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Notification of Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events.
	ML16028A194
Person / Time
Site:	Oconee
Issue date:	01/21/2016
From:	Batson S; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, ONS-201 -002
	Download: ML16028A194 (11)
	v • d • e

(~DUKEVice DUKSott .President B.tson ENEGY°Oconee Nuclear Station Duke Energy ONOlVP j 7800 Rochester Hwy Seneca, SC 29672 ONS-201 6-002 o: 864.873.3274

f. 864.873. 4208 Scott.Batson~duke-energy.com January 21, 2016 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

Oconee Nuclear Station, Unit 2 Docket Number 50-270 Renewed License Number DPR-47

Subject:

Notification of Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" for Oconee Nuclear Station, Unit 2

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, OrderModifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (Accession No. ML12054A735).

2. Oconee Nuclear Station's 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 (Accession No. MLI13063A065).

3. Oconee Nuclear Station, Units 1, 2, and 3 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 And EA-12-051 (TAC NOS. MF0782, 0783, 0784, 0785, 0786, AND 0787), dated October 6, 2015 (Accession No. ML15259A387).

Ladies and Gentlemen On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" (Reference 1).

The Order required holders of operating reactor licenses issued under 10 CFR 50 to submit an Overall Integrated Plan (OIP) which describes how compliance with the requirements of the Order will be achieved. The OIP for Oconee Nuclear Station (ONS) pertaining to Order EA-12-049 was submitted by letter dated February 28, 2013 (Reference 2).-

Order EA-1 2-049,Section IV.A.2 requires completion of full implementation to be no later than two (2) refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.Section IV.C.3 requires that Licensees report to the NRC when full

ONS-201 6-002 January 21, 2016 Page 2 compliance is achieved. Thus for ONS Unit 2, full implementation was required prior to restart from the End-of-Cycle 27 (EOC27) refueling outage.

Unit 2 entered Mode 2 (Startup) following the EOC27 refueling outage, on November 11, 2015 which established the full compliance date for Order EA-12-049. As such, ONS Unit 2 is in full compliance with Order EA-12-049 as demonstrated by this submittal and other docketed correspondence concerning this Order.

Attachment I provides a brief summary of the key elements associated with compliance to Order EA-12-049 for ONS Unit 2. The open and pending items from the NRC Audit Report (Reference 3) are provided in Attachment 2 with a summary response for each item to support closure. As such, Duke Energy considers these items complete, pending NRC closure.

In support of the ongoing NRC Audit process, Duke Energy will continue to work with the NRC staff for issuance of a combined Safety Evaluation (SE) for the Mitigation Strategies Order.

This letter contains no new or revised Regulatory Commitments.

Should you have any questions regarding this submittal, please contact David Haile with Oconee Regulatory Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 21, 2016.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station Attachments:

1. Oconee Nuclear Station, Unit 2, Summary of Compliance Elements for Order EA-1 2-049

2. Oconee Nuclear Station, Unit 2, NRC Audit Report Open and Pending Items

ONS-201 6-002 January 21, 2016 Page 3 cc:

Ms. Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James R. Hall, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike, M/S O-8G9A Rockville, MD 20852-2746 Mr. Jeffery Whited (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station

ONS-201 6-002 January 21, 2016 Page 4 bxc:

T.P. Gillespie (EC07H)

T.D. Ray (ON01 VP)

J. E. Burchfield (ON01 VP)

C.T. Dunton (ON01 VP)

T.L. Patterson (ON01 VP)

0. C. Jones (ON01 El)

C.J. Wasik (ON03RC)

D.C. Haile (ON03RC)

M.C. Nolan (EC05P)

C.J. Thomas (ECO1T)

D.H. Llewellyn (EC09E)

G.D. Robison (EC09E)

P. F. Guill (EC01T)

ONS Master File (ON02DM, File OS 801.01)

ELL (EC2ZF)

ATTACHMENT 1 OCONEE NUCLEAR STATION, UNIT 2

SUMMARY

OF COMPLIANCE ELEMENTS FOR ORDER EA-12-049 The elements identified below, along with the Overall Integrated Plan (OIP) (Reference A2), the 6-Month Status Reports (References A4 thru A8), and additional docketed correspondence, demonstrates Oconee Nuclear Station (ONS), Unit 2 compliance with Order EA-12-049 (Reference Al ).

STRATEGIES - COMPLETE ONS, Unit 2 strategies are in compliance with Order EA-12-049. All strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items have been addressed and are considered complete pending NRC closure.

