RS-13-117, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
| ML13241A241 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/28/2013 |
| From: | Kaegi G Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-12-049, RS-13-117 | |
| Download: ML13241A241 (24) | |
Text
Exelon Gene ration ~
Order No. EA-12-049 RS-13-117 August 28, 2013 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
References:
- 1. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to II Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events,n dated March 12, 2012
- 2. NRC Interim Staff Guidance JLD-ISG-2012-01. uCompliance with Order EA-12-049.
Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012
Revision 0, dated August 2012
- 4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049). dated October 25. 2012
- 5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12.
2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-019)
On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis extemal event. Specific requirements are outlined in of Reference 1.
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2013 Page 2 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Clinton Power Station, Unit 1 overall integrated plan.
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1. that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report. including any changes to the compliance method, schedule. or need for relief and the basis. if any.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525 .
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2013.
Respectfully submitted,
/:4-. i, ¥ Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company. LLC
Enclosure:
- 1. Clinton Power Station. Unit 1 First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Clinton Power Station. Unit 1 NRC Project Manager, NRR - Clinton Power Station, Unit 1 Ms. Jessica A. Kratchman, NRR/JLD/PMB. NRC Mr. Robert J. Fretz, Jr, NRRlJLD/PMB, NRC Mr. Robert L. Dennig. NRRlDSS/SCVB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety
Enclosure Clinton Power Station, Unit 1 First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (22 pages)
Clinton Power Station, Unit 1 First She Month Status Report for the Implementation of Order EA 049, Order Modifying licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External EVents 1 Introduction Clinton Power Station, Unit 1 developed an Overall Integrated Plan {Reference 1)1 documenting the diverse and flexible strategIes (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any to the method, or for relief/relaxation the basis, jf any.
2 Milestone Accomplishments None 3 Milestone Schedule Status following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
Original Target Activity Status Completion Date
{Include date changes in this column}
Submit 60 Day Report Complete Submit Overall Integrated Implementation Plan Contract with RRC tpll Aug 2013 Submit 6 month update Complete with this submittal Feb 2014 Submit 6 month update Not Started Aug 2014 Submit 6 month update Not Started Feb 2015 Submit 6 month update Not Started Modification Development Mar 2014 . Phase 2 modifications Started Dec 2014 Regional Response Center Started Operational Procedure development Feb ';H' CllO:;5 Y 1-" Started Page I of 22
Clinton Power Station, Unit 1 First Month Status Report Implementation of August 28,2013 Feb 2015 Validate Procedures (NElll-06, Sect. Not Started 11.4.3)
May 2015 Maintenance ,Jcedl.. Not Started Staffing analysis Not Started Modification llem May
- Phase 2 modifications Not Started May 2015 Storage plan and construction Not May 2015 FLEX equipment acquisition Not Started May 2015 Training completion Not Started May 2015 Unit 1 Implementation Not Started 4 Changes to Compliance Method Note; in the discussions below, italics are used to highlight the changes.
LnlU'ul!'121 Genera/Integrated Plan Elements BWR - Provide 0 sequence of events and identify any time constraint required for success Including the technical basIs fDr rhe tIme constraint. -Item 2 CDnt'ainment Analysis.
ReasDn /Dr Change: This discussion is updated to include results from MAAP a nalvsis of the containment strategy using a slightly higher suppression pool level band. The increased suppression pool volume allowed pool temperature to peak at a lower and provided more to containment design pressure.
Change: As part of the implementation plan of NEil2-06, the BWROG perfonned evaluations of generic BOiling Water Reactor (BWR) response to Extended Loss of AC Power (ElAP) events to demonstrate the I"TTI,,.:;ar'vof Reference 3 provides the results of evaluations for several representative BWR plant designs.
Several Clinton Modular ACcident Analysis Program (MAAP) (Reference 4] cases were run to analyze methods of containment heat removal, including containment venting, suppression pool feed and bleed, suppression pool cooling using a FLEX MAAP cases an pool cooling method provides the fewest operational while providing margin to the primary containment design pressure limit. UHS temperature was designated at 91.4"F in the alternate suppression pool cooling cases.
The following constraints were used as MAAP input or were identified In the FLEX suppression pool cooling MAAP Case 16
- a. RPV pressure is to a pressure band of 150-250 at a rate of SO°F/hr at tot 1 hr.
- b. Suppression Pool Heat Capacity Temperature Limit (HCTL) is reached in to+ 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Emergency is not required since RCIC is used for control during SBO conditions per CPS 4402.01, EOP-6 PRIMARY CONTAINMENT CONTROL 51.
