CNS-14-086, 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)

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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)
ML14247A232
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/28/2014
From: Henderson K
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-14-086, EA-12-049
Download: ML14247A232 (24)
v • d • e


Text

Kelvin Henderson KE Vice President SnENERGY Catawba Nuclear Station Duke Energy CN01VP I 4800 Concord Road York, SC 29745 o: 803.701.4251 f: 803.701.3221 CNS-14-086 10 CFR 50.4 August 28, 2014 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:

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)

References:

1. Nuclear Regulatory Commission (NRC) Order Number EA-1 2-049, 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.
6. Catawba First Six-Month Report 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 August 28, 2013 (ADAMS Accession No. ML13298A010).
7. Catawba Second Six-Month Report 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, 2014 (ADAMS Accession No. ML14065A038).

United States Nuclear Regulatory Commission Page 2 August 28, 2014 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 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. References 6 and 7 provided the first and second six-month status report respectively for Catawba.

The purpose of this letter is to provide the third 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 August 28, 2014.

Sincerely, Kelvin Henderson Vice President, Catawba Nuclear Station

Enclosure:

Third 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 Nuclear Regulatory Commission Page 3 August 28, 2014 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 D.H. Dorman, 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 THIRD 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

ENCLOSURE Page 2 CNS Third Sixth Month Status Report (Order EA-12-049) 1 Introduction Catawba Nuclear Station (CNS) developed an Overall Integrated Plan (Reference 1 in Section 7),

documenting the diverse and flexible strategies (FLEX), in response to NRC Order EA-12-049 (Reference 2 in Section 7). 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 January 28, 2014 to July 28, 2014 (hereafter referred to as "the update period").

2 Milestone Accomplishments The following milestones were completed during the update period:

1) Second Six-Month Status Report for Catawba Nuclear Station, Units 1 and 2 was submitted on February 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.

Target Revised Milestone Completion Activity Target M tCe Status Completion Date Date Date Not Revised Submit 60 Day Initial Status Report Oct 2012 Complete Date Not Submit Overall Integrated Plan Feb 2013 Complete Revised Date Not First 6 Month Status Update Aug 2013 Complete Revised Date Not Second 6 Month Status Update Feb 2014 Complete Revised Date Not Third 6 Month Status Update Aug 2014 Started Revise Revised

ENCLOSURE Page 3 CNS Third Sixth Month Status Report (Order EA-12-049)

Revised Target Activity Target Milestone Completion Status Completion DateDate Develop Engineering Changes (ECs) Jan 2015 Started Date Revised Develop Strategies Aug 2014 Started Date Revised Purchase Equipment Oct 2014 Started Date Revised Develop Equipment PMs Dec 2014 Started Date Revised Develop Guidelines Sep 2014 Started Date Revised Develop Training Dec 2014 Started Date Revised Date Not Implement Training May 2015 Not Started Revise Revised Date Not Staffing 12-01 Phase II Nov 2014 Started Revise 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 Not Started Date Revised Date Not Revise Site Implementation Complete Dec 2015 Not Started Revised SAFER National Response Centers Date Not Operational Feb 2015 Started Revised

ENCLOSURE Page 4 CNS Third 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 (References 1 in Section 7) or previous 6 Month Updates (References 3 and 4 in Section 7). These changes do not impact Catawba Nuclear Stations compliance with NEI 12-06.

1) Change: Equipment listed in the PWR Portable Equipment Phase 3 table and the Phase 3 Response Equipment/Commodities table in the OIP are constantly changing based on equipment being purchased for Storage at the SAFER National Response Centers (SNRC) in Phoenix and Memphis based on availability and industry participation. As such, an updated list of Portable Phase 3 equipment available from the SNRC will be referenced to the latest revision of Areva's Regional Response Center Equipment Technical Requirements Document 51-9199717.

Justification: Equipment being provided by the SAFER National Response Centers for Phase 3 are evaluated by Catawba and Corporate Fukushima Response Organization personnel to ensure it can meet the requirements for applicable Phase 3 mitigation strategies.

Documentation: Areva's Regional Response Center Equipment Technical Requirements Document 51-9199717. Open Items 64, 65, 66, 67, 68, 69, 71, and 95.

2) Change: The OIP credited approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of Condenser Cooling Water system (RC) water and approximately 13 more hours of Nuclear Service Water system (RN) water as being available as a static suction source for the Turbine Driven Auxiliary Feedwater pump. It has been determined during seismic robustness evaluations, that approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of static RC water is available (per unit) to provide the suction supply requirements for the Turbine Driven Auxiliary Feedwater pump. As such, no credit will be taken for any static RN water volume.