MODIFICATIONS - COMPLETE The modifications required to support the FLEX strategies for ONS, Unit 2 have been fully implemented in accordance with the station design control process.

EQUIPMENT - PROCURED AND MAINTENANCE & TESTING - COMPLETE The equipment required to implement the Mitigation Strategies has been procured and is ready for use at ONS, Unit 2. Testing and Maintenance processes have been established through the use of Industry endorsed Electric Power Research Institute (EPRI) Guideline and the ONS Preventative Maintenance program such that FLEX equipment reliability is achieved.

PROTECTED STORAGE - COMPLETE The storage facility required to implement the FLEX strategies for ONS, Unit 2 has been completed and provides protection from the applicable site hazards. The equipment required to implement the FLEX strategies for ONS, Unit 2 is stored in its protected configuration and is ready for use.

, PROCEDURES-"COMPLETE FLEX Guidelines (FGs) for ONS, Unit 2 have been developed in accordance with NE! 12-06, Revision 0, Section 3.2.2 (Reference Al11). The FGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

TRAINING - COMPLETE Training for ONS, Unit 2 has been completed using the ONS Systematic Approach to Training (SAT) as recommended in NEI 12-06, Revision 0, Section 11.6.

STAFFING - COMPLETE The staffing study for ONS has been completed in accordance with NEI 12-01, Revision 0 (Reference Al12) and Recommendation 9.3 of the 10OCFR50.54(f) letter, "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident,"

(Reference A9) and confirmed that ONS has adequate staffing to perform the actions to mitigate beyond design basis events. The ONS study is documented by letter dated June 17, 2015 (Reference A10).

ONS -20 16-003 Pg Page 1 off 3

ATTACHMENT 1 OCONEE NUCLEAR STATION, UNIT 2

SUMMARY

OF COMPLIANCE ELEMENTS FOR ORDER EA-12-049 NATIONAL SAFER RESPONSE CENTERS - COMPLETE Duke Energy has established a contract with the Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER)

Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support ONS with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

VALIDATION - COMPLETE Duke Energy has performed a validation in accordance with industry developed guidance which assures that required tasks, manual actions and decisions for FLEX strategies are feasible and can be executed.

FLEX PROGRAM DOCUMENT - ESTABLISHED The FLEX Program Document for ONS has been developed in accordance with the requirements of NEI 12-06, Revision 0.

REFERENCES Al. Nuclear Regulatory Commission Order Number EA-12-049, Order Modifying Licensees With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated March 12, 2012, ADAMS Accession No. ML12054A735 A2. Oconee Nuclear Station's 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 (Accession No. ML13063A065).

A3. Oconee Nuclear Station, Units 1, 2, and 3, Interim Staff Evaluation Regarding Overall

'Integrated Plan in Response to Order EA-12-049, dated February 10, 2014 (Accession No. ML13365A258).

A4. Oconee Nuclear Station First 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), dated August 29, 2013 (Accession No. ML13246A009).

A5. Oconee Nuclear Station Second 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), dated February 28, 2014 (Accession No. ML14064A197).

A6. Oconee Nuclear Station Third 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), dated August 27, 2014 (Accession No. ML14245A019).

A7. Oconee Nuclear Station 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), dated February 27, 2015 (Accession No. ML15063A027).

ONS-20 16-003Pae2o3 Page 2 of 3

ATTACHMENT 1 OCONEE NUCLEAR STATION, UNIT 2

SUMMARY

OF COMPLIANCE ELEMENTS FOR ORDER EA-12-049 A8. Oconee Nuclear Station Fifth 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), dated August 26, 2015 (Accession No. ML15247A068).

A9. I10CFR5O.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident", Recommendation 9.3, dated March 12, 2012, (Accession No. ML12053A340)

AI0. Oconee Nuclear Station NEI 12-01 Phase 2 Staffing Assessment Report in Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2 and 6 -Phase 2 Staffing Assessment, dated June 17, 2015 (Accession No. ML15176A343)

Al11. NEI 12-06, Revision 0 "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide."

A12. NEI 12-01, Revision 0 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities."

ONS -20 16-003 Pg3o Page 3 of 3

ATTACHMENT 2 OCONEE NUCLEAR STATION UNIT 2, NRC AUDIT REPORT OPEN AND PENDING ITEMS Duke Energy contends that ONS, Unit 2 is in full compliance with Orders EA-12-049 as demonstrated by the docketed correspondences concerning this order. Briefly, ONS, Unit 2 FLEX Interim Staff Evaluation (ISE) Open and Confirmatory Items are complete pending NRC closure; ONS, Unit 2 FLEX OIP Open Items are complete pending NRC Closure; ONS, Unit 2 FLEX Audit Questions are complete pending NRC closure; ONS, Unit 2 FLEX NRC Audit Report Open Items are complete pending NRC closure.

