ML16074A394

Sixth 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)

ML16074A394
Person / Time
Site:	Brunswick
Issue date:	02/24/2016
From:	Gideon W R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0006, EA-12-049
Download: ML16074A394 (13)

Text

DUKE William R. Gideon C Vice President E' NERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 February 24, 2016 Serial: BSEP 16-0006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Sixth 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-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML1 2054A735 2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

4. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's Initial 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 October 29, 2012, ADAMS Accession Number ML12307A021

5. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated February 28, 2013, ADAMS Accession Number ML13071A559

6. 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 20, 2013, ADAMS Accession Number ML13248A447 U.S. Nuclear Regulatory Commission Page 2 of 4 7. 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, ADAMS Accession Number ML14073A451

8. 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 (Order Number EA-12-049), dated August 28, 2014, ADAMS Accession Number ML14254A176

9. 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, ADAMS Accession Number ML15084A156

10. Duke Energy Letter, 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), dated August 26, 2015, ADAMS Accession Number ML15246A034

11. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (i.e., Reference

1) to Duke Energy Progress, Inc. (Duke Energy). Reference 1 was immediately effective and directs Duke Energy to develop, implement, and maintain 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. Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (i.e., Reference

2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (i.e., Reference

3) with clarifications and exceptions identified in Reference 2.Reference 4 provided the initial status report regarding mitigation strategies at the Brunswick, Robinson, and Shearon Harris Nuclear Power Plants. Reference 5 provided the OIP for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.References 6, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, for BSEP. Reference 11 provided notification of full compliance with Order EA-12-049 for BSEP, Unit 2.The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2, of Reference

1. The attached report provides an update of milestone U.S. Nuclear Regulatory Commission Page 3 of 4 accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.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) 457-2487.I declare under penalty of perjury that the foregoing is true and correct, executed on February 24, 2016.Sincerely, William R. Gideon Enclosure.

Sixth 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-1 2-049), Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 U.S. Nuclear Regulatory Commission Page 4 of 4 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Aye, NE, Suite 1200 Atlanta, GA 30303-1 257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWEN 8B3) (E~lectronic Copy Only)11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 ENCLOSURE SIXTH 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)

BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 RENEWED LICENSE NOS. DPR-71 AND DPR-62 Page 1 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 1Introduction Note: References are provided in Section 7 of this enclosure.

Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)(Reference

1) documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049.

The OIP was submitted to the NRC on February 28, 2013. The first six-month update was submitted to the NRC on August 20, 2013 (Reference 2). The second six-month update was submitted to the NRC on February 28, 2014 (Reference 3). The third six-month update was submitted to the NRC on August 28, 2014 (Reference 4). The fourth six-month update was submitted to the NRC on February 27, 2015 (Reference 5). The fifth six-month update was submitted to the NRC on August 26, 2015 (Reference 6). 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, that occurred during the period between July 28, 2015, and January 28, 2016, hereafter referred to as the update period. Reference 7 provided notification of full compliance with Order EA-1 2-049 for BSEP, Unit 2.2 Milestone Accomplishments The following milestones were completed during the update period:* Procure Equipment (Unit 1)* Develop Unit 1 Modification EC Packages* Submit Fifth Six-Month Status Report 3 Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates and subject to change as design and implementation details are developed.

The revised milestone target completion dates are not expected to impact the Order implementation date.Page 2 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

.. .. ...... *TargetIRe i d* *Milestone Completion Activity StatusReid

_________________.

...._____ Dae _____________

Completion Date,*lIndicates a change since last 6 month update.Submit 60 Day Status Report 10/29/12 Complete Date Not Revised Submit Overall Integrated 2/28/13 Complete Date Not Revised Implementation Plan Submit 6 Month Status Report 8/30/13 Complete Date Not Revised Perform Staffing Analysis Phase 1 1/91 opeeDt o eie of NEI 12-01 Submit 6 Month Status Report 2/28/14 Complete Date Not Revised Develop Unit 2 Modification 3/30/15 Unit 2 Engineering Change (EC) 3/71 opeeModifications will be Packages, including Storage 3/71 opee completed and ready to Facility _______exit RFO B222R1 Perform station-specific analysis following generic BWROG FLEX3/0113/5 implementation analysis review Cmlt (Open Item 19)Develop Strategies/Contract with Regional Response Center (RRC) February 2015 Complete Date Revised Submit 6 Month Status Report 8/29/14 Complete Date Not Revised SAT Process for Training (Unit 2) 01/27/14 Complete 10/31/14 Date Revised to SAT Process for Training (Unit 1 ) 1/26/15 Complete 06/25/2015 10/31/14 Unit 2 Training Plan Develop Training Plan (Unit 2) 07/27/14 Complete continues to be revised due to large amount of Operator training in 2014.Develop Training Plan (Unit 1) 07/26/15 Complete Date Not Revised 02/26/2015 Permanent Storage Procure Equipment (Unit 2) 11/27/14 Complete Building not available until Middle of January 2015 Procure Equipment (Unit 1) 11/26/15 *Complete Date Not Revised Create Maintenance Procedures 0/71 opee0/521 (Unit 2) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Page 3 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