2 of
Clinton Power Station, Uoit 1 First Mooth Status Report for the Implementation of FLEX August 28, 2013
- c. Suppression Pool Makeup (SPMU) from the upper containment pool is suppression pool to extend time required to establish the pool cooling lineup, and to allow time for a FLEX to provide AC power to the SPMU valves in the containment. power to the SPMU valves is olloilable at t o+ 6 hrs.
- d. pool cooling lineup is to occur at to+ 8 hrs to provide the maximum time for establishing a pool cooling lineup a FLEX while maintaining acceptable containment parameter values. The water tube side flow from the FLEX pump was designated at 2000 gpm, and the shell side suppression pool flow was designated at 1500 gpm.
The peak suppression pool temperature in this case is 209.44 of at to + 19.02 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This value is well below the acceptable suction temperature established in the BWROG feasibility study for ROC operation in a prolonged station blackout [Reference 6J. Peak containment pressure is 24.9 psia ot to + 45.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, compared to containment design pressure of 29.7 psia.
- e. Suppression pool makeup from an external source was designated to maintain level between the values of 23 ft. and 23 ft 9 in. The first Injection of makeup occurs at to + 8.02 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Change 2 Maintain Core Cooling - BWR Portable EquIpment 2 Reason/or Change: This discussion is updated to include improvements In the conceptual design. First, the RCIC pump suction is shifted to a cooler water source at to + 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and second, the primary source water for low pressure RPV makeup is changed to the suppression pool 2}. The UHS remains the alternate source of RPV p water (Figure Change: During Phase 2, high pressure RPV makeup is provided from RCIC and RPV pressure control is provided from RCIC and the SRVs. A pre-staged 480 VAC generator will be lined up to the Division 1 AC distribution system to repower the Division 1 battery charger and enable the continued use of RCIC, and instrumentation. A FLEX air compressor will to make up to the ADS backup air bottles, if required.
Alternatively, a separate generator can be lined up to swing battery charger to maintain the Division 1 DC bus energized [Reference 7].
Once the pool lineup is RCIC suction will be shifted to RHR heat exchanger shell outlet using installed RHR steam condensing mode piping (Figure 1). This action limits the ROC system exposure ta elevated suppression pool temperature to the first eight hours of the event. The maximum water temperature the RCIC pump is exposed to is 200.rF according to the MAAP analysis.
Once the RCIC suction is the ROC suction water is 138°F.
To accomplish low pressure RPV makeup when RCIC is no longer available, the suppression pool cooling return path can be directed to the RPV using Installed RHR system lPCI valve. Additionally, external water connections will be provided to a location that supports connection to the modified low Pressure Core Spray (LPCS) [Reference 8] and the Residual Removal (RHR) C 9]
A pre-staged section of fIre hose allows the final connection from the external water supply to the injection header (see Figure 3). The injection valves for these two systems are located outside the primary containment and can be operated manually with the handwheel or electrically via the FLEX RPV pressure will need to be further reduced to approximately 50 psig with SRVs to achieve the flow rate necessary from the external water connection. The supply to the external water connections is Page 3 of22
Clinton Power Station, Unit I First Six Month Status Report the Implementation of August 2013 described in Function Support Phase 2 section. The Suppression Pool Cleanup and Transfer Pump and the external connection will each be capable of meeting the decay heat boil-off rate, plus the assumed system leakage from reactor recirculation pump seals.
Core can be indefinitely with RCle first, then the pool cooling pump with SRVs RPV pressure, and finally pre-staged diesel driven pump with SRVs controlling RPV pressure [Reference 4].
Change 3 Maintain Containment - BWR Portable Equipment Phose 2 Reason for Change: This discussion is updated to include the chosen method of supplying suppression pool water to an RHR heat exchanger. The installed Suppression Pool Cleanup and Transfer system will be modified to allow a flowpath to be established through either RHR heat exchanger.
Change: During Phase 2, a 480 VAC will be lined up to the DiviSion 1, or Division 2 AC distribution to repower lSMOO1A and lSM002A, or alternatively lSMOO1B and lSM002B Upper Containment Pool Makeup to Suppression Pool Valves [Reference 10]. The added inventory from the upper pools will extend the time before suppression pool cooling is required to avoid significant containment pressurization. pool cooling will be accomplished using one of twa installed Suppression Pool Cleanup Transfer (SF) pumps lined up to pool water through the shell side of an RHR heat exchanger abandoned RHR Steam Condensing Mode Piping, and water from the external connections will supply the heat exchanger tube side. The proposed SX connection points are discussed in the Safety Functions Support Phase 2 section.
