LR-N16-0118, 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

ML16181A210
Person / Time
Site:	Hope Creek
Issue date:	06/29/2016
From:	Davison P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, LR-N16-0118
Download: ML16181A210 (14)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 Order EA-13-109 LR-N16-0118 JUN 2 9 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Hope Creek Generating Station's 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-13-1 09)

References:

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

2. PSEG Letter LR-N 14-0155, "PSEG Nuclear LLC's Phase 1 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-13-1 09)," dated June 25, 2014

3. PSEG Letter LR-N14-0258, "Hope Creek Generating Station's First 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)," dated December 19, 2014

4. PSEG Letter LR-N15-0129, "Hope Creek Generating Station's Second 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

JUN 2 9 2016 Page 2 Order EA-13-109 LR-N16-0118 Accident Conditions (Order Number EA-13-109)," dated June 18, 2015

5. PSEG Letter LR-N15-0257, "Hope Creek Generating Station's Phase 1 and Phase 2 Overall Integrated Plan and Third Six-Month Status Report (Phase 1) 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 December 28, 2015

6. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109,"

Revision 1, dated April 2015

7. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated November 14, 2013

8. 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

9. NRC Letter to PSEG, "Hope Creek Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC NO. MF4458)," dated February 12, 2015 On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 (Reference 1) to all licensees that operate boiling-water reactors (BWRs) with Mark I and Mark II containment designs. The Order was effective immediately and requires the Hope Creek Generating Station (HCGS) to install a reliable hardened venting capability for pre-core damage and severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of NRC Order EA-13-109.

Section IV of NRC Order EA-13-1 09 requires transmittal of an Overall Integrated Plan (OIP) for Phase 1 by June 30, 2014, status reports at six-month intervals thereafter, and an OIP for Phase 2 by December 31, 2015. PSEG submitted the Phase 1 OIP for HCGS via Reference 2. References 3 and 4, respectively, provided the first two six-month status reports for Phase 1 implementation. Via Reference 5, PSEG transmitted Revision 1 of the OIP, which addresses Phase 2 requirements and includes the third six-month status report. The purpose of this letter is to provide the fourth six month status report pursuant to Condition IV.D.3 of NRC Order EA-13-109.

JUN 9 2016 Page 3 Order EA-13-109 LR-N16-0118 Attachment 1 contains the fourth six-month status report for HCGS implementation of NRC Order EA-13-109, following the report content guidance of Nuclear Energy Institute (NEI) Report 13-02 (Reference 6) as endorsed by NRC Interim Staff Guidance documents JLD-ISG-2013-02 (Reference 7) and JLD-ISG-2015-01 (Reference 8). The attached report provides an update of the milestone accomplishments since the submittal of the previous six-month status report (Reference 5), including any changes to the compliance method, schedule, and the need and basis for relief or relaxation from specific requirements of NRC Order EA-13-109. The status of open items identified in the NRC's Interim Staff Evaluation for Phase 1 (Reference 9) is included in the attached update.

There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please do not hesitate to contact Mr. Brian J. Thomas at 856-339-2022.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 3v"'e. ) ;to\ b (Date)

Sincerely, a..l:O Paul J. Davison Site Vice President Hope Creek Generating Station Attachment 1: HCGS Fourth Six-Month Status Report for Implementation of NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc: Mr. Daniel Dorman, Administrator, Region I, NRC Mr. Justin Hawkins, NRC Senior Resident Inspector, Hope Creek Ms. Carleen J. Parker, Project Manager, NRC/NRRIDORL Dr. Rajendra Auluck, Project Manager, NRC/NRRIJLD Mr. Patrick Mulligan, Chief, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Corporate Commitment Coordinator

ATTACHMENT 1 LR-N16-0118 HCGS Fourth Six-Month Status Report for Implementation of NRC Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions"

LR-N16-0118 HCGS Fourth Six-Month Status Report for Implementation of NRC Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" References in this attachment are listed in Section 8.

1 Introduction PSEG Nuclear LLC (PSEG) developed an Overall Integrated Plan (OIP) (Reference 1) for the Hope Creek Generating Station (HCGS), to address the installation of a Hardened Containment Vent System (HCVS), in response to NRC Order EA-13-109 (Reference 2).

PSEG developed an updated and combined Phase 1 and 2 OIP (Reference 5), to address:

1. The installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Phase 1 of NRC Order EA-13-109.

2. An alternative strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Phase 2 of NRC Order EA-13-109.

This report provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 OIP, including any changes to the compliance method, schedule, and the need and basis for relief or relaxation from specific requirements of NRC Order EA-13-1 09.

