ML15061A124

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)

ML15061A124
Person / Time
Site:	Catawba
Issue date:	02/26/2015
From:	Henderson K Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-15-008, EA-12-049
Download: ML15061A124 (21)

Text

Kelvin Henderson DUKE Vice President ENERGY, Catawba Nuclear Station Duke Energy CN01VP I 4800 Concord Road York, SC 29745 o: 803.701.4251 f: 803.701.3221 CNS-15-008 10 CFR 50.4 February 26, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Renewed License Numbers NPF-35 and NPF-52

Subject:

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)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Order Modifying Licenses 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 for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ADAMS Accession 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 Order Modifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated October 29, 2012 (ADAMS Accession 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 Mitigation Strategies for Beyond Design Basis External Events (Order EA-12-049), dated February 28, 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 Energy to develop, implement, and maintain guidance and strategies to maintain or restore core 4-6 1 United States Regulatory Commission Page 2 February 26, 2015 cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

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

3) with clarification and exceptions identified in Reference

2. Reference 4 provided the initial status report regarding mitigation strategies at the Oconee, McGuire and Catawba Nuclear Stations.

Reference 5 provided the Catawba OIP.Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports.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 milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

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 February 26, 2015.Sincerely, Kelvin Henderson Vice 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 and NPF-52 United States Regulatory Commission Page 3 February 26, 2015 xc: V.M. McCree, Regional Administrator U. S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 W. M. Dean, Director, Office of Nuclear Reactor Regulation US. Nuclear Regulatory Commission One White Flint North, Mailstop 13-HI6M 11555 Rockville Pike Rockville, MD 20852-2738 G.E. Miller U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 G.A. Hutto NRC Senior Resident Catawba Nuclear Station Justin Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453 ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

ENCLOSURE FOURTH SIX MONTH STATUS REPORT (ORDER EA-12-049)

CATAWBA NUCLEAR STATION (CNS), UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 RENEWED LICENSE NOS. NPF-35 AND NPF-52 Page 1 ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 2 1 Introduction Catawba 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 on February 28, 2013. This enclosure provides an update of milestone accomplishments including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, that occurred during the period from July 29, 2014 to January 28, 2015 (hereafter referred to as "the update period").2 Milestone Accomplishments The following milestones were completed during the update period: 1) Third Six-Month Status Report for Catawba Nuclear Station, Units 1 and 2 was submitted on August 28, 2014.2) Phase II Staffing Study per NEI 12-01 submitted to the NRC on October 28, 2014.3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed from that stated in Attachment 2 of the OIP. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates are not expected to impact the order implementation date.Submit 60 Day Initial Status Report Oct 2012 Complete uate NOt Revised Submit Overall Integrated Plan Feb 2013 Complete Date Not Revised First 6 Month Status Update Aug 2013 Complete Date Not Revised Second 6 Month Status Update Feb 2014 Complete Date Not Revised Third 6 Month Status Update Aug 2014 Complete Date Not Revised ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 3 Fourth 6 Month Status Update Feb 2015 Started Date Not Revised Develop Engineering Changes (ECs) Jan 2015 Started Date Revised Develop Strategies Feb 2015 Started Date Revised Purchase Equipment Feb 2015 Started Date Revised Develop Equipment PMs Feb 2015 Started Date Revised Feb 2015 (U2)Develop Guidelines Started Date Revised Oct 2015 (Ul)Develop Training Feb 2015 Started Date Revised Date Not Implement Training May 2015 Started Revise Revised Date Not Staffing 12-01 Phase II Nov 2014 Complete Revised Date Not Communications Integrated Plan May 2015 Started Revise Revised Date Not EC Implementation (On-Line)

