JAFP-16-0111, Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

ML16182A377
Person / Time
Site:	FitzPatrick
Issue date:	06/30/2016
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, JAFP-16-0111
Download: ML16182A377 (12)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-16-0111 June 30, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Entergy - James A. FitzPatrick Fourth Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC Order, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, EA-13-109, dated June 6, 2013

2. NRC Interim Staff Guidance, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, JLD-ISG-2013-02, dated November 2013

3. NRC Interim Staff Guidance, Compliance with Phase 2 of Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, JLD-ISG-2015-01, dated April 2015

4. NEI document, Industry Guidance for Compliance with NRC Order EA-13-109: BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, NEI 13-02, dated April 2015

5. ENOI letter, James A. FitzPatrick Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP-14-0075, dated June 30, 2014

6. ENOI letter, James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP 0149, dated December 29, 2015

7. ENOI letter, Certification of Permanent Cessation of Power Operations, JAFP-16-0045, dated March 16, 2016

JAFP-16-0111 Page 2 of 2

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-13-109 to James A. FitzPatrick Nuclear Power Plant (JAF) [Reference 1]. EA-13-109 directs JAF to install a reliable hardened venting capability in accordance with the requirements detailed in the Order, including:

A Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D.1. Reference 2 endorses industry guidance document NEI 13-02, Revision O with clarifications and exceptions identified in Reference 2. Reference 5 provided the JAF's Phase 1 Overall Integrated Plan.

A Phase 2 Overall Integrated Plan pursuant to Section IV, Condition D.2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 [Reference 4]. Reference 6 provided the JAF's Phase 2 Overall Integrated Plan.

Submission of a status report at six-month intervals following submittal of the overall integrated plan phase 1 [Reference 5] pursuant to Section IV, Condition D.3. NEI 13-02

[Reference 4] provides direction regarding the content of the status reports.

The purpose of this letter is to provide the fourth six-month status report, which delineates progress made in implementing the requirements of EA-13-109. Attachment 1&2 provide an update to milestone status, including any changes to the compliance method, schedule, or possible need for relief and the basis.

JAF expects to comply with the Order implementation date; however, based on Entergy Nuclear Operations, Inc. (ENOI) plan to permanently shut down the JAF Nuclear Power Plant

[Reference 7], compliance with the Order will be affected. Future six-month status report submittals will address any requests for exemption from the Order requirements prior to the Order implementation date. No relief or relaxation is requested at this time.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. William C. Drews, Regulatory Assurance Manager, at 315-349-6562.

I declare under penalty of perjury that the foregoing is true and correct; executed on June 30, 2016.

Sincerely, BRS/WCD/mh : James A. FitzPatrick (JAF) Nuclear Power Plant's Fourth Six-Month Status Report for the Implementation of Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 2: Response to Phase 1 Interim Staff Evaluation Open Items cc: Director, Office of Nuclear Reactor NRG Project Manager Regulation NYSPSG NRC Regional Administrator NYSERDA NRG Resident Inspector

JAFP-16-0111 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (4 Pages)

JAFP-16-0111 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1 Introduction JAF developed a Phase 1 Overall Integrated Plan (Reference 2) and a Phase 2 Overall Integrated Plan (Reference 3), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability in response to NRC Order Number EA-13-109 (Reference 1). This attachment provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan, Phase 2 Overall Integrated Plan, and the subsequent Six Month Status Reports, including any changes to the compliance method, schedule, or need for relief / relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Phase 1 Overall Integrated Plan (Reference 2) and Phase 2 Overall Integrated Plan (Reference 3),

and are current as of June 30, 2016. (See Section 3)

Submitted Fourth 6 Month Status Report by letter JAFP-16-0111 3 Milestone Schedule Status The following provides an update to Part 5 of the Phase 1 Overall Integrated Plan (Reference 2) and Part 5 of the Phase 2 Overall Integrated Plan (Reference 3). It provides the status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Target Milestone Completion Activity Status Comments Date Phase 1 Hold preliminary / conceptual design Jan. 2014 Complete meeting Submit Overall Integrated Jun. 2014 Complete Implementation Plan Submit 6 Month Status Report Dec. 2014 Complete Submit 6 Month Status Report Jun. 2015 Complete Design Engineering On-site/Complete Dec. 2015 Complete Submit 6 Month Status Report Dec. 2015 Complete Submit 6 Month Status Report Jun. 2016 Complete Operations Procedure Changes Aug. 2016 On hold See section 5 Developed Site Specific Maintenance Procedure Aug. 2016 On hold See section 5 Developed Implementation Outage Oct. 2016 On hold See section 5 Page 1 of 4