2 Milestone Accomplishments No milestones have been completed since the third six-month status report was transmitted to the NRC via Reference 5.

3 Milestone Schedule Status The following table provides an update to the OIP (Reference 5) milestones. The table provides the target completion date and activity status of each item. The dates are planning dates subject to change as design and implementation details are developed.

Page 1 of 10

LR-N16-0118 NRC Order EA-13-1 09 Milestones Target Comments Activity Milestone Completion (Includes Date Status Date Changes)

Overall Integrated Plan and Six-Month Updates Submit OIP- Phase 1 Jun 2014 Complete Reference 1 Update 1 Dec 2014 Complete Reference 3 Update 2 Jun 2015 Complete Reference 4 Update 3 and Phase 2 01 P Dec 2015 Complete Reference 5 Complete via Update 4 Jun 2016 this Report Includes Phase 1 Update 5 Dec 2016 Not Started Completion Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Phase 1 Implementation Hold preliminary/conceptual Jun 2014 Complete design meeting Design Change Packages (DCPs)

Design Engineering On-Oct 2015 Started Issued and Being site/Complete Revised - Target is September 2016 Implementation Outage Oct 2016 Not started Walk-Through Demonstration I Nov 2016 Not started Functional Test Coordinated with Operations Procedure Changes DCPs- Revised Jun 2016 Started Developed Target is September 2016 Coordinated with Site-Specific Maintenance DCPs - Revised Jun 2016 Not started Procedures Developed Target is October 2016 Procedure Changes Active Nov 2016 Not started Page 2 of 10

LR-N16-0118 Target Comments Activity Milestone Completion (Includes Date Status Date Changes)

Phase 1 Implementation (continued)

Coordinated with DCPs- Revised Training Complete Jun 2016 Started Target is October 2016 Submit Completion Report- Include with Fifth Dec 2016 Not started Phase 1 Six-Month Update Phase 2 Implementation Hold preliminary/conceptual Dec 2015 Complete design meeting Submit Overall Integrated Dec 2015 Complete Implementation Plan Design Engineering On- April 2017 Started site/Complete Operations Procedure Changes Dec 2017 Not started Developed Site-Specific Maintenance Dec 2017 Not started Procedures Developed Training Complete Feb 2018 Not started Implementation Outage April 2018 Not started Procedure Changes Active April 2018 Not started Walk Through April 2018 Not started Demonstration/Functional Test Submit Completion Report June 2018 Not started Page 3 of 10

LR-N1 6-01 18 Attachment 1 4 Changes to Compliance Method PSEG identified planned alternatives to NEI 1 3-02 (Reference 6) and NRC Interim Staff Guidance documents JLD-ISG-201 3-02 (Reference 7) and JLD-ISG-201 5-01 (Reference 8) in Revision 1 to the OIP (Reference 5). These alternatives pertain to

1) monitoring the status of vent operation and 2) the height of the torus vent release point, and are associated with open items in the NRC Interim Staff Evaluation (ISE)

(Reference 9) for compliance with Phase 1 of NRC Order EA- 1 3-1 09. Sections 4.1 and 4.2 provide the current status of these items.

4. 1 Monitoring the Status of Vent Operation The following information was provided in OIP Revision 1 (Reference 5), and is repeated here for convenience:

Hope Creek is taking an alternative approach to vent monitoring. JLD-ISG-2013-02 requires temperature and pressure monitoring of the vent piping as an indication of flow.

Hope Creek currently has a dual-element flow monitor (high/low range) as part of the existing Hardened Torus Vent (HTV) radiation monitoring system. The vent flow signal will be displayed at the POS in lieu of vent pipe temperature and pressure. The vent operation will be monitored by HCVS valve position, vent flow, and effluent radiation levels. Containment parameters of pressure, torus level and temperature from the Main Control Room (MCR) instrumentation will be used to monitor effectiveness of the venting actions [ISE #6].

4.2 Vent Release Point Height In Reference 1 0, PSEG requested relaxation from NRC Order EA-1 3- 1 09 Attachment 2, Requirement 1 .2.2, which states:

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

The relaxation request is tracked as NRC ISE Open Item #1 3 (Reference 9).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation The vent release point height relaxation request described in Section 4.2 is an exception to NRC Order EA-1 3-1 09 Attachment 2, Requirement 1 .2.2. The need and basis for the relaxation are provided in Reference 1 0.