May 2015 Started Revise Revised Unit 1 EC Implementation (1EOC22) Dec 2015 Not Started Date Revised Unit 2 EC Implementation (2EOC20) Mar 2015 Started Date Revised Date Not Site Implementation Complete Dec 2015 Not Started Revise Revised SAFER National Response Centers Date Not Operational Feb 2015 Started Revised ENCLOSURE Page 4 CNS Fourth Sixth Month Status Report (Order EA-12-049) 4 Changes to Compliance Method The following summarizes the changes to the compliance method or strategies as documented in 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 Stations compliance with NEI 12-06.1) Changqe: All references to the Regional Response Center (RRC) in the OIP shall now be called 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 Centers and 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 (ADAMS Accession 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 driven pump should be aligned to the Nuclear Service Water (RN) system in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to provide long term makeup for the Spent Fuel Pool (SFP) and Steam Generators (S/Gs). Based on further analysis, it is not necessary to have the RN system filled and pressurized for at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to support SFP makeup.Justification:

Based on the available water supply in the seismically robust Condenser Cooling Water (RC) system, the Turbine Driven Auxiliary Feedwater Pump can feed the S/Gs with the RC water source for at least 5 days on Unit 1 and for at least 8 days on Unit 2. RN makeup to the SFP is not required for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to maintain at least 10 feet of water above 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 (Seismic Robustness Review Of Catawba Unit 1 Non-Safety Piping And Components For Diverse And Flexible Mitigation Strategies (Flex) dated January 2014, Westinghouse calculation CN-SEE-II-13-22 (Catawba Nuclear Station FLEX Alternate Cooling Evaluation Input Auxiliary Feedwater Usage) dated 7/23/14, and email from Darrell Davies to Jordan Penley 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 Page 35 of 94 in the OIP states that containment pressure remains below design limits for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The final containment analysis for Catawba determined that containment pressures actually exceed design pressure about 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> into the event (15 psig design and 17.5 psig at 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br />).Justification:

An evaluation of the containment structure and associated penetrations was performed and it was determined that no significant issues exist when containment pressures reach 17.5 psig Documentation:

Open Item 94.

ENCLOSURE Page 5 CNS 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 discussion starting 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 Site Plan drawing on Page 81 of 94, Open Items 21 and 22 on Page 91 of 94, and Open Item 42 on Page 92 of 94 in the OIP all deal with using Containment Spray for temperature/pressure control. Containment Spray will no longer be used for pressure/temperature control based on the latest containment analysis.Justification:

Due to concerns with not having enough containment spray capabilities (flow rates and pressures from the portable pumps) to provide adequate pressure/temperature control and the fact that the containment spray water would add to flooding issues inside containment, a different containment pressure/temperature control strategy was developed.

The new strategy makes use of the Hydrogen Skimmer, Containment Air Return, and Lower Containment ventilation fans to provide the necessary temperature and pressure 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 the 50.54(hh)(2) (B.5.b) pump is credited in the FLEX mitigating strategies and that this pump will 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 mitigation strategies.

Justification:

Additional pumps and equipment have been purchased to support all the requirements for the Flex mitigation strategies.

As such, use of the B.5.b pump is no longer necessary.

Documentation:

Reference Flex mitigation strategies in the Emergency Operating Procedures, Abnormal Operating Procedures, and Flex Support Guidelines.

Open Items 37 and 53.6) Change: There are a number of references to the RRC Playbook throughout the OIP (see Pages 3, 12, 23, and 92 of 94). This document is now referred to as the SAFER Response Plan for Catawba Nuclear Station.Justification:

Reference Rev. 001 of the SAFER Response Plan for Catawba Nuclear Station approved on 1/29/15.Documentation:

Open Item 55.

ENCLOSURE Page 6 CNS Fourth Sixth Month Status Report (Order EA-12-049)

7) Change: The wording related to the Alternate Power Distribution strategy mentioned on Page 16 and 55 in the OIP needs to be clarified as follows: Wording on Page 16 and 55 should say "If normal power supplies are not available, they will be disconnected to allow connection of alternate supply cables. A quantity of alternate supply cables will be available to replace the Flex power supplies normally provided to a common plant area. If necessary, 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 strategy can be interpreted a number of different ways. As such, the wording has been revised to provide a little more clarification.