Duke Energy provides the following response for the Audit Report Open and Pending Items and considers them to be complete with respect to establishing compliance for ONS, Unit 2:

ISE 01 3.2.1.1 .A Provide a description and A response for this tracker item is included in a station calculation (Section 8.5.2 of justfictionforthe pecfic 10937-02). The response provided in Section 8.5.2 provides a description for the specific evauatonode~s)use intheevaluation models used in the Oconee ELAP analyses. Also included are references for the EvAaaluainsoels) used icnethe associated Duke Energy topical reports covering the methodology used, and references for ELAPanayse forOcoee. the SERs [Safety Evaluation Reports] associated with these methodology reports.

IS 32..6CWhen O further analyses are The pressurizer PORV or safety valves are expected to lift during the initial 20 minutes of an compete, th liense shuld ELAP event beginning from full power conditions. Once steam generator feed flow is ISE 1 32.1..C ompeted th liense shuld established from the SSF, additional valve lifts are not anticipated.

provide additional information that either supports a conclusion These pressurizer relief valve lifts occur while the pressurizer responds to design basis that pressurizer relief or safety accident conditions, and is well within the design of the equipment. The initial transient valves do not lift during the evolution to an ELAP event mitigated by the SSF is consistent with other existing design ELAP event or that lifting of the basis analyses.

valve(s), if it occurs, is 'Response provided in a station calculation (Section 8.5.2 of 10937-02).

acceptable.

Provde dditona infrmaion The Duke response to RAI question 50 is included in a station calculation (Section 8.5.2 of ISE 01 3.2.1.6.D Prvdemoadditional information 10937-02). This tracker item is a follow up to that RAI question and the Duke response is dmontrgationg succEAPessful also included the station calculation. Evaluation of the SSF for mitigation of FLEX events is mitiatio ofan EAP eent documented in station calculation 11489-0.

involving an uncontrolled cooldown resulting from In addition to those responses, a variety of MSLB cases are evaluated in the station consequential damage to the calculation. The base case for FLEX steam line breaks at Oconee is considered to be a main steam system due to the single main steam line break [MSLB] without credit for AFIS actuation. A variety of severe natural hazard that additional MSLB scenarios have also been evaluated successfully as part of the FLEX initiates the ELAP event, analyses. The sensitivity runs include scenarios that result in initial overcooling, which has been demonstrated to be mitigated by use of the SSF and the guidance contained in Abnormal Procedure 25 (AP/25).

Page 1 of 4

ATTACHMENT 2 OCONEE NUCLEAR STATION UNIT 2, NRC AUDIT REPORT OPEN AND PENDING ITEMS

Item. - .. Description . ... * " /" Summar Response :,- .. .

ISE

. I Cofirmtha 32.11 th fial LAP A response for this tracker item is included in a station calculation (Section 8.5.3 of comptercode analyses for core 10937-02). This response reviews the computer codes and methodologies used for the comput, eatr coatsse NSSS and containment response separately, and provides references for the associated inventory, shutdown margin, and Duke Energy topical reports covering the methodology used, and references for the SERs containment integrity have [Safety Evaluation Reports] associated with these methodology reports.

acceptable methodology and The timelines for the seismic response scenario [T=0 no warning event] and the flood Sassumptions and support the response scenario [warning time event] are identified and included as Attachment 7 to sequence of events timeline. station calculation 10937-02. These timelines are reviewed and compared to the cases performed in station calculation 10937-02.

Attachment 19 to station calculation 11383-00, specifically addresses this concern. An ISE Cl 3.2.1.2.B Cofimp thatur RCPl sea excerpt from the conclusion portion of the attachment is provided below:

maintained at an acceptably low "Oconee Design Basis Events documentation (Appendix C of DBD 0254.00-00-4005) and value by establishing injection the SSF RC Makeup System documentation (Section 2.2.2, of DBD 0254.00-00-1004) flow to the RCP seals via the establishes 20 minutes as the time to establish SSF RC Make Up to the RCP seals in order SSF RCMU pump within 20 to limit seal heat-up and prevent seal damage or failure. In addition to reestablishing seal minutes of event initiation, cooling flow, these documents establish 15 minutes for the time to isolate Unit I RCP seal return flow and 20 minutes for Units 2 & 3. For Events with no warning (T=0) SSF RC Makeup is started from the SSF per Abnormal Procedure 25 (AP/25). Input 5.34 from Station Calculation 5372 provides much of the technical basis.

