ML15084A156: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
(3 intermediate revisions by the same user not shown)
Line 1: Line 1:
{{Adams
#REDIRECT [[BSEP 15-0008, 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 = ML15084A156
| issue date = 02/27/2015
| title = Brunswick, Units 1 & 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 = Gideon W R
| author affiliation = Duke Energy Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person =
| case reference number = BSEP 15-0008, EA-12-049
| document type = Letter, Status Report
| page count = 21
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:William R. GideonVice PresidentENERGY. Brunswick Nuclear PlantP.O. Box 10429Southport, NC 28461o: 910.457.3698February 27, 2015Serial: BSEP 15-0008U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==Subject:==
Brunswick Steam Electric Plant, Unit Nos. 1 and 2Renewed Facility Operating License Nos. DPR-71 and DPR-62Docket Nos. 50-325 and 50-324Fourth Six-Month Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA-12-049)
 
==References:==
: 1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance ofOrder to Modify Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events, dated March 12, 2012, AgencywideDocuments Access and Management System (ADAMS) Accession NumberML12054A7352. 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 Number ML12229A1743. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012, ADAMS Accession Number ML12242A3784. Duke Energy Letter, Carolina Power & Light Company and Florida PowerCorporation's Initial Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA- 12-049), datedOctober 29, 2012, ADAMS Accession Number ML12307A0215. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),dated February 28, 2013, ADAMS Accession Number ML13071A5596. Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),dated August 20, 2013, ADAMS Accession Number ML13248A447 U.S. Nuclear Regulatory CommissionPage 2 of 47. Duke Energy Letter, Second Six-Month Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049), dated February 28, 2014, ADAMS Accession Number ML14073A4518. Duke Energy Letter, Third Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),dated August 28, 2014, ADAMS Accession Number ML14254A176Ladies and Gentlemen:On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (i.e.,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 corecooling, 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 (i.e., Reference 2) and an Overall Integrated Plan (OIP) pursuant toSection 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 theBrunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.Reference 1 requires submission of a status report at six-month intervals following submittal ofthe OIP. Reference 3 provides direction regarding the content of the status reports.References 6, 7, and 8 provided the first, second, and third six-month status reportsrespectively, for BSEP.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.If you have any questions regarding this submittal, please contact Mr. Lee Grzeck,Manager -Regulatory Affairs, at (910) 457-2487.
U.S. Nuclear Regulatory CommissionPage 3 of 4I declare under penalty of perjury that the foregoing is true and correct,executed on February 27, 2015.Sincerely,William R. Gideon
 
==Enclosure:==
Fourth Six-Month Status Report in Response to March 12, 2012, CommissionOrder Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA 12 049), BrunswickSteam Electric Plant (BSEP), Unit Nos. 1 and 2 U.S. Nuclear Regulatory CommissionPage 4 of 4cc (with enclosure):U.S. Nuclear Regulatory Commission, Region IIATTN: Mr. Victor M. McCree, Regional Administrator245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257U.S. Nuclear Regulatory CommissionATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738U.S. Nuclear Regulatory CommissionATTN: Mr. Peter Bamford (Mail Stop OWFN 8B3) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory CommissionATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector8470 River RoadSouthport, NC 28461-8869Chair -North Carolina Utilities CommissionP.O. Box 29510Raleigh, NC 27626-0510 ENCLOSUREFOURTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012,COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTSFOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS(ORDER NUMBER EA-12-049)BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNIT NOS. 1 AND 2DOCKET NOS. 50-325 AND 50-324RENEWED LICENSE NOS. DPR-71 AND DPR-62Page 1 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)1 IntroductionBrunswick Steam Electric Plant (BSEP) developed an Overall Integrated Plan (OIP)(Reference 1 of this enclosure), documenting the diverse and flexible strategies (FLEX), inresponse 