LR-N15-0129, Second Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)
| ML15173A026 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/18/2015 |
| From: | Davison P Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, LR-N15-0129 | |
| Download: ML15173A026 (9) | |
Text
LR-N15-0129 JUN 1 2015 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 t>SEG NuclearLLC Order EA-13-1 09 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
References:
Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Hope Creek Generating Station's Second Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)
- 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.
PSEG Letter LR-N14-0258, "Hope Creek Generating Station's First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)," dated December 19, 2014
- 4.
NEI 13-02, "Industry Guidance for Compliance with Order EA-13-1 09,"
Revision 0, dated November 2013
JUN 1:8 2015 Page 2 LR-N15-0129 Order EA-13-1 09
- 5.
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
- 6.
NRC Letter to PSEG, "Hope Creek Generating Station-Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-1 09 (Severe Accident Capable Hardened Vents) (TAC NO. MF4458)," dated February 12, 2015 On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-1 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 a reliable hardened venting capability for pre-core damage and severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. 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 first six-month status report was transmitted to the NRC on December 19, 2014 (Reference 3). The purpose of this letter is to provide the second six-month status report for HCGS, pursuant to Condition IV. D.3 of NRC Order EA-13-1 09. contains the second six-month status report for HCSG implementation of Phase 1 of NRC Order EA-13-1 09, following the report content guidance of Nuclear Energy Institute (NEI) Report 13-02 (Reference 4) as endorsed by NRC Interim Staff Guidance JLD-ISG-2013-02 (Reference 5). The attached report provides an update of the milestone accomplishments since the submittal of the previous six-month status report (Reference 3), including any changes to the compliance method, schedule, and the need and basis for relief or relaxation from specific requirements of NRC Order EA-13-1 09. The status of open items identified in the NRC's Interim Staff Evaluation (Reference 6) is included in the attached update.
There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please do not hesitate to contact Mr. Brian J. Thomas at 856-339-2022.
JUN 18 2015 Page 3 LR-N15-0129 Order EA-13-1 09 I declare under penalty of perjury that the foregoing is true and correct.
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Sincerely, Paul J. Davison Site Vice President Hope Creek Generating Station : HCGS Second 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" cc:
Mr. William Dean, Director of Office of Nuclear Reactor Regulation Mr. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Parker, Project Manager, NRC Mr. Justin Hawkins, NRC Senior Resident Inspector, Hope Creek Mr. Charles Norton, Project Manager, NRC Mr. Patrick Mulligan, Manager IV, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Corporate Commitment Coordinator
LR-N 15-0129 HCGS Second 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 provides a status update of milestone accomplishments since submittal of the previous report (Reference 3) for HCGS implementation of NRC Order EA-13-1 09 Phase 1 (torus vent), including any changes to the compliance method, schedule, and the need and basis for relief or relaxation from specific requirements of NRC Order EA-13-1 09.
2 Milestone Accomplishments No milestones have been completed since the first six-month status report (Reference 3) 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 6
LR-N 15-0129 Milestone Target Activity Completion Status Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit Six-Month Updates Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 Dec 2015 Not Started Update 4 Jun 2016 Not Started Modifications Hold preliminary/conceptual design Jun 2014 Complete meeting Design Engineering On-Oct 2015 Started site/Complete Implementation Outage Oct 2016 Not started Walk-Through Demonstration I Nov 2016 Not started Functional Test Procedure Changes Active Operations Procedure Changes Jun 2016 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 6 Comments Completed via this report Vendor selection is complete and final design is in progress
LR-N 15-0129 4
Changes to Compliance Method PSEG's planned alternatives to NEI 13-02 (Reference 4) and NRC Interim Staff Guidance JLD-ISG-2013-02 (Reference 5) were identified in the previous six-month status report (Reference 3) and are also identified as open items in the NRC Interim Staff Evaluation (ISE) (Reference 6) for compliance with Phase 1 of NRC Order EA-13-1 09. These alternatives pertain to 1) monitoring the status of vent operation and
- 2) the height of the vent release point, and are described below in Sections 4.1 and 4.2.