For the Advanced Warning Time event (Jocassee Dam failure), Case 3, provides a methodology in which substantial unit shutdown and cooldown to less than 350F is accomplished prior to the ELAP condition. In this case the primary system is cooled down using normal station equipment on all three units to preclude seal damage. There is no requirement to establish SSF RCMU to provide seal protection."

ONS-201 6-003Pae2f4 Page 2 of 4

ATTACHMENT 2 OCONEE NUCLEAR STATION UNIT 2, NRC AUDIT REPORT OPEN AND PENDING ITEMS Item Description -Summary Response, ISE CI 3.2.1.2.0 Confirm there is justification for Attachment 19 of station calculation 11383-00 specifically addresses this concern. An the assumed seal leakage rates excerpt from the conclusion portion of the attachment is provided below:

for the Bingham RCPs with "Based on the ONS FLEX strategies there is no expectation of increased Sulzer RCP seal Suizer seal assemblies, leakage due to the early event response. Additional review of testing and correspondence with Sulzer provides additional confirmation that the Unit 2&3 seals are tolerant of the short duration temperature excursion.

The modeled leakage rates are arbitrary, with the 2 gpm per seal selected from WCAP-17601-P section 4.4.3 as values used in Generic B&W calculations as "normal leakage for seals that have not experienced overheating", and the 21 gpm per seal selected as representative of a large seal leak, also selected based on documentation from the same WCAPo Based on the credible failure mode (elastomers exposed to high temperatures) and the mechanism of temperature to time exposure, there is adequate justification for leakage values selected for the base case and the high leakage sensitivity case."

ISE C013.2.1.2.D Confirm there is justification for Attachment 19 of station calculation 11383-00 specifically addresses this concern. An the assumed seal leakage rates excerpt from the conclusion portion of the attachment is provided below:

for the Westinghouse 93-A "Based on the ONS FLEX strategies there is no expectation of increased Flowserve RCP RCPs with Flowserve N-9000 seal leakage due to the early event response. Additional review of the Flowserve White seals with the Abeyance feature. Paper provides additional confirmation that the Unit 1 seals are tolerant of the short duration temperature excursion. The modeled leakage rates are arbitrary, with the 2 gpm per seal selected from WCAP-1 7601-P section 4.4.3 as values used in Generic B&W calculations as "normal leakage for seals that have not experienced overheating", and the 21 gpm per seal selected as representative of a large seal leak, also selected based on documentation from the same WCAP. Based on the credible failure mode (elastomers exposed to high temperatures) and the mechanism of temperature to time exposure, there is adequate justification for leakage values selected for the base case and the high leakage sensitivity case (Note: ONS Unit 1 RCP seals have the Generation 1 Abeyance Feature)."

ONS-201 6-003Paeof Page 3 of 4

ATTACHMENT 2 OCONEE NUCLEAR STATION UNIT 2, NRC AUDIT REPORT OPEN AND PENDING ITEMS Ite °*Description* ... Summary Response.

Refer to Attachments 9 and 10 of station calculation 11383-00 for conclusion of survival and ISE~32.12.EWhen evaluations are ISE l 32.12.Ecompleted, confirm that the accessibility for implementation of FLEX strategies.

survivability and performance of the atmospheric dump valves is adequate to support Oconee's mitigation strategy.

(1) In accordance with the Oconee SSF RCSMU Design Basis Document and Oconee SE 20-E Please (1) state the ambient Environmental Qualification Calculation, the RCMU Pumps will operate in ambient conditions (temperature, conditions of 267 degrees F, 41.8 psig, and 0-100% humidity.

pressure, humidity) under which the SSF RCMU pumps are (2) In accordance with the Oconee ELAP Containment Response Calculation, each of the qualified or otherwise expected FLEX cases which utilize RCMU pump strategy exhibits a similar trend in the containment to function and provide a basis, response with each case reaching 100% humidity, a temperature of 170 - 185 deg. F, and a (2) state the expected conditions pressure response of 18 to 21 psig at the end of the simulation. The simulation was for 72 in containment during the period hours. Oconee expects to be capable of transitioning to Phase 2 RCS Makeup (with when the functionality of the portable diesel pump) well in advance of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

SSF RCMU pumps is credited (3) By comparison, the peak conditions expected during the ELAP event remain below or and provide a basis, and (3) equal to the pump's design basis conditions.

confirm that the credit taken for the SSF RCMU pumps under ELAP conditions is justified.

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