Either RHR heat exchanger can be used for the suppression pool cooling strategy. The RHR heat chosen will depend on the SX division supplied from the connection and the division aligned to the FLEX generator. This strategy will provide an unlimited coping period for the containment [Reference 4}.
Suppression pool water addition Is required to maintain ROC pump NPSH, makeup for reactor recirculation pump seal leakage into the drywell, makeup for evaporative The external water connection will supply the LPCS header or alternatively the RHR-C injection header. Water can as needed to the suppression pool using lE21-F012 LPCS Test Return To Suppression Pool Valve [Reference 8] or lE12-F021 RHR C Test Valve To Suppression Pool [Reference 9}. These two valves are located outSide the primary containment and can be operated manually with the handwheel or electrically via the FLEX 480 VAC FLEX generator will also repower the Division 1, or alternatively the Division 2, hydrogen igniter distribution panel from Aux Building MCC lAl, or alternatively Aux Building MCC 181
[Reference 111, to allow igniter operation as prescribed by the EOPs.
Change 4 Maintain Cantainment - BWR Portable Equipment Phase 2 - Identify Modifications Reason far Change: This discussion is updated to include the chosen method of supplying suppression pool water to an RHR exchanger. The installed Suppression Pool Cleanup and Transfer system will be modified to allow a flowpath to be established through either RHR heat using a hard-piped connection to the RHR steam condensing mode piping.
Page 4 of22
Clinton Power Station, Unit 1 Six Month Status Report for implementation of August 28, 2013 Additionally, the external water connection to the Shutdown Service Water (SX) system is changed to a tee that will be installed in the Division 1 Division 2 SX supply The February l;;o..lJ;;:II::U a connection at the DiviSion 1 and DiviSion 2 Control Room Ventilation (VC) chillers.
Change:
Identify modifications List modifications
" Two diverse external connections for a portable diesel powered pump to supply cooling water to an RHR heat exchanger.
- A tee will be installed in the Division 1 and DiviSion 2 SX system to support the connection of the external water connection to the SX supply headers.
" Adapt the RHR Steam Condensing Mode (currently abandoned) heat supply piping to provide a path for rr.>C<:l"n Pool Cleanup and Transfer pumps.
- The electrical support and COOling/makeup water modifications needed the containment function are in the Safety Function Support " ......,,,,, ...
5 Maintain Containment - BWR portable Equipment Phase 2 - Deployment Conceptual Design Reason for Change: This discussion is updated to include the chosen method of supplying suppression pool water to an RHR heat exchanger. The installed Suppression Pool Cleanup and system will be modified to allow a f10wpath to be through either RHR exchanger a hard-piped connection to the RHR steam mode piping.
Additionally, the external water connection to the Shutdown Service Water (SX) system is changed to a tee that will be installed in DivisIon 1 and Division 2 SX supply The February submittal u.:>'c.u",,,;;;u a connection at the Division 1 and Division 2 Control Room Ventilation (VC) chillers.
Change:
Deployment CDnceptual Design (Figures 7 and 8 contain deployment conceptual sketches)
Modifications Protection of connections Identify Strategy including Identify modifications Identify how the connection is how the equipment deployed to the point of use.
The support and The electrical and The external connection points cooling/makeup water cooling/makeup water support are common to core cooling, support deployment modifications are common to core containment, and spent fuel pool "1"~:.t""710': are common to cooling, containment, and makeup functions. The protection core cooling, fuel pool makeup functions. The discussion is in the Safety containment, and spent discussion is in the Safety Function Support section.
Page 5 of 22
Clinton Power Station, Unit 1 First Six Month Sratus Report for the Implementation of FLEX August 28, 2013 fuel pool makeup Function Support section.
functions. The discussion is in the Safety Function Support section.
Mechanical jumpers will None Mechanical jumpers will be c~"!fJ~)f'/
be pre-staged to connect in a structure protected from piping from the external external hazards.
water connection to the Division 1 and Division 2 SX supply headers.
Change 6 Safety Functions Support - BWR Portable Equipment Phase 2 Reason for Change: This discussion is updated to include:
.. The proposal to both the primary and FLEX In the Unit 2 side of the Control/Diesel Generator building.
.. The chosen method of supplying suppression pool water to an RHR heat exchanger. The installed Suppression Pool Cleanup and Transfer system will be modified to allow a fJowpath to be established through RHR heat exchanger using a hard-piped connection to the RHR steam mode piping.
.. The proposal to the driven FLEX pumps on the Unit 2 of the Screen House and to size the pumps such that a second pump at grade is not required.