• Indicates a change since last 6 month update.*Date Revised from Creae Mintnanc Prcedres01/26/16 to 03125/16.Create ManennePrcdue"03/25/16 Started Procedure changes (Unit 1)implemented during Spring 2016 Outage.Procedure Changes incorporating 0/71 opee0/521 response strategies (Unit 2) 0/71 opee0/521*Date Revised from ProcdureChanes icorpratig

• 01/26/16 to 03/25/1 6.PresonsedstraeCagies (Uinoprti)

"03/25/16 Started Procedure changes respnse tratgies(Uni 1)implemented during Spring 2016 Outage.Implement Training (Unit 2) 02/27/15 Complete Date Not Revised Submit 6 Month Status Report 2/27/15 Complete Date Not Revised Outage Start Date Unit 2 Implementation Outage March 2015 Complete moved up to February 2015 Implement Modifications (Unit 2) April 2015 Complete Date Not Revised Submit Completion Report (Unit 2) April 2015 Complete Date Not Revised Develop Unit 1 Modification EC112/5*mpe DtRvid Packages Submit 6 Month Status Report 8/31/15 *Complete Date Not Revised Implement Training (Unit 1) 02/26/16 Started Date Not Revised Submit 6 Month Status Report 2/29/16 *Started Date Not Revised Outage Start Date Unit 1 Implementation Outage February 2016 Not Started moved up to February 2016 Implement Modifications (Unit 1) April 2016 *Started Date Not Revised Submit Completion Report (Unit 1) April 2016 Not Started Date Not Revised Submit 6 Month Status Report 8/31/16 Not Started Date Not Revised Page 4 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 4 Changes to Compliance Method The following summarizes changes that were made during the sixth update period to the strategies as documented in the OIP (Reference 1 of this enclosure) or to the changes that were provided by References 2, 3, 4, 5, and 6 of this enclosure.

These changes do not impact BSEP's compliance with NEI 12-06.1) Chan~qe: One of two raw water supply methods for Condensate Storage Tank (CST) refill (i.e., water trucks and portable tanks) is removed from the OST fill strategy.

The discharge canal water supply is maintained as the raw water supply for the water makeup strategy.Reference 5 provided the initial long term makeup water strategy.Justification:

CST refill uses on-site clean water sources that survive the Beyond Design Basis External Event (BDBEE) before using raw water. During development of the CST refill strategy, the site established the "discharge canal" and "water trucks and portable tanks" as raw water sources. The "water trucks and portable tanks" water source, which relies upon a private off-site company to truck water to the site, may not be a reliable source following a BDBEE.BSEP has the resources (i.e., personnel, equipment, and procedures) to supply water to the CSTs from the plant discharge canal (i.e., an indefinite supply of water) following a BDBEE.BSEP has implemented the BWROG-TP-14-006 guidance for use of raw water into the Reactor Vessel Control Procedure Emergency Operating Procedure.

Compliance with NEI 12-06 is not impacted.Documentation:

1. 0EOP-01 -FSG-1 5, Unit 2 FLEX Condensate Storage Tank Fill 2. 1/2EOP-01-RVCP, Reactor Vessel Control 3. BWROG-TP-1 4-006, Raw Water Issue: Fuel Inlet Blockage from Debris, Revision 0, March 2014 (proprietary) 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There are no changes to the need for relief/relaxation during this sixth update period.6 Open Items Generic Concerns None Plan Open Items Tables 6a and 6b provide a summary status of the Open Items. Table 6a provides the open items that were previously identified in the original OIP submitted on February 28, 2013, and in the first, second, third, fourth, and fifth six-month status report submitted in Reference 2, 3, 4, 5, and 6 of this enclosure.

