LR-N14-0258, 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

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

ML14353A076
Person / Time
Site:	Hope Creek
Issue date:	12/19/2014
From:	Davison P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, LR-N14-0258
Download: ML14353A076 (7)

Text

LR-N 14-0258 DEC 1 *9 2014 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 p

1VucleaT LLC Order EA-13-1 09 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 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)

1.

NRC Order EA-13-1 09, "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-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

3.

NEI 13-02, "Industry Guidance for Compliance with Order EA-13-1 09,"

Revision 0, dated November 2013

4.

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

DEC 1.9 2014 Page 2 LR-N14-0258 Order EA-13-1 09 On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-1 09 (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 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.

In accordance with Condition IV.D.1 of NRC Order EA-13-1 09, PSEG submitted an Overall Integrated Plan (Reference 2) for implementation of the Phase 1 (torus vent) requirements of the Order. The purpose of this letter is to provide the first six-month status report for HCGS, pursuant to Condition IV.D.3 of NRC Order EA-13-1 09. contains the first six-month status report for HCGS implementation of Phase 1 of NRC Order EA-13-1 09, using the report content guidance of Nuclear Energy Institute (NEI) Report 13-02 (Reference 3) as endorsed by NRC Interim Staff Guidance JLD-ISG-2013-02 (Reference 4 ).

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 ----'\\!.-L_- ----l\\'--'\\-- J..=--.

0_\\_i-f (Date)

Sincerely,

J.\\)

Paul J. Davison Site Vice President Hope Creek Generating Station : HCGS First 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"

DEC l9 2014 Page 3 LR-N14-0258 Order EA-13-1 09 cc:

Mr. William Dean, Director of Office of Nuclear Reactor Regulation Mr. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Sanders-Parker, Project Manager, NRC Mr. Charles Norton, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. Patrick Mulligan, Manager IV, NJBNE Hope Creek Commitment Tracking Coordinator PSEG Commitment Coordinator-Corporate

ATTACHMENT 1 LR-N 14-0258 HCGS First 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 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) that provides 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, in response to NRC Order EA-13-1 09 (Reference 2). This report is the first six-month status update for HCGS implementation of Phase 1 (torus vent) of NRC Order EA-13-1 09.

2 Milestone Accomplishments As of November 30, 2014, no milestone(s) have been completed since the OIP (Reference 1) was transmitted to the NRC.

3 Milestone Schedule Status The following table provides an update to the OIP (Reference 1) 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 4

ATTACHMENT 1 LR-N 14-0258 Target Milestone Completion Activity Status Comments Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit Six-Month Updates Update 1 Dec 2014 Complete Completed via this report Update 2 Jun 2015 Not Started Update 3 Dec 2015 Not Started Update 4 Jun 2016 Not Started Modifications Hold preliminary/conceptual design Jun 2014 Complete meeting Vendor Design Engineering On-Oct 2015 Started evaluation and site/Complete selection in progress Implementation Outage Oct 2016 Not started Walk-Through Demonstration I Nov 2016 Not started Functional Test Procedure Changes Active Operations Procedure Changes Jun 2016 Not started Developed Site-Specific Maintenance Jun 2016 Not started Procedure Developed Procedure Changes Active Nov 2016 Not started Training Training Complete Jun 2016 Not started Completion Submit Completion Report Dec 2016 Not started Page 2 of 4

ATTACHMENT 1 LR-N 14-0258 4

Changes to Compliance Method The OIP (Reference 1) identifies PSEG's planned alternatives to NEI 13-02 (Reference 3) and NRC Interim Staff guidance JLD-ISG-2013-02 (Reference 4). These alternatives pertain to 1) monitoring the status of vent operation and 2) the height of the vent release point.

4.1 Monitoring the Status of Vent Operation NEI 13-02, which is endorsed by JLD-ISG-2013-02, contains criteria for monitoring HCVS vent pipe conditions including radiological releases, vent pipe pressure and temperature in order to monitor HCVS operation. HCGS currently has a dual element (high/low range) flow monitor as part of the existing torus vent radiation monitoring system and will use the flow monitor for HCVS operation. In lieu of vent pipe temperature and pressure, the vent flow signal will be displayed at the primary operating station. 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 instrumentation will be used to monitor effectiveness of the venting actions.

