuelClsdurnNR requirements to implement Phase 2 and Phase 3 strategies Jl 05Adt (Confirmatory Item #_3.2.1.9.A). __uy_2015__Audit._
17. Confirm acceptability of the SFP cooling strategy when it is completed Closed during NRC (Confirmatory Item # 3.2.2.A). July 2015 Audit.
18. Confirm that the results of the licensee's containment analysis beyond Closed during NRC 72 hours are acceptable (ONS open item 26)Juy05Adt (Confirmatory Item # 3.2.3.A). Jl 05Adt
19. Confirm using the analysis of hydrogen buildup (open item 24), that Closed during NRC there will be no impact on the Phase 2 ventilation strategies Jl 05Adt (Confirmatory Item # 3.2.4.2.A). Jl 05Adt
20. Confirm that the results of ONS 's evaluation of building and area temperatures (licensee-identified open item 32), are acceptable to Closed during NRC support the licensee's proposed FLAP mitigation strategies July 2015 Audit.

(Confirmatory Item # 3.2.4.2.B).

21. Confirm that the licensee's evaluation of freeze protection (ONS open Closed during NRC item 37) is acceptable (Confirmatory Item # 3.2.4.3.A). July 2015 Audit.
22. Confirm that the licensee's analysis of lighting (open item 29) is Closed during NRC acceptable (Confirmatory Item # 3.2.4.4.A). July 2015 Audit.
23. Confirm that upgrades to the site's communications systems have been Closed during NRC completed (Confirmatory Item # 3.2.4.4.B). July 2015 Audit.
24. Confirm that ONS's FLEX strategies with regard to protected and Closed during NRC internal locked area access are acceptable Jl 05Adt (Confirmatory Item #_3.2.4.5.A). __ uly_2015__Audit._

Endl. Page - 8 of '12

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

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

ISE Confirmatory Items Status

25. Confrmn that the use of non-safety related installed equipment Closed during NRC (licensee's open item 38) is acceptableJuy05Adt (Confirmatory Item #i 3.2.4.7.A). Jl 05Adt
26. Confirm that the licensee's strategy for providing chemical treatment pond make up water at a rate of 700,000 gallons per day following a Closed during NRC flooding event is acceptable. This is ONS Open Item 23 in the July 2015 Audit.

Integrated Plan (Confirmatory Item # 3.2.4.7.B).

27. Confirm that ONS's processes and procedures to prevent inappropriate interactions of portable electrical power sources with permanent plant Closed during NRC equipment (ONS's open item 4) conforms to the guidance mn NEI 12-06, Section 3.2.2, Guideline (13), or provides an acceptable alternative July 2015 Audit.

to that guidance (Confirmatory Item # 3.2.4.8.A).

28. Confirm that the licensee's FLEX generator sizing calculations/analysis anid single line diagrams showing proposed Closed during NRC connections of FLEX electrical equipment are acceptable July 2015 Audit.

(Confirmatory Item # 3.2.4.8.B).

29. Confirm that the licensee's fuel oil consumption analysis (licensee's Completed open item 14) is acceptable (Confirmatory Item # 3.2.4.9.A). (Reference E25, Att. 4)

Closed during NRC July 2015 Audit.

30. Confirm the licensee has considered the coordination of SSF and portable equipment during a "T=0" event, explaining what criteria will Completed be used to determine when to switch from use of the SSF to use of (Reference E25, Att. 1) portable equipment and to explain whether the SSF can be used Closed during NRC beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Confirmatory Item # 3.2.4.9.B). July 2015 Audit.
31. Confirm that the licensee's analyses on load shedding (licensee's open Completed item 12), and summaries of battery sizing calculations for both seismic (Reference E25 Att. 3) and flooding scenarios of ELAP are acceptable Closed during NRC (Confirmatory Item # 3.2.4.10.A). July 2015 Audit.
32. Confirm that the licensee's implementation of maintenance and testing Closed during NRC guidance for FLEX equipment is acceptable Jl 05Adt (Confirmatory Item # 3.3.1 .A). Jl 05Adt
33. Offsite Resources - Confirm NEI 12-06 Section 12.2, Guidelines 2 Closed during NRC through 10, are addressed with SAFER (Confirmatory Item # 3 .4.A). July 2015 Audit.

Encl. Page - 9of 12

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

(Note: The references for this Enclosure are listed in Section 8) d) Generic Concerns The following summarizes ONS's review of six generic issues:

i. Electric Power Research Institute (EPRI) Report 3002001785, Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications and NRC endorsement (Reference E8 & Reference E17).
  • The Oconee mitigating strategy is evaluated using RELAP5 and RETRAN for the NSSS response, and FATHOMS and GOTHIC for the containment response.

ii. Electric Power Research Institute (EPRI) Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment and NRC endorsement (Reference E9 & Reference EI0).