Justification: A large static water volume is needed as a suction source for the Turbine Driven Auxiliary Feedwater pump that provides enough time to install portable equipment that can be used to fill and pressurize the RN system using water from the Standby Nuclear Service Water Pond (SNSWP). The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of RC system static water volume provides more than enough time to get the RN system filled and pressurized. Not crediting the static RN system water volume not only reduces seismic walkdown and seismic analysis scope significantly, it also reduces the need for scarce operations resources during the important initial incident response time. The amount of RN system static water volume available was also questionable due to seismic/non-seismic interfaces between RN and other systems.

Documentation: ARES Report No. 030321.13.01-001 Revision 1 (Seismic Robustness Review Of Catawba Unit 1 Non-Safety Piping and Components For Diverse and Flexible Mitigation Strategies (Flex). Open Item 32.

ENCLOSURE Page 5 CNS Third Sixth Month Status Report (Order EA-12-049)

3) Change: Debris removal equipment will be stored in a single hardened structure that will house the other FLEX equipment.

Justification: Previous storage facility concepts assumed that CNS would utilize three spatially separated buildings. It has been decided that a single storage building will be constructed at CNS and all FLEX related equipment will be staged in this one facility.

Having the debris removal equipment stored in a single hardened structure will provide assurance that the equipment is protected and available.

Documentation: Open Items 27 and 52.

4) Change: A single hardened FLEX storage building will be utilized. The building will be located West of the Catawba garage.

Justification: A Fleet decision was made to use a single hardened FLEX storage building at a number of Duke Energy nuclear sites, including Catawba, that uses a common design. The use of a single hardened structure provides less regulatory risk, consolidation of the FLEX equipment at a single location for better administrative control, less construction issues, and improved flood protection. The single building will meet the NEI 12-06 storage requirements for all hazards identified in NEI 12-06 that are applicable to the site.

Documentation: Open Item 27. Revised sketches for Equipment Deployment Route -

Page 19 of this report, Portable Pump Supply to Essential Service Water Header / Storage Facility Locations - Page 20 of this report, and Portable Pump Supply to S/G's - Page 21 of this report.

5) Change: Attachment 1A in the OIP and the discussion of time constraints has charging of the A and D vital battery channels occurring at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and charging of the B and C vital battery channels occurring at 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. The current strategies will begin charging the A, B, C, and D battery channels all at the same time which will be around 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Justification: Setup of the portable Flex Phase 2 generators and powering the electrical distribution system will provide power for all four channels of vital batteries on each unit at essentially the same time. As such, there is no reason to delay charging the B and C vital battery channels. This will also provide conservative assumptions in the Hydrogen generation/ventilation analysis being performed by Zachry for the vital battery rooms and surrounding areas.

Documentation: Open Items 1, 5, 9, 10, 16.

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

6) Change: The OIP discussed having a FLEX storage building located near the Standby Nuclear Service Water Pond (SNSWP) and the need to move equipment stored in this building to higher ground during a flood event. This will no longer be necessary since a single FLEX storage building is being constructed in a location that is well above any postulated flood levels.

Justification: See Change Item #4 in this six month update.

Documentation: Open Item 27.

7) Chan-ie: A Phase 2 strategy discussed in the OIP states that discharge hoses from a portable pump located at the SNSWP will be routed to the suction of a second pump to be located between the Unit 1 and Unit 2 Reactor buildings with the discharge hoses of the second pump being routed to the Auxiliary Feedwater (CA) system connections located in the interior and exterior doghouses. The current strategy for supplying water from the SNSWP to the Steam Generators via portable pumps will employ the use of a pump staged near the Unit 1 doghouse and another pump staged near the Unit 2 doghouse in lieu of a single pump staged between the Unit 1 and Unit 2 Reactor buildings feeding both Units Steam Generators. The single pump was going to be the Hale 1500 gpm pump listed in the PWR Portable Equipment Phase 2 table in the OIP. The Hale 1500 gpm portable diesel driven pump should be deleted from this table. These pumps will also be used for Reactor Coolant System (RCS) makeup during Modes 5 and 6 and will not be staged in the Auxiliary building.

