ML15065A041
| ML15065A041 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/23/2015 |
| From: | Glover R M Duke Energy Corp, Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, RNP-RA/15-0009 | |
| Download: ML15065A041 (23) | |
Text
R. Michael GloverH. B. Robinson SteamElectric Plant Unit 2C ENERGY, Site Vice PresidentDuke Energy Progress3581 West Entrance RoadHartsville, SC 295500: 843 857 1704F: 843 857 1319Mike.Glover@duke-energy.com10 CFR 50.4Serial: RNP-RA/15-0009February 23, 2015ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23
Subject:
Fourth Six-Month Status Report in Response to March 12, 2012, Commission OrderModifying licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events (Order Number EA-12-049)
References:
- 1. Nuclear Regulatory Commission (NRC) Order Number EA-12-049, Order ModifyingLicensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, Dated March 12, 2012, (Agencywide DocumentsAccess and Management System (ADAMS) Accession No. ML12054A735)2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049,Order Modifying Licenses with Regard to Requirements for Mitigation Strategies forBeyond-Design-Basis External Events, Revision 0, Dated August 29, 2012 (ADAMSAccession No. ML12229A174)3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,Revision 0-A, Dated August 20124. Duke Energy Letter, Carolina Power and Light Company and Florida PowerCorporation's Initial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), Dated October 29, 2012,(ADAMS Accession No. ML12307A021)5. Duke Energy Letter, Carolina Power And Light Company's Overall Integrated Plan inResponse to March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), Dated February 26, 2013 (ADAMS Accession No. ML13071A415)
U.S. Nuclear Regulatory CommissionSerial: RNP-RA/15-0009Page 2 of 2Ladies and Gentlemen,On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference1) 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 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, as issued by the NRC, required submission of an initial status report 60 days followingissuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP)pursuant to Section IV, Condition C. Reference 2, as issued by the NRC, endorses industryguidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identifiedin Reference 2. Reference 4 provided Duke Energy's initial status report regarding mitigationstrategies at the Brunswick, Robinson and Shearon Harris Nuclear Power Plants. Reference 5provided Duke Energy's OIP for the H. B. Robinson Steam Electric Plant, Unit No. 2.Reference 1, as issued by the NRC, also required submission of status reports at six-month intervalsfollowing the submittal of the OIP. The purpose of this letter is to provide the fourth six-month statusreport pursuant to Section IV, Condition C.2, of Reference 1. The attached report provides an updateof milestone accomplishments since the last status report, including any changes to the compliancemethod, schedule, or need for relief and the basis, if any.This letter contains no new Regulatory Commitments and no revision to existing RegulatoryCommitments.Should you have any questions regarding this submittal, please contact Mr. Richard Hightower,Manager, Nuclear Regulatory Affairs at (843) 857-1329.I declare under penalty of perjury that the foregoing is true and correct.Executed on /zL32 01'5Sincerely,R. Michael GloverSite Vice PresidentRMG/shc
Enclosure:
Fourth Six-Month Status Report in Response to March 12, 2012 Commission OrderModifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)cc: Ms. M. C. Barillas, NRC Project Manager, NRRMr. K. M. Ellis, NRC Sr. Resident InspectorMr. V. M. McCree, NRC Region II Administrator Enclosure to Serial: RNP-RA/15-0009Page 1 of 21ENCLOSUREH. B. Robinson Steam Electric Plant, Unit No. 2Docket No. 50-261Renewed License No. DPR-23Fourth Six-Month Status Report in Response to March 12, 2012Commission Order Modifying Licenses With Regard toRequirements for Mitigation Strategies forBeyond-Design-Basis External Events(Order Number EA-12-049)
Enclosure to Serial: RNP-RA/15-0009Page 2 of 21H. B. Robinson Fourth Six-Month Status Report1 IntroductionH. B. Robinson Steam Electric Plant, Unit No. 2 developed an Overall Integrated Plan (OIP)(Reference 1), documenting the diverse and flexible strategies (FLEX), in response to NRCOrder EA-12-049 (Reference 2). The Overall Integrated Plan was submitted to the NRC onFebruary 26, 2013. This enclosure provides an update of milestone accomplishmentsincluding any changes to the compliance method, schedule, or need for relief/relaxationand the basis, if any, that occurred during the period from July 29, 2014 to January 30,2015 (hereafter referred to as "the update period"). This update is based on an approvedformal Engineering Change-Evaluation (88926R4) (Reference 6) that is discipline reviewedand design verified.2 Milestone AccomplishmentsThe following milestone(s) have been completed since the development of the OverallIntegrated Plan (Reference 1), and are current as of January 30, 2015:* Complete Strategy Development* Submit Integrated Plan* Complete Modification Identification* Submit First 6-month Status Update" Submit Second 6-month Status Update* Submit Third 6-month Status Update* Complete Staffing Assessment3 Milestone Schedule StatusThe following provides an update to Attachment 2 of the Overall Integrated Plan. Itprovides the activity status of each item, and whether the expected completion date haschanged. The dates are planning dates subject to change as design and implementationdetails are developed.The revised milestone target completion dates do not impact the order implementationdate.RevisedTarget Activity RetMilestone Completion Status TargetDate CompletionDateFebruary Complete Date NotComplete Strategy Development 2013 RevisedSubmit Integrated Plan February Complete Date Not2013 Revised Enclosure to Serial: RNP-RA/1 5-0009Page 3 of 21RevisedTarget Activity RetMilestone Completion Status TargetDate CompletionDateAugust 2013 Complete Date NotRevisedFebruary Complete Date NotSubmit 6-month Status Update 2014 RevisedAugust 2014 Complete Date NotRevisedFebruary Started Date Not2015 RevisedComplete Modification Identification March 2013 Complete Date NotRevisedComplete Modification Development February Started Date Not2015 RevisedFebruary