ML16074A394

Brunswick Steam Electric Plant - 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

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. GideonC Vice PresidentE' NERGY, Brunswick Nuclear PlantP.O. Box 10429Southport, NC 28461o: 910.457.3698February 24, 2016Serial: BSEP 16-0006U.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 50-324Sixth 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 NumberML1 2054A7352. 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 ML14254A1769. Duke Energy Letter, Fourth 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 27, 2015, ADAMS Accession Number ML15084A15610. Duke Energy Letter, Fifth 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 26, 2015, ADAMS Accession Number ML15246A03411. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign Basis External Events" and Order EA-12-051, "Order to Modify Licenses WithRegard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, datedJune 3, 2015, ADAMS Accession Number ML15173A013Ladies 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 immediatelyeffective and directs Duke Energy to develop, implement, and maintain guidance and strategiesto maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in theevent of a beyond-design-basis external event. Specific requirements are outlined inAttachment 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, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month statusreports, respectively, for BSEP. Reference 11 provided notification of full compliance with OrderEA-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 CommissionPage 3 of 4accomplishments 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. GideonEnclosure. Sixth 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-1 2-049), 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: Ms. Catherine Haney, Regional Administrator245 Peachtree Center Aye, NE, Suite 1200Atlanta, GA 30303-1 257U.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 OWEN 8B3) (E~lectronic 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 ENCLOSURESIXTH 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 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)1IntroductionNote: 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 OrderEA-12-049. The OIP was submitted to the NRC on February 28, 2013. The first six-month updatewas submitted to the NRC on August 20, 2013 (Reference 2). The second six-month update wassubmitted to the NRC on February 28, 2014 (Reference 3). The third six-month update wassubmitted to the NRC on August 28, 2014 (Reference 4). The fourth six-month update wassubmitted to the NRC on February 27, 2015 (Reference 5). The fifth six-month update wassubmitted to the NRC on August 26, 2015 (Reference 6). This enclosure provides an update ofmilestone accomplishments including any changes to the compliance method, schedule, or needfor 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 providednotification of full compliance with Order EA-1 2-049 for BSEP, Unit 2.2 Milestone AccomplishmentsThe following milestones were completed during the update period:* Procure Equipment (Unit 1)* Develop Unit 1 Modification EC Packages* Submit Fifth Six-Month Status Report3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the OIP. It provides the activity status ofeach item, and whether the expected completion date has changed. The dates are planning datesand subject 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 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 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 1/91 opeeDt o eieof NEI 12-01Submit 6 Month Status Report 2/28/14 Complete Date Not RevisedDevelop Unit 2 Modification 3/30/15 Unit 2Engineering Change (EC) 3/71 opeeModifications will bePackages, including Storage 3/71 opee completed and ready toFacility _______exit RFO B222R1Perform station-specific analysisfollowing generic BWROG FLEX3/0113/5implementation analysis review Cmlt(Open Item 19)Develop Strategies/Contract withRegional Response Center (RRC) February 2015 Complete Date RevisedSubmit 6 Month Status Report 8/29/14 Complete Date Not RevisedSAT Process for Training (Unit 2) 01/27/14 Complete 10/31/14Date Revised toSAT Process for Training (Unit 1 ) 1/26/15 Complete 06/25/201510/31/14Unit 2 Training PlanDevelop Training Plan (Unit 2) 07/27/14 Complete continues to be reviseddue to large amount ofOperator training in2014.Develop Training Plan (Unit 1) 07/26/15 Complete Date Not Revised02/26/2015Permanent StorageProcure Equipment (Unit 2) 11/27/14 Complete Building not availableuntil Middle of January2015Procure Equipment (Unit 1) 11/26/15 *Complete Date Not RevisedCreate 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 fromCreae Mintnanc Prcedres01/26/16 to 03125/16.Create ManennePrcdue"03/25/16 Started Procedure changes(Unit 1)implemented duringSpring 2016 Outage.Procedure Changes incorporating 0/71 opee0/521response strategies (Unit 2) 0/71 opee0/521*Date Revised fromProcdureChanes icorpratig *01/26/16 to 03/25/1 6.PresonsedstraeCagies (Uinoprti) "03/25/16 Started Procedure changesrespnse tratgies(Uni 1)implemented duringSpring 2016 Outage.Implement Training (Unit 2) 02/27/15 Complete Date Not RevisedSubmit 6 Month Status Report 2/27/15 Complete Date Not RevisedOutage Start DateUnit 2 Implementation Outage March 2015 Complete moved up toFebruary 2015Implement Modifications (Unit 2) April 2015 Complete Date Not RevisedSubmit Completion Report (Unit 2) April 2015 Complete Date Not RevisedDevelop Unit 1 Modification EC112/5*mpe DtRvidPackagesSubmit 6 Month Status Report 8/31/15 *Complete Date Not RevisedImplement Training (Unit 1) 02/26/16 Started Date Not RevisedSubmit 6 Month Status Report 2/29/16 *Started Date Not RevisedOutage Start DateUnit 1 Implementation Outage February 2016 Not Started moved up toFebruary 2016Implement Modifications (Unit 1) April 2016 *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 RevisedPage 4 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)4 Changes to Compliance MethodThe following summarizes changes that were made during the sixth update period to the strategiesas documented in the OIP (Reference 1 of this enclosure) or to the changes that were provided byReferences 2, 3, 4, 5, and 6 of this enclosure. These changes do not impact BSEP's compliancewith 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 dischargecanal 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 ExternalEvent (BDBEE) before using raw water. During development of the CST refill strategy, thesite established the "discharge canal" and "water trucks and portable tanks" as raw watersources. The "water trucks and portable tanks" water source, which relies upon a privateoff-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 theCSTs 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 theReactor Vessel Control Procedure Emergency Operating Procedure. Compliance withNEI 12-06 is not impacted.Documentation:1. 0EOP-01 -FSG-1 5, Unit 2 FLEX Condensate Storage Tank Fill2. 1/2EOP-01-RVCP, Reactor Vessel Control3. 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/RelaxationThere are no changes to the need for relief/relaxation during this sixth update period.6 Open ItemsGeneric ConcernsNonePlan Open ItemsTables 6a and 6b provide a summary status of the Open Items. Table 6a provides the open itemsthat 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 ofthis 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, Completeconnection, and action timelines after the proceduralguidance is developed and related staffing study iscompleted.2. Implement programmatic controls. Coinplete3. Develop plant equipment control guidelines, in Completeaccordance with NEI 12-06 Section 11.5, to managethe unavailability of equipment and applicableconnections that directly perform a FLEX mitigationstrategy._________________4. Establish programs and process to assure personnel Completeproficiency 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 Completedocuments.6. Modify existing plant configuration control procedures Completeto 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 Complete (Unit 2)implementation of FLEX. Started (Unit 1)8. Complete construction of FLEX Equipment Storage CompleteBuilding prior to the implementation of FLEX.9. Develop BSEP procedures and programs to address Completestorage structure requirements, deployment pathrequirements, and FLEX equipment requirementsrelative to the hazards applicable to BSEP. _______________10. 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, Complete (Unit 2)utilizing the industry developed guidance from the Started (Unit 1)Owners' Groups, EPRI, and NEI Task team, toaddress the criteria in NEI 12-06.13. Deleted Deleted14. 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 PoolInstrumentation. _______________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 Deletecoping time for station batteries. 2nd 6-month update change #7.Deep load shedding proceduresare not required. Load sheddingactivities 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 Completeskids/trailer-mounted equipment provided from off-site.19. Review generic BWROG analysis of FLEX Completeimplementation 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 plantpersonnel use in response to these failures.23. Provide justification showing the Unit 1 CST and CompleteUnit 2 CST are robust from applicable externalhazards.24. Develop a DC power coping analysis lAW IEEE-485 Completeand establish an appropriate coping time for FLEXresponse._______________Table 6b. Open Items added after July 28, 2015...... oie~rall lntegrated Plan Open item I

• StatusNo new open items durnn this sixth update period.Page 7 of 9 SIXTH 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. Duke Energy Letter, Fourth 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 27,2015, ADAMS Accession Number ML15084A1566. Duke Energy Letter, Fifth 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 26,2015, ADAMS Accession Number ML15246A0347. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order ModifyingLicenses with Regard to Requirements for Mitigation Strategies for Beyond Design BasisExternal Events" and Order EA-12-051, "Order to Modify Licenses With Regard To ReliableSpent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS AccessionNumber ML15173A0138. 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 ML12054A7359. 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 ML12229A17410. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012, ADAMS Accession Number ML12242A37811. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's InitialStatus Report in Response to March 12, 2012, Commission Order Modifying Licenses withPage 8 of 9 SIXTHr SI-ONHSTTSmEORbOREeNME EA-12-049),dtdOtbr2,21,A MScesinNm rRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated October 29, 2012, ADAMS Accession NumberML1 2307A0214Page 9 of 9 DUKE William R. GideonC Vice PresidentE' NERGY, Brunswick Nuclear PlantP.O. Box 10429Southport, NC 28461o: 910.457.3698February 24, 2016Serial: BSEP 16-0006U.