Justification: Change #2 described in Section 4 of the Second Six Month Status Report Update states that pumps are being purchased for the low pressure Steam Generator makeup strategy that can also be used for Reactor Coolant System (RCS) borated water makeup during Modes 5 and 6. The performance of these pumps is such that one pump per unit is required for these strategies. The pump being purchased is powered by a diesel engine, not an electric motor as originally thought. As such, it must be operated in an area with adequate ventilation (outdoors) and will stored in a protected structure when not in service.

Documentation: Open Items 37 and 53.

8) Change: The OIP stated that a high pressure pump used for RCS makeup during Phase 2 would be staged locally in the Category I Auxiliary building. The pump being purchased for high pressure RCS makeup will now be stored in the single hardened FLEX equipment building and will be deployed to a location in the yard next to the Auxiliary building when needed.

Justification: The pump being purchased is powered by a diesel engine, not an electric motor as originally thought. As such, it must be operated in an area with adequate ventilation (outdoors). Based on current analysis, adequate time exists to deploy this pump from the FLEX storage building and place it in operation.

Documentation: Open Item 37.

ENCLOSURE Page 7 CNS Third Sixth Month Status Report (Order EA-12-049) 5 Need for RelieflRelaxation and Basis for the Relief/Relaxation CNS expects to comply with the order implementation date and no relief/relaxation is required at this time.

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 and second six month status reports (References 1, 3, and 4 in Section 7). The table under Section 6.b. provides a list of Open Items that were added after January 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, and the Second 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. Started 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 2291.

Recharge communication system and satellite phone system. Not Started 4 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 28 in PIP C 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 PWROG to provide negative reactivity addition and maintain margin to criticality. Site specific analysis will need to be 6 performed to establish actual time. See Corrective Action 30 in PIP C-12-2291.

ENCLOSURE Page 8 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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-12-2291.

Provide portable lighting (beyond head and hand lamps and Started 8 installed battery lighting). Activity to be validated in conjunction with associated procedure changes. See Corrective Action 32 in PIP C-12-2291.

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. Not Started 10 Activity to be validated in conjunction with associated procedure changes. See Corrective Action 34 in PIP C 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 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 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-12-2291.

ENCLOSURE Page 9 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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.

21 Align portable diesel driven Hale Pump to Containment Spray Not 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 Not 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 Not 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 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 Not 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.

ENCLOSURE Page 10 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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.

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-12-2291 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.

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. Started 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 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.

44 Determine lighting requirements via Corrective Action 31 in Complete PIP C-11-6867.

ENCLOSURE Page 11 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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.

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 Not Started 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 Started 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 Started 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 Not 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 Started be available to support the FLEX mitigation strategies and associated activities. See Corrective Action 7 in PIP C 4953.

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

Item Overall Integrated Plan Open Item Status 57 Develop procedural guidelines to use handheld instruments Not 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 Not Started required areas. See Corrective Action 24 in PIP C-12-2291.

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 Not Started during Phase 3. See Corrective Action 65 in PIP C-12-2291.

62 Determine if portable lighting will be required from the RRC Not 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 2291.

64 Determine Phase 3 requirements related to Radiation Not Started Protection Equipment. See Corrective Action 68 in PIP C 2291.

65 Determine Phase 3 requirements related to Commodities Not Started 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 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 Not 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/O/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.

ENCLOSURE Page 13 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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)

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 Started 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 Not Started 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 Not 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 Not 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 Not Started site/fleet Shutdown/Refueling documents need to be revised to comply with the position paper related to Shutdown Risk 84 Management and Contingency Planning. See Corrective Action 96 in PIP C-12-2291.

ENCLOSURE Page 14 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status Perform a seismic robustness evaluation of the proposed cable Not 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-13-9158.

Due to normal operational input to the TDCA pump pit sump Not 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 6867.

b. Open Items added after January 28, 2014.

Item Overall Integrated Plan Open Item Status A calculation is needed to support the validation of the Not 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 Not Started 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 Not 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 in PIP C-12-2291.

Review DPC-1552.08-00-0278, Appendix C. Determine which Not Started 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 Not Started chemistry procedures perform surveillances of the CLAs boron 92 concentrations. Make the necessary revisions using the basis provided by DPC-1552.08-00-0278, Appendix C. See Corrective Action 105 in PIP C-12-2291.

ENCLOSURE Page 15 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Overall Integrated Plan Open Item Status 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.

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 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 Open 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 />.

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-1552.08-coolant system under natural circulation conditions potentially 00-0278) involving two-phase flow.

