JAFP-13-0024, Entergy’S Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

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Entergy’S Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)
ML13063A286
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 02/28/2013
From: Michael Colomb
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-050, JAFP-13-0024 ANP-3201, Rev 1
Download: ML13063A286 (35)
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Text

JAFP-13-0024 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Entergys Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

James A. FitzPatrick Nuclear Power Plant (JAF)

Docket No.

50-333 License No.

DPR-59

REFERENCE:

1. NRC Order Number EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, dated March 12, 2012.
2. NRC Interim Staff Guidance JLD-ISG-2012-02, Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, Revision 0, dated August 29, 2012.
3. Initial Status Report in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050), dated October 29, 2012 (JAFP-12-0123).

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference 1) to Entergy Nuclear Operations, Inc. (Entergy). Reference 1 was immediately effective and directs Entergy to have a reliable hardened vent (RHV) to remove decay heat and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability or prolonged station blackout (SBO). Specific requirements are outlined in of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013.

The interim staff guidance (Reference 2) was issued August 29, 2012 which provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1.

This letter confirms Entergy has an Overall Integrated Plan complying with the guidance for the purpose of ensuring the functionality of reliable hardened vent (RHV) systems to remove decay heat and control of containment pressure following events that result in Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Michael J. Colomb Site Vice President - JAF

JAFP-13-0024 Page 2 of 2 This letter confirms Entergy has an Overall Integrated Plan complying with the guidance for the purpose of ensuring the functionality of RHV systems to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged SBO as described in Attachment 2 of Reference 1.

For the purposes of compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, Entergy plans to use a wetwell vent.

Should you have any questions regarding this submittal, please contact Mr. Chris M.

Adner, Licensing Manager, at (315) 349-6766.

This letter contains no new regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2013.

Michael J. Glolomb MC/CA/jo Attachments: FitzPatrick's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050) cc:

Mr. Mohan Thadani, Senior Project Manager, NRG NRR DORL Mr. William M. Dean, Regional Administrator, NRG Region 1 NRG Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission ATTN: Robert J. Fretz Jr.

OW FN - Mailstop 4A 15A 11555 Rockville Pike Rockville, MD 20852-2378 U.S. Nuclear Regulatory Commission ATTN: Robert L. Dennig OWFN - Mailstop 10E1 11555 Rockville Pike Rockviile, MD 20852-2378

ATTACHMENT 1 JAFP-13-0024 FitzPatricks Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

February 2013 AREVA NP Inc.

(c) 2013 AREVA NP Inc.

Copyright © 2013 AREVA NP Inc.

All Rights Reserved

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page i Nature of Changes Item Section(s) or Page(s)

Description and Justification 1

All This is a new document 2

page 5, 17, Radiation monitor indication changed to relay room only to and 28 be consistent with the proposed conceptual design 3

page 22, 23 Editorial changes

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page ii ABSTRACT This document contains the response for FitzPatrick to the U.S. NRC regarding the Hardened Containment Venting System overall integrated implementation plan.

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 1 Table of Contents:

Section 1: System Description Section 2: Design objectives Requirement 1.1.1 - Minimize the Reliance on Operator Actions Requirement 1.1.2 - Minimize Plant Operators Exposure to Occupational Hazards Requirement 1.1.3 - Minimize Radiological Consequences Section 3: Operational Characteristics Requirement 1.2.1 - Capacity to Vent Equivalent of 1%

Requirement 1.2.2 - HCVS Shall be Accessible to Plant Operators Requirement 1.2.3 - Prevent Inadvertent Actuation Requirement 1.2.4 - Monitor the Status of the Vent System Requirement 1.2.5 - Monitor the Effluent Discharge for Radioactivity Requirement 1.2.6 - Minimize Unintended Cross Flow of Vented Fluids Requirement 1.2.7 - Provision for the Operation, Testing, Inspection and Maintenance Requirement 1.2.8 - Design Pressures Requirement 1.2.9 - Discharge Release Point Section 4: Applicable Quality Requirements Requirement 2.1 - Containment Isolation Function Requirement 2.2 - Reliable and Rugged Performance Section 5: Procedures and Training Requirement 3.1 - Develop, Implement, and Maintain Procedures Requirement 3.2 - Train Appropriate Personnel Section 6: Implementation Schedule Milestones Section 7: Changes/Updates to this Overall Integrated Implementation Plan Section 8: Figures/Diagrams

References:

1. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989
2. Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events, dated March 12, 2012
3. Order EA-12-050, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents,, dated March 12, 2012
4. JLD-ISG-2012-02, Compliance with Order EA-12-050, Reliable Hardened Containment Vents, Revision 0, dated August 29, 2012
5. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-02: Compliance with Order EA-12-050, Order

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 2 Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012

6. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 3 Section 1: System Description ISG Criteria:

Licensees shall provide a complete description of the system, including important operational characteristics. The level of detail generally considered adequate is consistent with the level of detail contained in the licensees Final Safety Analysis Report.

Response

System Overview:

The Hardened Containment Vent System (HCVS) will be designed to mitigate loss-of-decay-heat removal by providing sufficient containment venting capability to limit containment pressurization and maintain core cooling capability. The vent will be designed with sufficient capacity to accommodate decay heat input equivalent to 25.36 MWt, which is 1% of the current licensed thermal power (CLTP) at the containment design pressure of 56 psig. Thus, the hardened vent capacity will be adequate to relieve decay heat for a prolonged station blackout (SBO) event up to the Primary Containment Pressure Limit. The HCVS is intended for use as one element of core damage prevention strategy.

The HCVS flow path from the containment to an elevated release point is shown in the simplified diagram below (Figure 1). Noductwork will be used in the flow path.

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 4 Figure 1: Simplified Vent Line Connections to Wetwell and Other Systems

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 5 Equipment and components:

The following equipment and components will be provided:

i.

HCVS Mechanical Components -

a) Containment isolation piping, valves and controls - The HCVS vent piping and supports up to and including the second containment isolation are designed in accordance with existing design bases. Containment isolation valves (CIVs) are existing 20 valves (27AOV-117 and 27AOV-118) consistent with the plants design basis. The valves are air-to-open and spring-to-close that will be actuated by a DC powered solenoid valve (SOV). These SOVs can be operated from switches in the Relay Room.

b) Other system valves and piping - The HCVS piping and supports downstream of the second containment isolation valve, including valve actuator pneumatic supply components, will be designed/analyzed to conform to the requirements consistent with the applicable design codes for the plant and to ensure functionality following a design basis earthquake.

c) Interface valves provide positive isolation to the interconnected systems. The HCVS shares part of its flow path with the Standby Gas Treatment System (SGTS). The interfacing valves for the SGTS are two motor operated valves which will be modified to allow for operation in a loss of AC power event. These valves require administrative action for closure prior to venting the containment.

ii.