Specific actions related to the Alternate Power strategy will 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 each of the Reactor Coolant Pump (RCP) No.1 seal leak off lines, upstream of the existing flow orifice. Westinghouse has conservatively provided an assumed worst case pressure of 2045 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 to the existing flow orifice because of excessive delta P. Additional piping stress and support analysis will also be performed once the new temperature/pressure profile is determined to ensure all of the associated seal leak off line components retain their pressure boundary function.Justification:

All of the analyses related to an ELAP assume the leak rate from the RCP No. 1 seal is 21 gpm or less. To ensure this assumption remains valid, a new pressure breakdown orifice needs to be installed in the RCP No. 1 seal leak off line for each pump to lower pressures enough such that downstream components do not fail and create the possibility for leak rates greater than 21 gpm.Documentation:

Open Item 96.5 Need for Relief/Relaxation and Basis for the Relief/Relaxation CNS expects to comply with the order implementation date and no relief/relaxation is required at this time.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 7 6. Open Items The 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 February 28, 2013 and in the first, second, and third six month status reports (References 1, 3, 4, and 5 in Section 8). The table under Section 6.b. provides a list of Open Items that were added after July 28, 2014. The table under 6.c. provides a list of Open Items related to the Interim Staff Evaluation (ISE). The table under 6.d. provides a list of Confirmatory Items related to the Interim Staff Evaluation (ISE).a. Open Items Documented in the Overall Integrated Plan, the First Six Month Status Report, the Second Six Month Status Report, and the Third Six Month Status Report.Item Overall Integrated Plan Open Item Status Disconnect all non-critical loads from vital batteries.

Activity to Complete 1 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. Complete Additional analysis required to verify adequate pump head exists to overcome potential Turbine Building flooding.

See Corrective Action 26 in PIP C-12-2291.

Provide pumping capacity to control level in TDAFWP pit sump. Started 3 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 27 in PIP C-12-2291.Recharge communication system and satellite phone system. Started 4 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 28 in PIP C-12-2291.Align charging to Channel A and D Vital Batteries.

Activity to Started 5 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 Started Tank to Safety Injection System to provide Reactor Coolant System makeup and boration.

Approximate time suggested by 6 PWROG to provide negative reactivity addition and maintain margin to criticality.

Site specific analysis will need to be performed to establish actual time. See Corrective Action 30 in PIP C-12-2291.

Align portable injection pump from Refueling Water Storage Started Tank to Safety Injection System to provide Reactor Coolant 7 System makeup and boration.

Activity to be validated in conjunction with associated procedure changes. See Corrective Action 31 in PIP C-1 2-2291.Provide portable lighting (beyond head and hand lamps and Started installed battery lighting).

Activity to be validated in conjunction 8 with associated procedure changes. See Corrective Action 32 in PIP C-12-2291.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 8 Item Overall Integrated Plan Open Item Status Install portable fans in Control Room and Battery Rooms. Time Started based on engineering judgment.

Analysis will determine the need and timing for ventilation.

See Corrective Action 33 in PIP C-12-2291.

Install portable fans in Control Room and battery rooms. Started 10 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 34 in PIP C-12-2291.Connect diesel driven Hale Pump through Essential Service Started Water piping to Spent Fuel Pool skimmer loop to provide a means to make up to the SFP without entering the SFP area.Activity to be validated in conjunction with associated procedure changes. See Corrective Action 35 in PIP C-12-2291.Open Spent Fuel Pool bay doors. Activity to be validated in Started 12 conjunction with associated procedure changes. See Corrective Action 36 in PIP C-12-2291.

Align diesel driven Hale Pump to supply Essential Service Started 13 Water supply header from UHS. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 37 in PIP C-12-2291.

Align diesel driven Hale Pump to supply second diesel driven Started 14 Hale Pump to feed SGs. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 38 in PIP C-12-2291.

Re-power H2 igniters.

Activity to be validated in conjunction Started 15 with associated procedure changes. See Corrective Action 39 in PIP C-12-2291.