JAFP-16-0111 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Target Milestone Completion Activity Status Comments Date Procedure Changes Active Nov. 2016 On hold See section 5 Walk Through Nov. 2016 On hold See section 5 Demonstration/Functional Test Submit 6 Month Status Report Dec. 2016 Not started Training Complete Dec. 2016 On hold See section 5 Submit 6 Month Status Report Jun. 2017 Not started Submit Completion Report Jun. 2017 Not started Phase 2 Hold preliminary/conceptual design Oct 2015 Complete meeting Submit Overall Integrated Dec 2015 Complete Implementation Plan Submit 6 Month Status Report Jun 2016 Completed Submit 6 Month Status Report Dec 2016 Not started Submit 6 Month Status Report Jun 2017 Not started Design Engineering On-site/Complete Jun 2017 On hold See section 5 Submit 6 Month Status Report Dec 2017 Not started Operations Procedure Changes Jun 2018 On hold See section 5 Developed Site Specific Maintenance Procedure Jun 2018 On hold See section 5 Developed Training Complete Jun 2018 On hold See section 5 Submit 6 Month Status Report Jun 2018 Not started Implementation Outage Sep 2018 On hold See section 5 Walk Through Sep 2018 On hold See section 5 Demonstration/Functional Test Procedure Changes Active Sep 2018 On hold See section 5 Submit Completion Report Nov 2018 Not started Page 2 of 4

JAFP-16-0111 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 4 Changes to Compliance Method This six-month update does not change the compliance method contained in the Phase 1 &

2 Overall Integrated Plans (Reference 2 & 3) or previous six-month updates.

Note: On March 16, 2016, Entergy Nuclear Operations, Inc. (ENOI) submitted a plan to the NRC to permanently cease power operations at JAF on January 27, 2017 (Reference 8).

ENOI is evaluating its compliance with EA-13-109 (Reference 1) in order to determine the appropriate actions in alignment with the decision to permanently cease power operations.

5 Need for Relief / Relaxation and Basis for the Relief / Relaxation Based on ENOIs plan to permanently shut down the JAF Nuclear Power Plant (Reference 8), compliance with NRC Order EA-13-109 will be affected. JAF will submit a plan that resolves any issues relative to Order implementation. This plan may include a relief/relaxation request and up to a request to rescind the Order. However, no relief or relaxation is requested at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 and Phase 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 & 2 Open Item Status Phase 1 None Phase 2 Complete hydraulic analysis of diesel fire pump for SAWA / SAWM On hold. See section 5.

flowrates Identify and evaluate severe accident conditions for Phase 2 manual On hold. See section 5.

actions.

The FLEX Engineering Change (EC 52736) has not been completed; On hold. See section 5.

therefore, any reference to this information is considered unverified.

Open items from Phase 1 Interim Staff Evaluation (Reference 7) are provided in Attachment 2 to this letter. Note: Progress toward open items has been placed on hold (See section 5).

7 Interim Staff Evaluation Impacts There are no potential impacts to the Phase 1 Interim Staff Evaluation (Reference 7) identified at this time.

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JAFP-16-0111 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 8 References The following references support the updates to the Phase 1 & 2 Overall Integrated Plan described in this attachment:

1. NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions dated June 6, 2013 (ML13143A321).

2. Letter JAFP-14-0075, James A. FitzPatrick Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (ML14181B117).

3. Letter JAFP-15-0149, James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015 (ML15365A593)

4. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109: BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, dated April 2015 (ML15113B318).

5. NRC Interim Staff Guidance, JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013 (ML13304B836).

6. NRC Interim Staff Guidance, JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated April 2015 (ML15104A118)

7. James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated February 12, 2015, (ML15007A090).

8. Letter JAFP-16-0045, Certification of Permanent Cessation of Power Operations, dated March 16, 2016 (ML16076A391).

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JAFP-16-0111 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items (4 Pages)

JAFP-16-0111 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response COMPLETE Make available for NRC staff audit analyses JAF is capable of (a) venting the equivalent of (1) percent of demonstrating that HCVS has the capacity to licensed/rated thermal power and (b) the Torus is capable of vent the steam/energy equivalent of one (1) absorbing the decay heat from full power to (1) one percent percent of licensed/rated thermal power (unless licensed/rated thermal power to maintain the integrity of primary a lower value is justified), and that the containment.

suppression pool and the HCVS together are Section 3.2.2.1 Auditable analyses to justify the capability of the Torus, as described 1

able to absorb and reject decay heat, such that Section 3.2.2.2 in this action, have been issued as calculation JAF-CALC-14-00015 following a reactor shutdown from full power (part of the approved design change package EC 52721) and containment pressure is restored and then calculation JAF-CALC-15-00026 (part of the approved design maintained below the primary containment change package EC 58158).

design pressure and the primary containment pressure limit. Update June 2016: Progress on EC 52721 implementation has been suspended.

COMPLETE The HCVS piping from the Torus to the discharge above the RB Roof is designed to be seismically rugged as supported by calculations JAF-CALC-14-00017, JAF-CALC-15-00008, JAF-CALC-15-00033, and JAF-CALC-14-00016 (part of the approved design change package EC 52721).

Make available for NRC staff audit the seismic 2 and tornado missile final design criteria for the Section 3.2.2.3 Protection from tornado missiles relies on HCVS-WP-04 which HCVS stack. concludes that piping located a minimum of 30 above grade is unlikely to be damaged in a manner that prevents containment venting. All JAF HCVS piping is located a minimum of 30 above grade.

Update June 2016: Progress on EC 52721 implementation has been suspended.