Instrumentation to monitor the status of the HCVS -

a) Instrumentation is available in the Main Control Room (MCR) for CIV position indication. Remote CIV position indication will also be available at a remote control station located in an access hallway just outside of the Reactor Building on ground level. This hallway is readily accessible from the MCR.

b) The location of the effluent radiation monitor for the vent pipe will be downstream of the second isolation valve, inside the Reactor Building. Installation of the radiation monitor (inside or outside of the vent pipe) will be determined in the detailed design phase. Indication of radiation levels will be provided in the Relay Room.

c) HCVS vent flow path valve position indication, temperature and pressure instrumentation will allow monitoring the status of the HCVS to aid the operator to

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 6 ensure verification of proper venting operation. Note that failure of the position indication instrumentation would not prevent opening and closing the CIVs. The HCVS will be designed to use pre-staged nitrogen bottles to flow nitrogen directly into the air actuator to open the CIV regardless of valve position indication.

d) Local instrumentation will indicate pressure of the nitrogen backup bottles.

e) Pressure indication for the Wetwell and the Drywell along with temperature and level indication for the Wetwell will aid the operator to ensure proper venting operation.

iii.

Support systems -

a) Normal power for the HCVS valve solenoids is currently provided from plant 120 VAC power. These solenoid valves will be replaced with solenoid valves powered by 125 VDC from plant emergency batteries.

b) Back-up power will be provided from a permanently installed DC power source The battery capacity and charging strategy will be improved as part of the FLEX strategy (NRC order EA-12-049).

c) Motive gas supply for HCVS operation will be adequate for at least the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during operation under prolonged SBO conditions provided from the CAD (nitrogen) plant system or from the permanently installed nitrogen backup cylinders.

d) FLEX equipment will have the capability to provide back-up support equipment in order to achieve reliable HCVS operation after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Power will be supplied from diesel generators to maintain the HCVS batteries charged. Motive gas for HCVS operation is supplied from the CAD (nitrogen) plant system or from the permanently installed nitrogen backup cylinders. Power for instrumentation is supplied from a permanently installed DC power source, backed up by FLEX equipment System control:

a) Active: The CIVs are operated in accordance with plant procedures to control containment pressure. The HCVS will be designed for approximately 16 open/close cycles under prolonged SBO conditions. Controlled venting will be permitted in the revised plant procedures. A venting strategy will be developed

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 7 commensurate with the detailed design and associated analysis. The control circuit for the new vent CIVs will allow for manual override operation of the HCVS from its control panel regardless of the containment isolation signal.

b) Passive: No passive component (e.g. rupture disk) will be installed.

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 8 Section 2: Design Objective Requirement 1.1.1 - Minimize the Reliance on Operator Actions:

The HCVS shall be designed to minimize the reliance on operator actions.

ISG 1.1.1 Criteria:

During events that significantly challenge plant operations, individual operators are more prone to human error. In addition, the plant operations staff may be required to implement strategies and/or take many concurrent actions that further places a burden on its personnel. During the prolonged SBO condition at the Fukushima Dai-ichi units, operators faced many significant challenges while attempting to restore numerous plant systems that were necessary to cool the reactor core, including the containment venting systems. The difficulties faced by the operators related to the location of the HCVS valves, ambient temperatures and radiological conditions, loss of all alternating current electrical power, loss of motive force to open the vent valves, and exhausting dc battery power. The NRC staff recognizes that operator actions will be needed to operate the HCVS valves; however, the licensees shall consider design features for the system that will minimize the need and reliance on operator actions to the extent possible during a variety of plant conditions, as further discussed in this ISG.

The HCVS shall be designed to be operated from a control panel located in the main control room or a remote but readily accessible location. The HCVS shall be designed to be fully functional and self sufficient with permanently installed equipment in the plant, without the need for portable equipment or connecting thereto, until such time that additional on-site or off-site personnel and portable equipment become available. The HCVS shall be capable of operating in this mode (i.e., relying on permanently installed equipment) for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the prolonged SBO, unless a shorter period is justified by the licensee. The HCVS operation in this mode depends on a variety of conditions, such as the cause for the SBO (e.g., seismic event, flood, tornado, high winds), severity of the event, and time required for additional help to reach the plant, move portable equipment into place, and make connections to the HCVS.

When evaluating licensee justification for periods less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the NRC staff will consider the number of actions and the cumulative demand on personnel resources that are needed to maintain HCVS functionality (e.g., installation of portable equipment during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore power to the HCVS controls and/or instrumentation) as a result of design limitations. For example, the use of supplemental portable power sources may be acceptable if the supplemental power was readily available, could be quickly and easily moved into place, and installed through the use of pre-engineered quick disconnects, and the necessary human actions were identified along with the time needed to complete those actions.

Conversely, supplemental power sources located in an unattended warehouse that require a qualified electrician to temporarily wire into the panel would not be considered acceptable by the staff because its installation requires a series of complex, time-consuming actions in order to achieve a successful outcome.

There are similar examples that could apply to mechanical systems, such as pneumatic/compressed air systems.

Response (ref. ISG Item 1.1.1):

The operation of the HCVS will be designed to minimize the reliance on operator actions in response to hazards identified in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide. Immediate operator actions can be completed by Reactor Operators and include remote-manual initiation from the HCVS control station. The operator actions required to open a vent path are:

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 9 Operator Actions necessary to Vent the Containment during a SBO Vent containment with containment pressure at specified pressure from MCR /

Relay Room Vent containment with containment pressure at specified pressure from remote panel

1. Open new motor-operated HCVS valve from Relay Room
1. Open new motor-operated HCVS valve from the Relay Room
2. Open 1st containment isolation valve from Relay Room
2. Align valves at remote panel for manual operation of CIVs.
3. Open 2nd containment isolation valve from Relay Room to start venting
3. Open 1st containment isolation valve from remote panel
4. Monitor electrical power status, pneumatic pressure and containment / HCVS conditions
4. Open 2nd containment isolation valve from remote panel to start venting
5. Monitor electrical power status, pneumatic pressure and containment / HCVS conditions Remote-manual is defined in this report as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting under primary procedural protocol.

The HCVS will be designed to allow initiation, control, and monitoring of venting from the MCR/Relay Room and from the remote control station in the hallway outside the RB. These locations minimize plant operator exposure to adverse temperature and radiological conditions and is protected from hazards assumed in NEI 12-06.