Align charging to Channel B and C Vital Batteries.

Activity to Started 16 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 Started conjunction with associated procedure changes. See Corrective Action 41 in PIP C-1 2-2291.18 Evaluate need to provide freeze protection for instrumentation Not Started located in Doghouses and yard. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is based on engineering judgment.

Evaluation will be performed to determine actual action time. See Corrective Action 42 in PIP C-12-2291.

19 Evaluate need to provide freeze protection for instrumentation Not Started located in Doghouses and yard. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 43 in PIP C-12-2291.

20 Isolate Instrument Air to Containment.

Activity to be validated Started in conjunction with associated procedure changes. See Corrective Action 44 in PIP C-12-2291.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 9 Item Overall Integrated Plan Open Item Status 21 Align portable diesel driven Hale Pump to Containment Spray Started connection.

Contingency to be available if required to reduce Containment temperature.

Modification of an existing B.5.b Strategy.

Activity to be validated in conjunction with associated procedure changes. See Corrective Action 45 in PIP C-12-2291.

22 Align RRC diesel generator to power installed Containment Started Spray pumps. Activity to be validated in conjunction with associated procedure changes. See Corrective Action 46 in PIP C-12-2291.

23 Arrangements with local transportation businesses and Started Regional Response Centers will need to be established to ensure personnel and equipment can reach the site considering 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 Started placed in critical rooms and floor elevations in the Auxiliary building to mitigate/control internal flooding.

See Corrective Action 48 in PIP C-12-2291.

25 Develop adequate procedural and administrative guidance to Started implement mitigation strategies and supporting activities during 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 Started supply -Procedural guidelines and ECR 6139 and 6140. See Corrective Action 7 and 19 in PIP C-12-2291.

27 A site specific Building Specification will be written that details Started the storage facility design requirements and ECR 5979 will design and construct the facilities.

See Corrective Action 12 in PIP C-12-2291.

28 Add appropriate FLEX equipment to the site Periodic Started Maintenance (PM) program. See Corrective Action 50 in PIP C-12-2291.

29 Develop a Document for the FLEX program. See Corrective Started Action 51 in PIP C-12-2291.

30 Determine if Engineering Change program documents or Started checklists need to be revised to include verification that the modification does not impact the FLEX program. See Corrective Action 52 in PIP C-12-2291.

31 Develop applicable training programs to support the FLEX Started strategies and supporting activities.

Training will be provided once programs are in place. Corrective Action 53 in PIP C-12-2291 has been closed to the Needs and Evaluation Database (NED). NED 13-02758 has been initiated and assigned for processing.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 10 Item Overall Integrated Plan Open Item Status 32 Develop flow model calculations to support the various FLEX Started strategies and document the available static water volume in the RN/CA piping (PIP C-1 2-2291 CA 20).33 Provide RN supply header hose connections in the yard and Started in the pumphouse for portable pump to fill/pressurize RN system -ECR 5976 and 5977. See Corrective Action 9 and 10 in PIP C-12-2291.

34 Provide primary CA piping connections for S/G Makeup via Started portable pump (ECR 5980 and 5981). See Corrective Action 13 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 in PIP C-12-2291.

36 Provide primary and alternate RCS makeup and injection Started connections (ECR 5983 and 5984). See Corrective Action 15 and 16 in PIP C-12-2291.

37 Purchase high pressure and low pressure RCS injection Started pumps. See Corrective Action 54 in PIP C-12-2291.

38 Provide seismically qualified connection on the FD piping to Started access diesel fuel in safety related underground storage tanks (ECR 5985 and 5988). See Corrective Action 17 and 18 in PIP C-12-2291.

39 Purchase portable diesel fuel transfer pump and storage tank. Complete See Corrective Action 55 in PIP C-12-2291.

40 Provide access road to the SNSWP for the portable diesel Started pump (ECR 5978). See Corrective Action 11 in PIP C-12-2291.41 An analysis is needed to determine whether or not Started venting/letdown is required when providing borated water injection.