Table 6b provides a list of open items that were added after July 28, 2015.Page 5 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

Table 6a. Open Items Documented in the Overall Integrated Plan..... Overall integrated Plan 0pen Item Status*Indicates a change since last 6 month update.1. Perform a formal validation of FLEX deployment, Complete connection, and action timelines after the procedural guidance is developed and related staffing study is completed.

2. Implement programmatic controls.

Coinplete 3. Develop plant equipment control guidelines, in Complete accordance with NEI 12-06 Section 11.5, to manage the unavailability of equipment and applicable connections that directly perform a FLEX mitigation strategy._________________

4. Establish programs and process to assure personnel Complete proficiency in the mitigation of beyond- design-basis events is developed and maintained in accordance with NEI 12-06 Section 11.6.5. Maintain FLEX strategies in overall FLEX basis Complete documents.

6. Modify existing plant configuration control procedures Complete to ensure that changes to the plant design, physical plant layouts, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06 Section 11 .8.7. Complete applicable training prior to the Complete (Unit 2)implementation of FLEX. Started (Unit 1)8. Complete construction of FLEX Equipment Storage Complete Building prior to the implementation of FLEX.9. Develop BSEP procedures and programs to address Complete storage structure requirements, deployment path requirements, and FLEX equipment requirements relative to the hazards applicable to BSEP. _______________

10. Design FLEX equipment connection points (e.g. Complete mechanical, pneumatic, and electrical) to withstand the applicable external hazards.11. Perform study to validate Suppression Pool Complete temperatures exceeding 220°F.12. Develop site specific procedures or guidelines, Complete (Unit 2)utilizing the industry developed guidance from the Started (Unit 1)Owners' Groups, EPRI, and NEI Task team, to address the criteria in NEI 12-06.13. Deleted Deleted 14. Complete SFP level instrumentation modifications per Complete (Unit 2)NRC Order EA 12-051, Issuance of Order to Modify Started (Unit 1)Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

_______________

Page 6 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

.... Overall lIntegrated Plan 0pen Item ..... IStatus*Indicates a change since last 6 month update.15. Develop deep load-shedding procedures to extend Delete coping time for station batteries.

2nd 6-month update change #7.Deep load shedding procedures are not required.

Load shedding activities are contained in SBO-1 0.16. Modify procedures such that operator manual actions, Complete (Unit 2)in areas where habitability is a concern, occur early in Started (Unit 1)the FLEX timeline, to the extent practical.

17. Revise procedures to open Reactor Building doors to Complete (Unit 2)provide a natural air circulation path. *Complete (Unit 1)18. Provide transportation equipment to move large Complete skids/trailer-mounted equipment provided from off-site.19. Review generic BWROG analysis of FLEX Complete implementation and perform station-specific analysis (NEDC 33771 P, Revision 1).20. Develop a process/methodology to rupture the Complete (Unit 2)Wetwell Vent Disc with Containment pressure below *Complete (Unit 1)55 psi.21. Develop a process/methodology to provide Clean Complete (Unit 2)Water Makeup to the CST during Phase 3 response.

Started (Unit 1)22. Develop guidance for obtaining local vital indications Complete (Unit 2)during a loss of DC in conjunction with an ELAP. This Started (Unit 1)strategy will be available for appropriate plant personnel use in response to these failures.23. Provide justification showing the Unit 1 CST and Complete Unit 2 CST are robust from applicable external hazards.24. Develop a DC power coping analysis lAW IEEE-485 Complete and establish an appropriate coping time for FLEX response._______________

Table 6b. Open Items added after July 28, 2015...... oie~rall lntegrated Plan Open item I

• Status No new open items durnn this sixth update period.Page 7 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 7 References The following references support updates to the Overall Integrated Plan as described in this enclosure.

1. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013, Agencywide Documents Access and Management System (ADAMS)Accession Number ML13071A559

2. 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 20, 2013, ADAMS Accession Number ML13248A447

3. 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, ADAMS Accession Number ML14073A451

4. 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 (Order Number EA- 12-049), dated August 28, 2014, ADAMS Accession Number ML14254A176

5. 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, ADAMS Accession Number ML15084A156

6. Duke Energy Letter, 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), dated August 26, 2015, ADAMS Accession Number ML15246A034

7. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013

8. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, ADAMS Accession Number ML12054A735

9. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

10. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

11. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Page 8 of 9 SIXTHr SI-ONHSTTSmEORbOREeNME EA-12-049),dtdOtbr2,21,A MScesinNm r Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012, ADAMS Accession Number ML1 2307A021 4 Page 9 of 9 DUKE William R. Gideon C Vice President E' NERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 February 24, 2016 Serial: BSEP 16-0006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Sixth 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-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession Number ML1 2054A735 2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

4. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's Initial 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 October 29, 2012, ADAMS Accession Number ML12307A021

5. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated February 28, 2013, ADAMS Accession Number ML13071A559

6. 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 20, 2013, ADAMS Accession Number ML13248A447 U.S. Nuclear Regulatory Commission Page 2 of 4 7. 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, ADAMS Accession Number ML14073A451

8. 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 (Order Number EA-12-049), dated August 28, 2014, ADAMS Accession Number ML14254A176

9. 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, ADAMS Accession Number ML15084A156

10. Duke Energy Letter, 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), dated August 26, 2015, ADAMS Accession Number ML15246A034

11. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (i.e., Reference

1) to Duke Energy Progress, Inc. (Duke Energy). Reference 1 was immediately effective and directs Duke Energy to develop, implement, and maintain 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. Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (i.e., Reference

2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (i.e., Reference

3) with clarifications and exceptions identified in Reference 2.Reference 4 provided the initial status report regarding mitigation strategies at the Brunswick, Robinson, and Shearon Harris Nuclear Power Plants. Reference 5 provided the OIP for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports.References 6, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, for BSEP. Reference 11 provided notification of full compliance with Order EA-12-049 for BSEP, Unit 2.The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2, of Reference

1. The attached report provides an update of milestone U.S. Nuclear Regulatory Commission Page 3 of 4 accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.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) 457-2487.I declare under penalty of perjury that the foregoing is true and correct, executed on February 24, 2016.Sincerely, William R. Gideon Enclosure.

Sixth 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-1 2-049), Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 U.S. Nuclear Regulatory Commission Page 4 of 4 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Aye, NE, Suite 1200 Atlanta, GA 30303-1 257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Peter Bamford (Mail Stop OWEN 8B3) (E~lectronic Copy Only)11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 ENCLOSURE SIXTH 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)

BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 RENEWED LICENSE NOS. DPR-71 AND DPR-62 Page 1 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 1Introduction Note: References are provided in Section 7 of this enclosure.

Brunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)(Reference

1) documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049.

The OIP was submitted to the NRC on February 28, 2013. The first six-month update was submitted to the NRC on August 20, 2013 (Reference 2). The second six-month update was submitted to the NRC on February 28, 2014 (Reference 3). The third six-month update was submitted to the NRC on August 28, 2014 (Reference 4). The fourth six-month update was submitted to the NRC on February 27, 2015 (Reference 5). The fifth six-month update was submitted to the NRC on August 26, 2015 (Reference 6). 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, that occurred during the period between July 28, 2015, and January 28, 2016, hereafter referred to as the update period. Reference 7 provided notification of full compliance with Order EA-1 2-049 for BSEP, Unit 2.2 Milestone Accomplishments The following milestones were completed during the update period:* Procure Equipment (Unit 1)* Develop Unit 1 Modification EC Packages* Submit Fifth Six-Month Status Report 3 Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates and subject to change as design and implementation details are developed.

The revised milestone target completion dates are not expected to impact the Order implementation date.Page 2 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

.. .. ...... *TargetIRe i d* *Milestone Completion Activity StatusReid

_________________.

...._____ Dae _____________

Completion Date,*lIndicates a change since last 6 month update.Submit 60 Day Status Report 10/29/12 Complete Date Not Revised Submit Overall Integrated 2/28/13 Complete Date Not Revised Implementation Plan Submit 6 Month Status Report 8/30/13 Complete Date Not Revised Perform Staffing Analysis Phase 1 1/91 opeeDt o eie of NEI 12-01 Submit 6 Month Status Report 2/28/14 Complete Date Not Revised Develop Unit 2 Modification 3/30/15 Unit 2 Engineering Change (EC) 3/71 opeeModifications will be Packages, including Storage 3/71 opee completed and ready to Facility _______exit RFO B222R1 Perform station-specific analysis following generic BWROG FLEX3/0113/5 implementation analysis review Cmlt (Open Item 19)Develop Strategies/Contract with Regional Response Center (RRC) February 2015 Complete Date Revised Submit 6 Month Status Report 8/29/14 Complete Date Not Revised SAT Process for Training (Unit 2) 01/27/14 Complete 10/31/14 Date Revised to SAT Process for Training (Unit 1 ) 1/26/15 Complete 06/25/2015 10/31/14 Unit 2 Training Plan Develop Training Plan (Unit 2) 07/27/14 Complete continues to be revised due to large amount of Operator training in 2014.Develop Training Plan (Unit 1) 07/26/15 Complete Date Not Revised 02/26/2015 Permanent Storage Procure Equipment (Unit 2) 11/27/14 Complete Building not available until Middle of January 2015 Procure Equipment (Unit 1) 11/26/15 *Complete Date Not Revised Create Maintenance Procedures 0/71 opee0/521 (Unit 2) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Page 3 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