Permanently installed power and motive gas will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Permanently installed equipment will supply nitrogen and power to HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As described in NEI 12-06, allowance is provided for operator actions to restore power. Staffing studies when completed in response to NRC EA-12-049 will demonstrate that sufficient manpower is available to ensure that supplemental DC control power can be established.

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, available personnel will be able to connect supplemental motive air/gas to the HCVS. Connections for supplementing electrical power and motive air/gas required for HCVS will be located in accessible areas with reasonable protection per NEI 12-06 that minimize personnel exposure to adverse conditions following a prolonged SBO and venting. Connections will be pre-engineered quick disconnects to minimize manpower resources.

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 10 Requirement 1.1.2 - Minimize Plant Operators Exposure to Occupational Hazards:

The HCVS shall be designed to minimize plant operators exposure to occupational hazards, such as extreme heat stress, while operating the HCVS system.

ISG 1.1.2 Criteria:

During a prolonged SBO, the drywell, wetwell (torus), and nearby areas in the plant where HVCS components are expected to be located will likely experience an excursion in temperatures due to inadequate containment cooling combined with loss of normal and emergency building ventilation systems.

In addition, installed normal and emergency lighting in the plant may not be available. Licensees should take into consideration plant conditions expected to be experienced during applicable beyond design basis external events when locating valves, instrument air supplies, and other components that will be required to safely operate the HCVS system. Components required for manual operation should be placed in areas that are readily accessible to plant operators, and not require additional actions, such as the installation of ladders or temporary scaffolding, to operate the system.

When developing a design strategy, the NRC staff expects licensees to analyze potential plant conditions and use its acquired knowledge of these areas, in terms of how temperatures would react to extended SBO conditions and the lighting that would be available during beyond design basis external events. This knowledge also provides an input to system operating procedures, training, the choice of protective clothing, required tools and equipment, and portable lighting.

Response (ref. ISG Item 1.1.2):

The HCVS design allows initiating and then operating and monitoring the HCVS from the MCR/Relay Room and from the remote control station in the Reactor Building access hallway which minimizes plant operator exposure to adverse temperature and radiological conditions.

Both these areas are protected from hazards assumed in NEI 12-06.

In order to minimize operator exposure to temperature excursions due to the impact of the prolonged SBO (i.e., loss of normal and emergency building ventilation systems and/or containment temperature changes) procedures will not require access to suppression pool (wetwell) area and exposure to extreme occupational hazards for normal and backup operation of electrical and pneumatic systems.

Connections for supplemental equipment needed for sustained operation will be located in accessible areas protected from severe natural phenomena and minimize exposure to occupational hazards. Tools required for sustained operation, such as portable headlamps or lighting alternatives like flashlights or portable lights and connection specific tooling, will be pre-staged in the NEI 12-06 storage locations.

Neither temporary ladders nor scaffolding are required to access these connections or storage locations.

Requirement 1.1.3 - Minimize Radiological Consequences:

The HCVS shall also be designed to minimize radiological consequences that would impede personnel actions needed for event response.

ISG 1.1.3 Criteria:

The design of the HCVS should take into consideration the radiological consequences resulting from the event that could negatively impact event response. During the Fukushima event, personnel actions to manually operate the vent valves were impeded due to the location of the valves in the torus rooms. The HCVS shall be designed to be placed in operation by operator actions at a control panel, located in the main

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 11 control room or in a remote location. The system shall be deigned to function in this mode with permanently installed equipment providing electrical power (e.g., dc power batteries) and valve motive force (e.g., N2/air cylinders). The system shall be designed to function in this mode for a minimum duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no operator actions required or credited, other than the system initiating actions at the control panel.

Durations of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be considered if justified by adequate supporting information from the licensee. To ensure continued operation of the HCVS beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, licensees may credit manual actions, such as moving portable equipment to supplement electrical power and valve motive power sources.

In response to Generic Letter (GL) 89-16, a number of facilities with Mark I containments installed vent valves in the torus room, near the drywell, or both. Licensees can continue to use these venting locations or select new locations, provided the requirements of this guidance document are satisfied. The HCVS improves the chances of core cooling by removing heat from containment and lowering containment pressure, when core cooling is provided by other systems. If core cooling were to fail and result in the onset core damage, closure of the vent valves may become necessary if the system was not designed for severe accident service. In addition, leakage from the HCVS within the plant and the location of the external release from the HCVS could impact the event response from on-site operators and off-site help arriving at the plant.

An adequate strategy to minimize radiological consequences that could impede personnel actions should include the following:

1. Licensees shall provide permanent radiation shielding where necessary to facilitate personnel access to valves and allow manual operation of the valves locally. Licensee may use alternatives such as providing features to facilitate manual operation of valves from remote locations, as discussed further in this guidance under Requirement 1.2.2, or relocate the vent valves to areas that are significantly less challenging to operator access/actions.
2. In accordance with Requirement 1.2.8, the HCVS shall be designed for pressures that are consistent with the higher of the primary containment design pressure and the primary containment pressure limit (PCPL),

as well as including dynamic loading resulting from system actuation. In addition, the system shall be leak-tight. As such, ventilation duct work (i.e., sheet metal) shall not be utilized in the design of the HCVS.

Licensees should perform appropriate testing, such as hydrostatic or pneumatic testing, to establish the leak-tightness of the HCVS.

3. The HCVS release to outside atmosphere shall be at an elevation higher than adjacent plant structures.

Release through existing plant stacks is considered acceptable, provided the guidance under Requirement 1.2.6 is satisfied. If the release from HCVS is through a vent stack different than the plant stack, the elevation of the stack should be higher than the nearest building or structure.

Response (ref. ISG Item 1.1.3):

The HCVS will be designed for reliable remote-manual operation. Operators will not be required to access the suppression pool area. The HCVS is designed to minimize system cross flow, prevent steam flow into unintended areas, provide containment isolation, and provide reliable and rugged performance as discussed below for Order requirement 1.2.6.

Dose rates are evaluated consistent with the assumption that the HCVS is to be used for the prevention of core damage. Shielding or other alternatives to facilitate manual actions are not required for operation of the vent under these conditions since no core damage has occurred.

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ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 12 Section 3: Operational Characteristics Requirement 1.2.1 - Capacity to Vent Equivalent of 1%:

The HCVS shall have the capacity to vent the steam/energy equivalent of 1 percent of licensed/rated thermal power (unless a lower value is justified by analyses), and be able to maintain containment pressure below the primary containment design pressure.