See Corrective Action 56 in PIP C-12-2291.

42 An analysis is needed to determine if containment spray for Started temperature/pressure control is not required over the long term. See Corrective Action 57 in PIP C-12-2291.

43 Provide redundant SFP Level Instruments per NRC Order -Started EC109413 and 109414. See Corrective Action 4 and 5 in PIP C-12-2205.

44 Determine lighting requirements via Corrective Action 31 in Complete PIP C-1 1-6867.45 Determine lighting requirements and implement as needed via Started Corrective Action 24 in PIP C-12-2291.

46 Determine long term environmental conditions in the Control Started Room and CA Pump room via Corrective Action 13 in PIP C-11-6867. This evaluation will be part of Corrective Action 33 in PIP C-12-2291.

47 Ensure that an appropriate inventory of portable hand-held Complete satellite phones, spare batteries, and chargers, is available for use by the Emergency Response Organization.

See Corrective Action 7 in PIP C-12-2195.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 11 Item Overall Integrated Plan Open Item Status 48 Evaluate and purchase, if necessary, additional portable Complete radios, spare batteries, and chargers to ensure required communications links are fully established.

Corrective Action 8 in PIP C-12-2195.

49 Ensure that portable communications equipment (i.e., satellite Complete phones, radios, and diesel generators) are stored in a manner such that maximizes survivability from applicable external events per NEI 12-01, Section 4.5. Corrective Action 9 in PIP C-12-2195.

50 Ensure that programmatic controls are established for Complete communications equipment (i.e., portable satellite phones, radios, small generators) to ensure availability and reliability, including the performance of periodic inventory checks and operability testing per NEI 12-01, Section 4.8. Also, provide training on the locations and use of communications systems and equipment (NEI 12-01, Section 4.11). Corrective Action 10 in PIP C-12-2195.

51 Ensure that arrangements are in place with communications Complete service providers to utilize their emergency services as described in NEI 12-01, Section 4.10. Corrective Action 12 in PIP C-12-2195.

Purchase debris removal equipment that is also capable of Complete 52 towing all FLEX equipment.

See Corrective Action 58 in PIP C-12-2291.

53 Provide additional portable FLEX equipment such as pumps, Started air compressors, and generators to be purchased with specific identifiers/labels maintained in the Equipment Data Base (EDB). See Corrective Action 59 in PIP C-12-2291.

54 Develop periodic surveillance procedures and Operator Started rounds to verify that all FLEX equipment is in its proper storage location and not degraded.

See Corrective Action 60 in PIP C-12-2291.

55 Develop Regional Response Center Playbook.

See Started Corrective Action 61 in PIP C-1 2-2291.56 Complete staffing studies and ensure adequate personnel will Complete be available to support the FLEX mitigation strategies and associated activities.

See Corrective Action 7 in PIP C-12-4953.57 Develop procedural guidelines to use handheld instruments Started tied into local in plant components to monitor essential parameters.

See Corrective Action 62 in PIP C-12-2291.

58 Develop procedural guidelines to disconnect normal power Started supplies and attach alternate power cables from disconnect devices and portable generators for select components.

See Corrective Action 63 in PIP C-12-2291.

59 Develop procedural guidelines to deploy and install lighting in Started required areas. See Corrective Action 24 in PIP C-12-2291.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 12 Item Overall Integrated Plan Open Item Status 60 Determine if Phase 3 ventilation needs (RRC equipment, Started additional procedural guidelines, etc.) are required.

See Corrective Action 64 in PIP C-12-2291.

61 Determine if Mobile Boration will be required from the RRC Started during Phase 3. See Corrective Action 65 in PIP C-12-2291.

62 Determine if portable lighting will be required from the RRC Started during Phase 3. See Corrective Action 66 in PIP C-12-2291.

63 Determine if portable fans/ducting will be required from the Started RRC during Phase 3. See Corrective Action 67 in PIP C-12-2291.64 Determine Phase 3 requirements related to Radiation Started Protection Equipment.