Date NotComplete Equipment Procurement 2015 Started Revise2015 RevisedComplete Equipment PM Development February Started Date Not2015 RevisedDate isComplete FSG Development May 2015 Started RevisedIssue FSGs June 2015 Not Started Date isRevisedComplete Training Development March 2015 Started Date NotRevisedInitiate Training Implementation May 2014 Started Date NotRevisedComplete Training May 2015 Started Date NotRevisedComplete Staffing Assessment November Complete Date Not2014 RevisedIssue Regional Response Center Playbook for RNP May 2015 Started Date NotRevisedComplete Communications Integrated Plan April 2015 Started DateRevisedDate NotComplete Online Modification Implementation May 2015 Started RevisedComplete Outage Modification Implementation June 2015 Started Date Not(R229) RevisedRNP FLEX Implementation Complete June 2015 Not Started Date NotRevise Enclosure to Serial: RNP-RA/15-0009Page 4 of 214 Changes to Compliance MethodThe following summarizes the changes to the strategies as documented in the OverallIntegrated Plan (Reference 1) that were made during the update period. These changesdo not impact RNP compliance with NEI 12-06.1) Change:NRC letter dated February 19, 2014, Interim Staff Evaluation Regarding Overall IntegratedPlan In Response To Order EA-12-049, listed Open Item 3.2.4.8.A which stated:The strategy to use a pre-staged portable diesel generator to supply ac power directly to thevital battery chargers is an alternative approach for satisfying the Mitigating Strategies Order,which relies primarily on portable equipment. Verify that this strategy provides the equivalentlevel of flexibility for responding to an undefined event as would be achieved throughconformance with the endorsed guidance of NEI 12-06.The FLEX Diesel Generators are permanently Pre-Staged in the Reactor Auxiliary BuildingDrumming Room, and as such are not portable. The Interim Staff Evaluation stated that thepre-staging of the FLEX DGs is an alternative approach to NEI 12-06, which describes theuse of portable equipment.Update:H. B. Robinson acknowledged the alternative approach for satisfying the MitigatingStrategies Order in the response to NRC Open Item 3.2.4.8.A which was posted to theRobinson ePortal in a Folder titled RESPONSE TO NRC STAFF OPEN ITEM 3.2.4.8.ACLARIFICATION FOR H. B. ROBINSON NUCLEAR PLANT, UNIT 2 MITIGATIONSTRATEGIES INTEGRATED PLAN, Phase 2 Electrical Strategy, Revision 1.Justification:The use of pre-staged FLEX DGs allows re-energizing the critical plant electrical loadsmore quickly and efficiently than the use of portable generators that would have to betransferred from the 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 hasan access path that will be clear after the initiating event. Although the pre-staged FLEXDGs are not portable as discussed in NEI 12-06, the overall strategy has advantages thatoutweigh the lack of portability of the FLEX DGs. The FLEX DGs have been pre-staged toprovide a significant reduction in the amount of large portable equipment required to betransported and setup in the first hours following a beyond-design-basis external event overother strategies that were evaluated. The strategy also minimizes risk by utilizing robustequipment that is located within a robust structure that is adequately protected from allexternal events. The opportunity to improve response times, simplify required manualactions, and to utilize robust equipment in robust locations justifies the consideration of thisalternative strategy.
Enclosure to Serial: RNP-RA/15-0009Page 5 of 21Documentation:0 EC EVAL 88926 Rev. 4, FLEX Strategies and Implementation Plan (Reference 6)2) Changqe:The RNP Overall Integrated Plan dated February 26, 2013 (Reference 1), Item 7 describedthe following strategy for reactor core cooling and heat removal with the SGs unavailable inModes 5 and 6:The primary strategy to supply power to the charging pumps is by energizing 480Vswitchgear El or E2. The switchgear will be powered by modifying the current 480Vswitchgear El or E2 to include connection points near the existing diesel generator thatwill be capable of switching between the existing diesel generator power feeds and theportable FLEX generator power feeds, (Open Item 26). If El or E2 are unavailable, thesecondary method will entail utilizing a manual transfer switch with portable generatorconnections that will be installed for a charging pump, (Open Item 27). The source ofwater for the charging pumps is the RWS T. Currently, the RWS T is seismically qualified,but is not protected from wind or missiles. The RWST will be hardened to protect againstthese hazards, (Open Item 41).Update:The RNP First Six-Month Status Report dated August 28, 2013 described changes to thisstrategy that are still feasible and valid. A refinement to the strategy is to use the SpentFuel Pool (SFP) as a possible borated water source for RCS makeup and cooling in Modes5 and 6 via an Emergency Cooling Connection (ECC) in the SFP Cooling System anddeliver through pre-staged connections in the safety injection lines using a portablepumper. Installation of the FLEX connections will be controlled using the shutdown riskmanagement process as described in the Shutdown Modes Position Paper endorsed bythe NRC.The RWST remains a viable seismically protected source of borated water, but will not beprotected against the RNP high wind and missile hazard as noted in the same item of theFirst Six-Month Status Report. Open Item 41 has been deleted.Justification:The SFP is a viable source of borated water and can be replenished using existing SFPmakeup strategies (EDMG-01 1, SFP Casualty (Reference 12)) and manual addition ofboric acid to the SFP. Calculations in EC95216 can be extrapolated to show that theaddition of approximately 100 lbs. of boric acid per 1000 gallons of SFP makeup issufficient to maintain shutdown margin in the SFP and the RCS. The SFP containsapproximately 615 gallons of borated water per inch of level (OP-910, Spent Fuel PitCooling And Purification System (Reference 13)), with at least 4 feet of water availableabove the ECC connection suction source, or a usable volume of 29,520 gallons. The SFPTransfer canal has a normal volume of 40,753 gallons. Injection flow to remove decay heatis less than 150 gpm when the RCS is in a reduced inventory vented condition.