• Indicates a change since last 6 month update.*Date Revised from Creae Mintnanc Prcedres01/26/16 to 03125/16.Create ManennePrcdue"03/25/16 Started Procedure changes (Unit 1)implemented during Spring 2016 Outage.Procedure Changes incorporating 0/71 opee0/521 response strategies (Unit 2) 0/71 opee0/521*Date Revised from ProcdureChanes icorpratig

• 01/26/16 to 03/25/1 6.PresonsedstraeCagies (Uinoprti)

"03/25/16 Started Procedure changes respnse tratgies(Uni 1)implemented during Spring 2016 Outage.Implement Training (Unit 2) 02/27/15 Complete Date Not Revised Submit 6 Month Status Report 2/27/15 Complete Date Not Revised Outage Start Date Unit 2 Implementation Outage March 2015 Complete moved up to February 2015 Implement Modifications (Unit 2) April 2015 Complete Date Not Revised Submit Completion Report (Unit 2) April 2015 Complete Date Not Revised Develop Unit 1 Modification EC112/5*mpe DtRvid Packages Submit 6 Month Status Report 8/31/15 *Complete Date Not Revised Implement Training (Unit 1) 02/26/16 Started Date Not Revised Submit 6 Month Status Report 2/29/16 *Started Date Not Revised Outage Start Date Unit 1 Implementation Outage February 2016 Not Started moved up to February 2016 Implement Modifications (Unit 1) April 2016 *Started Date Not Revised Submit Completion Report (Unit 1) April 2016 Not Started Date Not Revised Submit 6 Month Status Report 8/31/16 Not Started Date Not Revised Page 4 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 4 Changes to Compliance Method The following summarizes changes that were made during the sixth update period to the strategies as documented in the OIP (Reference 1 of this enclosure) or to the changes that were provided by References 2, 3, 4, 5, and 6 of this enclosure.

These changes do not impact BSEP's compliance with NEI 12-06.1) Chan~qe: One of two raw water supply methods for Condensate Storage Tank (CST) refill (i.e., water trucks and portable tanks) is removed from the OST fill strategy.

The discharge canal water supply is maintained as the raw water supply for the water makeup strategy.Reference 5 provided the initial long term makeup water strategy.Justification:

CST refill uses on-site clean water sources that survive the Beyond Design Basis External Event (BDBEE) before using raw water. During development of the CST refill strategy, the site established the "discharge canal" and "water trucks and portable tanks" as raw water sources. The "water trucks and portable tanks" water source, which relies upon a private off-site company to truck water to the site, may not be a reliable source following a BDBEE.BSEP has the resources (i.e., personnel, equipment, and procedures) to supply water to the CSTs from the plant discharge canal (i.e., an indefinite supply of water) following a BDBEE.BSEP has implemented the BWROG-TP-14-006 guidance for use of raw water into the Reactor Vessel Control Procedure Emergency Operating Procedure.

Compliance with NEI 12-06 is not impacted.Documentation:

1. 0EOP-01 -FSG-1 5, Unit 2 FLEX Condensate Storage Tank Fill 2. 1/2EOP-01-RVCP, Reactor Vessel Control 3. BWROG-TP-1 4-006, Raw Water Issue: Fuel Inlet Blockage from Debris, Revision 0, March 2014 (proprietary) 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There are no changes to the need for relief/relaxation during this sixth update period.6 Open Items Generic Concerns None Plan Open Items Tables 6a and 6b provide a summary status of the Open Items. Table 6a provides the open items that were previously identified in the original OIP submitted on February 28, 2013, and in the first, second, third, fourth, and fifth six-month status report submitted in Reference 2, 3, 4, 5, and 6 of this enclosure.

Table 6b provides a list of open items that were added after July 28, 2015.Page 5 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

Table 6a. Open Items Documented in the Overall Integrated Plan..... Overall integrated Plan 0pen Item Status*Indicates a change since last 6 month update.1. Perform a formal validation of FLEX deployment, Complete connection, and action timelines after the procedural guidance is developed and related staffing study is completed.