4.2 Vent Release Point Height PSEG provided a 20-day response to JLD-ISG-2013-02 via Reference 5, which describes an exception to NRC Order EA-13-1 09 Attachment 2, Requirement 1.2.2, regarding the vent release point height. The HCVS discharge path is a dedicated 12-inch vent pipe with the release point of the vent piping located approximately 50 feet below the top of the Reactor Building dome. The vent pipe is routed to a point above adjacent structures except for the Reactor Building dome, and is located such that the release point will vent away from ventilation system intake and exhaust openings, main control room, and emergency response facilities. The location of the release was originally analyzed to support the design and installation of the existing torus vent to ensure habitability of the control room and is being re-evaluated as part of the HCVS design.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation The vent release point height described in Section 4.2 above is an exception to NRC Order EA-13-1 09 Attachment 2, Requirement 1.2.2, and will be the subject of a request for relief upon completion of further evaluation of vent releases.

Page 3 of 4

ATTACHMENT 1 LR-N 14-0258 6

Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a status of 01 P (Reference 1) open items.

ID Item Ref.

Description Status

1.

OIP Open Finalize time constraints and their bases Started Item 1

2.

OIP Open Confirm vent sizing and suppression pool heat Not Started Item 2 cap_acity

3.

OIP Open Finalize x/Q analysis Not Started Item 3

4.

OIP Open Perform dose evaluation for venting actions Not Started Item 4

5.

OIP Open Finalize design of the HCVS for hydrogen Not Started Item 5 detonation/deflagration

6.

OIP Open Missile protection Not Started Item 6 7

Interim Staff Evaluation Impacts None.

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-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013

3.

NEI 13-02, "Industry Guidance for Compliance with Order EA 13 1 09," Revision 0, dated November 2013

4.

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

5.

PSEG Letter LR-N13-0289, "Hope Creek Generating Station's Notification Pursuant to Condition IV.C.1 of the June 6, 2013 Commission Order Modifying License With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)," dated December 13, 2013 Page 4 of 4

LR-N 14-0258 DEC 1 *9 2014 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 p

1VucleaT LLC Order EA-13-1 09 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 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)

1.

NRC Order EA-13-1 09, "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-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

3.

NEI 13-02, "Industry Guidance for Compliance with Order EA-13-1 09,"

Revision 0, dated November 2013

4.

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

DEC 1.9 2014 Page 2 LR-N14-0258 Order EA-13-1 09 On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-1 09 (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 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.

In accordance with Condition IV.D.1 of NRC Order EA-13-1 09, PSEG submitted an Overall Integrated Plan (Reference 2) for implementation of the Phase 1 (torus vent) requirements of the Order. The purpose of this letter is to provide the first six-month status report for HCGS, pursuant to Condition IV.D.3 of NRC Order EA-13-1 09. contains the first six-month status report for HCGS implementation of Phase 1 of NRC Order EA-13-1 09, using the report content guidance of Nuclear Energy Institute (NEI) Report 13-02 (Reference 3) as endorsed by NRC Interim Staff Guidance JLD-ISG-2013-02 (Reference 4 ).

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 ----'\\!.-L_- ----l\\'--'\\-- J..=--.

0_\\_i-f (Date)

Sincerely,

J.\\)

Paul J. Davison Site Vice President Hope Creek Generating Station : HCGS First 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"

DEC l9 2014 Page 3 LR-N14-0258 Order EA-13-1 09 cc:

Mr. William Dean, Director of Office of Nuclear Reactor Regulation Mr. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Sanders-Parker, Project Manager, NRC Mr. Charles Norton, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. Patrick Mulligan, Manager IV, NJBNE Hope Creek Commitment Tracking Coordinator PSEG Commitment Coordinator-Corporate

ATTACHMENT 1 LR-N 14-0258 HCGS First 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 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) that provides 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, in response to NRC Order EA-13-1 09 (Reference 2). This report is the first six-month status update for HCGS implementation of Phase 1 (torus vent) of NRC Order EA-13-1 09.