Enclosure to Serial: RNP-RAI15-0009Page 6 of 21Documentation:* EC EVAL 88926 Rev. 4, FLEX Strategies and Implementation Plan (Reference 6)* EDMG-01 1, Spent Fuel Pool Casualty, Rev. 14 (Reference 12)* OP-910, Spent Fuel Pit Cooling And Purification System (Reference 13)3) Change:As a result of the NTTF 2.3 Seismic Hazard Re-Evaluation, RNP has taken action to stagean additional AFW strategy.Update:Two portable pumps have been procured, each capable of 300 gpm at 1000 psig; thiscombination eliminates the need to depressurize the SGs in the event the backup AFWfeed capability is needed due to an AFW interruption early in the ELAP transient resultingfrom a seismic event. The strategy is designed to provide a minimum of 900 psi at 240gpm for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following a beyond design basis seismic event; 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> forERO to arrive and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for ERO to align other water source(s). The alternate source offeedwater is stored in six 20,000 gallon tanks aligned to the suction of the two pumps. Fouradditional 20,000 gallon tanks are staged at the lake front.Justification:Engineering Change 95263, Fukushima AFW, provides an alternate source of Feedwaterto the Steam Generators via a new high pressure pump skid and a new source of water inresponse to Fukushima Seismic concern for a beyond design basis seismic event.Documentation:* EC EVAL 88926 Rev. 4, FLEX Strategies and Implementation Plan (Reference 6)* EC 95263, Fukushima AFW (Reference 14)5 Need for Relief/Relaxation and Basis for the Relief/RelaxationRNP expects to comply with the order implementation date and no relief/relaxation is requiredat this time.
Enclosure to Serial: RNP-RAI15-0009Page 7 of 216 Open ItemsRNP Duke Energy confirms that the FLEX strategy station battery run-time was calculatedin accordance with the IEEE-485 methodology using manufacturer discharge test dataapplicable to the licensee's FLEX strategy as outlined in the NEI white paper on ExtendedBattery Duty Cycles (Ref 8). This Generic Open Item is complete and was included in theRNP Second Six-Month Status Report (Ref 3).The Electric Power Research Institute (EPRI) Report 3002000623 entitled "NuclearMaintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment,"(Ref 9) continues to be evaluated by RNP Duke Energy. This is Open Item 93 in Section6.a of this report.RNP Duke Energy will incorporate the guidance provided in the Westinghouse positionpaper entitled "Westinghouse Response to NRC Generic Request for Additional information(RAI) on Boron Mixing in support of the Pressurizer Water Reactor Owners Group(PWROG)" (ADAMS Accession Number ML1 3235A1 35) (Ref 10) with clarifications. Thiswas identified as Open Item 3.2.1.8.B in the ISE. The Open Item has been dispositionedand the RNP response is uploaded to the Robinson ePortal.RNP Duke Energy will incorporate the supplemental guidance provided in the NEI positionpaper entitled "Shutdown/Refueling Modes" to enhance the shutdown risk process andprocedures (Ref 11). This is Open Item 143 in Section 6.b of this report.The MAAP4 and CENTS computer code Generic Open items do not apply to RNP.The following tables provide a summary status of the Open Items. The table under Section6.a. provides the open items that were previously identified in the original OIP submitted onFebruary 28, 2013 and in the first, second, and third six-month status reports submitted by(Ref 1, 2, 3, 4). The table under Section 6.b. provides a list of open items that were addedafter July 30, 2014.a. Open Items Documented in Overall Integrated Plan and in first and second six-monthupdate.Item # Open Item Description Status1. A Regional Response Centers (RRC) playbook will be developed to support StartedRNP during beyond design basis events.2. Figure(s) (site plot plan) showing FLEX equipment storage locations and Completedeployment routes will be provided.3. Deployment strategies will be incorporated into an administrative program. NotStarted4. RNP will implement the programmatic controls in accordance with NEI 12-06. Started Enclosure to Serial: RNP-RAI15-0009Page 8 of 21Item # Open Item Description Status5. Equipment associated with these strategies will be procured as commercial Startedequipment with design, storage, maintenance, testing, and configuration controlin accordance with NEI 12-06, Section 11.1.6. The unavailability of equipment and applicable connections that directly perform Starteda FLEX mitigation strategy will be managed using plant equipment controlguidelines developed in accordance with NEI 12-06, Section 11.5.7. Programs and processes will be established to ensure personnel proficiency in Startedthe mitigation of beyond-design-basis events as developed and maintained inaccordance with NEI 12-06, Section 11.6.8. The FLEX strategies and basis will be maintained in overall FLEX basis Starteddocuments.9. Existing plant configuration control procedures will be modified to ensure that Notchanges to the plant design, physical plant layout, roads, buildings, and Startedmiscellaneous structures will not adversely impact the approved FLEXstrategies in accordance with NEI 12-06, Section 11.8.10. Applicable training initiated through the Systematic Approach to Training (SAT) Startedprocess will be completed prior to the implementation of FLEX.16. A seismically qualified pressure source capable of supplying SG PORV Strategyoperation will be installed. Deleted17, Site-specific procedures and/or FSGs will be developed using industry guidance Startedto address the criteria in NEI 12-06, Section 11.4.18, A portable pump will be procured and pre-staged near the condensate pump Pre-area. stagingStrategyDeleted20. Valve C-66 to be modified to include FLEX connections. Started22. A tee-connection will be added to the C AFW Pump discharge. Complete23. Sufficient nitrogen tanks (for SG PORV) for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coping duration will be Startedrelocated to a protected location.24. The existing connection point for the portable nitrogen tank will be modified to Strategyinclude quick-connects. Deleted25. The SI accumulator isolation valves will be re-powered via switchgear El or E2 Startedwith portable diesel generators.