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 of thisenclosure). The second six-month update was submitted to the NRC on February 28, 2014(Reference 3 of this enclosure). The third six-month update was submitted to the NRC onAugust 28, 2014 (Reference 4 of this enclosure). This enclosure provides an update of milestoneaccomplishments including any changes to the compliance method, schedule, or need forrelief/relaxation and the basis, if any, that occurred during the period between July 28, 2014,andJanuary 28, 2015, hereafter referred to as the "update period."2 Milestone AccomplishmentsThe following milestones were completed during the update period:* Submit Third Six-Month Status Report* SAT process for Training (Unit 2)" Develop Training Plan (Unit 2)* Perform station-specific analysis following generic BWROG FLEX implementationanalysis review* Develop Unit 2 Modification Engineering Change (EC) Packages, including StorageFacility3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the OIP. It provides the activity status of eachitem, and whether the expected completion date has changed. The dates are planning dates andsubject to change as design and implementation details are developed.The revised milestone target completion dates are not expected to impact the Orderimplementation date.Page 2 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)Target RevisedMilestone Completion Activity Status Completion DateDateSubmit 60 Day Status Report 10/29/12 Complete Date Not RevisedSubmit Overall Integrated 2/28/13 Complete Date Not RevisedImplementation PlanSubmit 6 Month Status Report 8/30/13 Complete Date Not RevisedPerform Staffing Analysis Phase 1 11/29/13 Complete Date Not Revisedof NEI 12-01Submit 6 Month Status Report 2/28/14 Complete Date Not RevisedDevelop Unit 2 Modification 3/30/15 Unit 2Engineering Change (EC) Modifications will bePackages, including Storage 3/27/14 *Complete completed and ready toFacility exit RFO B222R1Perform station-specific analysisfollowing generic BWROG FLEX 3/30/14 *Complete *1/31/15implementation analysis review(Open Item 19)*Final Response PlanDevelop Strategies/Contract with provided to SAFERRegional Response Center (RRC) 4/1/14 Started for NSRC responseand is being routedfor approval.Submit 6 Month Status Report 8/29/14 *Complete Date Not RevisedSAT Process for Training (Unit 2) 01/27/14 *Complete 10/31/14*Date Revised toSAT Process for Training (Unit 1) 1/26/15 *Started 06/25/201506/25/201510/31/14Unit 2 Training Plancontinues to be revisedDevelop Training Plan (Unit 2) 07/27/14 *Complete due to large amount ofOperator training in2014.Develop Training Plan (Unit 1) 07/26/15 Not Started Date Not Revised*Indicates a change since last 6 month update.Page 3 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)Target RevisedMilestone Completion Activity Status Completion DateDate02/26/2015Permanent StorageProcure Equipment (Unit 2) 11/27/14 Started Building not availableuntil Middle of January2015Procure Equipment (Unit 1) 11/26/15 Started Date Not RevisedCreate Maintenance Procedures 01/27/15 *Started *03/15/2015(Unit 2)Create Maintenance Procedures 01/26/16 Not Started Date Not Revised(Unit 1)Procedure Changes incorporating 01/27/15 Started *03/15/2015response strategies (Unit 2)Procedure Changes incorporating 01/26/16 Not Started Date Not Revisedresponse strategies (Unit 1)Implement Training (Unit 2) 02/27/15 Started Date Not RevisedSubmit 6 Month Status Report 2/27/15 *Started Date Not RevisedOutage Start DateUnit 2 Implementation Outage March 2015 Not Started moved up toFebruary 2015Implement Modifications (Unit 2) April 2015 *Started Date Not RevisedSubmit Completion Report (Unit 2) April 2015 Not Started Date Not RevisedDevelop Unit 1 Modification EC 3/26/15 *Started Date Not RevisedPackagesSubmit 6 Month Status Report 8/31/15 Not Started Date Not RevisedImplement Training (Unit 1) 02/26/16 Not Started Date Not RevisedSubmit 6 Month Status Report 2/29/16 Not Started Date Not RevisedUnit 1 Implementation Outage March 2016 Not Started Date Not RevisedImplement Modifications (Unit 1) April 2016 Not Started Date Not RevisedSubmit Completion Report (Unit 1) April 2016 Not Started Date Not RevisedSubmit 6 Month Status Report 8/31/16 Not Started Date Not Revised*Indicates a change since last 6 month update.Page 4 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)4 Changes to Compliance MethodThe following summarizes changes that were made during the fourth update period to thestrategies as documented in the OIP (Reference 1 of this enclosure) or the changes that wereprovided by Reference 2, 3 & 4 of this enclosure. These changes do not impact BSEP'scompliance with NEI 12-06.1) Change: Brunswick Nuclear Plant (BNP) identified a change in