See Corrective Action 68 in PIP C-12-2291.65 Determine Phase 3 requirements related to Commodities Complete such as food and water. See Corrective Action 69 in PIP C-12-2291.Calculate diesel fuel consumption rates for the portable FLEX Complete equipment and compare that to the available fuel stored in the 66 Emergency Diesel Generator safety related underground storage tanks to determine if additional diesel fuel is needed from off-site resources during Phase 3. See Corrective Action 70 in PIP C-12-2291.

67 Select and purchase Phase 3 debris clearing equipment Started and/or transport vehicles if needed to move RRC equipment around the site. See Corrective Action 71 in PIP C-12-2291.

68 Implement Flood mitigation activities per Corrective Action Started Program (Ref. PIP C-12-0833).

69 Complete initial testing of FLEX mitigation equipment prior to Started full implementation dates. See Corrective Action 72 in PIP C-12-2291.70 Establish a Special Emphasis Code in the EDB and Work Complete Control program for FLEX equipment.

See Corrective Action 73 in PIP C-12-2291.

71 Obtain and store any additional equipment in FLEX Storage Started Facilities or Category I buildings needed to aid in the connection of the RRC equipment to plant components.

See Corrective Action 74 in PIP C-12-2291.

72 Revise RP/0/A/5000/007 (Natural Disaster and Earthquake) to Complete move equipment at the SNSWP if flooding is imminent.

See Corrective Action 79 in PIP C-12-2291.

Formally evaluate/document potential deployment route Started 73 concerns such as soil liquefaction discussed in NEI 12-06. See Corrective Action 86 in PIP C-1 2-2291.Document seismic qualification (robustness in accordance with Started 74 NEI 12-06) of assured RN to KF make up piping on Unit 1. See Corrective Action 87 in PIP C-12-2291.

Add new FWST low/high pressure borated water injection Started 75 pump suction connection.

See Corrective Action 83 and 84 in PIP C-12-2291 (ECR-6787 and ECR-6788)

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 13 Item Overall Integrated Plan Open Item Status 76 Evaluate travel paths into the Auxiliary Building through non Started seismic structures.

See Corrective Action 88 in PIP C-12-2291.

An analysis is needed to determine if there are any impacts to Started FLEX strategies due to large internal flooding sources that are not seismically robust or that require AC power for isolation.

The analysis shall also consider the effects of ground water intrusion during an Extended Loss of All AC Power event. See Corrective Action 89 in PIP C-12-2291.

A Catawba specific shutdown margin calculation performed in Complete 78 accordance with PWROG guidance is required.

See Corrective Action 90 in PIP C-12-2291.

Westinghouse assistance is required to provide additional Started 79 information related to seal leakage on the Catawba Reactor Coolant Pumps. See Corrective Action 91 in PIP C-12-2291.

The number of Steam Generators and PORVs required for the Started 80 Low Pressure portable pump makeup FLEX strategy needs to be validated and formally documented in a Catawba station calculation.

See Corrective Action 92 in PIP C-12-2291.

Westinghouse assistance is needed to perform thermal Started 81 hydraulic analyses to support plant specific decision making and provide justification for the duration of each phase. See Corrective Action 93 in PIP C-12-2291.

Additional analyses is needed to evaluate whether containment Started penetration seals and other equipment located inside 82 containment and used in the mitigation strategies are still functional based on the predicted temperatures and pressures during a Fukushima type event. See Corrective Action 94 in PIP C-12-2291.

Station controlled documents need to be created to capture Not Started 83 vendor reports related to generator machine capabilities to power the designated FLEX loads in Phase 2 and 3. See Corrective Action 95 in PIP C-12-2291.

Determine if any changes to WPM 602, NSD 403, or any other Complete site/fleet Shutdown/Refueling documents need to be revised to 84 comply with the position paper related to Shutdown Risk Management and Contingency Planning.

See Corrective Action 96 in PIP C-12-2291.

Perform a seismic robustness evaluation of the proposed cable Started 85 "backbone" and it's associated components.