ISG 1.2.1 Criteria:

Beyond design basis external events such as a prolonged SBO could result in the loss of active containment heat removal capability. The primary design objective of the HCVS is to provide sufficient venting capacity to prevent a long-term overpressure failure of the containment by keeping the containment pressure below the primary containment design pressure and the PCPL. The PCPL may be dictated by other factors, such as the maximum containment pressure at which the safety relief valves (SRVs) and the HCVS valves can be opened and closed.

The NRC staff has determined that, for a vent sized under conditions of constant heat input at a rate equal to 1 percent of rated thermal power and containment pressure equal to the lower of the primary containment design pressure and the PCPL, the exhaust-flow through the vent would be sufficient to prevent the containment pressure from increasing. This determination is based on studies that have shown that the torus suppression capacity is typically sufficient to absorb the decay heat generated during at least the first three hours following the shutdown of the reactor with suppression pool as the source of injection, that decay heat is typically less than 1 percent of rated thermal power three hours following shutdown of the reactor, and that decay heat continues to decrease to well under 1 percent, thereafter. Licensees shall have an auditable engineering basis for the decay heat absorbing capacity of their suppression pools, selection of venting pressure such that the HCVS will have sufficient venting capacity under such conditions to maintain containment pressure at or below the primary containment design pressure and the PCPL. If required, venting capacity shall be increased to an appropriate level commensurate with the licensees venting strategy. Licensees may also use a venting capacity sized under conditions of constant heat input at a rate lower than 1 percent of thermal power if it can be justified by analysis that primary containment design pressure and the PCPL would not be exceeded. In cases where plants were granted, have applied, or plan to apply for power uprates, the licensees shall use 1 percent thermal power corresponding to the uprated thermal power. The basis for the venting capacity shall give appropriate consideration of where venting is being performed from (i.e., wetwell or drywell) and the difference in pressure between the drywell and the suppression chamber. Vent sizing for multi-unit sites must take into consideration simultaneous venting from all the units, and ensure that venting on one unit does not negatively impact the ability to vent on the other units.

Response (ref. ISG Item 1.2.1):

The HCVS wetwell path will be designed for venting steam/energy at a nominal capacity of 1%

of 2536 MWt thermal power at a pressure of 56 psig. This pressure is the lower of the containment design pressure and the PCPL value.

The 1% value assumes that the suppression pool pressure suppression capacity is sufficient to absorb the decay heat generated during the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The vent would then be able to prevent containment pressure from increasing above the containment design pressure. As part of the detailed design, the duration of suppression pool decay heat absorption will be confirmed.

The HCVS is intended for use as one element of a comprehensive core damage prevention strategy as described in the response to NRC Order EA-12-049, which is summarized as follows:

Phase 1 employs the permanently installed Reactor Core Isolation Cooling (RCIC) system to inject water from the Condensate Storage Tanks (CSTs) or torus to the Reactor Pressure

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Page 13 Vessel (RPV) to maintain core cooling. Containment integrity is maintained by the containment isolation valves, with the ability to vent through the HCVS if required.

Phase 2 continues to employ RCIC for RPV injection until the supply of water in the CSTs is exhausted, prior to which the fire protection system will be aligned through the Residual Heat Removal Service Water (RHRSW) cross-tie to the Residual Heat Removal (RHR) system to provide RPV injection supplied by water from the Ultimate Heat Sink (UHS). During Phase 2, venting through the HCVS to remove heat from the primary containment will be used to maintain the integrity of the containment.

Phase 3 will employ equipment from the Regional Response Center (RRC) to enable placing RHR into the shutdown cooling mode to remove heat from the reactor (and primary containment). Heat removal from containment will be supplemented as necessary using the HCVS.

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Page 14 Requirement 1.2.2 - HCVS Shall be Accessible to Plant Operators:

The HCVS shall be accessible to plant operators and be capable of remote operation and control, or manual operation, during sustained operations.

ISG 1.2.2 Criteria:

The preferred location for remote operation and control of the HCVS is from the main control room. However, alternate locations to the control room are also acceptable, provided the licensees take into consideration the following:

1. Sustained operations mean the ability to open/close the valves multiple times during the event. Licensees shall determine the number of open/close cycles necessary during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation and provide supporting basis consistent with the plant-specific containment venting strategy.
2. An assessment of temperature and radiological conditions that operating personnel may encounter both in transit and locally at the controls. Licensee may use alternatives such as providing features to facilitate manual operation of valves from remote locations or relocating/reorienting the valves.
3. All permanently installed HCVS equipment, including any connections required to supplement the HCVS operation during a prolonged SBO (electric power, N2/air) shall be located above the maximum design basis external flood level or protected from the design basis external flood.
4. During a prolonged SBO, manual operation/action may become necessary to operate the HCVS. As demonstrated during the Fukushima event, the valves lost motive force including electric power and pneumatic air supply to the valve operators, and control power to solenoid valves. If direct access and local operation of the valves is not feasible due to temperature or radiological hazards, licensees should include design features to facilitate remote manual operation of the HCVS valves by means such as reach rods, chain links, hand wheels, and portable equipment to provide motive force (e.g., air/N2 bottles, diesel powered compressors, and dc batteries). The connections between the valves and portable equipment should be designed for quick deployment. If a portable motive force (e.g., air or N2 bottles, dc power supplies) is used in the design strategy, licensees shall provide reasonable protection of that equipment consistent with the staffs guidance delineated in JLD-ISG-2012-01 for Order EA-12-049.
5. The design shall preclude the need for operators to move temporary ladders or operate from atop scaffolding to access the HCVS valves or remote operating locations.

Response (ref. ISG Item 1.2.2):

The HCVS design allows initiating and then operating and monitoring the HCVS from the MCR/Relay Room and remote control station. This location is also protected from adverse natural phenomena.

1. The HCVS flow path valves are CIVs that are air-operated valves (AOV) with air-to-open and spring-to-close. Opening the valves currently requires energizing an AC powered solenoid valve (SOV) to provide motive air/gas to the actuator cylinder. The detailed design will provide a permanently installed DC powered SOV and backup motive gas supply for each CIV adequate for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Improvements to the plant DC battery source will be necessary under the FLEX strategy and will be outlined in the response to NRC Order EA-12-049. The initial stored motive gas will allow for a minimum of 16 valve operating cycles; however, the detailed design will determine the number of required valve cycles for the first 24-hours. The initial stored motive gas will support the required number of valve cycles. The SOVs are the only electrical component required for valve functionality that are located inside an area that may be inaccessible following a prolonged SBO. The AOVs do not require torque switches or limit switches. Backup manual operation from the remote control station allows for

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Page 15 opening the AOVs without DC power by bypassing the SOVs and directly supplying nitrogen to the valve actuators.