the second 6 month update(Change # 4) where the planned utilization of the SAMA Diesel Generators was not feasibleand BNP would be pre-staging the FLEX Diesel Generators (DGs) within a new FLEX DieselGenerator Building. The FLEX Diesel Generators are permanently pre-staged in a qualifiedstructure located on top of the existing Emergency Diesel Generator 4-day tank roof and assuch, are not portable. During the on-site audit, the NRC concluded that the pre-staging of theFLEX DGs is an alternative approach to NEI 12-06 which describes the use of portableequipment.Justification:The use of pre-staged FLEX DGs allows re-energizing the critical plant electrical loads morequickly and efficiently than the use of portable generators that would have to be transferredfrom the Permanent FLEX Storage Building. This mitigation strategy constitutes analternative approach to NEI 12-06 guidance and is acceptable because the FLEX DGs arestored in a robust structure designed to adequately withstand all external events that has anaccess path that will be clear after the initiating event. Although the pre-staged FLEX DGsare not portable as discussed in NEI 12-06, the overall strategy has advantages that outweighthe lack of portability of the FLEX DGs. The FLEX DGs have been pre-staged to provide asignificant reduction in the amount of large portable equipment required to be transported andsetup in the first hours following a beyond-design-basis external event over other strategiesthat were evaluated. The strategy also minimizes risk by utilizing robust equipment that islocated within a robust structure that is adequately protected from all external events. Theopportunity to improve response times, simplify required manual actions, and to utilize robustequipment in robust locations justifies the consideration of this alternative strategy. A moredetailed justification is provided in the position paper that has been provided to the staff.Documentation: Full discussion of the FLEX Diesel Generators and the FLEX DieselGenerator Building is documented in EC's 90388, 90389 and 90390.2) Change: The following clarifications are made to the Sequence of Events TimelineConstraints as documented in the OIP and six-month update reports.a. Added New Action Item 3 at time 0.50 hours to Open Control Room back panel doorsif Control Room ventilation is not in service.b. Changed Old Action Item 3 to New Action Item 4.c. Added New Action Item 5 to align Reactor Core Isolation Cooling (RCIC) suction toTorus.d. Change Old Action Item 4 to New Action Item 6 for starting FLEX DG or Battery LoadShedding completed within 1 hour.e. Changed Old Action Item 5 to New Action Item 7 to establish FLEX DG loaded to Div IIBattery Chargers within 2 hours.f. Changed Old Action Item 7 to New Action Item 8 to realign RCIC to CondensateStorage Tank (CST) and revised time line based on Modular Accident AnalysisProgram (MAAP) analysis.g. Changed Old Action Item 6 to New Action Item 9.h. Deleted Old Action Item 8, (Align SAMA diesel generator to 480 VAC to power MOV'sPage 5 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)with critical load being 24/48 VDC Battery Chargers).i. Added New Action Item 10 to establish Battery Room Ventilation or Open BatteryRoom doors.j. Added New Action Item 11 to refuel FLEX equipment.k. Changed Old Action Item 9 to New Action Item 12 and revised time line based onMAAP analysis.I. Added New Action Item 13 to establish long term Pneumatic supply for safety reliefvalves (SRVs) and hardened wetwell vent (HWWV).m. Added New Action Item 14 to Establish makeup capability to CST's.n. Changed Old Action Item 10 to New Action Item 15 and revised time line based oncalculation OFLEX-0001.o. Deleted Old Action Item 11, Transition from Phase 2 to Phase 3.Justification:a) This action is an existing requirement for Station Blackout Response at Brunswick.b) Changed order of action items to accommodate additional timed responses.c) RCIC normally aligned to CST by transferring to Torus while Torus temperature isbelow 190'F extends coping time for CST volume. (Included in MAAP analysis.)d) Changed from SAMA DG to FLEX DG due to problems with qualifications of SAMAequipment and connections. FLEX DG qualifications documented in EC 90388, 90389and 90390.e) Changed order of action items to accommodate additional timed responses.f) Old action item 7 discussed changing RCIC to clean water tank but the CST has beenqualified and RCIC suction will be transferred back to the CST.g) Changed order of action items to accommodate additional timed responses.h) Old Action Item 8 was developed based on NRC Order EA-12-050 which has beensuperseded by NRC Order EA-13-109 this action will not be required until weimplement EA-13-109.i) Action