See Corrective Action 97 in PIP C-12-2291.

Vendor data and system calculations needed to support FLEX Started 86 response strategies involving low speed operation of Turbine-Driven CA (TDCA) Pumps in support of ELAP EOP setpoint 0.12 development.

See Corrective Action 1 in PIP C-1 3-9158.Due to normal operational input to the TDCA pump pit sump Started and having both TDCA pumps in simultaneous operation, 87 additional portable sump pumps, hoses, and associated equipment are required.

See Corrective Action 15 in PIP C-11-6867.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

Page 14 Item Overall Integrated Plan Open Item Status A calculation is needed to support the validation of the Started Fukushima Phase 3 strategy associated with providing core cooling via the portable pump feeding RN from the SNSWP, powering up one KC pump and one ND pump via the 4160 Volt 88 portable generator from the Regional Response Center. The calculation should determine whether or not adequate core cooling can be achieved with reduced RN flow rates assuming worst case SNSWP upper temperature limits and core decay heat loads when this Phase 3 strategy is put in service. See Corrective Action 98 in PIP C-12-2291.

As documented in Actual Corrective Action #8 in PIP C Complete 2291, EC110650 (Install New Fire Hydrant Near The SNSWP 89 For Flex Buildings

& B.5.B) is to be cancelled.

Complete actions to finalize cancellation of this Engineering See Corrective Action 101 in PIP C-12-2291.

Ensure that hard copies of Procedures needed to support EP Started and AP implementation (and any additional supporting 90 procedures identified by FLEX procedures) are accessible during a BDBEE causing an Extended Loss of All AC Power (ELAP greater than 4 hrs.). See Corrective Action 102 and 120 in PIP C-12-2291.

Review DPC-1552.08-00-0278, Appendix C. Determine which Complete operations procedures perform surveillances of the CLAs boron 91 concentrations.

Make the necessary revisions using the basis provided by DPC-1552.08-00-0278, Appendix C. See Corrective Action 104 in PIP C-12-2291.

Review DPC-1 552.08-00-0278, Appendix C. Determine which Started chemistry procedures perform surveillances of the CLAs boron 92 concentrations.

Make the necessary revisions using the basis provided by DPC-1 552.08-00-0278, Appendix C. See Corrective Action 105 and 121 in PIP C-12-2291.

Portions of the Flex equipment deployment paths will traverse Started under existing power/transmission lines located on site. As such, guidance needs to be developed and placed in 93 procedures (FSG's) on how to use the deployment path if power/transmission lines and/or towers have fallen across the path. An evaluation on the impact to deployment and mitigation strategy timelines also needs to be documented.

See Corrective Action 106 in PIP C-12-2291.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-12-049)

b. Open Items added after July 28, 2014.Page 15 Item Overall Integrated Plan Open Item Status NRC Audit question #44 asks about containment pressures Complete during an ELAP event. Based on the Rev. 2 draft of DPC-1552.08-00-0280 (Extended Loss of AC Power (ELAP) -Ice Condenser Containment Response with FLEX Mitigation 94 Strategies), containment pressures for Catawba Units 1 and 2 will exceed design pressures.

Justification for operating above containment design pressures during an ELAP event needs to be addressed by engineering.

See Corrective Action 119 in PIP C-12-2291.

Section 1.4 in Attachment 1 of DPC-1 552.08-00-0280 Rev. 2 Started provides Catawba specific Containment Acceptance Criteria.Based on results in Rev. 2 of DPC-1552.08-00-0280, the following Acceptance Criteria item could be exceeded for a 95 short period of time: 1.4.2 Recovery to less than 212°F in the containment cubicles (i.e., SGs and Pzr) prior to RHR operation is desired, but not necessary.

This Corrective Action should justify exceeding this Acceptance Criteria limit. See Corrective Action 122 in PIP C-12-2291.