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 50-324Sixth 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 NumberML1 2054A7352. 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 ML14254A1769. Duke Energy Letter, Fourth 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 27, 2015, ADAMS Accession Number ML15084A15610. Duke Energy Letter, Fifth 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 26, 2015, ADAMS Accession Number ML15246A03411. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign Basis External Events" and Order EA-12-051, "Order to Modify Licenses WithRegard To Reliable Spent Fuel Pool Instrumentation" for BSEP, Unit 2, datedJune 3, 2015, ADAMS Accession Number ML15173A013Ladies 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 immediatelyeffective and directs Duke Energy to develop, implement, and maintain guidance and strategiesto maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in theevent of a beyond-design-basis external event. Specific requirements are outlined inAttachment 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, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month statusreports, respectively, for BSEP. Reference 11 provided notification of full compliance with OrderEA-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 CommissionPage 3 of 4accomplishments 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. GideonEnclosure. Sixth 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-1 2-049), 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: Ms. Catherine Haney, Regional Administrator245 Peachtree Center Aye, NE, Suite 1200Atlanta, GA 30303-1 257U.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 OWEN 8B3) (E~lectronic 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 ENCLOSURESIXTH 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 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)1IntroductionNote: 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 OrderEA-12-049. The OIP was submitted to the NRC on February 28, 2013. The first six-month updatewas submitted to the NRC on August 20, 2013 (Reference 2). The second six-month update wassubmitted to the NRC on February 28, 2014 (Reference 3). The third six-month update wassubmitted to the NRC on August 28, 2014 (Reference 4). The fourth six-month update wassubmitted to the NRC on February 27, 2015 (Reference 5). The fifth six-month update wassubmitted to the NRC on August 26, 2015 (Reference 6). This enclosure provides an update ofmilestone accomplishments including any changes to the compliance method, schedule, or needfor 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 providednotification of full compliance with Order EA-1 2-049 for BSEP, Unit 2.2 Milestone AccomplishmentsThe following milestones were completed during the update period:* Procure Equipment (Unit 1)* Develop Unit 1 Modification EC Packages* Submit Fifth Six-Month Status Report3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the OIP. It provides the activity status ofeach item, and whether the expected completion date has changed. The dates are planning datesand subject 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 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 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 1/91 opeeDt o eieof NEI 12-01Submit 6 Month Status Report 2/28/14 Complete Date Not RevisedDevelop Unit 2 Modification 3/30/15 Unit 2Engineering Change (EC) 3/71 opeeModifications will bePackages, including Storage 3/71 opee completed and ready toFacility _______exit RFO B222R1Perform station-specific analysisfollowing generic BWROG FLEX3/0113/5implementation analysis review Cmlt(Open Item 19)Develop Strategies/Contract withRegional Response Center (RRC) February 2015 Complete Date RevisedSubmit 6 Month Status Report 8/29/14 Complete Date Not RevisedSAT Process for Training (Unit 2) 01/27/14 Complete 10/31/14Date Revised toSAT Process for Training (Unit 1 ) 1/26/15 Complete 06/25/201510/31/14Unit 2 Training PlanDevelop Training Plan (Unit 2) 07/27/14 Complete continues to be reviseddue to large amount ofOperator training in2014.Develop Training Plan (Unit 1) 07/26/15 Complete Date Not Revised02/26/2015Permanent StorageProcure Equipment (Unit 2) 11/27/14 Complete Building not availableuntil Middle of January2015Procure Equipment (Unit 1) 11/26/15 *Complete Date Not RevisedCreate 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 fromCreae Mintnanc Prcedres01/26/16 to 03125/16.Create ManennePrcdue"03/25/16 Started Procedure changes(Unit 1)implemented duringSpring 2016 Outage.Procedure Changes incorporating 0/71 opee0/521response strategies (Unit 2) 0/71 opee0/521*Date Revised fromProcdureChanes icorpratig *01/26/16 to 03/25/1 6.PresonsedstraeCagies (Uinoprti) "03/25/16 Started Procedure changesrespnse tratgies(Uni 1)implemented duringSpring 2016 Outage.Implement Training (Unit 2) 02/27/15 Complete Date Not RevisedSubmit 6 Month Status Report 2/27/15 Complete Date Not RevisedOutage Start DateUnit 2 Implementation Outage March 2015 Complete moved up toFebruary 2015Implement Modifications (Unit 2) April 2015 Complete Date Not RevisedSubmit Completion Report (Unit 2) April 2015 Complete Date Not RevisedDevelop Unit 1 Modification EC112/5*mpe DtRvidPackagesSubmit 6 