Item added to ensure hydrogen buildup from battery charging does not reachan explosive mixture.j) Added new Action Item 11 since this action will be required within the first 24 hours.k) Changed order of action items to accommodate additional timed responses.I) Added as a sequence of events due to the need to setup equipment at time 20 hours.Strategy may not be required but equipment should be in the field ready to support.m) Makeup water to CST will be required at approximately 52 hours based on MAAPanalysis of event response.n) Changed order of action items to accommodate additional timed responses.o) Deleted Old Action Item because no FLEX strategies require a transition from phase 2to phase 3 within 72 hours.Documentation: See Attachment 1 to this update. New Timeline will be included in FinalImplementation Plan.3) Change: Change table for BWR Portable Equipment phase 2.a. Change electric fuel oil transfer pump to diesel driven fuel oil transfer pumpb. Change Radiation Protection Equipment to not required.Justification:a) Diesel-driven fuel oil transfer pump same as phase 3 equipment obtained to keepresponse for phase 2 and phase 3 consistent.b) Evaluation completed with site radiation protection (RP) organization and no additionalPage 6 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)RP equipment identified as being required.Documentation: Final table will be included in the Final Integrated Plan.4) Change: Change table for BWR Portable Equipment Phase 3.a. Change 3 to 4 MWe 4160 VAC generator to 500 KWe 480 VAC generatorb. Delete diesel fuel requiredc. Delete 4160 VAC transformersd. Delete 480 VAC transformerse. Delete water purification skidf. Delete large heat exchangersg. Delete fresh water tankersh. Delete battery chargers for 125 V DCi. Delete water removal and storagej. Delete temporary housingk. Delete portable ventilation fansJustification:a) Determined need for FLEX strategy was a 480 VAC generator and not a 4160 VACgenerator.b) Development of SAFER response determined fuel oil would not be delivered.c) No 4160 VAC transformers require use of 480 VAC generator.d) No 480 VAC transformers required as connections for phase 3 generator are built intothe FLEX distribution system.e) Determined purification skid not feasible, makeup to CST established through a tieredapproach with Demineralized Water Tank, Fire Protection Tank, Offsite Capability (i.e.,water trucks) and Discharge Canal.f) Heat exchangers determined to be a recovery action and not a coping action.g) Fresh water tankers not available from SAFER.h) Alternate battery chargers not required to support flex strategy response.i) No identified need for water removal and storage associated with flex strategies.j) No housing needs identified for coping strategies.k) No ventilation fans identified for phase 3 response.Documentation: Final table will be included in the Final Integrated Plan. For change item 4.e,see Change to Compliance Method change item 5.5) Change: Guidance has been developed for a long-term makeup water strategy using a tieredapproach.Justification:The strategy for water supply to the reactor and the spent fuel pool uses a tiered approach tosupply water in order of preference based on its purity, temperature, and supply volume. Theinitial makeup to the RPV is from the CST until the early transfer to the suppression pool (SP).Since decay heat removal during an extended loss of AC power (ELAP) is via safety-reliefvalve (SRV) discharge to the SP, this strategy maximizes the time during which no outsidemakeup source of water is required. The limiting factor in this configuration is the required netpositive suction head (NPSH) for the RCIC pump as well as the potential for RCIC pump sealPage 7 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)leakage. BNP RCIC analysis indicated that there is no concern for NPSH with SPtemperature less than 193°F (Reference 1, Page 9). BWROG documents indicate that noRCIC seal leakage is expected for suction temperatures less than 190°F (Reference 2, Page9). The Modular Accident Analysis Program (MAAP) analysis of BNP-MECH-002 (Reference3, Page 9) indicates that the SP heats up to 190°F in about 2 hours. Once the SPtemperature reaches 1900F, RCIC suction is realigned to the CST. The MAAP analysisfurther calculates that RCIC uses 375,000 gallons, likely making the CST empty or nearly so,in about 52 hours after event initiation. This gives adequate time to establish CST makeup.If an ELAP occurs, part of the response in the first few hours will be to call for outside CSTmakeup in order to ensure this water arrives before the CST is depleted. Initially however,installed station tanks that have survived the initiating event will be used. Long term outsidemakeup