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{{Adams
#REDIRECT [[CNS-15-008, 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)]]
| number = ML15061A124
| issue date = 02/26/2015
| title = Catawba, Units 1 and 2 - 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)
| author name = Henderson K
| author affiliation = Duke Energy Carolinas, LLC, Duke Energy Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000413, 05000414
| license number = NPF-035, NPF-052
| contact person =
| case reference number = CNS-15-008, EA-12-049
| document type = Letter
| page count = 21
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:Kelvin HendersonDUKE Vice PresidentENERGY, Catawba Nuclear StationDuke EnergyCN01VP I 4800 Concord RoadYork, SC 29745o: 803.701.4251f: 803.701.3221CNS-15-008 10 CFR 50.4February 26, 2015ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555Duke Energy Carolina, LLC (Duke Energy)Catawba Nuclear Station, Units 1 and 2Docket Numbers 50-413 and 50-414Renewed License Numbers NPF-35 and NPF-52
 
==Subject:==
Fourth Six-Month Status Report in Response to March 12, 2012 Commission OrderModifying Licenses With Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049)
 
==References:==
: 1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Order ModifyingLicenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated March 12, 2012, (ADAMS Accession No.ML12054A735).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 forBeyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ADAMSAccession No. ML12229A174).3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378).4. Duke Energy's Initial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated October 29, 2012 (ADAMSAccession No. ML12307A023).5. Catawba Nuclear Station Overall Integrated Plan in Response to March 12, 2012,Commission Order to Modify Licenses With Regard To Requirements for MitigationStrategies for Beyond Design Basis External Events (Order EA-12-049), dated February28, 2013 (ADAMS Accession No. ML1 3066A1 73).Ladies and Gentlemen,On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049(Reference 1) to Duke Energy. Reference 1 was immediately effective and directs Duke Energyto develop, implement, and maintain guidance and strategies to maintain or restore core4-6 1 United States Regulatory CommissionPage 2February 26, 2015cooling, 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 thefinal interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant toSection IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06,Revision 0 (Reference 3) with clarification and exceptions identified in Reference 2. Reference 4provided the initial status report regarding mitigation strategies at the Oconee, McGuire andCatawba Nuclear Stations. Reference 5 provided the Catawba OIP.Reference 1 requires submission of a status report at six-month intervals following submittal ofthe overall integrated plan. Reference 3 provides direction regarding the content of the statusreports.The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV,Condition C.2, of Reference 1. The attached report provides an update of milestoneaccomplishments 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 and no revision to existing RegulatoryCommitments.Should you have any questions regarding this submittal, please contact Phil Barrett at (803)701-4138.I declare under penalty of perjury that the foregoing is true and correct. Executed on February26, 2015.Sincerely,Kelvin HendersonVice President, Catawba Nuclear Station
 
==Enclosure:==
Fourth Six-Month Status Report in Response (Order EA-12-049), Catawba Nuclear Station(CNS), Units 1 and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 andNPF-52 United States Regulatory CommissionPage 3February 26, 2015xc:V.M. McCree, Regional AdministratorU. S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, GA 30303-1257W. M. Dean, Director, Office of Nuclear Reactor RegulationUS. Nuclear Regulatory CommissionOne White Flint North, Mailstop 13-HI6M11555 Rockville PikeRockville, MD 20852-2738G.E. MillerU.S. Nuclear Regulatory CommissionOne White Flint North, Mailstop 8 G9A11555 Rockville PikeRockville, MD 20852-2738G.A. HuttoNRC Senior ResidentCatawba Nuclear StationJustin FolkweinAmerican Nuclear Insurers95 Glastonbury Blvd., Suite 300Glastonbury, CT 06033-4453 ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)ENCLOSUREFOURTH SIX MONTH STATUS REPORT (ORDER EA-12-049)CATAWBA NUCLEAR STATION (CNS), UNITS 1 AND 2DOCKET NOS. 50-413 AND 50-414RENEWED LICENSE NOS. NPF-35 AND NPF-52Page 1 ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 21 IntroductionCatawba Nuclear Station (CNS) developed an Overall Integrated Plan (Reference 1 in Section 8),documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049(Reference 2 in Section 8). The Overall Integrated Plan (OIP) was submitted to the NRC onFebruary 28, 2013. This enclosure provides an update of milestone accomplishments includingany changes to the compliance method, schedule, or need for