2. An assessment of temperature and radiological conditions that operating personnel may encounter both in transit and locally at the controls will be performed.
3. All permanently installed HCVS equipment, including any connections required to supplement the HCVS operation during a prolonged SBO (electric power, N2/air) will be located in areas reasonably protected from defined hazards from NEI 12-06.
4. All valves required to open to establish the flow path are designed for remote manual operation following a prolonged SBO, i.e., no valve operation via handwheel, reach-rod or similar means that requires close proximity to the valve. Any supplemental connections will be pre-engineered to minimize manpower resources and any needed portable equipment will be reasonably protected from defined hazards from NEI 12-06.
5. Access to the locations described above will not require temporary ladders or scaffolding.
6. To address a failure of a HCVS valve to open due to a failure of a DC circuit (SOV, etc),

the design will provide a contingency for remotely operating the HCVS valve by permanently connected equipment supplying nitrogen directly to the AOV actuators.

The manual operation will be performed from the remote control station located in the access hallway to the Reactor Building.

Requirement 1.2.3 - Prevent Inadvertent Actuation:

The HCVS shall include a means to prevent inadvertent actuation.

ISG 1.2.3 Criteria:

The design of the HCVS shall incorporate features, such as control panel key-locked switches, locking systems, rupture discs, or administrative controls to prevent the inadvertent use of the vent valves. The system shall be designed to preclude inadvertent actuation of the HCVS due to any single active failure. The design should consider general guidelines such as single point vulnerability and spurious operations of any plant installed equipment associated with HCVS.

The objective of the HCVS is to provide sufficient venting of containment and prevent long-term overpressure failure of containment following the loss of active containment heat removal capability or prolonged SBO. However, inadvertent actuation of HCVS due to a design error, equipment malfunction, or operator error during a design basis loss-of-coolant accident (DBLOCA) could have an undesirable effect on the containment accident pressure (CAP) to provide adequate net positive suction head to the emergency core cooling system (ECCS) pumps. Therefore, prevention of inadvertent actuation, while important for all plants, is essential for plants relying on CAP. The licensee submittals on HCVS shall specifically include details on how this issue will be addressed on their individual plants for all situations when CAP credit is required.

Response (ref. ISG Item 1.2.3):

The HCVS containment isolation valves are normally closed AOVs that are air-to-open and spring-to-shut. The DC SOV must be energized to allow the motive gas to open the valve.

Although the same DC and nitrogen source will be used, separate control circuits including switches will be used for the two valves to address single point vulnerabilities that may cause the flow path to inadvertently open.

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Page 16 The features that prevent inadvertent actuation are administrative procedural controls and key lock switches in the Relay Room to override containment isolation logic for the two CIVs in series. Inadvertent action from the remote control station is prevented by administrative procedural controls and several manual steps to open the CIVs.

Plant procedures provide clear guidance that the HCVS is not to be used to defeat containment integrity during any design basis transients and accidents. In addition, the HCVS will be designed to provide features to prevent inadvertent actuation due to a design error, equipment malfunction, or operator error such that any credited containment accident pressure (CAP) that would provide net positive suction head to the emergency core cooling system (ECCS) pumps will be available (inclusive of a design basis loss-of-coolant accident (DBLOCA)). For the long term DBLOCA, containment pressure is available to ensure adequate margin is available for NPSH of the RHR and CS pumps. For Appendix R and SBO, credit for containment pressure is not required to ensure adequate RHR and CS pump NPSH.

Requirement 1.2.4 - Monitor the Status of the Vent System:

The HCVS shall include a means to monitor the status of the vent system (e.g., valve position indication) from the control room or other location(s). The monitoring system shall be designed for sustained operation during a prolonged SBO.

ISG 1.2.4 Criteria:

Plant operators must be able to readily monitor the status of the HCVS at all times, including being able to understand whether or not containment pressure/energy is being vented through the HCVS, and whether or not containment integrity has been restored following venting operations. Licensees shall provide a means to allow plant operators to readily determine, or have knowledge of, the following system parameters:

(1) HCVS vent valves position (open or closed),

(2) system pressure, and (3) effluent temperature.

Other important information includes the status of supporting systems, such as availability of electrical power and pneumatic supply pressure. Monitoring by means of permanently installed gauges that are at, or nearby, the HCVS control panel is acceptable. The staff will consider alternative approaches for system status instrumentation; however, licensees must provide sufficient information and justification for alternative approaches.

The means to monitor system status shall support sustained operations during a prolonged SBO, and be designed to operate under potentially harsh environmental conditions that would be expected following a loss of containment heat removal capability and SBO. Power supplies to all instruments, controls, and indications shall be from the same power sources supporting the HCVS operation. Sustained operations may include the use of portable equipment to provide an alternate source of power to components used to monitor HCVS status. Licensees shall demonstrate instrument reliability via an appropriate combination of design, analyses, operating experience, and/or testing of channel components for the following sets of parameters:

radiological conditions that the instruments may encounter under normal plant conditions, and during and after a prolonged SBO event.

temperatures and pressure conditions as described under requirement 1.2.8, including dynamic loading from system operation.

humidity based on instrument location and effluent conditions in the HCVS.

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Page 17 Response (ref. ISG Item 1.2.4):

The design of the HCVS will have temperature and pressure monitoring downstream of the last CIV with indication at the remote control station and relay room. The existing CIV will have position indication at the MCR, relay room, and remote control station. The new isolation valve will be operated from the relay room with position indication at the relay room and remote control station. Motive gas pressure and power source voltage will also be monitored.

Power for the instrumentation will be from the same source used for CIV position indication.

Refer to the response to 1.2.2 for discussion on electrical power.

The approximate range for the temperature indication will be 50°F to 600°F. The approximate range for the pressure indication will be 0 psig to 120 psig. The upper limits are approximately twice the required design containment temperature and pressure. The ranges will be finalized when the detailed design and equipment specifications are prepared.

The detailed design will address the radiological, temperature, pressure, flow induced vibration (if applicable) and internal piping dynamic forces, humidity/condensation and seismic qualification requirements. Assumed radiological conditions are those expected after a prolonged SBO (without fuel failure), which will bound normal plant conditions.

Requirement 1.2.5 - Monitor the Effluent Discharge for Radioactivity:

The HCVS shall include a means to monitor the effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication in the control room or other location(s), and shall be designed for sustained operation during a prolonged SBO.