is via clean water trucks as a preferred source and from the discharge canal if watertrucks are not available in time. The Emergency Response Organization will determine whatwater is available and will take steps to put the various sources in service in the followingorder of preference:1. Suppression Pool with temperature below 1900F.2. Condensate Storage Tanks (Unit 1 and Unit 2 CSTs can be cross-tied)3. Demineralized Water Tank (MUD)4. Fire Protection Tank5. Water trucks6. Discharge CanalFor the water truck strategy, portable tanks will be set up in the parking lot east of the TACbuilding. Hoses, fittings, and pumps will be available from the NSRC or, if available, in theFLEX building, to pump this water from the portable tanks to the CSTs. The water trucks willbe routed through the parking lot to empty their water into these portable tanks as needed.For the discharge canal strategy, the NSRC pumps, strainer, hoses and fittings will beavailable to pump water from the canal to the CSTs of both units.As part of the makeup water strategy, consideration was given for the implications of injectingraw water into the reactor pressure vessel, which occurs if either the truck method ordischarge canal is used. BWROG documents (Reference 4, Page 9) and the EPRI TechnicalBasis document (Reference 5, Page 9) provide the basis for the expectation that raw waterwill adequately cool the core. However, in accordance with the BWROG document, steps inthe EOPs or SAGs that direct injection of raw water also provide guidance that the water levelin the RPV should be maintained at the level of the moisture separator drains. This willensure core cooling in the case that the flow orifices and debris filters at the bottom of thecore become clogged (Reference 6, Page 9).In order to ensure that the NSRC pumps are able to supply water from the discharge canal tothe CSTs, the capacity of the NSRC pumps was compared to the existing calculation verifyingthat the station's EDMG pump can supply water from the discharge canal to the CST.Calculation BNP-MECH-B5B (Reference 7, below) analyzed the station's B.5.b pumpcapacity. In this calculation, the pump is assumed to have a capacity of 500 gpm at 250 psigwith a suction lift of 21 feet. This capacity was used in the flow model that analyzed the headPage 8 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)loss in the hoses, fittings and connections for various modes of operation and demonstratedsufficient capacity of the B.5.b pump.Reference 8 below states that the Low Pressure / Medium Flow portable pump supplied bythe NSRC is rated for 300 psi at 2500 gpm and that the suction lift pump will be capable ofsupplying 5000 gpm with 26 feet of lift to the Low Pressure / Medium flow pump. Reference 7(below) shows that only 21 feet of lift is required to pump from the discharge canal. Since theNSRC pumps are rated for higher pressure, flow and suction lift than the EDMG pump, it isassured that they will be capable of providing more flow to the CST and SFP than the B.5.Bpump and no further analysis is required.
 
==References:==
: 1. Calculation 9527-8-E41-06F, Revision 1, NPSH Requirements -RCIC and HPCI.2. Beyond Design Basis RCIC Elevated Temperature Functionality Assessment, BWROG-TP-14-018, December 2014 (proprietary).3. Calculation BNP-MECH-FLEX-0002, Brunswick Nuclear Plant Containment analysis ofFLEX Strategies, Revision 0, December 2014.4. Raw Water Issue: Fuel Inlet Blockage from Debris, BWROG-TP-1 4-006, Revision 0,March 2014 (proprietary).5. Severe Accident Management Guidance Technical Basis Report, EPRI 1025295, 2012(proprietary).6. BWROG Emergency Procedures Committee EPG/SAG issue 1216, approvedSeptember 2014.7. Calculation BNP-MECH-B5B, Extreme Damage Mitigation Guidelines: EngineeringHydraulic Basis, Revision 1, June 2009.8. AREVA, Inc., Engineering Information Record 51-9199717-012, National SAFERResponse Center Equipment Technical Requirements, January 2014.Documentation:1) Reactor Vessel Control flow chart (2EOP-01-RVCP) Override in step RC/L-3 providesguidance that if injecting salt water OR off-site water to Restore and Maintain levelbetween +192 inches and +225 inches per EPG approved Issue Item 1216.2) Guidance will be provided to the Emergency Response Organization for utilizing thedischarge canal to refill the CST.3) Reference 4 which was provided to the NRC discusses the basis to utilize salt water.5 Need for Relief/Relaxation and Basis for the Relief/RelaxationBSEP expects to comply with the order implementation but has selected an alternate approach toNEI 12-06 associated with FLEX response to energize the Division II Battery Chargers. SeeChange to Compliance Method change item 1.Page 9 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)6 