.. The external water connection to the Shutdown Service Water (SX) system is changed to a tee that will be installed in the Division 1 and Division 2 SX supply headers. The February submittal discussed a connection at Division 1 Division 2 Control Room Ventilation (VC)
Change:
Electrical Support Key ponions of the Division 1, Division 2, and non-divisional 480 VAC distribution system will be able to be re-energized /rom a pre-staged primary or FLEX independently will enable maintaining DC power for RCIC, SRV controls and vital instrumentation1 and provide AC power for hydrogen Igniters, SPMU valves and Suppression Pool Cleanup and Transfer pumps (Figure 4).
The primary and alternate FLEX generator and switchgear will be permanently housed in the Unit 2 side the Control and Diesel Generator buildings, so deployment will not impeded by a beyond design basis external event (BD8EE). Where necessary to meet the requirements of the timeline, some connecting cabling may be pre-routed from the Vicinity of the primary and alternate FLEX switchgear to the vicinity of the required 480 VAC unit substations which will have connection points for an external source of power. Where supported by timeline and staffing, some cabling may be manually deployed at the time of the event.
Once the event is identified as an ELAP/LUHS, operations personnel will line up and start the primary or alternate FLEX generator and perform a lineup that enables key 480 VAC components, including the Division 1 battery charger, to be re-energized by t o+6 hrs.
Page 6 of
Clinton Power Station, Unit 1 First Month Status Report for the Implementation of August 2013 Cooling/Makeup Water ;JI.UJILlUI A diesel driven pump will be pre-staged at the Unit 2 side of the Circulating Water Screen House (699' elevation) to enable access to the Ultimate Heat Sink (UHS). The FLEX pumps will have deployable booster pumps to enable access to the UHS if the the main dam has failed elevation). The pump will take suction from the UHS and discharge to the Unit 2 Division 1 SX Supply header at the Screenhouse.
The Unit 2 Division 1 SX Supply header terminates in the Unit 2 side of the Diesel Generator Building. A modification to this line will be routed outside the Diesel Generator building where the FLEX pump supply can be connected to of twa external water connections.
The external water connections will be routed to the vicinity of tees in the Division 1 and Division 2 Shutdown Service Water (SX) System supply headers on the 752' elevation of the Control bUilding.
Mechanical jumpers will allow the external connections to supply the SX supply headers. The SX system will allow cooling water to supplied to the RHR Heat Exchanger for suppression pool cooling and to supply makeup water to the Spent Fuel Pool.
The external connections will also supply makeup water to the RPV and suppression pool using the LPCS and RHR-C modifications described in Core Cooling Phase 2.
Change 7 Safety Functions Support - BWR Portable Equipment Phase 2 -Identify Modifications Reason for Change: This discussion is updated to include:
- proposal to both the primary and altemate FLEX generator in the Unit 2 side of the Control/Diesel Generator building.
- The proposal to pre-stage primary and alternate driven FLEX pumps on the Unit 2 of the Screen House and to size the pumps such that a second pump at grade elevation Is not required.
Change:
Identify modifications List modifications necessary for phase 2 Electrical Support
- A 480 VAC primary and FLEX will in the Unit:2 side the Control/Diesel Generator building.
Iltclull?l'1r will be installed for the primary and the alternate FLEX generators.
.. Cabling will be installed or staged for connecting to 480 VAC distribution system.
.. Unit Substations will be modified to enable cabling from the generators to supply power to the bus and feed the Motor Control Centers (MCCs) supplving required 480 VAC components.
III An external electrical connection point for an external generator will be installed on the south side of the Diesel Generator Building.
Cooling/Makeup Water Support ram the UHS Page 7 of22
Clinton Power UIM."V'l" Unit l Six Month Status Report for the Implementation of August 28, 2013 will be installed ot the Screen House, including UHS access modifications.
- Two external connections for a diesel powered pump to supply low pressure makeup and cooling water In the plant will be installed.
- A connection to the Division 1 and Division 2 Shutdown Service Water (SX) systems from the external water connections will be installed.
Change 8 Functions Support - BWR Portable Equipment 2 - Deployment Conceptual Design Reason/or This discussion is updated to include:
- The proposal to pre-stage both the primary and alternate FLEX generator in the Unit 2 of Control/Diesel Generator
- proposal to the primary and alternate diesel driven FLEX pumps on the Unit 2 side of the Screen House and to size pumps such that a second pump at grade elevation is not required.
Change:
Deployment Conceptual Design (Figures 7 and 8 deployment Strategy Modifications Identify including Identify modifications how equipment will be deployed to the pOint of use.