relief/relaxation and the basis, ifany, that occurred during the period from July 29, 2014 to January 28, 2015 (hereafter referred toas "the update period").2 Milestone AccomplishmentsThe following milestones were completed during the update period:1) Third Six-Month Status Report for Catawba Nuclear Station, Units 1 and 2 wassubmitted on August 28, 2014.2) Phase II Staffing Study per NEI 12-01 submitted to the NRC on October 28, 2014.3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the Overall Integrated Plan. It provides theactivity status of each item, and whether the expected completion date has changed from thatstated in Attachment 2 of the OIP. The dates are planning dates subject to change as designand implementation details are developed.The revised milestone target completion dates are not expected to impact the orderimplementation date.Submit 60 Day Initial Status ReportOct 2012Completeuate NOtRevisedSubmit Overall Integrated Plan Feb 2013 Complete Date NotRevisedFirst 6 Month Status Update Aug 2013 Complete Date NotRevisedSecond 6 Month Status Update Feb 2014 Complete Date NotRevisedThird 6 Month Status Update Aug 2014 Complete Date NotRevised ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 3Fourth 6 Month Status UpdateFeb 2015StartedDate NotRevisedDevelop Engineering Changes (ECs) Jan 2015 Started Date RevisedDevelop Strategies Feb 2015 Started Date RevisedPurchase Equipment Feb 2015 Started Date RevisedDevelop Equipment PMs Feb 2015 Started Date RevisedFeb 2015 (U2)Develop Guidelines Started Date RevisedOct 2015 (Ul)Develop Training Feb 2015 Started Date RevisedDate NotImplement Training May 2015 Started ReviseRevisedDate NotStaffing 12-01 Phase II Nov 2014 Complete RevisedDate NotCommunications Integrated Plan May 2015 Started ReviseRevisedDate NotEC Implementation (On-Line) May 2015 Started ReviseRevisedUnit 1 EC Implementation (1EOC22) Dec 2015 Not Started Date RevisedUnit 2 EC Implementation (2EOC20) Mar 2015 Started Date RevisedDate NotSite Implementation Complete Dec 2015 Not Started ReviseRevisedSAFER National Response Centers Date NotOperational Feb 2015 Started Revised ENCLOSURE Page 4CNS Fourth Sixth Month Status Report (Order EA-12-049)4 Changes to Compliance MethodThe following summarizes the changes to the compliance method or strategies as documentedin the Overall Integrated Plan (Reference 1 in Section 8) or previous 6 Month Updates(References 3, 4, and 5 in Section 8). These changes do not impact Catawba Nuclear Stationscompliance with NEI 12-06.1) Changqe: All references to the Regional Response Center (RRC) in the OIP shall now becalled the National SAFER Response Center (NSRC). Further designation can be NSRC-M for the Memphis location and NSRC-P for the Phoenix location.Justification: Industry/Utility groups decided to rename the Regional Response Centersand all involved parties agreed upon the change.Documentation: Reference 9/11/14 letter from Joseph E. Pollack, NEI, to Jack R. Davis,NRC/NRR regarding National SAFER Response Center Operational Status (ADAMSAccession No. ML14259A222) and White Paper on National SAFER Response Center(ADAMS Accession No. ML14259A223)2) Change: Line Item 12 on Page 7 of 94 in the OIP states that a portable diesel drivenpump should be aligned to the Nuclear Service Water (RN) system in 10 hours to providelong term makeup for the Spent Fuel Pool (SFP) and Steam Generators (S/Gs). Based onfurther analysis, it is not necessary to have the RN system filled and pressurized for atleast 40 hours to support SFP makeup.Justification: Based on the available water supply in the seismically robust CondenserCooling Water (RC) system, the Turbine Driven Auxiliary Feedwater Pump can feed theS/Gs with the RC water source for at least 5 days on Unit 1 and for at least 8 days on Unit2. RN makeup to the SFP is not required for 40 hours to maintain at least 10 feet of waterabove the top of the fuel assemblies based on worst case evaporation rates in the SFP.Documentation: Reference Appendix L in Report No. 030321.13.01-001, Rev. 1 (SeismicRobustness Review Of Catawba Unit 1 Non-Safety Piping And Components For DiverseAnd Flexible Mitigation Strategies (Flex) dated January 2014, Westinghouse calculationCN-SEE-II-13-22 (Catawba Nuclear Station FLEX Alternate Cooling Evaluation InputAuxiliary Feedwater Usage) dated 7/23/14, and email from Darrell Davies to JordanPenley dated 5/21/14 with subject line "RE: Catawba ELAP".3) Change: Line Item 19 on Page 7 of 94 and the Phase 1 Containment discussion on Page35 of 94 in the OIP states that containment pressure remains below design limits for atleast 72 hours. The final containment analysis for Catawba determined that containmentpressures actually exceed design pressure about 52 hours into the event (15 psig designand 17.5 psig at 52 hours).Justification: An evaluation of the containment structure and associated penetrations wasperformed and it was determined that no significant issues exist when containmentpressures reach 17.5 psigDocumentation: Open Item 94.