2. Implement programmatic controls.

Coinplete 3. Develop plant equipment control guidelines, in Complete accordance with NEI 12-06 Section 11.5, to manage the unavailability of equipment and applicable connections that directly perform a FLEX mitigation strategy._________________

4. Establish programs and process to assure personnel Complete proficiency in the mitigation of beyond- design-basis events is developed and maintained in accordance with NEI 12-06 Section 11.6.5. Maintain FLEX strategies in overall FLEX basis Complete documents.

6. Modify existing plant configuration control procedures Complete to ensure that changes to the plant design, physical plant layouts, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06 Section 11 .8.7. Complete applicable training prior to the Complete (Unit 2)implementation of FLEX. Started (Unit 1)8. Complete construction of FLEX Equipment Storage Complete Building prior to the implementation of FLEX.9. Develop BSEP procedures and programs to address Complete storage structure requirements, deployment path requirements, and FLEX equipment requirements relative to the hazards applicable to BSEP. _______________

10. Design FLEX equipment connection points (e.g. Complete mechanical, pneumatic, and electrical) to withstand the applicable external hazards.11. Perform study to validate Suppression Pool Complete temperatures exceeding 220°F.12. Develop site specific procedures or guidelines, Complete (Unit 2)utilizing the industry developed guidance from the Started (Unit 1)Owners' Groups, EPRI, and NEI Task team, to address the criteria in NEI 12-06.13. Deleted Deleted 14. Complete SFP level instrumentation modifications per Complete (Unit 2)NRC Order EA 12-051, Issuance of Order to Modify Started (Unit 1)Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

_______________

Page 6 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)

.... Overall lIntegrated Plan 0pen Item ..... IStatus*Indicates a change since last 6 month update.15. Develop deep load-shedding procedures to extend Delete coping time for station batteries.

2nd 6-month update change #7.Deep load shedding procedures are not required.

Load shedding activities are contained in SBO-1 0.16. Modify procedures such that operator manual actions, Complete (Unit 2)in areas where habitability is a concern, occur early in Started (Unit 1)the FLEX timeline, to the extent practical.

17. Revise procedures to open Reactor Building doors to Complete (Unit 2)provide a natural air circulation path. *Complete (Unit 1)18. Provide transportation equipment to move large Complete skids/trailer-mounted equipment provided from off-site.19. Review generic BWROG analysis of FLEX Complete implementation and perform station-specific analysis (NEDC 33771 P, Revision 1).20. Develop a process/methodology to rupture the Complete (Unit 2)Wetwell Vent Disc with Containment pressure below *Complete (Unit 1)55 psi.21. Develop a process/methodology to provide Clean Complete (Unit 2)Water Makeup to the CST during Phase 3 response.

Started (Unit 1)22. Develop guidance for obtaining local vital indications Complete (Unit 2)during a loss of DC in conjunction with an ELAP. This Started (Unit 1)strategy will be available for appropriate plant personnel use in response to these failures.23. Provide justification showing the Unit 1 CST and Complete Unit 2 CST are robust from applicable external hazards.24. Develop a DC power coping analysis lAW IEEE-485 Complete and establish an appropriate coping time for FLEX response._______________

Table 6b. Open Items added after July 28, 2015...... oie~rall lntegrated Plan Open item I

• Status No new open items durnn this sixth update period.Page 7 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049) 7 References The following references support updates to the Overall Integrated Plan as described in this enclosure.

1. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013, Agencywide Documents Access and Management System (ADAMS)Accession Number ML13071A559

2. 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 20, 2013, ADAMS Accession Number ML13248A447

3. 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, ADAMS Accession Number ML14073A451

4. 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 (Order Number EA- 12-049), dated August 28, 2014, ADAMS Accession Number ML14254A176

5. 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, ADAMS Accession Number ML15084A156

6. Duke Energy Letter, 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), dated August 26, 2015, ADAMS Accession Number ML15246A034

7. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS Accession Number ML15173A013

8. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, ADAMS Accession Number ML12054A735

9. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12229A174

10. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ADAMS Accession Number ML12242A378

11. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Page 8 of 9 SIXTHr SI-ONHSTTSmEORbOREeNME EA-12-049),dtdOtbr2,21,A MScesinNm r Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012, ADAMS Accession Number ML1 2307A021 4 Page 9 of 9