Electrical Support (Figure 4)
The primary and alternate
- A permanently staged primary FLEX and FLEX will and alternate 480 VAC connections (electrical & fluid) permanently staged and generator able to supply will meet NEI 12-06 Rev.O do not require necessary partions of the 480 protection requirements.
deployment. VAC distribution system to repower the Division 1 battery Pre-staged cabling will be charger and other needed deployed from the FLEX loads.
generator to the Unit
- An external electrical Substations that supply connection able to supply 480 components needed VAC power to switchgear inside to meet the FLEX timeline. the building. The switchgear will be to supply necessary portions the 480 VAC distribution system to repower the DiviSion 1 battery charger or the swing battery charger to supply DC 8 of
Clinton Power Station, Unit I Month Status Report for the Implementation of August 28. 2013 MCC lA, AC
- Pre-routed cabling with cam-lock conn ectors Cooling/Makeup Water Support (Figure 3) driven pumps Two ClVT<>r .... :>. water connections. FLEX piping, and (electrical & fluid) will meet NEI12*06 Rev.O protection requirements.
rements. A heavy duty truck capable of clearing debris will be stored In the same location.
The proposed means of Connection to Unit 2 routing the water from supply piping from the UHS FLEX the UHS to the plant is pump (proposed).
the unused ically robust Unit 2 SX piping.
Change 9 Attachment lA - Sequence of Events Timeline Reason for Change:
- 1. tlmeline for energizing key components from a FLEX was set at to + 5 hrs. was overly restrictive the DC analysis [Reference 12] extended Division 1 battery life to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The coping analysis itself was conservative in that 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> includes consideration of a battery aging factor. Eliminating the battery aging factor extends the coping time further to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- 2. An additional MAAP run was to the effect on suppression pool fj:>rr,nj:>f::t by controlling suppression level at a higher level and in a narrower band.
Change:
- 1. The to the following key components moved down on the timeline from to ... 5 hrs to to
... 6 hrs.
11\ Energize MCC lAl
- 2. The time to begin making up to the pool moved up on timeline from to + 12 hrs to to
+ 8 hrs. change lowered peak pool from to 209"F.
9 ofn
Station, Unit 1 Month Status Report for the Implementation of August 28, 2013 Change 10 - Conceptual Sketches Reason for Change: Changes to deployment plan and system alignments required updated sketches.
Figures 1 through 8 of this document 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Clinton Power Station expects to comply with the order implementation date and no relief/relaxation is required at time.
G Open Items from Overall Integrated Plan and Draft safety EvaluatIon provide a summary of open items "... .. ,.. .."I'! in the Plan or Evaluation (SE) the status of each item.
Section Reference Overall Integrated Plan Open Item Status Sequence of Initial calculations were used to determine the fuel pool Not Started Events (p. 6) timelines. Formal calculations will performed to validate this information during development of spent fuel pool cooling strategy and will be provided in a future six (6) month update.
of Analysis of deviations between Exelon's engineering Completed.
Events {p. 5) the analyses contained in BWROG document is expected to Attached to completed, documented on Attachment 1B, and provided to 6-month update the NRC in the August 2013 six month status update. (Attachment 1)
Sequence of The times to complete actions in the Events Timeline are based Not Started Events (p. 5) on operating judgment, the conceptual designs, and the current supporting analyses. The final timeline will be time validated once detailed deSigns are completed, are developed, and the will provided in a future six (6) month update.
Identify how locations and creation of the strategies will be administrative program are open items. Closure of these items deployed (p. 10) will be documented in a six (6) month update.
Safety Fundio n Habitabmty conditions will be evaluated and a strategy be Not Started Support (p. 41) developed to maintain Main Control Room habitability. The and support will be submitted in a six (6) month 10 of
Clinton Power Station, Unit 1 Six Month Status Report the Implementation of August 28, 2013 Safety Function Battery room conditions will be evaluated and a strategy will be Not Started Support (p. 41) developed to maintain acceptable conditions. strategy and support will submitted In a future six (6)
Safety Function Inverter room conditions will be evaluated and a strategy will Not Started Support (p. 41) developed to maintain conditions. The CT"~I"""<"I and support analyses will be submitted in a future six (6) month update.
Safety for further analysis of building conditions during Not ":<I,T""I'I Support (p. 41) an ELAP/LUHS and mitigating actions is an open item. Closure of this item will be documented in a future six (6) month Multiple Sections Procedures and programs will be developed to address storage Not Started structure requirements, haul path requirements, and FLEX equipment requirements to the external hazards applicable to Clinton Power Station.