Open ItemsGeneric ConcernsNonePlan Open ItemsTables 6A and 6B provide a summary status of the Open Items. Table 6.a. provides the openitems that were previously identified in the original OIP submitted on February 28, 2013, and in thefirst, second and third six-month status report submitted in Reference 2, 3 and 4 of this enclosure.Table 6.b. provides a list of open items that were added after July 28, 2014.Table 6a. Open Items Documented in the Overall Integrated PlanOverall Integrated Plan Open Item Status1. Perform a formal validation of FLEX deployment, Startedconnection, and action timelines after the proceduralguidance is developed and related staffing study iscompleted.2. Implement programmatic controls. StartedProgrammatic Controls(Also 04, 06, 09 & 12)3. Develop plant equipment control guidelines, in Startedaccordance with NEI 12-06 Section 11.5, to manage NRC Audit closed to trackingthe unavailability of equipment and applicable documentconnections that directly perform a FLEX mitigationstrategy.4. Establish programs and process to assure personnel Startedproficiency in the mitigation of beyond- design-basisevents is developed and maintained in accordancewith NEI 12-06 Section 11.6.5. Maintain FLEX strategies in overall FLEX basis Starteddocuments.6. Modify existing plant configuration control procedures Startedto ensure that changes to the plant design, physicalplant layouts, roads, buildings, and miscellaneousstructures will not adversely impact the approvedFLEX strategies in accordance with NEI 12-06Section 11.8.7. Complete applicable training prior to the Startedimplementation of FLEX.8. Complete construction of FLEX Equipment Storage StartedBuilding prior to the implementation of FLEX.9. Develop BSEP procedures and programs to address Startedstorage structure requirements, deployment pathrequirements, and FLEX equipment requirementsrelative to the hazards applicable to BSEP.Page 10 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)Overall Integrated Plan Open Item Status10. Design FLEX equipment connection points (e.g. Completemechanical, pneumatic, and electrical) to withstandthe applicable external hazards.11. Perform study to validate Suppression Pool Completetemperatures exceeding 220'F.12. Develop site specific procedures or guidelines, Startedutilizing the industry developed guidance from theOwners' Groups, EPRI, and NEI Task team, toaddress the criteria in NEI 12-06.13. Deleted Deleted14. Complete SFP level instrumentation modifications per StartedNRC Order EA 12-051, Issuance of Order to Modify EC 89577 (Ul)Licenses With Regard to Reliable Spent Fuel Pool EC 89578 (U2)Instrumentation.15. Develop deep load-shedding procedures to extend Deletecoping time for station batteries. 2nd 6-month updatechange #7.Deep load shedding proceduresare not required. Load sheddingactivities are contained in SBO-1 0.16. Modify procedures such that operator manual actions, Startedin areas where habitability is a concern, occur early in AR 593834-16 Incorporate earlythe FLEX timeline, to the extent practical. timeline for manual operatoractions.17. Revise procedures to open Reactor Building doors to Startedprovide a natural air circulation path. OEOP-01-SBO-0418. Provide transportation equipment to move large Startedskids/trailer-mounted equipment provided from off-site.19. Review generic BWROG analysis of FLEX Completedimplementation and perform station-specific analysis(NEDC 33771 P, Revision 1).20. Develop a process/methodology to rupture the StartedWetwell Vent Disc with Containment pressure below OEOP-01-SEP-01 rev. 2555 psi. Attachment 121. Develop a process/methodology to provide Clean StartedWater Makeup to the CST during Phase 3 response.22. Develop guidance for obtaining local vital indications Startedduring a loss of DC in conjunction with an ELAP. This OEOP-01-FSG-08strategy will be available for appropriate plant NRC Audit trackingpersonnel use in response to these failures.23. Provide justification showing the Unit 1 CST & Unit 2 StartedCST are robust from applicable external hazards. EC 95856EC 9581124. Develop a DC power coping analysis lAW IEEE- 485 Startedand establish an appropriate coping time for FLEX Nexus Report No.:response. 13-4085.001Page 11 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)Table 6b. Open Items added after July 28, 2014Overall Integrated Plan Open Item Status25. NRC Audit SE.8 Started.Verify SFP crane bridge does not impede SFPstrategy.26. NRC Audit SE.9 Completed stack tornado missileVerify plant stack vulnerability to seismic, tornado, analysis. Started update toand wind-driven missile hazards. 