ENCLOSURE Page 5CNS Fourth Sixth Month Status Report (Order EA-12-049)4) Change: Line Items 20 and 21 on Page 7 of 94, the Phase 2 Containment discussionstarting on Page 37 of 94, the Phase 3 Containment discussion starting on Page 41 of 94,Action Item 26 and 27 on Page 71 of 94, Portable Pump Supply to Containment Spray SitePlan drawing on Page 81 of 94, Open Items 21 and 22 on Page 91 of 94, and Open Item42 on Page 92 of 94 in the OIP all deal with using Containment Spray fortemperature/pressure control. Containment Spray will no longer be used forpressure/temperature control based on the latest containment analysis.Justification: Due to concerns with not having enough containment spray capabilities (flowrates and pressures from the portable pumps) to provide adequate pressure/temperaturecontrol and the fact that the containment spray water would add to flooding issues insidecontainment, a different containment pressure/temperature control strategy wasdeveloped. The new strategy makes use of the Hydrogen Skimmer, Containment AirReturn, and Lower Containment ventilation fans to provide the necessary temperature andpressure controls until Residual Heat Removal strategies are put in service.Documentation: Reference Rev. 2 of DPC-1 552.08-00-0280 (Extended Loss of AC Power(ELAP) -Ice Condenser Containment Response with FLEX Mitigation Strategies).5) Change: The last paragraph under Item 3 on Page 9 of 94 in the OIP states that the50.54(hh)(2) (B.5.b) pump is credited in the FLEX mitigating strategies and that this pumpwill be moved into one of the new FLEX storage facilities that also meets all 50.54(hh)(2)requirements. The B.5.b pump is no longer being credited in the Flex mitigationstrategies.Justification: Additional pumps and equipment have been purchased to support all therequirements for the Flex mitigation strategies. As such, use of the B.5.b pump is nolonger necessary.Documentation: Reference Flex mitigation strategies in the Emergency OperatingProcedures, Abnormal Operating Procedures, and Flex Support Guidelines. Open Items37 and 53.6) Change: There are a number of references to the RRC Playbook throughout the OIP (seePages 3, 12, 23, and 92 of 94). This document is now referred to as the SAFERResponse Plan for Catawba Nuclear Station.Justification: Reference Rev. 001 of the SAFER Response Plan for Catawba NuclearStation approved on 1/29/15.Documentation: Open Item 55.
ENCLOSURE Page 6CNS Fourth Sixth Month Status Report (Order EA-12-049)7) Change: The wording related to the Alternate Power Distribution strategy mentioned onPage 16 and 55 in the OIP needs to be clarified as follows: Wording on Page 16 and 55should say "If normal power supplies are not available, they will be disconnected to allowconnection of alternate supply cables. A quantity of alternate supply cables will beavailable to replace the Flex power supplies normally provided to a common plant area. Ifnecessary, alternate supply cables can be connected at the portable diesel generator.Procedural guidelines will direct these activities (Open Item 58)".Justification: The existing wording in the OIP for the Alternate Power Distribution strategycan be interpreted a number of different ways. As such, the wording has been revised toprovide a little more clarification. Specific actions related to the Alternate Power strategywill be contained in the associated procedures.Documentation: Open Item 58.8) Change: Per discussion with CNS and MNS Engineering, Safety Analysis, Westinghouse,and MPR it was determined that a new pressure breakdown orifice will be required in eachof the Reactor Coolant Pump (RCP) No.1 seal leak off lines, upstream of the existing floworifice. Westinghouse has conservatively provided an assumed worst case pressure of2045 psia at the No.1 seal outlet following an Extended Loss of All AC Power (ELAP)event. The new pressure breakdown orifice is needed to prevent damage/degradation tothe existing flow orifice because of excessive delta P. Additional piping stress and supportanalysis will also be performed once the new temperature/pressure profile is determined toensure all of the associated seal leak off line components retain their pressure boundaryfunction.Justification: All of the analyses related to an ELAP assume the leak rate from the RCPNo. 1 seal is 21 gpm or less. To ensure this assumption remains valid, a new pressurebreakdown orifice needs to be installed in the RCP No. 1 seal leak off line for each pumpto lower pressures enough such that downstream components do not fail and create thepossibility for leak rates greater than 21 gpm.Documentation: Open Item 96.5 Need for Relief/Relaxation and Basis for the Relief/RelaxationCNS expects to comply with the order implementation date and no relief/relaxation is required atthis time.