Month Status Report 8/31/15 *Complete Date Not RevisedImplement Training (Unit 1) 02/26/16 Started Date Not RevisedSubmit 6 Month Status Report 2/29/16 *Started Date Not RevisedOutage Start DateUnit 1 Implementation Outage February 2016 Not Started moved up toFebruary 2016Implement Modifications (Unit 1) April 2016 *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 RevisedPage 4 of 9 SIXTH SIX-MONTH STATUS REPORT (ORDER NUMBER EA-12-049)4 Changes to Compliance MethodThe following summarizes changes that were made during the sixth update period to the strategiesas documented in the OIP (Reference 1 of this enclosure) or to the changes that were provided byReferences 2, 3, 4, 5, and 6 of this enclosure. These changes do not impact BSEP's compliancewith 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 dischargecanal 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 ExternalEvent (BDBEE) before using raw water. During development of the CST refill strategy, thesite established the "discharge canal" and "water trucks and portable tanks" as raw watersources. The "water trucks and portable tanks" water source, which relies upon a privateoff-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 theCSTs 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 theReactor Vessel Control Procedure Emergency Operating Procedure. Compliance withNEI 12-06 is not impacted.Documentation:1. 0EOP-01 -FSG-1 5, Unit 2 FLEX Condensate Storage Tank Fill2. 1/2EOP-01-RVCP, Reactor Vessel Control3. 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/RelaxationThere are no changes to the need for relief/relaxation during this sixth update period.6 Open ItemsGeneric ConcernsNonePlan Open ItemsTables 6a and 6b provide a summary status of the Open Items. Table 6a provides the open itemsthat 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 ofthis 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, Completeconnection, and action timelines after the proceduralguidance is developed and related staffing study iscompleted.2. Implement programmatic controls. Coinplete3. Develop plant equipment control guidelines, in Completeaccordance with NEI 12-06 Section 11.5, to managethe unavailability of equipment and applicableconnections that directly perform a FLEX mitigationstrategy._________________4. Establish programs and process to assure personnel Completeproficiency 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 Completedocuments.6. Modify existing plant configuration control procedures Completeto 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 Complete (Unit 2)implementation of FLEX. Started (Unit 1)8. Complete construction of FLEX Equipment Storage CompleteBuilding prior to the implementation of FLEX.9. Develop BSEP procedures and programs to address Completestorage structure requirements, deployment pathrequirements, and FLEX equipment requirementsrelative to the hazards applicable to BSEP. _______________10. 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, Complete (Unit 2)utilizing the industry developed guidance from the Started (Unit 1)Owners' Groups, EPRI, and NEI Task team, toaddress the criteria in NEI 12-06.13. Deleted Deleted14. 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 PoolInstrumentation. _______________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 Deletecoping time for station batteries. 2nd 6-month update change #7.Deep load shedding proceduresare not required. Load sheddingactivities 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 Completeskids/trailer-mounted equipment provided from off-site.19. Review generic BWROG analysis of FLEX Completeimplementation 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 plantpersonnel use in response to these failures.23. Provide justification showing the Unit 1 CST and CompleteUnit 2 CST are robust from applicable externalhazards.24. Develop a DC power coping analysis lAW IEEE-485 Completeand establish an appropriate coping time for FLEXresponse._______________Table 6b. Open Items added after July 28, 2015...... oie~rall lntegrated Plan Open item I

• StatusNo new open items durnn this sixth update period.Page 7 of 9 SIXTH 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. Duke Energy Letter, Fourth 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 27,2015, ADAMS Accession Number ML15084A1566. Duke Energy Letter, Fifth 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 26,2015, ADAMS Accession Number ML15246A0347. Duke Energy Letter, Notification of Full Compliance with Order EA- 12-049, "Order ModifyingLicenses with Regard to Requirements for Mitigation Strategies for Beyond Design BasisExternal Events" and Order EA-12-051, "Order to Modify Licenses With Regard To ReliableSpent Fuel Pool Instrumentation" for BSEP, Unit 2, dated June 3, 2015, ADAMS AccessionNumber ML15173A0138. 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 ML12054A7359. 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 ML12229A17410. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0, dated August 2012, ADAMS Accession Number ML12242A37811. Duke Energy Letter, Carolina Power & Light Company and Florida Power Corporation's InitialStatus Report in Response to March 12, 2012, Commission Order Modifying Licenses withPage 8 of 9 SIXTHr SI-ONHSTTSmEORbOREeNME EA-12-049),dtdOtbr2,21,A MScesinNm rRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated October 29, 2012, ADAMS Accession NumberML1 2307A0214Page 9 of 9