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JAFP-16-0111 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response NOT COMPLETE The HCVS Battery System will support a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of Section 3.2.2.4 operation. This evaluation is included in EC 52721.

Section 3.2.3.1 Make available for NRC staff audit the final Section 3.2.3.2 The power source for the charger will be backed by a FLEX DG.

sizing evaluation for HCVS batteries/battery Section 3.2.4.1 3 The FLEX DG loading will be issued as part of the FLEX design charger including incorporation into FLEX DG Section 3.2.4.2 change package.

loading calculation. Section 3.2.5.1 Section 3.2.5.2 Update June 2016: Progress on EC 52721 implementation has been Section 3.2.6 suspended. In addition, FLEX design change package has been suspended.

COMPLETE Section 3.2.2.4 The HCVS pneumatic system design sizing will be capable of 12 Section 3.2.3.1 cycles in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The sizing of the nitrogen motive force Section 3.2.3.2 Make available for NRC staff audit and purge systems are provided in calculations JAF-CALC Section 3.2.4.1 4 documentation of the HCVS nitrogen pneumatic 00013 and JAF-CALC-15-00038, respectively (part of the approved Section 3.2.4.2 system design including sizing and location. design change package EC 52721).

Section 3.2.5.1 Section 3.2.5.2 Update June 2016: Progress on EC 52721 implementation has been Section 3.2.6 suspended.

COMPLETE The JAF strategy for preventing hydrogen detonation and Provide a description of the final design of the deflagration beyond the final isolation point (valve) is a nitrogen 5 HCVS to address hydrogen detonation and Section 3.2.2.6 purge system. Concurrent with closing the isolation valve, the purge deflagration.

system will be initiated to purge the vented fluid from the HCVS pipeline.

COMPLETE At JAF the interfaces between the RB and the HCVS pipeline are Provide a description of the strategies for limited to normally closed, small bore drain and instrument valves hydrogen control that minimizes the potential for 6 Section 3.2.2.6 minimizing the hydrogen gas migration and ingress into the Reactor hydrogen gas migration and ingress into the Building. In addition, migration to the Standby Gas Treatment reactor building or other buildings.

System is minimized through the use of existing Class VI MOVs that will be leak tested in accordance with NEI 13-02.

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JAFP-16-0111 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response NOT COMPLETE The required instrumentation and controls (existing and new) are identified as part of the JAF OIP, Part 2. The qualification of the Make available for NRC staff audit descriptions equipment has been described within the approved design change of all instrumentation and controls (existing and 7 Section 3.2.2.10 package EC 52721; however, additional documentation must be planned) necessary to implement this order supplied by vendors before this item is completed.

including qualification methods.

Update June 2016: Progress on EC 52721 implementation has been suspended.

NOT COMPLETE The qualification of the equipment has been described within the approved design change package EC 52721; however, additional Make available for NRC staff audit documentation must be supplied by vendors before this item is 8 documentation of a seismic qualification Section 3.2.2.9 completed.

evaluation of HCVS components.

Update June 2016: Progress on EC 52721 implementation has been suspended.

Make available for NRC staff audit the descriptions of local conditions (temperature, COMPLETE radiation and humidity) anticipated during ELAP The approved design change package EC 52721 describes the and severe accident for the components Section 3.2.2.3 conditions and capability of the equipment to function within the (valves, instrumentation, sensors, transmitters, Section 3.2.2.5 9 stated conditions.

indicators, electronics, control devices, etc.) Section 3.2.2.9 required for HCVS venting including Section 3.2.2.10 Update June 2016: Progress on EC 52721 implementation has been confirmation that the components are capable suspended.

of performing their functions during ELAP and severe accident conditions.

Make available for NRC staff audit documentation of an evaluation verifying the COMPLETE existing containment isolation valves, relied Calculations 14620.9011-US(N)-004 confirms that the PCIVs are 10 Section 3.2.2.9 upon for the HCVS, will open under the capable of operation under the maximum expected differential maximum expected differential pressure during pressure during BDBEE and severe accident wetwell venting.

BDBEE and severe accident wetwell ventinq.

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JAFP-16-0111 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response NOT COMPLETE Make available for NRC staff audit The capability for communication between the HCVS operation documentation that demonstrates adequate locations and decision makers will be evaluated as part of EP-11 communication between the remote HCVS Section 3.2.2.5 Comms modifications.

operation locations and HCVS decision makers Update June 2016: Progress on EP-Comms design change during ELAP and severe accident conditions.

package EC 53903 has been suspended.

Section 3.2.1 COMPLETE Section 3.2.2.3 The approved design change package EC 52721, along with Make available for NRC staff audit an Section 3.2.2.4 supporting calculations, has identified the anticipated conditions evaluation of temperature and radiological Section 3.2.2.5 during ELAP and a Severe Accident and confirm the capability for 12 conditions to ensure that operating personnel Section 3.2.2.10 operating personnel to safely access and operate controls and can safely access and operate controls and Section 3.2.4.1 support equipment.

support equipment. Section 3.2.4.2 Update June 2016: Progress on EC 52721 implementation has been Section 3.2.5.2 suspended.

Section 3.2.6 Page 4 of 4