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 76. Open ItemsThe following tables provide a summary status of the Open Items. The table under Section 6.a.provides the Open Items identified in Attachment 5 of the original OIP submitted on February28, 2013 and in the first, second, and third six month status reports (References 1, 3, 4, and 5 inSection 8). The table under Section 6.b. provides a list of Open Items that were added afterJuly 28, 2014. The table under 6.c. provides a list of Open Items related to the Interim StaffEvaluation (ISE). The table under 6.d. provides a list of Confirmatory Items related to theInterim Staff Evaluation (ISE).a. Open Items Documented in the Overall Integrated Plan, the First Six Month StatusReport, the Second Six Month Status Report, and the Third Six Month Status Report.Item Overall Integrated Plan Open Item StatusDisconnect all non-critical loads from vital batteries. Activity to Complete1 be validated in conjunction with associated procedure changes.See Corrective Action 25 in PIP C-12-2291.Provide pumping capacity to control level in TDAFWP pit sump. CompleteAdditional analysis required to verify adequate pump headexists to overcome potential Turbine Building flooding. SeeCorrective Action 26 in PIP C-12-2291.Provide pumping capacity to control level in TDAFWP pit sump. Started3 Activity to be validated in conjunction with associatedprocedure changes. See Corrective Action 27 in PIP C-12-2291.Recharge communication system and satellite phone system. Started4 Activity to be validated in conjunction with associatedprocedure changes. See Corrective Action 28 in PIP C-12-2291.Align charging to Channel A and D Vital Batteries. Activity to Started5 be validated in conjunction with associated procedure changes.See Corrective Action 29 in PIP C-12-2291.Align portable injection pump from Refueling Water Storage StartedTank to Safety Injection System to provide Reactor CoolantSystem makeup and boration. Approximate time suggested by6 PWROG to provide negative reactivity addition and maintainmargin to criticality. Site specific analysis will need to beperformed to establish actual time. See Corrective Action 30 inPIP C-12-2291.Align portable injection pump from Refueling Water Storage StartedTank to Safety Injection System to provide Reactor Coolant7 System makeup and boration. Activity to be validated inconjunction with associated procedure changes. SeeCorrective Action 31 in PIP C-1 2-2291.Provide portable lighting (beyond head and hand lamps and Startedinstalled battery lighting). Activity to be validated in conjunction8 with associated procedure changes. See Corrective Action 32in PIP C-12-2291.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 8Item Overall Integrated Plan Open Item StatusInstall portable fans in Control Room and Battery Rooms. Time Startedbased on engineering judgment. Analysis will determine theneed and timing for ventilation. See Corrective Action 33 in PIPC-12-2291.Install portable fans in Control Room and battery rooms. Started10 Activity to be validated in conjunction with associatedprocedure changes. See Corrective Action 34 in PIP C-12-2291.Connect diesel driven Hale Pump through Essential Service StartedWater piping to Spent Fuel Pool skimmer loop to provide ameans to make up to the SFP without entering the SFP area.Activity to be validated in conjunction with associatedprocedure changes. See Corrective Action 35 in PIP C-12-2291.Open Spent Fuel Pool bay doors. Activity to be validated in Started12 conjunction with associated procedure changes. SeeCorrective Action 36 in PIP C-12-2291.Align diesel driven Hale Pump to supply Essential Service Started13 Water supply header from UHS. Activity to be validated inconjunction with associated procedure changes. SeeCorrective Action 37 in PIP C-12-2291.Align diesel driven Hale Pump to supply second diesel driven Started14 Hale Pump to feed SGs. Activity to be validated in conjunctionwith associated procedure changes. See Corrective Action 38in PIP C-12-2291.Re-power H2 igniters. Activity to be validated in conjunction Started15 with associated procedure changes. See Corrective Action 39in PIP C-12-2291.Align charging to Channel B and C Vital Batteries. Activity to Started16 be validated in conjunction with associated procedure changes.See Corrective Action 40 in PIP C-12-2291.17 Isolate the Cold Leg Accumulators. Activity to be validated in Startedconjunction with associated procedure changes. SeeCorrective Action 41 in PIP C-1 2-2291.18 Evaluate need to provide freeze protection for instrumentation Not Startedlocated in Doghouses and yard. 48 hours is based onengineering judgment. Evaluation will be performed todetermine actual action time. See Corrective Action 42 in PIPC-12-2291.19 Evaluate need to provide freeze protection for instrumentation Not Startedlocated in Doghouses and yard. Activity to be validated inconjunction with associated procedure changes. SeeCorrective Action 43 in PIP C-12-2291.20 Isolate Instrument Air to Containment. Activity to be validated Startedin conjunction with associated procedure changes. SeeCorrective Action 44 in PIP C-12-2291.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 9Item Overall Integrated Plan Open Item Status21 Align portable diesel driven Hale Pump to Containment Spray Startedconnection. Contingency to be available if required to reduceContainment temperature. Modification of an existing B.5.bStrategy. Activity to be validated in conjunction withassociated procedure changes. See Corrective Action 45 inPIP C-12-2291.22 Align RRC diesel generator to power installed Containment StartedSpray pumps. Activity to be validated in conjunction withassociated procedure changes. See Corrective Action 46 inPIP C-12-2291.23 Arrangements with local transportation businesses and StartedRegional Response Centers will need to be established toensure personnel and equipment can reach the siteconsidering extensive damage to surrounding infrastructure(roads, bridges, etc.). See Corrective Action 47 in PIP C-12-2291.24 Additional sump pumps need to be specified, purchased, and Startedplaced in critical rooms and floor elevations in the