RS-14-305, 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.

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.

ML14353A125
Person / Time
Site:	Peach Bottom
Issue date:	12/19/2014
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-14-305
Download: ML14353A125 (8)

Text

RS-14-305 December 19, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Order No. EA-13-109 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

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-14-062)

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 19, 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 Peach Bottom Atomic Power Station, Units 2 and 3 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 19th day of December 2014.

Respectfully submitted, d~~

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

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 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 19, 2014 Page 3 cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector-Peach Bottom Atomic Power Station, Units 2 and 3 NRC Project Manager, NRA - Peach Bottom Atomic Power Station, Units 2 and 3 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 Peach Bottom Atomic Power Station, Units 2 and 3 First Six Month Status Report for the 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 Peach Bottom Atomic Power Station, Units 2 and 3 developed an Overall Integrated Plan (Reference I in Section 8). documenting the installation or a Hardened Containment Vent System (HCYS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach or the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Phase I Overall Integrated Plan. including any changes lo the compliance method. schedule. or need for relier/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference l), and arc current as of December 2. 2014:

First Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Part 5 or the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion elate has changed. The dates arc planning elates subject to change as design and irnplcmentation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Target Comments Milestone Completion Activity Status Date Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Uudates:

Update 1 December 2014 Complete with this submittal Update 2 June 2015 Not Started Update 3 f simultaneous with Phase 2 OIP]

December 2015 Not Started Update 4 June 2016 Not Started Page 1 of 4

PBAPS's Hrst Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 Target Comments Milestone Completion Activity Status Date Update 5 December 20 16 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Update 8 June 2018 Not Started Modifications:

Hold preliminary/conceptual design meeting April 2014 Complete U2 Design Engineering for Wetwell Vent September 201 5 Started Approved U3 Design Engineering for Wetwell Vent September 2016 Not Started Approved Procedures:

U2 Wetwell Operations Procedure Changes September 2016 Not Started Developed U2 Wetwell Maintenance Procedure Changes Septemher 2016 Not Started Developed U2 Wet well Procedure Changes Active November 2016 Not Started U3 Wetwell Operations Procedure Changes September 2017 Not Started Developed U3 Wetwell Maintenance Procedure Changes September 20 l 7 Not Started Developed U3 Wetwell Procedure Changes Active October 201 7 Not Started Training:

U2 Wetwell Training Complete September 2016 Not Started U3 Wetwell Training Complete September 2017 Not Started Com~letion:

U2 Wetwell Implementation Outage November 2016 Not Started U2 Wetwell Walk-Through Demonstration/

November 2016 Not Started Functional Test Submit U2 Wetwell Completion Report January 2017 Not Started U3 Wetwell Implementation Outage October 2017 Not Started U3 Wetwell Walk-Through Demonstration/

October 2017 Not Started Page 2 of 4

PBAPS's First Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 Target Comments Milestone Completion Activity Status Date Functional Test Suhmit U3 Wetwell Completion Report December 2017 Nol Started 4

Changes to Compliance Method There are no changes to the compliance method as documented in the Phase I Overall Integrated Plan (Reference I).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Peach Bottom Atomic Power Station, Units 2 and 3 expects to comply with the order implementation date: therefore, no rclieUrelaxation 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 I Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase l Open Item Status

1. Confirm that the Remote Operating Station (ROS)

Not Started - will be confirmed during will be in an accessible area following a Severe detailed design.

Accident (SA)

2. Provide procedures for HCVS Operation Not Started existing procedures will be revised and/or new procedures will he created during procedure development.

3. Identify Site Specific Controlling Document for Not Started - existing procedures will he HCVS out of service and compensatory measures revised and/or new procedures will be created during procedure development.

4. Determine the design approach for combustible gas Started - design approach discussed in preliminary conceptual design meeting is to purge the exhaust line with inert gas. This will he confirmed during detailed design.

Interim Staff Evaluation Open Item Status No items at the present time.

Page 3 of 4

PBAPS's l'irst Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 7

Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff I \\valuation identified at this time.

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

I.

Peach Bottom Atomic Power Station, Units 2 and ::L Overall Integrated Plan in Response to.June 6.

2013 Commission Order Modifying I,icenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June

30. 2014.

2.

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

3.

NEI 13-02. "Industry Guidance for Compliance with NRC Order EA-13-109. 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capahle of Operation under Severe Accident Conditions," Revision O. dated 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, dated November 14. 2013 (Accession No. ML13304B836).

5.

NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase l Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. MLl4128A219).