Draft Safety Evaluation Open Item Status N/A 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
8 References The following support the 11"11'1", .. " to the Overall Plan described in this enclosure.
- 1. Clinton Power Station's Overall Integrated Plan in to March 2012 Commission Order Modifying licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049l," dated February 28 2013. 1
- 2. NRC Order Number EA-12-049, "Order Modifying licenses with rd to Requirements for Mitigation for Beyond-Deslgn-Basis External Events," dated March 12, 2012.
- 3. BWROG report NEDC- 33771P Rev 2, "GEH Evaluation of FLEX Implementation Guidelines Rev 2"
- 6. 00OO-0143-0382-R1, DRF 0000-0143-0380, "BWROG RCIC System Operation in Prolonged Station Blackout - Study'
- 7. Clinton UFSAR Section 8.1.3.4 Page 11 of 22
Clinton Power Station, Unit l First Six Month Status Report for the Implementation of FLEX 2013
- 8. CPS Drawing M05~1073, Sheet 001, Rev AG, LOW*PRESSURE CORE SPRAY (LPCS) (LP)
- 9. CPS Drawing MOS-l07S, Sheet 003, Rev AG, RESIDUAL HEAT REMOVAL (RH)
- 10. E02.-1AP49, Sheet 001, AUXiliARY BUILDING MCC lA3, Rev Z, DOl,KEY DIAGRAM AUX BUILDING MCC lA4 AND 1B4 (lAP93E) (lAP94E', Rev R
E02-1APS1, Sheet 002, Rev M, KEY DIAGRAM AUX BLDG MCC lBl
- 1. NSSS Significant Reference Analysis Deviation Table (Attachment lB in the Overall Integrated Plan Report Template).
10 Figures
- 1. ROC Operation During Phase 2 (Conceptual)
- 2. Suppression Pool Cooling and Low Pressure RPV Makeup from Suppression Pool (Conceptual)
- 3. Low Pressure RPV Makeup from External Source (Conceptual)
- 4. Electrical Strategy (Conceptual)
- 5. Spent Fuel Pool Makeup (Conceptual)
- 6. Fuel Pool Spray (Conceptual)
- 7. FLEX Deployment Sketch
- 8. RRC Equipment Deployment Conceptual Sketch Page 12of22
Clinton Power Station, Unit 1 First Six Month Status Report for the Implementation of FLEX August 28. 2013 Attachment 1 NSSS Significant Reference Analysis Deviation Table (Attachment 18 in the Overall Integrated Plan Report Template)
NEDC-NEDC-33771P 33771P Design Item Parameter of Interest Rev 2 Villue Page Plant Applied Value Value Gap and Discussion NEDC-33771P Rev 2 Appendix S is dosest to the Clinton strategy for Maintaining Containment Integrity. Differences between the GEH SHEX case and the MAAP analysis ofthe Clinton strategy are listed below.
Input Parameter Values 1 Core thermal power Note 1 20 3473 MWT NA The GEH modelBWR 6 Mark Iii plant has larger decay heat load than Clinton by 26.9%.
2 Heat Sink Temperature Note 1 L 21 91.4°F NA The SHEX input parameter values for the GEH 3 Primary System Leakage Note 1 20 lOOgpm NA model plant differ in some cases from the 4 RPV Depressurization Rate Note 1 20 5O~F/hr NA MAAP input parameter values for Clinton due to differences in assumptions and some design 5 Drywell Free Volume Note 1 20 215,000 ft3 NA differences.
6 Initial Drywell Temperature Note 1 20 150°F NA Despite these differences the SHEX case for 7 Initial Drywell Pressure Note 1 20 15.3 psia NA the model plant and the MAAP case for Clinton I demonstrate the effectiveness of suppression 8 Initial Drywell Humidity Note 1 20 55% NA pool cooling in reducing suppression pool 9 Wetwell Free Volume Note 1 20 1,512,341 fe NA temperature and stabilizing containment I
Note 1 pressure and temperature as shown in Figures .
10 Initial Wetwell Pressure 20 14.31 psia NA S-1, S-2, and S-3 in NEDC-33771P Revision 2.
I 11 Suppression Pool Volume Note 1 20 130,000 ftl NA 3
12 Containment Pool Volume Note 1 20 15,OOOft NA I
13 Containment Pool Initial Note 1 20 100°F NA Temperature 14 Suppression Pool Temperature Note 1 20 95°F NA I
- --~ -- - '--- - - -- - - - - -
Page 13 of22
Clinton Power Station, Unit I First Six Month Sratus Report for the Implementation of FLEX August28,2013 15 Heat Removal (BTU/sec-~F) Note 1 21 200.8 - 202.4 (ClAHRI1X NA SHEX uses a heat removal constant to (BTU/hr)/(3600*(Supp Pool characterize the RHR heat exchan8er. MAAP Temp-RHR HX Shell Out uses Clinton specific RHR heat exchanger Temp))) details. The Clinton heat removal value was I calculated from MAAP data for comparison.