Auxiliarybuilding to mitigate/control internal flooding. See CorrectiveAction 48 in PIP C-12-2291.25 Develop adequate procedural and administrative guidance to Startedimplement mitigation strategies and supporting activitiesduring Phase 1, 2, and 3. See Corrective Action 49 in PIP C-12-2291.26 Provide S/G Makeup via CA TDP with static RC/RN suction Startedsupply -Procedural guidelines and ECR 6139 and 6140. SeeCorrective Action 7 and 19 in PIP C-12-2291.27 A site specific Building Specification will be written that details Startedthe storage facility design requirements and ECR 5979 willdesign and construct the facilities. See Corrective Action 12in PIP C-12-2291.28 Add appropriate FLEX equipment to the site Periodic StartedMaintenance (PM) program. See Corrective Action 50 in PIPC-12-2291.29 Develop a Document for the FLEX program. See Corrective StartedAction 51 in PIP C-12-2291.30 Determine if Engineering Change program documents or Startedchecklists need to be revised to include verification that themodification does not impact the FLEX program. SeeCorrective Action 52 in PIP C-12-2291.31 Develop applicable training programs to support the FLEX Startedstrategies and supporting activities. Training will be providedonce programs are in place. Corrective Action 53 in PIP C-12-2291 has been closed to the Needs and EvaluationDatabase (NED). NED 13-02758 has been initiated andassigned for processing.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 10Item Overall Integrated Plan Open Item Status32 Develop flow model calculations to support the various FLEX Startedstrategies and document the available static water volume inthe RN/CA piping (PIP C-1 2-2291 CA 20).33 Provide RN supply header hose connections in the yard and Startedin the pumphouse for portable pump to fill/pressurize RNsystem -ECR 5976 and 5977. See Corrective Action 9 and 10in PIP C-12-2291.34 Provide primary CA piping connections for S/G Makeup via Startedportable pump (ECR 5980 and 5981). See Corrective Action13 and 14 in PIP C-12-2291.35 Provide MCC cable plug in connections for various loads Started(ECR 6047 and 6048). See Corrective Action 75 and 76 inPIP C-12-2291.36 Provide primary and alternate RCS makeup and injection Startedconnections (ECR 5983 and 5984). See Corrective Action 15and 16 in PIP C-12-2291.37 Purchase high pressure and low pressure RCS injection Startedpumps. See Corrective Action 54 in PIP C-12-2291.38 Provide seismically qualified connection on the FD piping to Startedaccess diesel fuel in safety related underground storage tanks(ECR 5985 and 5988). See Corrective Action 17 and 18 inPIP C-12-2291.39 Purchase portable diesel fuel transfer pump and storage tank. CompleteSee Corrective Action 55 in PIP C-12-2291.40 Provide access road to the SNSWP for the portable diesel Startedpump (ECR 5978). See Corrective Action 11 in PIP C-12-2291.41 An analysis is needed to determine whether or not Startedventing/letdown is required when providing borated waterinjection. See Corrective Action 56 in PIP C-12-2291.42 An analysis is needed to determine if containment spray for Startedtemperature/pressure control is not required over the longterm. See Corrective Action 57 in PIP C-12-2291.43 Provide redundant SFP Level Instruments per NRC Order -StartedEC109413 and 109414. See Corrective Action 4 and 5 in PIPC-12-2205.44 Determine lighting requirements via Corrective Action 31 in CompletePIP C-1 1-6867.45 Determine lighting requirements and implement as needed via StartedCorrective Action 24 in PIP C-12-2291.46 Determine long term environmental conditions in the Control StartedRoom and CA Pump room via Corrective Action 13 in PIP C-11-6867. This evaluation will be part of Corrective Action 33in PIP C-12-2291.47 Ensure that an appropriate inventory of portable hand-held Completesatellite phones, spare batteries, and chargers, is available foruse by the Emergency Response Organization. SeeCorrective Action 7 in PIP C-12-2195.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 11Item Overall Integrated Plan Open Item Status48 Evaluate and purchase, if necessary, additional portable Completeradios, spare batteries, and chargers to ensure requiredcommunications links are fully established. Corrective Action8 in PIP C-12-2195.49 Ensure that portable communications equipment (i.e., satellite Completephones, radios, and diesel generators) are stored in a mannersuch that maximizes survivability from applicable externalevents per NEI 12-01, Section 4.5. Corrective Action 9 in PIPC-12-2195.50 Ensure that programmatic controls are established for Completecommunications equipment (i.e., portable satellite phones,radios, small generators) to ensure availability and reliability,including the performance of periodic inventory checks andoperability testing per NEI 12-01, Section 4.8. Also, providetraining on the locations and use of communications systemsand equipment (NEI 12-01, Section 4.11). Corrective Action10 in PIP C-12-2195.51 Ensure that arrangements are in place with communications Completeservice providers to utilize their emergency services asdescribed in NEI 12-01, Section 4.10. Corrective Action 12 inPIP C-12-2195.Purchase debris removal equipment that is also capable of Complete52 towing all FLEX equipment. See Corrective Action 58 in PIPC-12-2291.53 Provide additional portable FLEX equipment such as pumps, Startedair compressors, and generators to be purchased with specificidentifiers/labels maintained in the Equipment Data Base(EDB). See