RS-14-304, First Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable to Reliable Hardened Containment Vents Capable of Operation Under.

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First Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable to Reliable Hardened Containment Vents Capable of Operation Under.
ML14353A110
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/17/2014
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-14-304
Download: ML14353A110 (8)
v • d • e


Text

Order No. EA-13-109 RS-14-304 December 17, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

First Six-Month Status Report 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-13-109)

References:

1. NRC Order Number EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013
2. 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 14, 2013
3. NEI 13-02, "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 0, dated November 2013

4. Exelon Generation Company, LLC's Answer 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 26,2013
5. Exelon Generation Company, LLC 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-13-109), dated June 30, 2014 (RS-14-060)

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities have a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 2 within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 20 days following issuance of the final interim staff guidance (Reference 2) and a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D by June 30, 2014. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the EGC initial status report regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 5 provided the Limerick Generating Station, Units 1 and 2 Phase 1 Overall Integrated Plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Phase 1 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 for Phase 1 pursuant to Section IV, Condition D.3, 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 1yth day of December 2014.

R~= suz:i--

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions"

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Limerick Generating Station, Units 1 and 2 NRC Project Manager, NRA - Limerick Generating Station, Units 1 and 2 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. John D. Hughey, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (4 pages)

Enclosure Limerick Generating Station, Unit~ 1 and 2 First Six Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction Limerick Generating Station, Units I and 2 developed an Overall Integrated Plan (Reference I in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core darnage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since suhmittal of the Phase I Overall Integrated Plan (OIP), including any changes to the compliance method, schedule. or need for relief/relaxation and the basis. if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP (Reference 1), and are current as of December Ol. 2014.

  • Held preliminary/conceptual design kickoff
  • Initial layouts for Unit l and Unit 2 vent pipe have been completed
  • First Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Part 5 included in the OIP. It provides the activity status of each item. and whether the expected completion date has changed. The dates arc planning dates subject to change as design and implementation details are developed.

The revised milestone schedule does not impact the order implementation elate.

Note: Phase 2 implementation milestones for Limerick will be provided with the December 2015 OIP suhmittal.

Page 1of4

Limerick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I Deccmher 17, 2014 Target Activity Milestone Completion Comments Status Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Updates:

Comp !etc Update I December 20 14 with this submittal Update 2 June 2015 Not Started Simultaneous with Update 3 December 2015 Not Started Phase 2 OIP Update 4 June 2016 Not Started Update 5 December 2016 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Modifications:

Hold preliminary/conceptual design meeting July 2014 Complete Started REI ,AP Modifications Evaluation March 2016 Started Analysis for line size verification Unit 2 Design l ~nginecring Complete March 2016 Started Unit 2 Implementation Outage April 2017 Not Started Unit 2 Walk Through April 2017 Not Started Demonstration/Functional Test Unit l Design Engineering Complete March 2017 Started Unit 1 Implementation Outage April 2018 Not Started Unit 1 Walk Through April 2018 Not Started Demonstration/Functional Test Procedure Changes Operations Procedure Changes Developed December 2016 Not Started Site Specific Maintenance Procedure December 20 l 6 Not Started Developed Unit 2 Procedure Changes Active April 2017 Not Started Page 2 of 4

I jmerick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I December 17, 2014 Target Activity Milestone Completion Comments Status Date Phase 1 H CVS Milestone Table Unit I Procedure Changes Active April 2018 Not Started Training:

Training Complete March 2017 Not Started Completion Unit 2 HCVS Phase 1 Implementation April 2017 Not Started Submit Unit 2 Phase I Completion Report June 2017 Not Started Unit l HCVS Phase I Implementation April 2018 Not Started Submit Unit I Phase I Completion Report June 2018 Not Started Full Site HCVS Phase l Implementation April 2018 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 OIP (Reference l).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Limerick Clenerating Station expects to comply with the order implementation elate; therefore, no relief/relaxation is required 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 OIP or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status Determine how Motive Power and/or HCVS Battery Power Completed - Conceptual Design will be disabled during normal operation (completed July 2014) determined the HCVS control panel will be provided with a key lock switch to activate the system. This must be unlocked prior to performing any actuations of the DC powered components.

Confirm that the Remote Operating Station (ROS) will be in Not Started - Design Dependent an accessible area following a severe accident Page 3 of 4

I ,imcrick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I December 17, 2014 Determine wctwcll linc size to meet I <;f. venting criteria Started - RELAP Analysis started for line si1.c verification: will he posted on cPortal when completed Confirm suppression pool heat capacity Started MAAP runs being completed: will be posted on cPortal when finalized Determine the approach for combustible gases Not Started - Design Dependent Provide procedures for HCVS Operation Not Started - Design Dependent Interim Staff Evaluation Open Item Status No items at the present time.

7 Interim Staff Evaluation Impacts There arc no potential impacts to the Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the Phase l Overall Integrated Plan described in this enclosure.