A new pressure breakdown orifice will be required in each of Started the Reactor Coolant Pump (RCP) No.1 seal leak off lines upstream of the existing flow orifice (Ref. ECR 8527). See Corrective Action 1 in PIP C-1 5-355.c. Interim Staff Evaluation Open Items (Item Number is associated with the section of the Technical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)Item Interim Staff Evaluation Open Item Status Resolve the conflict between the need to pump the TDAFW Complete (Ref.3.1.2.2.A pump pit before submergence at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and deploying NRC SE generators to power the sump pumps by 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. See Tracker List)Corrective Action 107 in PIP C-12-2291.

Core Sub-Criticality

-Confirm resolution of the generic concern associated 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.

ENCLOSURE CNS Fourth Sixth Month Status Report (Order EA-1 2-049)Page 16 d. Interim Staff Evaluation Confirmatory Items (Item Number is associated with the section of the Technical Evaluation Report performed by Mega-Tech Services, LLC for the NRC)Item Interim Staff Evaluation Confirmatory Item Status Seismic 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 SE as soil liquefaction can proceed. Confirm attributes of Nrc sE deployment routes, including liquefaction potential.

See Corrective Action 109 in PIP C-12-2291.

Procedural Interfaces-Seismic- Confirm completion of 3.1.1.3.A evaluation of potential internal Aux Building flooding and Open appropriate actions and procurement of sump pumps. See Corrective Action 110 in PIP C-1 2-2291.Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to reflux condensation initiation.

This includes specifying an Complete (Ref.3.2.1.1.A acceptable definition for reflux condensation cooling. Confirm NRC SE that 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 further 3.2.1.3.A information regarding decay heat modeling.

Evaluate for NRC SE applicability and implementation.

See Corrective Action 112 in Nrc sE PIP C-12-2291.

Tracker List)Licensee will confirm that the final containment analysis validates that containment spray for temperature/pressure 3.2.3.A control is not required over the long term, or will provide Open procedures to cool the containment.

See Corrective Action 113 in PIP C-12-2291.

Room temperature analyses being performed will provide a 3.2.4.1.A better idea of the environmental conditions expected during the Open event. Confirm completion of analyses and appropriate actions. See Corrective Action 114 in PIP C-12-2291.

Evaluations to address the needs for freeze protection are in 3.2.4.3.A progress.

Confirm completion of evaluations and appropriate Open actions. See Corrective Action 115 in PIP C-12-2291.

Confirm evaluations for additional lighting have been 3.2.4.4.A completed (licensee's open item 45 and 59), and appropriate Open actions 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 SE Tracker List)Offsite Resources-Confirm NEI 12-06 Section 12.2, Guidelines 3.4.A 2 through 10, are addressed with SAFER. See Corrective Open Action 118 in PIP C-12-2291.

ENCLOSURE Page 17 CNS Fourth Sixth Month Status Report (Order EA-12-049) 7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.8 References The following references support the updates to the Overall Integrated Plan described in this attachment.

1) Catawba Nuclear Station, Unit Nos. 1 and 2, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013.2) NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2013.3) First Six-Month Status Report (Order EA-12-049), Catawba Nuclear Station (CNS), Units 1 and 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), Units 1 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 I and 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, Order Modifying 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, Revision 0, dated August 2012 8) Duke Energy's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049), dated October 29, 2012, (ADAMS Accession No. ML12307A023).

9) Catawba Nuclear Station, Units 1 and 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-1 2-049 (Mitigation Strategies) (Tac Nos. Mf 1162 and Mfl 163), Dated February 6, 2014 (ADAMS Accession No. ML13364A173).

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

11) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, Program Management Office Westinghouse Electric Company LLC, October 7, 2013, (ADAMS Accession No. ML13276A555).

ENCLOSURE Page 18 CNS Fourth Sixth Month Status Report (Order EA-12-049)

12) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, Program Management Office Westinghouse Electric Company LLC, dated January 8, 2014, (ADAMS Accession No. ML13276A183).

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

14) NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear 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 Nuclear Reactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice President Nuclear Operations, dated October 7, 2013, (ADAMS Accession No.: ML13276A224).