Corrective Action 59 in PIP C-12-2291.54 Develop periodic surveillance procedures and Operator Startedrounds to verify that all FLEX equipment is in its properstorage location and not degraded. See Corrective Action 60in PIP C-12-2291.55 Develop Regional Response Center Playbook. See StartedCorrective Action 61 in PIP C-1 2-2291.56 Complete staffing studies and ensure adequate personnel will Completebe available to support the FLEX mitigation strategies andassociated activities. See Corrective Action 7 in PIP C-12-4953.57 Develop procedural guidelines to use handheld instruments Startedtied into local in plant components to monitor essentialparameters. See Corrective Action 62 in PIP C-12-2291.58 Develop procedural guidelines to disconnect normal power Startedsupplies and attach alternate power cables from disconnectdevices and portable generators for select components. SeeCorrective Action 63 in PIP C-12-2291.59 Develop procedural guidelines to deploy and install lighting in Startedrequired areas. See Corrective Action 24 in PIP C-12-2291.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 12Item Overall Integrated Plan Open Item Status60 Determine if Phase 3 ventilation needs (RRC equipment, Startedadditional procedural guidelines, etc.) are required. SeeCorrective Action 64 in PIP C-12-2291.61 Determine if Mobile Boration will be required from the RRC Startedduring Phase 3. See Corrective Action 65 in PIP C-12-2291.62 Determine if portable lighting will be required from the RRC Startedduring Phase 3. See Corrective Action 66 in PIP C-12-2291.63 Determine if portable fans/ducting will be required from the StartedRRC during Phase 3. See Corrective Action 67 in PIP C-12-2291.64 Determine Phase 3 requirements related to Radiation StartedProtection Equipment. See Corrective Action 68 in PIP C-12-2291.65 Determine Phase 3 requirements related to Commodities Completesuch as food and water. See Corrective Action 69 in PIP C-12-2291.Calculate diesel fuel consumption rates for the portable FLEX Completeequipment and compare that to the available fuel stored in the66 Emergency Diesel Generator safety related undergroundstorage tanks to determine if additional diesel fuel is neededfrom off-site resources during Phase 3. See Corrective Action70 in PIP C-12-2291.67 Select and purchase Phase 3 debris clearing equipment Startedand/or transport vehicles if needed to move RRC equipmentaround the site. See Corrective Action 71 in PIP C-12-2291.68 Implement Flood mitigation activities per Corrective Action StartedProgram (Ref. PIP C-12-0833).69 Complete initial testing of FLEX mitigation equipment prior to Startedfull implementation dates. See Corrective Action 72 in PIP C-12-2291.70 Establish a Special Emphasis Code in the EDB and Work CompleteControl program for FLEX equipment. See Corrective Action73 in PIP C-12-2291.71 Obtain and store any additional equipment in FLEX Storage StartedFacilities or Category I buildings needed to aid in theconnection of the RRC equipment to plant components. SeeCorrective Action 74 in PIP C-12-2291.72 Revise RP/0/A/5000/007 (Natural Disaster and Earthquake) to Completemove equipment at the SNSWP if flooding is imminent. SeeCorrective Action 79 in PIP C-12-2291.Formally evaluate/document potential deployment route Started73 concerns such as soil liquefaction discussed in NEI 12-06. SeeCorrective Action 86 in PIP C-1 2-2291.Document seismic qualification (robustness in accordance with Started74 NEI 12-06) of assured RN to KF make up piping on Unit 1. SeeCorrective Action 87 in PIP C-12-2291.Add new FWST low/high pressure borated water injection Started75 pump suction connection. See Corrective Action 83 and 84 inPIP C-12-2291 (ECR-6787 and ECR-6788)
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 13Item Overall Integrated Plan Open Item Status76 Evaluate travel paths into the Auxiliary Building through non Startedseismic structures. See Corrective Action 88 in PIP C-12-2291.An analysis is needed to determine if there are any impacts to StartedFLEX strategies due to large internal flooding sources that arenot seismically robust or that require AC power for isolation.The analysis shall also consider the effects of ground waterintrusion during an Extended Loss of All AC Power event. SeeCorrective Action 89 in PIP C-12-2291.A Catawba specific shutdown margin calculation performed in Complete78 accordance with PWROG guidance is required. See CorrectiveAction 90 in PIP C-12-2291.Westinghouse assistance is required to provide additional Started79 information related to seal leakage on the Catawba ReactorCoolant Pumps. See Corrective Action 91 in PIP C-12-2291.The number of Steam Generators and PORVs required for the Started80 Low Pressure portable pump makeup FLEX strategy needs tobe validated and formally documented in a Catawba stationcalculation. See Corrective Action 92 in PIP C-12-2291.Westinghouse assistance is needed to perform thermal Started81 hydraulic analyses to support plant specific decision makingand provide justification for the duration of each phase. SeeCorrective Action 93 in PIP C-12-2291.Additional analyses is needed to evaluate whether containment Startedpenetration seals and other equipment located inside82 containment and used in the mitigation strategies are stillfunctional based on the predicted temperatures and pressuresduring a Fukushima type event. See Corrective Action 94 inPIP C-12-2291.Station controlled documents need to be created to capture Not