Page 4 of 1 0

LR-N16-0118 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Phase 1 Open Items Item Ref. Action Comment ISE#1 Finalize time constraints and their bases. Make Started. Anticipatory venting time constraints OIP#1 available for NRC staff audit the finalized time are included in the FLEX strategy timeline which constraints for remote manual operations and their assumes torus venting is initiated approximately bases. four hours following an ELAP event, based on torus water temperature of 200 degrees F.

HCGS is following EPG/SAG R3. MAAP analysis is in progress to support venting prior to vessel breach to prevent PCPL exceedance.

ISE#2 Make available for NRC staff audit analyses Complete.

OIP#2 demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

ISE#3 Provide the seismic and tornado missile final design Started. The HCVS design change is OIP#6 criteria for the HCVS stack. addressing seismic and missile design criteria.

Page 5 of 10

LR-N16-0118 I

Phase 1 Open Items Ii I

Item Ref. Action Comment ISE #4 Make available for NRC staff audit documentation that Complete (Reference 5).

demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

ISE #5 Perform dose evaluation for venting actions (OIP #4). Started. Evaluations are being finalized.

OIP #4 Make available for NRC staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

ISE #6 Make available for NRC staff audit descriptions of all Started. The HCVS design change includes instrumentation and controls (existing and planned) qualification of instrumentation and controls.

necessary to implement this order including qualification This includes indication of HCVS valve position, methods. vent flow, and effluent radiation levels as an alternative to vent piping temperature and pressure monitoring. Containment parameters of pressure, torus level and temperature from the Main Control Room (MCR) instrumentation will be used to monitor effectiveness of the venting actions.

ISE #7 Make available for NRC staff audit the final sizing Started. Evaluations are being finalized.

evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

ISE #8 Make available for NRC staff audit documentation of the Complete.

HCVS nitrogen pneumatic system design including sizing and location.

Page 6 of 10

LR-N16-0118 Phase 1 Open Items Item Ref. Action Comment ISE #9 Make available for NRC staff audit the descriptions of Started. Completion requires documentation for local conditions (temperature, radiation, and humidity) upgraded radiation monitor.

anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.)

required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

ISE #10 Make available for NRC staff audit an evaluation Complete.

verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

ISE #11 Provide a description of the strategies for hydrogen Started. Evaluations are being finalized.

control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

ISE #12 Provide a description of the final design of the HCVS to Started. Evaluations are being finalized.

OIP #5 address hydrogen detonation and defl_agration.

ISE #13 Finalize x/Q analysis (OIP #3). Submit a relaxation Complete (Reference 1 0).

OIP #3 request as stated in the Order for the deviation from Order EA-13-109 provision 1.2.2, "The HCVS Section 3.2.2.3 shall discharge the effluent to a release point above the main plant structures," which includes a technical justification for the deviation.

Page 7 of 10

LR-N1 6-0 1 1 8 Phase 2 Open Items Item Ref. Action Comment OIP #7 Finalize design of SAWA flow control and indication for flooded condition OIP #8 Evaluate Control/Diesel Building temperature, humidity, and radiological conditions during a non-flooding event.

OIP #9 Evaluate Turbine and Auxiliary Building temperature, humidity, and radiological conditions during a flooding event.

OIP#1 0 Evaluate SAWA equipment and connections external to

• protected buildings.

OIP #1 1 Procedures for Phase 2 SAWA/SAWM Page 8 of 10

LR-N16-0118 7 Interim Staff Evaluation Impacts Items identified in the Phase 1 ISE (Reference 9) are addressed in the Phase 1 Open Items table in Section 6, above. There are no other impacts to the ISE identified at this time.

8 References

1. PSEG letter LR-N14-0155, "PSEG Nuclear LLC's Phase 1 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-13-1 09)," dated June 25, 2014

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

3. PSEG Letter LR-N14-0258, "Hope Creek Generating Station's First 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-13-1 09), dated December 19, 2014

4. PSEG Letter LR-N15-0129, "Hope Creek Generating Station's Second 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-13-1 09)," dated June 18, 2015

5. PSEG Letter LR-N15-0257, "Hope Creek Generating Station's Phase 1 and Phase 2 Overall Integrated Plan and Third Six-Month Status Report (Phase 1) 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 December 28, 2015

6. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-1 09," Revision 1, dated April 2015

7. 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,"

dated November 14, 2013

8. 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 Page 9 of 10

LR-N16-0118

9. NRC Letter to PSEG, "Hope Creek Generating Station- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC NO. MF4458)," dated February 12, 2015

10. PSEG Letter LR-N16-0041, "Hope Creek Generating Station's Request for Relaxation from the Hardened Containment Vent Release Point Height Requirement of NRC Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)," dated June 21, 2016 Page 10 of 10