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 3.1.1.2.A evaluation of potential deployment routes and concerns such Open as soil liquefaction can proceed. Confirm attributes of deployment routes, including liquefaction potential.

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.

Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to the flow conditions prior to 3.2.1.1.A reflux condensation initiation. This includes specifying an Open acceptable definition for reflux condensation cooling. Confirm that the NOTRUMP code is used within the accepted limits.

Westinghouse will be assisting CNS in providing further information regarding decay heat modeling. Evaluate for 3.2.1.3.A applicability and implementation. Open

ENCLOSURE Page 16 CNS Third Sixth Month Status Report (Order EA-12-049)

Item Interim Staff Evaluation Confirmatory Item Status Licensee will confirm that the final containment analysis 3.2.3.A validates that containment spray for temperature/pressure Open control is not required over the long term, or will provide procedures to cool the containment.

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.

Evaluations to address the needs for freeze protection are in 3.2.4.3.A progress. Confirm completion of evaluations and appropriate Open actions.

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.

3.2.4.4. B Confirm upgrades to the site's communication systems have Open been completed. Open 3.4.A Offsite Resources- Confirm NEI 12-06 Section 12.2, Guidelines Open 3.4.A_ 2 through 10, are addressed with SAFER.

Duke Energy will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown/Refueling Modes" to enhance the shutdown risk process and procedures.

Catawba will incorporate the guidance provided in the Westinghouse position paper 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 ML13235A135) with the following clarifications:

1. The required timing for providing borated makeup to the primary system should consider conditions with no reactor coolant system leakage and with the highest applicable leakage rate for the reactor coolant pump seals and unidentified reactor coolant system leakage.
2. For the condition associated with the highest applicable reactor coolant system leakage rate, two approaches have been identified, either of which is acceptable to the staff:
a. Adequate borated makeup should be provided such that the loop flow rate in two phase natural circulation does not decrease below the loop flow rate corresponding to single-phase natural circulation.
b. If loop flow during two-phase natural circulation has decreased below the single phase natural circulation flow rate, then the mixing of any borated primary makeup added to the reactor coolant system is not to be credited until one hour after the flow in all loops has been restored to a flow rate that is greater than or equal to the single-phase natural circulation flow rate.

ENCLOSURE Page 17 CNS Third Sixth Month Status Report (Order EA-12-049)

3. In all cases, credit for increases in the reactor coolant system boron concentration should be delayed to account for the mixing of the borated primary makeup with the reactor coolant system inventory. Provided that the flow in all loops is greater than or equal to the corresponding single-phase natural circulation flow rate, the staff considers a mixing delay period of one hour following the addition of the targeted quantity of boric acid to the reactor coolant system to be appropriate.

The boron mixing guidance above has been incorporated into DPC-1552.08-00-0278/CNC-1552.08-00-0503 (Boration Analysis for Extended Loss of AC Power at MNS/CNS) Rev. 1.

The NRC has recently endorsed the following Generic Issues associated with FLEX:

1. Use of the MAAP4 computer code in simulating the Extended Loss of AC Power (ELAP) event for Boiling Water Reactors (BWR). Catawba Nuclear Station will not abide by this generic resolution.
2. Westinghouse report entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on CENTS Code in Support of the Pressurized Water reactor Owners Group (PWROG)". Duke Energy will not abide by this generic resolution 7 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) 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).
6) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
7) 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).

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

8) Catawba Nuclear Station, Units 1 and 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (Tac Nos. Mf1162 and Mfl 163), Dated February 6, 2014 (ADAMS Accession No. ML13364A173).
9) 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)
10) 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)
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, dated January 8, 2014, (ADAMS Accession No. ML13276A183)
12) 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)

ENCLOSURE Page 19 CNS Third Sixth Month Status Report (Order EA-1 2-049)

CNS ENTRANCE CONCORD ROAD EQUIPMENT DEPLOYMENT ROUTE

ENCLOSURE Page 20 CNS Third Sixth Month Status Report (Order EA-1 2-049)

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ENCLOSURE Page 21 CNS Third Sixth Month Status Report (Order EA-12-049)

(RN)I TAKE0 0 WYLIQ

  • .._..PORTABLE Q0 CDOLING TOWERS PORTABLE 00O H S -- WATER CHEMISTRY RN SUPLY LDG.BLDG.

2EDE II CONCORD ROAD PORTABLE PUMP SUPPLY TO SG's

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