Started83 vendor reports related to generator machine capabilities topower the designated FLEX loads in Phase 2 and 3. SeeCorrective Action 95 in PIP C-12-2291.Determine if any changes to WPM 602, NSD 403, or any other Completesite/fleet Shutdown/Refueling documents need to be revised to84 comply with the position paper related to Shutdown RiskManagement and Contingency Planning. See CorrectiveAction 96 in PIP C-12-2291.Perform a seismic robustness evaluation of the proposed cable Started85 "backbone" and it's associated components. See CorrectiveAction 97 in PIP C-12-2291.Vendor data and system calculations needed to support FLEX Started86 response strategies involving low speed operation of Turbine-Driven CA (TDCA) Pumps in support of ELAP EOP setpoint0.12 development. See Corrective Action 1 in PIP C-1 3-9158.Due to normal operational input to the TDCA pump pit sump Startedand having both TDCA pumps in simultaneous operation,87 additional portable sump pumps, hoses, and associatedequipment are required. See Corrective Action 15 in PIP C-11-6867.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)Page 14Item Overall Integrated Plan Open Item StatusA calculation is needed to support the validation of the StartedFukushima Phase 3 strategy associated with providing corecooling via the portable pump feeding RN from the SNSWP,powering up one KC pump and one ND pump via the 4160 Volt88 portable generator from the Regional Response Center. Thecalculation should determine whether or not adequate corecooling can be achieved with reduced RN flow rates assumingworst case SNSWP upper temperature limits and core decayheat loads when this Phase 3 strategy is put in service. SeeCorrective Action 98 in PIP C-12-2291.As documented in Actual Corrective Action #8 in PIP C Complete2291, EC110650 (Install New Fire Hydrant Near The SNSWP89 For Flex Buildings & B.5.B) is to be cancelled. Completeactions to finalize cancellation of this Engineering SeeCorrective Action 101 in PIP C-12-2291.Ensure that hard copies of Procedures needed to support EP Startedand AP implementation (and any additional supporting90 procedures identified by FLEX procedures) are accessibleduring a BDBEE causing an Extended Loss of All AC Power(ELAP greater than 4 hrs.). See Corrective Action 102 and 120in PIP C-12-2291.Review DPC-1552.08-00-0278, Appendix C. Determine which Completeoperations procedures perform surveillances of the CLAs boron91 concentrations. Make the necessary revisions using the basisprovided by DPC-1552.08-00-0278, Appendix C. SeeCorrective Action 104 in PIP C-12-2291.Review DPC-1 552.08-00-0278, Appendix C. Determine which Startedchemistry procedures perform surveillances of the CLAs boron92 concentrations. Make the necessary revisions using the basisprovided by DPC-1 552.08-00-0278, Appendix C. SeeCorrective Action 105 and 121 in PIP C-12-2291.Portions of the Flex equipment deployment paths will traverse Startedunder existing power/transmission lines located on site. Assuch, guidance needs to be developed and placed in93 procedures (FSG's) on how to use the deployment path ifpower/transmission lines and/or towers have fallen across thepath. An evaluation on the impact to deployment and mitigationstrategy timelines also needs to be documented. SeeCorrective Action 106 in PIP C-12-2291.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-12-049)b. Open Items added after July 28, 2014.Page 15Item Overall Integrated Plan Open Item StatusNRC Audit question #44 asks about containment pressures Completeduring an ELAP event. Based on the Rev. 2 draft of DPC-1552.08-00-0280 (Extended Loss of AC Power (ELAP) -IceCondenser Containment Response with FLEX Mitigation94 Strategies), containment pressures for Catawba Units 1 and 2will exceed design pressures. Justification for operating abovecontainment design pressures during an ELAP event needs tobe addressed by engineering. See Corrective Action 119 inPIP C-12-2291.Section 1.4 in Attachment 1 of DPC-1 552.08-00-0280 Rev. 2 Startedprovides Catawba specific Containment Acceptance Criteria.Based on results in Rev. 2 of DPC-1552.08-00-0280, thefollowing Acceptance Criteria item could be exceeded for a95 short period of time: 1.4.2 Recovery to less than 212°F in thecontainment cubicles (i.e., SGs and Pzr) prior to RHR operationis desired, but not necessary. This Corrective Action shouldjustify exceeding this Acceptance Criteria limit. See CorrectiveAction 122 in PIP C-12-2291.A new pressure breakdown orifice will be required in each of Startedthe Reactor Coolant Pump (RCP) No.1 seal leak off linesupstream of the existing flow orifice (Ref. ECR 8527). SeeCorrective Action 1 in PIP C-1 5-355.c. Interim Staff Evaluation Open Items (Item Number is associated with the section of theTechnical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)Item Interim Staff Evaluation Open Item StatusResolve the conflict between the need to pump the TDAFW Complete (Ref.3.1.2.2.A pump pit before submergence at 6 hours and deploying NRC SEgenerators to power the sump pumps by 8 hours. See Tracker List)Corrective Action 107 in PIP C-12-2291.Core Sub-Criticality -Confirm resolution of the generic concernassociated with the modeling of the timing and uniformity of the Complete (Ref.3.2.1.8.A mixing of a liquid boric acid solution injected into the reactor DPC-1 552.08-coolant system under natural circulation conditions potentially 00-08)involving two-phase flow. See Corrective Action 108 in PIP C- 00-0278)12-2291.