Page 4 of 4

RS-14-305 December 19, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Order No. EA-13-109 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

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-14-062)

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 19, 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 Peach Bottom Atomic Power Station, Units 2 and 3 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 19th day of December 2014.

Respectfully submitted, d~~

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

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 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 19, 2014 Page 3 cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector-Peach Bottom Atomic Power Station, Units 2 and 3 NRC Project Manager, NRA - Peach Bottom Atomic Power Station, Units 2 and 3 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 Peach Bottom Atomic Power Station, Units 2 and 3 First Six Month Status Report for the 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 Peach Bottom Atomic Power Station, Units 2 and 3 developed an Overall Integrated Plan (Reference I in Section 8). documenting the installation or a Hardened Containment Vent System (HCYS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach or the reactor vessel by molten core debris, in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Phase I Overall Integrated Plan. including any changes lo the compliance method. schedule. or need for relier/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference l), and arc current as of December 2. 2014:

First Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Part 5 or the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion elate has changed. The dates arc planning elates subject to change as design and irnplcmentation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Target Comments Milestone Completion Activity Status Date Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Uudates:

Update 1 December 2014 Complete with this submittal Update 2 June 2015 Not Started Update 3 f simultaneous with Phase 2 OIP]

December 2015 Not Started Update 4 June 2016 Not Started Page 1 of 4

PBAPS's Hrst Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 Target Comments Milestone Completion Activity Status Date Update 5 December 20 16 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Update 8 June 2018 Not Started Modifications:

Hold preliminary/conceptual design meeting April 2014 Complete U2 Design Engineering for Wetwell Vent September 201 5 Started Approved U3 Design Engineering for Wetwell Vent September 2016 Not Started Approved Procedures:

U2 Wetwell Operations Procedure Changes September 2016 Not Started Developed U2 Wetwell Maintenance Procedure Changes Septemher 2016 Not Started Developed U2 Wet well Procedure Changes Active November 2016 Not Started U3 Wetwell Operations Procedure Changes September 2017 Not Started Developed U3 Wetwell Maintenance Procedure Changes September 20 l 7 Not Started Developed U3 Wetwell Procedure Changes Active October 201 7 Not Started Training:

U2 Wetwell Training Complete September 2016 Not Started U3 Wetwell Training Complete September 2017 Not Started Com~letion:

U2 Wetwell Implementation Outage November 2016 Not Started U2 Wetwell Walk-Through Demonstration/

November 2016 Not Started Functional Test Submit U2 Wetwell Completion Report January 2017 Not Started U3 Wetwell Implementation Outage October 2017 Not Started U3 Wetwell Walk-Through Demonstration/

October 2017 Not Started Page 2 of 4

PBAPS's First Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 Target Comments Milestone Completion Activity Status Date Functional Test Suhmit U3 Wetwell Completion Report December 2017 Nol Started 4

Changes to Compliance Method There are no changes to the compliance method as documented in the Phase I Overall Integrated Plan (Reference I).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Peach Bottom Atomic Power Station, Units 2 and 3 expects to comply with the order implementation date: therefore, no rclieUrelaxation 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 I Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase l Open Item Status

1. Confirm that the Remote Operating Station (ROS)

Not Started - will be confirmed during will be in an accessible area following a Severe detailed design.

Accident (SA)

2. Provide procedures for HCVS Operation Not Started existing procedures will be revised and/or new procedures will he created during procedure development.

3. Identify Site Specific Controlling Document for Not Started - existing procedures will he HCVS out of service and compensatory measures revised and/or new procedures will be created during procedure development.

4. Determine the design approach for combustible gas Started - design approach discussed in preliminary conceptual design meeting is to purge the exhaust line with inert gas. This will he confirmed during detailed design.

Interim Staff Evaluation Open Item Status No items at the present time.

Page 3 of 4

PBAPS's l'irst Six Month Status Report for the Implementation of HCVS Phase I December 19, 2014 7

Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff I \\valuation identified at this time.

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

I.

Peach Bottom Atomic Power Station, Units 2 and ::L Overall Integrated Plan in Response to.June 6.

2013 Commission Order Modifying I,icenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June

30. 2014.

2.

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

3.

NEI 13-02. "Industry Guidance for Compliance with NRC Order EA-13-109. 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capahle of Operation under Severe Accident Conditions," Revision O. dated 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, dated November 14. 2013 (Accession No. ML13304B836).

5.

NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase l Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. MLl4128A219).

Page 4 of 4