ISG 1.2.5 Criteria:

Licensees shall provide an independent means to monitor overall radioactivity that may be released from the HCVS discharge. The radiation monitor does not need to meet the requirements of NUREG 0737 for monitored releases, nor does it need to be able monitor releases quantitatively to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 100 or 10 CFR Section 50.67. A wide-range monitoring system to monitor the overall activity in the release providing indication that effluent from the containment environment that is passing by the monitor is acceptable. The use of other existing radiation monitoring capability in lieu of an independent HCVS radiation monitor is not acceptable because plant operators need accurate information about releases coming from the containment via the HCVS in order to make informed decisions on operation of the reliable hardened venting system.

The monitoring system shall provide indication in the control room or a remote location (i.e., HCVS control panel) for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an extended SBO with electric power provided by permanent DC battery sources, and supplemented by portable power sources for sustained operations. Monitoring radiation levels is required only during the events that necessitate operation of the HCVS. The reliability of the effluent monitoring system under the applicable environmental conditions shall be demonstrated by methods described under Requirement 1.2.4.

Response (ref. ISG Item 1.2.5):

The HCVS radiation monitoring system (RMS) will be dedicated to the HCVS. The approximate range of the RMS is 0.1 mrem/hr to 1000 mrem/hr. This range is considered adequate to determine core integrity per the NRC Responses to Public Comments document.

The mounting position of the radiation detector will be determined in the detailed design. The radiation level will be indicated in the relay room. The RMS will be powered from the same

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Page 18 source as all other powered HCVS components. Refer to the response to 1.2.2 for discussion on sustainability of the power.

Requirement 1.2.6 - Minimize Unintended Cross Flow of Vented Fluids:

The HCVS shall include design features to minimize unintended cross flow of vented fluids within a unit and between units on the site.

ISG 1.2.6 Criteria:

At Fukushima, an explosion occurred in Unit 4, which was in a maintenance outage at the time of the event.

Although the facts have not been fully established, a likely cause of the explosion in Unit 4 is that hydrogen leaked from Unit 3 to Unit 4 through a common venting system. System cross-connections present a potential for steam, hydrogen, and airborne radioactivity leakage to other areas of the plant and to adjacent units at multi-unit sites if the units are equipped with common vent piping. In this context, a design that is free of physical and control interfaces with other systems eliminates the potential for any cross-flow and is one way to satisfy this requirement. Regardless, system design shall provide design features to prevent the cross flow of vented fluids and migration to other areas within the plant or to adjacent units at multi-unit sites.

The current design of the hardened vent at several plants in the U.S. includes cross connections with the standby gas treatment system, which contains sheet metal ducts and filter and fan housings that are not as leak tight as hard pipes. In addition, dual unit plant sites are often equipped with a common plant stack.

Examples of acceptable means for prevention of cross flow is by valves, leak-tight dampers, and check valves, which shall be designed to automatically close upon the initiation of the HCVS and shall remain closed for as long as the HCVS is in operation. Licensees shall evaluate the environmental conditions (e.g.

pressure, temperature) at the damper locations during venting operations to ensure that the dampers will remain functional and sufficiently leak-tight, and if necessary, replace the dampers with other suitable equipment such as valves. If power is required for the interfacing valves to move to isolation position, it shall be from the same power sources as the vent valves. Leak tightness of any such barriers shall be periodically verified by testing as described under Requirement 1.2.7.

Response (ref. ISG Item 1.2.6):

The HCVS shares part of its flow path with the Standby Gas Treatment System (SGTS). The HCVS ties in upstream of the filter trains with the discharge pipe going up the inside wall of the Reactor Building independent of any other system. The SGTS is isolated from the HCVS by two existing motor operated valves that are normally closed. The detailed design phase will review these valves to determine if they can meet the required leakage criteria under the limiting HCVS design conditions. If required, the valves will be modified, replaced or upgraded.

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Page 19 Requirement 1.2.7 - Provision for the Operation, Testing, Inspection and Maintenance:

The HCVS shall include features and provision for the operation, testing, inspection and maintenance adequate to ensure that reliable function and capability are maintained.

ISG 1.2.7 Criteria:

The HCVS piping run shall be designed to eliminate the potential for condensation accumulation, as subsequent water hammer could complicate system operation during intermittent venting or to withstand the potential for water hammer without compromising the functionality of the system. Licensees shall provide a means (e.g., drain valves, pressure and temperature gauge connections) to periodically test system components, including exercising (opening and closing) the vent valve(s). In situations where total elimination of condensation is not feasible, HCVS shall be designed to accommodate condensation, including applicable water hammer loads.

The HCVS outboard of the containment boundary shall be tested to ensure that vent flow is released to the outside with minimal leakage, if any, through the interfacing boundaries with other systems or units.

Licensees have the option of individually leak testing interfacing valves or testing the overall leakage of the HCVS volume by conventional leak rate testing methods. The test volume shall envelope the HCVS between the outer primary containment isolation barrier and the vent exiting the plant buildings, including the volume up to the interfacing valves. The test pressure shall be based on the HCVS design pressure.

Permissible leakage rates for the interfacing valves shall be within the requirements of American Society of Mechanical Engineers Operation and Maintenance of Nuclear Power Plants Code (ASME OM) - 2009, Subsection ISTC - 3630 (e) (2), or later edition of the ASME OM Code. When testing the HCVS volume, allowed leakage shall not exceed the sum of the interfacing valve leakages as determined from the ASME OM Code. The NRC staff will consider a higher leakage acceptance values if licensees provide acceptable justification. When reviewing such requests, the NRC staff will consider the impact of the leakage on the habitability of the rooms and areas within the building and operability of equipment in these areas during the event response and subsequent recovery periods. Licensees shall implement the following operation, testing and inspection requirements for the HCVS to ensure reliable operation of the system.

Testing and Inspection Requirements Description Frequency Cycle the HCVS valves and the interfacing system valves not used to maintain containment integrity during operations.

Once per year Perform visual inspections and a walkdown of HCVS components Once per operating cycle Test and calibrate the HCVS radiation monitors.

Once per operating cycle Leak test the HCVS.

(1) Prior to first declaring the system functional; (2) Once every five years thereafter; and (3) After restoration of any breach of system boundary within the buildings Validate the HCVS operating procedures by conducting an open/close test of the HCVS control logic from its control panel and ensuring that all interfacing system valves move to their proper (intended) positions.