ENCLOSURECNS Fourth Sixth Month Status Report (Order EA-1 2-049)Page 16d. Interim Staff Evaluation Confirmatory Items (Item Number is associated with the sectionof the Technical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)Item Interim Staff Evaluation Confirmatory Item StatusSeismic Deployment (applicable to all hazards deployment) -since a final location for the building has been selected, formal Complete (Ref.3.1.1.2.A evaluation of potential deployment routes and concerns such NRC SEas soil liquefaction can proceed. Confirm attributes of Nrc sEdeployment routes, including liquefaction potential. SeeCorrective Action 109 in PIP C-12-2291.Procedural Interfaces- Seismic- Confirm completion of3.1.1.3.A evaluation of potential internal Aux Building flooding and Openappropriate actions and procurement of sump pumps. SeeCorrective Action 110 in PIP C-1 2-2291.Reliance on the NOTRUMP code for the ELAP analysis ofWestinghouse plants is limited to the flow conditions prior toreflux condensation initiation. This includes specifying an Complete (Ref.3.2.1.1.A acceptable definition for reflux condensation cooling. Confirm NRC SEthat the NOTRUMP code is used within the accepted limits. Tracker List)See Corrective Action 111 in PIP C-1 2-2291.Westinghouse will be assisting CNS in providing further3.2.1.3.A information regarding decay heat modeling. Evaluate for NRC SEapplicability and implementation. See Corrective Action 112 in Nrc sEPIP C-12-2291. Tracker List)Licensee will confirm that the final containment analysisvalidates that containment spray for temperature/pressure3.2.3.A control is not required over the long term, or will provide Openprocedures to cool the containment. See Corrective Action113 in PIP C-12-2291.Room temperature analyses being performed will provide a3.2.4.1.A better idea of the environmental conditions expected during the Openevent. Confirm completion of analyses and appropriateactions. See Corrective Action 114 in PIP C-12-2291.Evaluations to address the needs for freeze protection are in3.2.4.3.A progress. Confirm completion of evaluations and appropriate Openactions. See Corrective Action 115 in PIP C-12-2291.Confirm evaluations for additional lighting have been3.2.4.4.A completed (licensee's open item 45 and 59), and appropriate Openactions taken. See Corrective Action 116 in PIP C-12-2291.Confirm upgrades to the site's communication systems have Complete (Ref.3.2.4.4. B been completed. See Corrective Action 117 in PIP C-12-2291. NRC SETracker List)Offsite Resources- Confirm NEI 12-06 Section 12.2, Guidelines3.4.A 2 through 10, are addressed with SAFER. See Corrective OpenAction 118 in PIP C-12-2291.
ENCLOSURE Page 17CNS Fourth Sixth Month Status Report (Order EA-12-049)7 Potential Interim Staff Evaluation ImpactsThere are no potential impacts to the Interim Staff Evaluation identified at this time.8 ReferencesThe following references support the updates to the Overall Integrated Plan described in thisattachment.1) Catawba Nuclear Station, Unit Nos. 1 and 2, Overall Integrated Plan in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA-12-049), datedFebruary 28, 2013.2) NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2013.3) First Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.4) Second Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units1 and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.5) Third Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units Iand 2, Docket Nos. 50-413 and 50-414, Renewed License Nos. NPF-35 and NPF-52.6) NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External Events, dated August 29, 2012, 2012 (ADAMS Accession No.ML12229A174).7) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision0, dated August 20128) Duke Energy's Initial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated October 29, 2012, (ADAMSAccession No. ML12307A023).9) Catawba Nuclear Station, Units 1 and 2 -Interim Staff Evaluation Relating To OverallIntegrated Plan In Response To Order EA-1 2-049 (Mitigation Strategies) (Tac Nos. Mf 1162and Mfl 163), Dated February 6, 2014 (ADAMS Accession No. ML13364A173).10) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated September 30, 2013, (ADAMS Accession No. ML13267A382).11) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, ProgramManagement Office Westinghouse Electric Company LLC, October 7, 2013, (ADAMSAccession No. ML13276A555).
ENCLOSURE Page 18CNS Fourth Sixth Month Status Report (Order EA-12-049)12) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, ProgramManagement Office Westinghouse Electric Company LLC, dated January 8, 2014, (ADAMSAccession No. ML13276A183).13) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated October 3, 2013, (ADAMS Accession No. ML13275A318).14) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated September 16, 2013, (ADAMS Accession Nos.: (Pkg.)ML13241A182, (NEI) ML13241A186, (Rsp.) ML13241A188).15) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated October 7, 2013, (ADAMS Accession No.: ML13276A224).}}

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