16 RCiC Suction Source Note 1 21 * < ~ + 8 hrs - Suppression NA In the Clinton strategy, RCiC suction is shifted Pool from the suppression pool to the RHR heat I
- ~ to + 8 hrs - RHR heat exchanger shell outlet at to -+- 8 hrs. This action exchanger outlet (138°F) ,
limits the RCIC system e)(posure to elevated suppression pool water temperature.
Resultant PiII'ameter Values I
17 Maximum Suppression Pool Note 1 33 209.44°F (to -+- 19.02 hrs) 18S'F The decay heat load of the GEH model BWR 6 I Temperature Mark III plant drives suppression pool I temperature to [Note 1) by the time 18 Maximum Wetwelt Temperature Note 1 33 185.06°F (~ + 43.8 hrs) 18soF suppression pool cooling is started at ~ + 8 19 Maximum Wetwell Pressure Note 1 33 24.9 psia (to + 45.9 hrs) 29.7 hrs. This causes containment and drywelJ psia I pressure to reach a higher value than the Clinton strategy.
20 Maximum Drywell Temperature Note 1 33 253.79°F (to + 71.7 hrs) 330°F In the Clinton strategy, suppression pool I 21 Maximum Drvwell Pressure Note 1 33 29.12 psia (~+ 47.8 hrs) 44.7 temperature is 200.5°F when cooling Is started psia at ~ + 8 hrs. It continues to rise and peaks at 209.44°F at to + 19.02 hrs, when the heat I
transfer rate in the RHR heat exchanger I matches the decay heat input.
Note L The NEDC-33771P Rev 2 values are proprietary but can be found on the referenced pages of the document.
Page 14 of22
Clinton Power Station, Unit 1 First Six Month Status Report for the Implementation of FLEX August28,2013 Figure 1 RCIC Operation During Phase 2 (Conceptual)
Containment Bou-ndarv Cnmt U __ Cnmt Spray Pool from ~",~."
Pump
'" ~.p*F111 ICII ros~ ... 1 Ull""91 "" UU...fOJT4 1t1l1....
I(\N QS.lA .11 UU f081A lCn..fOZ7A Iht*'l)aIA
""UU4 0 ,...".
51 P......p 0dLh.....
..... ""\"<
s......
Ir.;, *,~
V I .. C
.... ,..ron MX_~_
lrUl'Olft
(.............1 (It Suppression Pool Page 15 of22
Clinton Power Station, Unit I First Six Month Status Report for the Implementation of FLEX August 28,2013 Figure 2 Suppression Pool Cooling and Low Pressure RPV Makeup from Suppression Pool (Conceptual)
Cnmt UpperCnmt Spray Pool LPcr FromRHR-A IA Pump Feedwater Keep-Fill wl'I=1240281A 1l'2.f048A I f11-HIS:zA l f11-F087A RH~
11)(-"
IA RC~ ~IJPm lfl2.f027A HU-FOO2'I Suction lEU-F0264 1I12-f06 SA.
"0 T""bin. D:ctc (Or P"~h."
$U,P"rJ-5;~ioh Pool T-o RiltlwtU .. aM, l."jow~
(AII!r Dr,")
lSfOO!l IA~lSFOll Suppression Pool Cleilllup PUmps 1750 gpm, 230' head Page 16 of 22
Clinton Power Station, Unil 1 First Six Month Status Report for the Implementation of FLEX August 28,2013 Figure 3 Low Pressure RPV Makeup from External Source (Conceptual) c;f FIUIh line
....\ ..
... I
, " ~ LP~I.(;("jed1on 10 RPV .*
lEI2-F042C Fro ... RHR-t Pump Flrr Hose ,
CY Flush Unt FU'e HOse::
/
Suppression Pool LPCS 1"I.dion 10 Rl'V .......
U2I*F012
..,~ c i ...C
~ ~
8: eonne""," "" IJ'CS/RIlR-C III c:
makeup \0 RPVI
~
'" SUPIJ",,,I... Pool ':g
>C III N
- =
.:r-------------------,,i
> ~
i3
- .l.Z
- H h'.raol w*** , Supply to Diy 2 $X i
1 1i
"-i _/
- ~
\
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1 i
1i Wemal WAllO" Suppfy 10 DIv 1 $I(
H;ordR_ JlnKtu **
......... d_ma1 I I
"",,-aionl i !