2MSS-001 1, Evaluation of thePlant Stack for Tornado WindForces and 2 x SSE Earthquake.27. NRC Audit SE.10 Started.Verify robustness of RWCU piping credited in FLEXstrategies.Page 12 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)7 ReferencesThe following references support updates to the Overall Integrated Plan as described in thisenclosure.1. Duke Energy Letter, Overall Integrated Plan in Response to March 12, 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, Agencywide Documents Access and Management System (ADAMS)Accession Number ML13071A5592. Duke Energy Letter, First Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA- 12-049), dated August 20,2013, ADAMS Accession Number ML13248A4473. Duke Energy Letter, Second Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2014, ADAMS Accession Number ML14073A4514. Duke Energy Letter, Third Six-Month Status Report in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events (Order Number EA- 12-049), dated August 28,2014, ADAMS Accession Number ML14254A1765. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Issuance of Order toModify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, ADAMS accession Number ML1 2054A7356. 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, Revision 0,dated August 29, 2012, ADAMS AccessionNumber ML12229A1747. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012, ADAMS Accession Number ML12242A3788. CP&L and FPC to NRC, Carolina Power & Light Company and Florida Power Corporation'sInitial Status Report in Response to March 12, 2012, Commission Order Modifying Licenseswith Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents (Order EA- 12-049), dated October 29, 2012, ADAMS Accession NumberML12307A0219. 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 NumberML13241A188)10. NRC Order Number EA-1 2-050, Issuance of Order to Modify Licenses with Regard toReliable Hardened Containment Vents, dated March 12, 2012, ADAMS Accession NumberML12054A694Page 13 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)11. NRC Order Number EA-1 3-109, Issuance of Order to Modify Licenses with Regard toReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions, dated June 6, 2013, ADAMS Accession Number ML13143A321Page 14 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)Attachment 1Updated Attachment 1A from OIPSequence of Events TimelineTimeAction Elapsed constraintTime Action YIN Remarks/ApplicabilityItem (hours) Level ofValidation1 0 Event Starts NA Plant @ 100% powerEmergency DC oil2 0.25 SBO is N pumps will be cycleddeclared off as turbines coastdown and H2 vented.Open ControlRoom back Y3 0.50 panel doors if Level A SBO-02CR ventilationnot in serviceBegin to4 1.0 depressurize Y >100&deg;F/hrRPV to 150 -Level A300 psigAlign RCIC Y Input to MAAP analysis5 <1.0 suction to Level A for coping time of CSTTorusFLEX DG Both do not have to bestarted and completed, if FLEX DGloaded or Y not in service loadBattery Load Level A shed extends copingShedding time for Div II batteriescompleted to 2 hours.FLEX DG Div. II Batteries7 2 loaded to Div II Y required for Key2 Battery Level A Electrical ComponentsChargersPage 15 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)TimeAction Elapsed constraintAtio Time Action Y/N Remarks/Applicability(hours) Level ofValidationTransfer to CST isbased on TorusTemperature of 190'F8 -2.9 RCIC aligned N This is not a timeto CST constraint for FLEXresponse. Timeestimate from MAAPanalysis.Perform andcomplete These actions are formanual actions habitability concernson 117' and the time line isReactor y based on temperatures9 6 Building for Level B at the 117' elevationSFP spray and roof. This is a timeReactor constraint for ReactorBuilding Building habitabilityNatural analysis.CirculationEstablishBattery Room Ventilation to prevent10 8.4 ventilation Y H2 explosiveOR Level B concentration inOpen Battery Battery RoomsRoom DoorsUse normal means if11 12 efuel FLEX Y available or OEOP-01 -FSG-06 if required.Takes place prior toexceeding PCPL-AVent (70 psia). This is not a12 -17.7 containment N time constraint forvia HCVS FLEX response. Timeestimate from MAAPanalysis.Establish long 20 hours is minimumterm time limit, actual time13 20 Pneumatic Y expected >20 hoursSupply for Level C based on BackupSRV's and Nitrogen BankHWWV pressure.Establish Y Time estimate from14 -52 makeup water Level C MAAP.to CST'sPage 16 of 17 FOURTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)TimeAction Elapsed constraintAtio Time Action Y/N Remarks/ApplicabilityItem (hours) Level ofValidationTime evaluationEstablish FLEX contained in calculation15 72 pump Y OFLEX-0001 andconnection to Level C determines makeup isSFP makeup. not required to SFPprior to 72 hours.Page 17 of 17}}

Latest revision as of 00:38, 21 April 2019

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML15084A156&oldid=1489708"