Once per every other operating cycle

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Page 20 Response (ref. ISG Item 1.2.7):

The detailed design for the HCVS will address condensation accumulation resulting from intermittent venting. In situations where total elimination of condensation is not feasible, the HCVS will be designed to accommodate condensation, including allowance for applicable water hammer loads.

The HCVS Containment Isolation Valves will be tested in accordance with the licensing and design basis for the plant. The HCVS past the outboard Containment Isolation Valve will be tested in conformance to one of the ISG methods. The test pressure shall be based on the HCVS design pressure with 62 psig. Permissible leakage rates for the interfacing valves will be within the requirements of American Society of Mechanical Engineers Operation and Maintenance of Nuclear Power Plants Code (ASME OM) - 2009, Subsection ISTC - 3630 (e)

(2), or later edition of the ASME OM Code. When testing the HCVS volume, the allowed leakage will not exceed the sum of the interfacing valve leakages as determined from the ASME OM Code unless a higher leakage acceptance value is justified to the NRC.

The test types and frequencies will conform to the ISG 1.2.7 Table Testing and Inspection Requirements with the clarification that Leak test the HCVS applies to the HCVS boundary valves.

Requirement 1.2.8 - Design Pressures:

The HCVS shall be designed for pressures that are consistent with maximum containment design pressures, as well as, dynamic loading resulting from system actuation.

ISG 1.2.8 Criteria:

The vent system shall be designed for the higher of the primary containment design pressure or PCPL, and a saturation temperature corresponding to the HCVS design pressure. However, if the venting location is from the drywell, an additional margin of 50 °F shall be added to the design temperature because of the potential for superheated conditions in the drywell. The piping, valves, and the valve actuators shall be designed to withstand the dynamic loading resulting from the actuation of the system, including piping reaction loads from valve opening, concurrent hydrodynamic loads from SRV discharges to the suppression pool, and potential for water hammer from accumulation of steam condensation during multiple venting cycles.

Response (ref. ISG Item 1.2.8):

The HCVS design pressure will be 62 psig and the design temperature will be 309°F. The HCVS design pressure is the higher of the containment design pressure or the PCPL value.

The detailed design will ensure a HCVS design temperature of 309°F, corresponding to a design pressure of 62 psig under saturated conditions.

The piping, valves, and valve actuators will be designed to withstand the dynamic loading resulting from the actuation of the HCVS, including piping reaction loads from valve opening, concurrent hydrodynamic loads from SRV discharges to the suppression pool, and potential for water hammer from accumulation of condensation during multiple venting cycles.

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Page 21 Requirement 1.2.9 - Discharge Release Point:

The HCVS shall discharge the effluent to a release point above main plant structures.

ISG 1.2.9 Criteria:

The HCVS release to outside atmosphere shall be at an elevation higher than adjacent plant structures.

Release through existing plant stacks is considered acceptable, provided the guidance under Requirement 1.2.6 is satisfied. If the release from HCVS is through a stack different than the plant stack, the elevation of the stack should be higher than the nearest building or structure. The release point should be situated away from ventilation system intake and exhaust openings, and emergency response facilities. The release stack or structure exposed to outside shall be designed or protected to withstand missiles that could be generated by the external events causing the prolonged SBO (e.g., tornadoes, high winds).

Response (ref. ISG Item 1.2.9):

The HCVS discharge path will be routed up the southwest corner inside the Reactor Building to a point above any adjacent structure. Note that only the plant common stack is at a higher elevation but it is not adjacent to the Reactor Building. This discharge point will be above the Reactor Building. The design will minimize the potential interferences with the air intake to the MCR, other emergency facilities, FLEX equipment, and access routes required following a prolonged SBO. For normal operation, the release path via the SGTS to the plant stack, remains unchanged.

The conceptual design indicates the entire discharge path of the HCVS line will be within the confines of the Reactor Building; thus, meet seismic requirements and missile protection requirements specified in Order EA-12-050. If a portion of the discharge line needs to be routed outside of the Reactor Building wall, the detailed design will address missile protection from external events as defined by NEI 12-06.

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Page 22 Section 4: Applicable Quality Requirements Requirement 2.1 - Containment Isolation Function:

The HCVS vent path up to and including the second containment isolation barrier shall be designed consistent with the design basis of the plant. These items include piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication components.

ISG 2.1 Criteria:

The HCVS design, out to and including the second containment isolation barrier, shall meet safety-related requirements consistent with the design basis of the plant. The staff notes that in response to GL 89-16, in many cases, the HCVS vent line connections were made to existing systems. In some cases, the connection was made in between two existing containment isolation valves and in others to the vacuum breaker line.

The HCVS system design shall not preclude the containment isolation valves, including the vent valve from performing their intended containment isolation function consistent with the design basis for the plant. The design shall include all necessary overrides of containment isolation signals and other interface system signals to enable the vent valves to open upon initiation of the HCVS from its control panel Response (ref. ISG Item 2.1):

The HCVS vent path up to the second containment isolation valve, including piping and supports, is designed in accordance with existing design basis. The HCVS system design will not preclude the containment isolation valves, including the vent valve, from performing their intended containment isolation function consistent with the design basis for the plant.

Associated actuators, position indication, and power supplies are designed consistent with the design basis of the plant as required to maintain their design basis function of maintaining the valves closed. The control circuit will allow operation of the HCVS from its control panel regardless of containment isolation signals.

Requirement 2.2 - Reliable and Rugged Performance:

All other HCVS components shall be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. These items include electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components.

ISG 2.2 Criteria:

All components of the HCVS beyond the second containment isolation barrier shall be designed to ensure HCVS functionality following the plants design basis seismic event. These components include, in addition to the hardened vent pipe, electric power supply, pneumatic supply and instrumentation. The design of power and pneumatic supply lines between the HCVS valves and remote locations (if portable sources were to be employed) shall also be designed to ensure HCVS functionality. Licensees shall ensure that the HCVS will not impact other safety-related structures and components and that the HCVS will not be impacted by non-seismic components. The staff prefers that the HCVS components, including the piping run, be located in seismically qualified structures. However, short runs of HCVS piping in non-seismic structures are acceptable if the licensee provides adequate justification on the seismic ruggedness of these structures. The hardened vent shall be designed to conform to the requirements consistent with the applicable design codes for the plant, such as the American Society of Mechanical Engineers Boiler and Pressure Vessel Code and the applicable Specifications, Codes and Standards of the American Institute of Steel Construction.