  • 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-1 2-049 unless otherwise justified.

iii. 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) and NRC endorsement (Reference Eli & Reference El12).

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

iv. Nuclear Energy Institute (NEI) position paper, Position Paper: Shutdown/Refueling Modes and NRC endorsement (Reference E13 & Reference E14).

  • It is Oconee's intent to abide by the NEI position paper for shutdown and refueling modes.
v. Nuclear Energy Institute (NEI) white paper, Battery Life Issue and NRC endorsement (Reference E15 & Reference E16).
  • The SSF has a design basis mission time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ONS plans to utilize the SSF as long as it remains operational. After an ELAP is determined, ONS will utilize the SSF in a dual loop feed to cooldown to 240-250 degrees. ONS will simultaneously deploy Phase 2 equipment during this timeframe utilizing the priority established from our thermal-hydraulic analysis. 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.

vi. Westinghouse position paper, Westinghouse Response to NRC Generic Request for Additional information (RAI) on Boron Mixing in support of the Pressurizer Water Reactor Owners Group (PWROG) and NRC endorsement (References E20 & E21).

  • Oconee Nuclear Station will address this generic issue in the ISE Open Item # 3.2.1.8.8.

Encl. Page - 10 of 12

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

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

7) Potential Interim Staff Evaluation Impacts Changes to the NRC Phone Audit Questions, alP Open Items, and ISE Open/Confirmatory Items were dispositioned during the July 2015 NRC Onsite Audit. No other changes have the potential to impact the ISE.
8) References The following references support the updates to the Overall Integrated Plan described in this enclosure:

El. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (Accession No. ML12054A735).

E2. NRC Interim Staff Guidance JLD-ISG-201 2-01, Compliance with Order EA-2-049, Order Modifying Licenses with Regard to Requirements for Mitigation strategiesfor Beyond-Design-Basis External Events, 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 IntegratedPlan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated February 28 th, 2013 (Accession No. ML13063A065).

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 Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 29, 2013 (Accession No. ML13246A009).

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

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

E8. EPRI Report 3002001785, Use of Modular Accident Analysis Program(MAAP) in Support of Post-FukushimaApplications, dated June 2013 (Accession No. ML13190A201 ).

E9. EPRI Report 3002000623, Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment, dated September 2013 (Accession No. ML13276A573).

EI0. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock Vice President Nuclear Operations, dated October 7, 2013 (Accession No. ML13276A224).

Eli. Westinghouse Report, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the PressurizedWater reactorOwners Group (PWROG), dated September 25, 2013 (Withheld from public disclosure).

E12. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Jack Stringfellow, PWR Owners Group, Program Management - Westinghouse, dated October 7, 2013 (Accession No. ML13276A555).

E13. NEI Position Paper, Shutdown/Refueling Modes, dated September 18, 2013 (Accession No. ML13273A514).

E14. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 30, 2013 (Accession No. ML13267A382).

Encl. Page -l11of 12

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

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

E15. NEI White Paper, Battery Life Issues, dated August 21, 2013 (Accession No. ML13241A186).

E16. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated September 16, 2013 (Accession No. ML13241A188).

E17. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 3, 2013 (Accession No. ML13275A318).

El18. Duke Energy Letter, 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), dated February 28, 2014 (Accession No. ML14064A197).

E19. NRC letter from Jeremy S. Bowen, Mitigating Strategies Directorate (NRR), Mr. Scott Batson, Site Vice President Oconee Nuclear Station, dated February 10, 2014 (Accession No. ML13365A258).

E20. Westinghouse Position Paper, Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in support of the PressurizerWater Reactor Owners Group (PWROG),I dated August 16, 2013 (Accession No. ML13235A135).

E21. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate (NRR), to Jack Stringfellow, PWR Owners Group, Program Management - Westinghouse, dated January 8, 2014 (Accession No. ML13276A183).

E22. ONS Hydraulic Analysis Calculation - 11232.

E23. ONS Engineering Change Document - 113065.

E24. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012 (Accession No. ML12125A412).

E25. ONS Select Fukushima Related Technical Evaluations, Analyses, and Position Papers Calculation -11383.

E26. ONS FLEX Strategy Intermediate Cooling Hydraulic Calculation -11329.

E27. ONS Auxiliary Building GOTHIC Heat-Up Analysis - ELAP Event Cases - 11253.

E28. Duke Energy Letter, Third 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 (OrderNumber EA-12-049), dated August 27, 2014 (Accession No. ML14245A019).

E29. Duke Energy Letter, Fourth 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 February 27, 2015 (Accession No. ML15063A027).

Encl. Page-l12 of 12

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