Enclosure to Serial: RNP-RA/15-0009Page 9 of 21Item # Open Item Description Status26. Modify the current 480V switchgear El or E2 and existing diesel generator s to Startedinclude portable diesel generator connection points capable of switchingbetween the existing diesel generator power feeds and portable FLEXgenerator power feeds.28. To provide primary and alternate connections for portable pumps, an alternate Startedmechanical tee-connection will be provided.29. Mechanical connections will be available for the south and north SW headers to Startedallow connection of a portable pump.30. N+1 portable pumps will be procured and stored in a robust structure in a Pre-protected location near the intake structure in support of Item 29 above, stagingStrategyDeleted31. During Modes 5 and 6, a portable pump will be used to take suction from the StartedRWST or SFP or portable tanker and discharge to the SI header.32. Primary and alternate mechanical FLEX connections will be added to the SI Startedheader.33. Drain valve (SI-837) at the base of the RWST will be modified to align it to the Startedstandardized connection type.34. Structures to provide protection of the FLEX equipment will be built prior to the StartedFLEX implementation date.35. The RNP procedures and programs must be developed to address storage Notstructure requirements, deployment path requirements, and FLEX equipment Startedrequirements relative to the hazards applicable to RNP.36. Necessary modifications will be made to existing SSC connections to facilitate StrategyFLEX equipment deployment. Deleted37. Necessary modifications will be made to existing onsite fences, structures or Strategysecurity parameters to facilitate flex equipment deployment. Deleted38. The equipment connection points will be designed to withstand the applicable Strategyexternal hazards. Deleted39. The means for connecting the Phase 3 generator will be identified based on the Strategyselected onsite location of the generator. Deleted40. Low leakage Reactor Coolant Pump (RCP) seals will be installed. Started42. Actual size of generator to be determined at a later time. Complete Enclosure to Serial: RNP-RA/15-0009Page 10 of 21Item # Open Item Description Status43. A containment over-pressure and over-temperature analysis will be performed. Complete44. The resolution of method for SFP level determination is being addressed by the Startedactions taken in response to Order 12-051.45. To maintain SFP inventory, a portable pump equipped with suction and Strategydischarge lines and compatible hose connections will be available. Deleted46. The alternate strategy for SFP cooling is to provide makeup via installed SFP Startedpiping which will require modifications. One of two Emergency CoolingConnections (ECCs) can be used for external filling to robust piping. Theseconnections will be used with portable pumps to draw water from diverselocations directly into the pool. This change was reported in the Second Six-Month Update.47. Alternate methods for powering the 480V MCC 5 and 6 require either bus Strategymodification to accommodate the diesel generator connector, or the addition of Deleteda new diesel generator connection integrated into vertical panel design.50. Applicable areas of the Turbine Building will be analyzed or hardened to provide Startedan adequate level of assurance of critical instrumentation availability.51. Calculations will be performed for extending the time before HVAC is needed to Startedbeyond eight hours.53. Additional portable lighting will be procured to facilitate implementation of the StartedFLEX strategies.54. Strategies to mitigate the loss of communications systems will be developed per StartedNEI 12-06 Section 3.2.2(8).55. Staffing studies will be performed in accordance with NRC RFI and NEI 12-01 Completeto ensure adequate staffing is available to support, install, and operate FLEXequipment in the time necessary.56. Phase 2 battery coping will require portable diesel generators to power the Completebattery chargers and the Battery Room exhaust fans in order to removehydrogen gas accumulation during charging.57. Manual disconnect switches, compatible for quick portable diesel generator Startedconnection, will be installed to directly power the battery chargers.58. Permanent cable and raceway will be installed to make cable deployment Strategydirectly to the battery chargers feasible. Deleted60. Manual transfer switches with the ability to quick-connect to portable 5kW diesel Strategygenerators will be installed to provide ventilation to the Battery Rooms. Deleted Enclosure to Serial: RNP-RAI15-0009Page 11 of 21Item # Open Item Description Status61. An analysis of HVAC requirements for operating equipment will be performed Startedbased on area heat-up times without cooling available for indefinite coping.62. Portable fan blowers/generators will be procured and used to provide forced Completeconvection.63. RNP will acquire a fuel pumping vehicle/trailer that can be used to extract and Completedeliver fuel oil.64. An analysis to determine the fuel consumption rate of all portable Completegenerators/equipment will be performed.65. Provisions will be made for an offsite fuel delivery to RNP before all onsite fuel Completeis depleted.66. Results of the PWROG task will be used in determining the minimum flow rate Completeand pumping capacity required for borated water makeup.67. Portable equipment maintenance will be performed in accordance with the Notrequirements of NEI 12-06, Section 11.5. Started68. An analysis will be performed to determine the radiation protection equipment Completerequirements.69. An analysis will be performed to determine the commodities requirements. Complete70. Transportation equipment will be provided to move large skid/trailer mounted Completeequipment provided from off-site.71. Additional or revised conceptual sketches will be provided in future