To ensure the functionality of instruments following a seismic event, the NRC staff considers any of the following as acceptable methods:

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Page 23 Use of instruments and supporting components with known operating principles that are supplied by manufacturers with commercial quality assurance programs, such as ISO9001. The procurement specifications shall include the seismic requirements and/or instrument design requirements, and specify the need for commercial design standards and testing under seismic loadings consistent with design basis values at the instrument locations.

Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard could be used.

Demonstration that the instrumentation is substantially similar in design to instrumentation that has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performed for the plant licensing basis.

Response (ref. ISG Item 2.2):

The HCVS components downstream of the second containment isolation valve and components that interface with the HCVS will be routed in seismically qualified structures.

The HCVS downstream of the second containment isolation valve, including piping and supports, electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components, will be designed/analyzed to conform to the requirements consistent with the applicable design codes for the plant and to ensure functionality following a design basis earthquake.

The HCVS instruments, including valve position indication, process instrumentation, radiation monitoring, and support system monitoring, will be qualified by using one of the three methods described in the ISG, which includes:

1. Purchase of instruments and supporting components with known operating principles from manufacturers with commercial quality assurance programs (e.g., ISO9001) where the procurement specifications include the applicable seismic requirements, design requirements, and applicable testing.
2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-2004 or equivalent specification (e.g. an earlier version of IEEE-344).
3. Demonstration that instrumentation is substantially similar to the design of instrumentation previously qualified.

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Page 24 Instrument Qualification Method*

HCVS Process Temperature ISO9001 / IEEE 344-2004 / Demonstration HCVS Process Pressure ISO9001 / IEEE 344-2004 / Demonstration HCVS Process Radiation Monitor ISO9001 / IEEE 344-2004 / Demonstration HCVS Process Valve Position ISO9001 / IEEE 344-2004 / Demonstration HCVS Pneumatic Supply Pressure ISO9001 / IEEE 344-2004 / Demonstration HCVS Electrical Power Supply Availability ISO9001 / IEEE 344-2004 / Demonstration Drywell pressure Existing instruments / pre-qualified Wetwell pressure Existing instruments / pre-qualified Wetwell level Existing instruments / pre-qualified Reactor Pressure Existing instruments / pre-qualified

  • The specific qualification method used for each required HCVS instrument will be reported in future 6 month status reports.

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Page 25 Section 5: Procedures and Training Requirement 3.1 - Develop, Implement, and Maintain Procedures:

Licensees shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during SBO conditions.

ISG 3.1 Criteria:

Procedures shall be developed describing when and how to place the HCVS in operation, the location of system components, instrumentation available, normal and backup power supplies, directions for sustained operation, including the storage location of portable equipment, training on operating the portable equipment, and testing of equipment. The procedures shall identify appropriate conditions and criteria for use of the HCVS. The procedures shall clearly state the nexus between CAP and ECCS pumps during a DBLOCA and how an inadvertent opening of the vent valve could have an adverse impact on this nexus.

The HCVS procedures shall be developed and implemented in the same manner as other plant procedures necessary to support the execution of the Emergency Operating Procedures (EOPs).

Licensees shall establish provisions for out-of-service requirements of the HCVS and compensatory measures. These provisions shall be documented in the Technical Requirements Manual (TRM) or similar document. The allowed unavailability time for the HCVS shall not exceed 30 days during modes 1, 2, and 3.

If the unavailability time exceeds 30 days, the TRM shall direct licensees to perform a cause assessment and take the necessary actions to restore HCVS availability in a timely manner, consistent with plant procedures and prevent future unavailability for similar causes.

Response (ref. ISG Item 3.1):

Procedures will be established for system operations when normal and backup power is available, and during prolonged SBO conditions.

The HCVS procedures will be developed and implemented following the plants process for initiating or revising procedures and contain the following details:

appropriate conditions and criteria for use of the HCVS when and how to place the HCVS in operation, the location of system components, instrumentation available, normal and backup power supplies, directions for sustained operation(reference NEI 12-06), including the storage location of portable equipment, training on operating the portable equipment, and testing of portable equipment The procedures will state the impact on ECCS, RHR and CS pumps NPSH (loss of CAP) during a DBLOCA due to an inadvertent opening of the vent.

Licensees will establish provisions for out-of-service requirements of the HCVS and compensatory measures. The following provisions will be documented in the Technical Requirements Manual (TRM) or other controlled document.

The allowed unavailability time for the HCVS shall not exceed 30 days during modes 1, 2, and 3.

If the unavailability time exceeds 30 days o The condition will entered into the corrective action system,

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 26 o The HCVS availability will be restored in a manner consistent with plant procedures, o A cause assessment will be performed to prevent future unavailability for similar causes.

Requirement 3.2 - Train Appropriate Personnel:

Licensee shall train appropriate personnel in the use of the HCVS. The training curricula shall include system operations when normal and backup power is available, and during SBO conditions.

ISG 3.2 Criteria:

All personnel expected to operate the HVCS shall receive training in the use of plant procedures developed for system operations when normal and backup power is available, and during SBO conditions consistent with the plants systematic approach to training. The training shall be refreshed on a periodic basis and as any changes occur to the HCVS.

Response (ref. ISG Item 3.2):

Personnel expected to perform direct execution of the HVCS will receive necessary training in the use of plant procedures for system operations when normal and backup power is available and during prolonged SBO conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS. The training will utilize the systematic approach to training.

In addition, per NEI 12-06, all personnel on-site will be available to supplement trained personnel.

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 27 Section 6: Implementation Schedule Milestones The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent 6 month status reports.

Original Target Date Activity Status Oct. 2012 Hold preliminary/conceptual design meeting Complete Oct. 2012 Submit 60 Day Status Report Complete Feb. 2013 Submit Overall Integrated Implementation Plan Complete Aug 2013 Submit 6 Month Status Report Feb. 2014 Submit 6 Month Status Report Aug. 2014 Submit 6 Month Status Report Feb. 2015 Submit 6 Month Status Report Aug. 2015 Submit 6 Month Status Report Oct. 2015 Complete Design, Develop Procedures, Issue Final Modification Feb. 2016 Submit 6 Month Status Report Aug. 2016 Submit 6 Month Status Report Nov. 2016 Complete Implementation of Modifications Dec. 2016 Submit Completion Report Section 7: Changes/Updates to this Overall Integrated Implementation Plan Any significant changes to this plan will be communicated to the NRC staff in the 6 Month Status Reports

AREVA NP Inc.

ANP-3201 Revision 1 FitzPatrickss Overall Integrated Plan in Response to March 12, 2012 Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Page 28 Section 8: Figures/Diagrams ISG IV.C. 1. Reporting Requirements:

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