1. "Limerick Generating Station. Units 1 and 2 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 Condit.ions (Order Number EA-13-109)," elated June 30,2014
2. NRC Order Number EA-13-l 09, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," elated June 6, 2013
3. NEJ 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 0, elated November 2013
4. 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, elated November 14, 2013 (Accession No. ML13304B836)
5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O," (Accession No. ML14128A219)

Page 4 of 4

Order No. EA-13-109 RS-14-304 December 17, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

First Six-Month Status Report 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-13-109)

References:

1. NRC Order Number EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013
2. 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 14, 2013
3. NEI 13-02, "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 0, dated November 2013

4. Exelon Generation Company, LLC's Answer 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 26,2013
5. Exelon Generation Company, LLC 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-13-109), dated June 30, 2014 (RS-14-060)

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities have a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 2 within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 20 days following issuance of the final interim staff guidance (Reference 2) and a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D by June 30, 2014. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the EGC initial status report regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 5 provided the Limerick Generating Station, Units 1 and 2 Phase 1 Overall Integrated Plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Phase 1 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 for Phase 1 pursuant to Section IV, Condition D.3, 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 1yth day of December 2014.

R~= suz:i--

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions"

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Limerick Generating Station, Units 1 and 2 NRC Project Manager, NRA - Limerick Generating Station, Units 1 and 2 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. John D. Hughey, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (4 pages)

Enclosure Limerick Generating Station, Unit~ 1 and 2 First Six Month Status Report for Phase 1 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction Limerick Generating Station, Units I and 2 developed an Overall Integrated Plan (Reference I in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core darnage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since suhmittal of the Phase I Overall Integrated Plan (OIP), including any changes to the compliance method, schedule. or need for relief/relaxation and the basis. if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP (Reference 1), and are current as of December Ol. 2014.

  • Held preliminary/conceptual design kickoff
  • Initial layouts for Unit l and Unit 2 vent pipe have been completed
  • First Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Part 5 included in the OIP. It provides the activity status of each item. and whether the expected completion date has changed. The dates arc planning dates subject to change as design and implementation details are developed.

The revised milestone schedule does not impact the order implementation elate.

Note: Phase 2 implementation milestones for Limerick will be provided with the December 2015 OIP suhmittal.

Page 1of4

Limerick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I Deccmher 17, 2014 Target Activity Milestone Completion Comments Status Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Updates:

Comp !etc Update I December 20 14 with this submittal Update 2 June 2015 Not Started Simultaneous with Update 3 December 2015 Not Started Phase 2 OIP Update 4 June 2016 Not Started Update 5 December 2016 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Modifications:

Hold preliminary/conceptual design meeting July 2014 Complete Started REI ,AP Modifications Evaluation March 2016 Started Analysis for line size verification Unit 2 Design l ~nginecring Complete March 2016 Started Unit 2 Implementation Outage April 2017 Not Started Unit 2 Walk Through April 2017 Not Started Demonstration/Functional Test Unit l Design Engineering Complete March 2017 Started Unit 1 Implementation Outage April 2018 Not Started Unit 1 Walk Through April 2018 Not Started Demonstration/Functional Test Procedure Changes Operations Procedure Changes Developed December 2016 Not Started Site Specific Maintenance Procedure December 20 l 6 Not Started Developed Unit 2 Procedure Changes Active April 2017 Not Started Page 2 of 4

I jmerick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I December 17, 2014 Target Activity Milestone Completion Comments Status Date Phase 1 H CVS Milestone Table Unit I Procedure Changes Active April 2018 Not Started Training:

Training Complete March 2017 Not Started Completion Unit 2 HCVS Phase 1 Implementation April 2017 Not Started Submit Unit 2 Phase I Completion Report June 2017 Not Started Unit l HCVS Phase I Implementation April 2018 Not Started Submit Unit I Phase I Completion Report June 2018 Not Started Full Site HCVS Phase l Implementation April 2018 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 OIP (Reference l).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Limerick Clenerating Station expects to comply with the order implementation elate; therefore, no relief/relaxation is required 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 OIP or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status Determine how Motive Power and/or HCVS Battery Power Completed - Conceptual Design will be disabled during normal operation (completed July 2014) determined the HCVS control panel will be provided with a key lock switch to activate the system. This must be unlocked prior to performing any actuations of the DC powered components.

Confirm that the Remote Operating Station (ROS) will be in Not Started - Design Dependent an accessible area following a severe accident Page 3 of 4

I ,imcrick Generating Station, Units I and 2 First Six Month Status Report for the Implementation of HCVS Phase I December 17, 2014 Determine wctwcll linc size to meet I <;f. venting criteria Started - RELAP Analysis started for line si1.c verification: will he posted on cPortal when completed Confirm suppression pool heat capacity Started MAAP runs being completed: will be posted on cPortal when finalized Determine the approach for combustible gases Not Started - Design Dependent Provide procedures for HCVS Operation Not Started - Design Dependent Interim Staff Evaluation Open Item Status No items at the present time.

7 Interim Staff Evaluation Impacts There arc no potential impacts to the Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the Phase l Overall Integrated Plan described in this enclosure.

1. "Limerick Generating Station. Units 1 and 2 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 Condit.ions (Order Number EA-13-109)," elated June 30,2014
2. NRC Order Number EA-13-l 09, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," elated June 6, 2013
3. NEJ 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 0, elated November 2013
4. 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, elated November 14, 2013 (Accession No. ML13304B836)
5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O," (Accession No. ML14128A219)

Page 4 of 4

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