updates as Completeengineering packages mature from conceptual design to final design.72. Develop procedures, references, and tables to determine key parameters using Completea portable DVM in the instrument racks.73. Order EA-12-049, requires that status reports be submitted on six month Completeintervals, following the submittal of the Overall Integrated Plan, until complianceis achieved. Provide the six month status report to licensing for processing.74. Implement the RNP integrated plan for Order EA-12-049 as stated in the Startedsubmittal. If plans change, ensure that the changes are reflected in future sixmonth status reports that are required to be submitted per the Order. EnsureOpen Items listed in RNP-RA/13-0022 (i.e., 588978), are addressed.79. Revise SAMG and other RNP Emergency procedures to include FLEX Startedresponse and related setpoints.Note: This activity / scope does not include revision of other site procedures asthey will be revised as part of the mods that impact them. Mod estimatesinclude budget for associated procedure revisions.
Enclosure to Serial: RNP-RAI15-0009Page 12 of 21Item # Open Item Description Status80. FI-6416 installed per EC83801 is a safety related instrument and is currently Startedused in DSP-002, "Hot Shutdown Using the Dedicated/Alternate ShutdownSystem" Attachment 6. Ensure use of this instrument is accounted for in thenew FSGs.81. Ensure no credited SBO circuits are removed from operation when determining Completewhich additional loads can be shed for a deep load shedding strategy. Refer to8S19-P-101, Station Blackout Coping Analysis Report, Table 1 for credited SBOequipment.82. When new load shedding strategies are developed, perform manual action Startedwalk-throughs and validation (simulated) to demonstrate the proposed operatoractions are feasible and achievable.86. Re-evaluate SI Accumulator Isolation Valve closure as a phase 2 strategy Complete(determine how to get power to the valves by possibly using the battery chargerdiesel generators.87. Loss of heat tracing on significant required instrumentation sensing lines has Startedbeen identified. The heat tracing is not safety related and it is not robust.Develop strategies to address the loss of heat tracing on instrument sensinglines.88. Verify that AC power is not required for access to all areas of the plant in an CompleteELAP event.89. Develop an ELAP boration strategy that includes rates, times, and SDM Completecalculations for all times in core life.90. Develop a one-line electrical sketch of the RNP battery bus power scheme Completeshowing connections for the FLEX portable equipment to be used in an ELAPevent.91. Describe how electrical isolation will be maintained such that (a) Class 1 E Startedequipment is protected from faults in portable/FLEX equipment and (b) multiplesources do not attempt to power electrical buses.92. Develop a formal strategy for refueling of all FLEX portable equipment during an CompleteELAP event. Explain how fuel quality will be assured if it stored for extendedperiods of time. See Open Item 64 also. Include the strategy in FSG-005.93. Provide details in the OIP of how RNP will incorporate the EPRI industry Notprogram for maintenance and testing of FLEX electrical equipment such as Startedbatteries, cables, and diesel generators.94. Discuss the reliability of the SDAFWP with respect to the following: Not-The steam traps are all ganged into one line to the condenser that has the Startedpotential to be pinched or crimped in an event and render the SDAFWP Enclosure to Serial: RNP-RAI15-0009Page 13 of 21Item # Open Item Description Statusinoperable.-The SDAFWP miniflow recirculation line has the same exposure to beingpinched or crimped in an event and render the SDAFWP inoperable.95. Evaluate the SG PORVs for an Uncontrolled Cooldown scenario as follows: Complete(a) Clarify whether the ADV or upstream associated piping is a safety-relatedsystem, protected from external events such as tornadoes. If not, addressthe following questions:(b) Clarify whether damage to an ADV or upstream associated piping couldoccur during an ELAP that would result in an uncontrolled cooldown of thereactor coolant system and provide a basis for the response.(c) Clarify whether postulated damage would be limited to a single ADV and/orassociated piping, or whether failures could be postulated resulting in anuncontrolled cooldown affecting both steam generators, and provide a basisfor the response.(d) If ELAP scenarios involving the uncontrolled cooldown of one or moresteam generators may be postulated, describe key operator actions thatwould be taken to mitigate these events.(e) If ELAP scenarios involving the uncontrolled cooldown of one or moresteam generators may be postulated, provide analysis demonstrating thatthe intended mitigating actions would lead to satisfaction of the requirementsof Order EA-12-049 for these cases.(f) As applicable, if the operator actions to mitigate an ELAP event involving anuncontrolled cooldown results in an asymmetric cooldown of the reactor coolantsystem, address the consequences of the asymmetric cooldown on the mixingof boric acid that is added to the reactor coolant system to ensure sub-criticality.96. The issue of how to control critical equipment without control power must be Startedassessed as part of the response to load shedding.97. Purchase portable gas or propane heaters to replace the 480 VAC heaters used Strategyfor freeze protection in cold weather operations. The portable heaters will be Deletedstored in the FLEX storage facility.98. Provide documentation of high wind and missile protection for the components Notassociated with EC94741. Started99. Procure a diesel driven sump pump to dewater the Intake SW Strainer Pit Strategyfollowing a rain event. Deleted100. Evaluate the Rad Waste building to determine if it is robust against the high Completewind and missile hazard.