- I
! !Connection for $fP Makeup/
&jl-:r>' J.=--..--- =--., -_ __._______ ._~ Spray St rategy Unli z iii;lsx 'lltfecl30" SUIJIIly LIt>e Ultimate Heilt Sink Page 17 of 22
Clinton Power Station, Unit J First Six Month Status Report for the Implementation of FLEX Augusr 28,2013 Figure 4 Electrical Strategy (Conceptual)
.n.-....'..~ . .....'.
IFXOlKA P rimary FLEX :. t.. .n V ':. If)(01KB Alt e rnate FLEX Generator
.....V.....:
...... , .... Generator
).1 4160 VAC SW/irr 1A1 4160 VAC SWl1r 1B1
! 4160/480 VA<
480 VAC Unit Sub lA 4160/... VA' l bA
- : 480 VAC Unit Sub 8 1::
T
<160/<80VA, 4160/,,",VA' 480 VAC Unit Sub 18 f
- : : ~ ~ ! i . ,., II 'I '
- _ _ _ . t I CI : ,: r ,',' I. * :. '1 II'~ ! : ~ < tl "l1 " In ti : lll'oJ I Lh . It:pr. ':\P.VS. :
I l 1111 i : ' .... I
\"'.1., N':ir:::, :
~ ------~ :.. ...... ..... ___ ... ___ ** _____ J
. r'I, 'J::Y
--- . . . . . . j ~_ .. .. .. ........... __ ..... _ .. _ ....... ......... __ ......................... _ .. ............. _ .............. __ ...... .......... J
.f::.-::----:.-:::--......-.:::-----:--:----:--:---:--:::--.-:.-:----.-.-::--.-.-----::--::.-::----:::--:.---:---::------::-:--:---.-:--__ 1 - - ........ --- -- -- ..... _----- ---. -............. --- ....... -------..... _---- ........ _.. -- ... --- . _... ---_ . -- ....... _-
... ... ~ ~
6900 VAC Swg,r lA 6!100 VAC SWf(r 18 1.-------$ ~
I 6900/480VAC......- 6900/480 VAC flEX Cables 6900/4BOVAC - . - - 6900/480 VAC 1
480 VAC Unit Sub II 480 VAC Unit Sub 1M 480 VAC Unit Sub lG
' ,,!, ' I u :
'-,.,'" " J.' erl,' .. '(' , : SF ! 'lImp B :
. 1'-J or \1" ( II*~
1 c . ~ .1 1 l __ ... __ ...... __ ..t
--...----.. ---~ . . ---------.-~--- ....... j Page 18 of 22
Clinton Power Station. Unit I First Six Month Status Report for the Implementation of FLEX August 28, 2013 Figure 5 SpentFuelPooJ~akeup (Conceptual)
- l1li ~ Spent r",,1 Poo~ -I 1$)(0168 lSXOISli.
.g
. o C/
l:
' ...c*
,i ll)
I!J
>- IfX0058 11110051'. "X
' VI Ii ConnKtlon ro, LPCSlRHR-C c
Do m.keup to RPV/
- J ."
III Sul'pr .. !lon POD' 1FXOO4 ,~
X III : :1:
N
> Z Q.
r" .. - - - - -.. ~~--- .. ------------~
i5 ;~
ISKOXJ(8 r'. IFKOO3B 1 IfKOO211 lfXOO2A!
A}. =:r',
. " ** * ~
bienia' Wah, Supply to Olv 1 SX !; He, _~
I i
Hwdened RrUctu,.l lFXOOl B i around eJllem" COOIMdIons i
i i
I! ~4 J jConnectiOl1 for SFP Makeup/
i'---_.....-._-_..._..... _,
I r lr _____ .ll~E!.~ ____ j Spray Strategy nlt-l-DNT~Burle-d'jO* supii/YUiie Page 19 of22
Clinton Power Station, Unit 1 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Figure 6 Spent Fuel Pool Spray (Conceptual)
Steam Tunnel Aux Bldg Aux Bldg Control Bldg 01'V;!; S)(
Suppty G ~~,l.~K ...._ _ _--,
Diesel Generator Bide 755' Fuel Bldg lrJOO."
Fral1'II F1&Ic P... ...."
Page 20 of 22
Clinton Power Station, Unit 1 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Figure 7 FLEX Deployment Conceptual Sketch Page 21 of 22
Clinton Power Station, Unit t First Six Month Status Report for the Implementation of FLEX August 28,2013 FIgure 8 RRC EquIpment Deployment Conceptual Sketch Page 22 of 22