2 Milestone Accomplishments As of November 30, 2014, no milestone(s) have been completed since the OIP (Reference 1) was transmitted to the NRC.

3 Milestone Schedule Status The following table provides an update to the OIP (Reference 1) 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 4

ATTACHMENT 1 LR-N 14-0258 Target Milestone Completion Activity Status Comments Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit Six-Month Updates Update 1 Dec 2014 Complete Completed via this report Update 2 Jun 2015 Not Started Update 3 Dec 2015 Not Started Update 4 Jun 2016 Not Started Modifications Hold preliminary/conceptual design Jun 2014 Complete meeting Vendor Design Engineering On-Oct 2015 Started evaluation and site/Complete selection in progress Implementation Outage Oct 2016 Not started Walk-Through Demonstration I Nov 2016 Not started Functional Test Procedure Changes Active Operations Procedure Changes Jun 2016 Not started Developed Site-Specific Maintenance Jun 2016 Not started Procedure Developed Procedure Changes Active Nov 2016 Not started Training Training Complete Jun 2016 Not started Completion Submit Completion Report Dec 2016 Not started Page 2 of 4

ATTACHMENT 1 LR-N 14-0258 4

Changes to Compliance Method The OIP (Reference 1) identifies PSEG's planned alternatives to NEI 13-02 (Reference 3) and NRC Interim Staff guidance JLD-ISG-2013-02 (Reference 4). These alternatives pertain to 1) monitoring the status of vent operation and 2) the height of the vent release point.

4.1 Monitoring the Status of Vent Operation NEI 13-02, which is endorsed by JLD-ISG-2013-02, contains criteria for monitoring HCVS vent pipe conditions including radiological releases, vent pipe pressure and temperature in order to monitor HCVS operation. HCGS currently has a dual element (high/low range) flow monitor as part of the existing torus vent radiation monitoring system and will use the flow monitor for HCVS operation. In lieu of vent pipe temperature and pressure, the vent flow signal will be displayed at the primary operating station. 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 instrumentation will be used to monitor effectiveness of the venting actions.

4.2 Vent Release Point Height PSEG provided a 20-day response to JLD-ISG-2013-02 via Reference 5, which describes an exception to NRC Order EA-13-1 09 Attachment 2, Requirement 1.2.2, regarding the vent release point height. The HCVS discharge path is a dedicated 12-inch vent pipe with the release point of the vent piping located approximately 50 feet below the top of the Reactor Building dome. The vent pipe is routed to a point above adjacent structures except for the Reactor Building dome, and is located such that the release point will vent away from ventilation system intake and exhaust openings, main control room, and emergency response facilities. The location of the release was originally analyzed to support the design and installation of the existing torus vent to ensure habitability of the control room and is being re-evaluated as part of the HCVS design.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation The vent release point height described in Section 4.2 above is an exception to NRC Order EA-13-1 09 Attachment 2, Requirement 1.2.2, and will be the subject of a request for relief upon completion of further evaluation of vent releases.

Page 3 of 4

ATTACHMENT 1 LR-N 14-0258 6

Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a status of 01 P (Reference 1) open items.

ID Item Ref.

Description Status

1.

OIP Open Finalize time constraints and their bases Started Item 1

2.

OIP Open Confirm vent sizing and suppression pool heat Not Started Item 2 cap_acity

3.

OIP Open Finalize x/Q analysis Not Started Item 3

4.

OIP Open Perform dose evaluation for venting actions Not Started Item 4

5.

OIP Open Finalize design of the HCVS for hydrogen Not Started Item 5 detonation/deflagration

6.

OIP Open Missile protection Not Started Item 6 7

Interim Staff Evaluation Impacts None.

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-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013

3.

NEI 13-02, "Industry Guidance for Compliance with Order EA 13 1 09," Revision 0, dated November 2013

4.

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

5.

PSEG Letter LR-N13-0289, "Hope Creek Generating Station's Notification Pursuant to Condition IV.C.1 of the June 6, 2013 Commission Order Modifying License With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)," dated December 13, 2013 Page 4 of 4