Enclosure to Serial: RNP-RA/15-0009Page 14 of 21Item # Open Item Description Status101. Develop a formal calculation to determine the time to boil off the SFP inventory Completeto 10' above the fuel racks and to the top of the fuel racks assuming:0 1/3 Core Offload 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after refuelingMode 6 Full Core Offload102. Evaluate the Lake Robinson dam to determine if it is robust against the high Completewind and missile hazard.103. Determine if it is required to store HazMat equipment in the FLEX storage Completefacility to cope with an acid or caustic tank rupture/spill.104. Perform walkdowns and simulations to verify and validate that time critical Notactions required for mitigating strategies for core cooling are feasible. Started105. Perform walkdowns and simulations to verify and validate that time critical Notactions required for mitigating strategies for RCS boration and inventory are Startedfeasible.106. Perform walkdowns and simulations to verify and validate that time critical Completeactions required for mitigating strategies for SFP cooling are feasible.107. Revise drawing Z25R2 to specify all 'A' staging areas, deployment routes from Completestorage to staging, equipment to be staged in each area, and distance to therelated FLEX connection points.108. Add a section to the FLEX/Fukushima Program document to list all SSCs Notaffected by FLEX implementation. See EC 88926, Rev. 2, Design Verification StartedComment #81.109. Determine which of the following instruments located in the Turbine Class 1 Bay Completeare critical to FLEX response strategies for core cooling.Secondary Control Panel on the mezzanineLI-607A-2 LI-607B-2LI-607C-2 LI-607D-2PI-607E-2 LI-1454CTI-410B TI-413BInstruments, LI-477A, 487A and 497A on the mezzanineInstrument FI-6416 on the mezzanineMain Steam Line Pressure transmitters Cabinet on the mezzaninePT-474 PT-475PT-484 PT-485PT-495 PT-496Ensure critical instruments are included in EC 90627 before the 30% DesignReview.
Enclosure to Serial: RNP-RA/15-0009Page 15 of 21b. Open Items added after January 28, 2014. This table includes Open and ConfirmatoryItems that were identified in the NRC Interim Staff Evaluation and Audit Report (Reference7). Items with a status of Complete are posted on the H. B. Robinson ePortal.Item # New Open, ISE Open, and Confirmatory Items Status110. Open Item 3.2.1.8.B CompleteCore Sub-Criticality -Verify that RNP will apply the generic resolution for boron mixingunder natural circulation conditions potentially involving two-phase flow, in accordancewith the PWROG position paper, dated August 15, 2013, subject to the additionalconditions provided in the NRC endorsement letter dated January 8, 2014; oralternatively, justify the boric acid mixing assumptions that will ensure adequateshutdown margin exists through all 3 phases of an ELAP event.111. Open Item 3.2.4.8.A CompleteThe strategy to use a pre-staged portable diesel generator to supply ac power directly tothe vital battery chargers is an alternative approach for satisfying the MitigatingStrategies Order, which relies primarily on portable equipment. Verify that this strategyprovides the equivalent level of flexibility for responding to an undefined event as wouldbe achieved through conformance with the endorsed guidance of NEI 12-06.112. Confirmatory Item 3.1.1.1.A CompleteConfirm that the final design of the FLEX equipment storage building and locationensures that FLEX equipment such as pumps and power supplies will be secured, andthat stored equipment and structures will be protected from seismic interactions, highwind events, and extreme temperature conditions.113. Confirmatory Item 3.1.1.2.A CompleteConfirm that the vehicles and equipment provided for debris removal will be protectedfrom seismic events.114. Confirmatory Item 3.1.1.2.B.1 StartedConfirm that all site travel paths and deployment routes for FLEX equipment have beenanalyzed to ensure survivability following a seismic event.115. Confirmatory Item 3.1.1.2.B.2 StartedConfirm that the deployment strategies for FLEX equipment ensure that connectionpoints are protected and that key areas are accessible through seismically robuststructures following a seismic event.116. Confirmatory Item 3.1.1.3.A StartedConfirm that guidance will be made available to operators on critical actions to performwhile establishing alternate indication for key instruments and on how to control criticalequipment without control power.117. Confirmatory Item 3.1.1.4.A CompleteOff-Site Resources -Confirm the identification of the local staging area, the evaluationof access routes, and the method of transportation to the site for the RRC providedequipment.
Enclosure to Serial: RNP-RA115-0009Page 16 of 21Item # New Open, ISE Open, and Confirmatory Items Status118. Confirmatory Item 3.1.5.2.A CompleteConfirm that potential problems with door access, such as sheet metal expansion orswollen door seals due to high temperature conditions, will be mitigated.119. Confirmatory Item 3.2.1.A CompleteConfirm that the generic ELAP analyses in WCAP-1 7601 -P, "Reactor Coolant SystemResponse to the Extended Loss of AC Power Event for Westinghouse, CombustionEngineering and Babcock & Wilcox NSSS Designs," (ADAMS Accession Nos. ML13042A011 and ML 13042A013, non-public), are applicable to RNP, and specifically,that the important parameters and assumptions used are representative andappropriate for simulating the ELAP transient.120. Confirmatory Item 3.2.11.B CompleteConfirm that the RNP FLEX mitigation strategies address each of the 7 PWROGrecommendations listed in Section 3.2 of WCAP-17601-P. This information shouldinclude the rationale for whether each issue is applicable to the plant, how theapplicable recommendations have been considered in the ELAP coping analysis, andhow they will be implemented in the RNP mitigating strategies.121. Confirmatory Item 3.2.1.C CompleteConfirm that the SG PORVs will be provided with motive force and adequately protectedfrom hazards so that they can function as required for the RNP mitigating strategies.122. Confirmatory Item 3.2.1.E NotConfirm that the configurations of the SDAFW pump steam traps and mini-flow Startedrecirculation line are such that the pump will not be rendered inoperable if the lines aredamaged.123. Confirmatory Item 3.2.1.1 .A CompleteConfirm that the application of the NOTRUMP code for the ELAP analysis for RNP islimited to the flow conditions prior to reflux condensation initiation. This includesspecifying an acceptable definition for reflux condensation cooling.124. Confirmatory Item 3.2.1.2.A CompleteConfirm that the impacts of the Westinghouse 10 CFR Part 21 report, "Notification ofthe Potential Existence of Defects Pursuant to 10 CFR Part 21," dated July 26, 2013(ADAMS Accession No. ML 13211A1 68) on the use of the low seal leakage rate havebeen addressed in the ELAP analysis for RNP. (Note: The TER, on page 27 of 60, listedan incorrect ADAMS accession number for the August 16, 2013, PWROG positionpaper on RCP seal leakage; it should be ML 13235A 151).125. Confirmatory Item 3.2.1.2.B CompleteIf the RCP seals are changed to the newly designed Generation 3 SHIELD seals ornon-Westinghouse seals, confirm that acceptable justification is provided for the sealleakage rates used in the revised ELAP analysis for RNP.126. Confirmatory Item 3.2.1.3.A CompleteConfirm that appropriate methods and assumptions are used in the decay heatcalculations for RNP for an ELAP event. This should include justification for the modeland the values used for the key parameters.
Enclosure to Serial: RNP-RN15-0009Page 17 of 21Item # New Open, ISE Open, and Confirmatory Items Status127. Confirmatory Item 3.2.1.6.A CompleteConfirm that the revised analyses for makeup rates, boration strategies, and corecooling times based on the use of low leakage RCP seals are adequately justified andappropriately reflected in the sequence of events timeline.128. Confirmatory Item 3.2.1.6.B CompleteConfirm that the revised safety injection accumulator isolation strategy will ensure timelyisolation to prevent nitrogen injection into the RCS.129. Confirmatory Item 3.2.1.8.A CompleteConfirm that the revised boration strategies ensure that acceptable shutdown marginwill be maintained throughout all phases of an ELAP event.130. Confirmatory Item 3.2.1.9.A StartedConfirm that the design requirements and supporting analyses for the portable FLEXpumps show that they are capable of performing their respective functions as credited inthe mitigating strategies.131. Confirmatory Item 3.2.3.A CompleteConfirm that the RNP strategies for maintaining containment are consistent with thecontainment pressure and temperature analysis for all 3 phases of an ELAP event.132. Confirmatory Item 3.2.4.1 .A CompleteConfirm that cooling water will be supplied, as needed, to plant equipment credited toperform a mitigation strategies function under ELAP conditions.133. Confirmatory Item 3.2.4.2.A StartedConfirm that actions necessary to ensure equipment functionality and personnelhabitability during an ELAP event are appropriately incorporated into the FLEXstrategies, based on the analyses of the impact of high temperatures on variousareas/compartments {main control room, battery room, SDAFW pump room).134. Confirmatory Item 3.2.4.2.B StartedConfirm that adequate ventilation is provided to the battery rooms to preventunacceptable levels of hydrogen accumulation.135. Confirmatory Item 3.2.4.2.8 StartedConfirm that appropriate actions are implemented to address the loss of heat tracing oninstrument lines under ELAP conditions.136. Confirmatory Item 3.2.4.4.A StartedThe NRC staff has reviewed the licensee communications assessment (ADAMSAccession Nos. ML 12311A299 and ML 13058A045) and has determined that theassessment is reasonable (ADAMS Accession No. ML 13105A413). Confirm thatupgrades to the site's communications systems have been completed.137. Confirmatory Item 3.2.4.7.A CompleteConfirm that alternate sources of cooling water, such as Lake Robinson or thedischarge canal, have been evaluated for the potential impacts of reduced water quality,and that actions to address water quality have been developed, as needed to ensurethe successful implementation of the RNP mitigating strategies.
Enclosure to Serial: RNP-RA/15-0009Page 18 of 21Item # New Open, ISE Open, and Confirmatory Items Status138. Confirmatory Item 3.2.4.9.A CompleteConfirm that the methods and sources for refueling the FLEX equipment are consistentwith the analyzed fuel consumption rates of all portable generators and pumpingequipment.139. Confirmatory Item 3.2.4.10.A CompleteConfirm the sizing calculations for the FLEX DGs to show that they can supply the loadsassumed in Phases 2 and 3.140. Confirmatory Item 3.2.4.10.B CompleteConfirm that the ELAP load shed analysis has adequately accounted for the loss offunctions and has addressed any impacts on defense in depth and redundancy.141. Confirmatory Item 3.3.1.A NotStartedConfirm that the licensee's implementation of maintenance and testing guidance forFLEX equipment conforms to the generic approach endorsed by the staff, or constitutesan acceptable alternate approach. The generic approach is provided in the EPRItechnical report on preventive maintenance of FLEX equipment, submitted by NEI byletter dated October 3, 2013 (ADAMS Accession No. ML 13276A573). The NRC staffsendorsement letter is dated October 7, 2013 (ADAMS Accession No. ML 13276A224).142. Confirmatory Item 3.4.A CompleteConfirm that NEI 12-06, Section 12.2, guidelines 2 through 10, regarding minimumcapabilities for offsite resources, have been adequately addressed.143. Duke Energy will incorporate the supplemental guidance provided in the NEI position Startedpaper entitled "Shutdown/Refueling Modes" to enhance the shutdown risk process andprocedures.144. Incorporate the SG cooldown MSIV bypass strategy (EPP-1, Attachment 4) into the new NotECA-0.0 (ELAP) or an FSG. Started Enclosure to Serial: RNP-RA/15-0009Page 19 of 21c. Open Items added after July 30, 2014. This table includes New Open Items that wereidentified during the implementation process.Item # New Open Items Status145. Develop a Final Implementation Plan. This is a formal NRC submittal due 60 days after NotFLEX implementation is declared at RNP. Include a cross-reference matrix of each Startedstrategy, required N+1 equipment, primary and alternate connections, NEI 12-06requirements, related ECs, and other related information for the final implementationplan.146. Complete the owners review of the calculations performed under Westinghouse/Duke Startedcontract no. 696451.147. Revision 4 of EC88926 should include the following assumptions: Complete" assumed CST level at T=O for an ELAP event is 90% (normal level at power basedon chemistry concerns)* minimum level prior to implementing FSGs to access alternate coolant sources is20% per EC94474.148. Determine if External Containment Cooling (spraying the containment dome) is a Completefeasible containment cooling strategy.149. Submit a report to the NRC describing full compliance with the EA-12-049 Order within Not60 days of implementation. Implementation is scheduled for R0229 prior to entering StartedMode 4 on unit startup. The report should be formatted according to the NEI templatein effect at the time of implementation.
Enclosure to Serial: RNP-RAI15-0009Page 20 of 217. ReferencesThe following references support the updates to the Overall Integrated Plan described inthis attachment.1. Duke Energy Letter, Carolina Power and Light Company's Overall Integrated Plan inResponse to March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated February 26, 2013 (ADAMS Accession No. ML13071A415).2. Duke Energy Letter, H. B. Robinson Steam Electric Plant, Unit No. 2, First Six-MonthStatus Report in Response to March 12, 2012, Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 28, 2013 (ADAMS Accession No.ML13252A243).3. Duke Energy Letter, H. B. Robinson Steam Electric Plant, Unit No. 2, Second Six-MonthStatus Report in Response to March 12, 2012, Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated February 24, 2014 (ADAMS Accession No.ML14063A283)4. Duke Energy Letter, H. B. Robinson Steam Electric Plant, Unit No. 2, Third Six-MonthStatus Report in Response to March 12, 2012, Commission Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 26, 2014 (ADAMS Accession No.ML14253A161)5. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirementsfor Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012(ADAMS Accession No. ML12054A735).6. EC EVAL 88926 Rev. 4, FLEX Strategies and Implementation Plan7. H.B. Robinson Steam Electric Plant, Unit 2 -Interim Staff Evaluation Regarding OverallIntegrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NO.MF0720), dated 2/19/14 (ADAMS Accession No. ML13365A291).8. 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 No. ML13241A188)9. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated October 7, 2013, (ADAMS Accession No. ML13276A22410. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Jack Stringfellow, PWROG PWR Owners Group, ProgramManagement Office Westinghouse Electric Company LLC, dated January 8, 2014,(ADAMS Accession No. ML1 3276A1 83)11. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate Office of NuclearReactor Regulation, to Nuclear Energy Institute, Mr. Joseph E. Pollock, Vice PresidentNuclear Operations, dated September 30, 2013, (ADAMS Accession No. ML13267A382)
Enclosure to Serial: RNP-RA/15-0009Page 21 of 2112. EDMG-011, Spent Fuel Pool Casualty13. OP-910, Spent Fuel Pit Cooling And Purification System14. EC 95263, Fukushima AFW