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 (POS). The vent operation will be monitored by HCVS valve position, vent flow, and effluent radiation levels. Containment parameters of pressure, torus level and temperature from the Main Control Room (MCR) instrumentation will be used to monitor effectiveness of the venting actions. This item is related to NRC ISE Open Item #6 regarding identification and qualification of all instrumentation necessary to support HCVS operation.
4.2 Vent Release Point Height PSEG provided a 20-day response to JLD-ISG-2013-02 via Reference 7, 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, MCR, and other 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.
The need for PSEG to request relaxation of this Order requirement is tracked as NRC ISE Open Item #13.
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 relaxation upon completion of further evaluation of vent releases. PSEG plans to submit the request for relaxation via separate letter, prior to the next six-month update due in December 2015.
Page 3 of 6
LR-N15-0129 6
Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a status of open items identified in the HCGS Overall Integrated Plan (OIP) (Reference 1) and NRC Interim Staff Evaluation (IS E)
(Reference 6).
Item Ref.
Description Status ISE #1 Finalize time constraints and their bases. Make Started OIP #1 available for NRC staff audit the finalized time constraints for remote manual operations and their bases.
ISE#2 Make available for NRC staff audit analyses Started OIP#2 demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
ISE#3 Provide the seismic and tornado missile final design Started OIP#6 criteria for the HCVS stack.
ISE#4 Make available.for NRC staff. audit documentation that Started demonstrates adequate communication between the See §7.1 remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.
ISE#5 Perform dose evaluation for venting actions (OIP #4).
Started OIP#4 Make available for NRC staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.
ISE#6 Make available for NRC staff audit descriptions of all Started instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.
ISE#7 Make available for NRC staff audit the final sizing Started evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.
ISE#8 Make available for NRC staff audit documentation of the Started HCVS nitrogen pneumatic system design including sizing and location.
Page 4 of 6
LR-N15-0129 Item Ref.
Description ISE#9 Make available for NRC staff audit the descriptions of local conditions (temperature, radiation, and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.)
required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
ISE #10 Make available for NRC staff audit an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.
ISE #11 Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.
ISE #12 Provide a description of the final design of the HCVS to OIP#5 address hydrogen detonation and deflagration.
ISE #13 Finalize x/Q analysis (OIP #3). Submit a relaxation OIP#3 request as stated in the Order for the deviation from Order EA-13-1 09 provision 1.2.2, 11The HCVS Section 3.2.2.3 shall discharge the effluent to a release point above the main plant struCtures,µµ which includes a technical justification for the deviation.
7 Interim Staff Evaluation Impacts Status Started Started Started Started Started The information in this section is provided in support of resolution of open items identified in Section 6.
7.1 ISE Open Item #4, Communications The HCVS Primary Operating Station (POS) in the Lower Control Equipment Room and the Remote Operating Station (ROS) in the electrical chase are located at 102 ft elevation of the Control/Diesel Building. The POS and ROS are two levels below the Main Control Room (MCR) and are accessible from the MCR via pathways within the power block. Accessibility under postulated temperature and radiological conditions is being addressed to support resolution of ISE Open Item #5.
PSEG has implemented communications enhancements ihcluding radio upgrades to support diverse and flexible (FLEX) mitigating strategies for beyond-design-basis external events.
These enhancements include the addition of a remote desk set in the MCR which will be provided with FLEX-backed uninterruptible power supplies and direct connections to repeaters for reliable radio communication within the power block, Page 5 of 6
LR-N15-0129 including the MCR and the Operations Support Center. Communication between HCVS operators and decision makers would be maintained to support HCVS operation based on the proximity of the POS and ROS to the emergency response facilities, and radio communications capability.
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. PSEG Letter LR-N14-0258, "Hope Creek Generating Station's First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09), dated December 19, 2014
- 4. NEl 13-02, "Industry Guidance for Compliance with Order EA 13 1 09," Revision 0, dated November 2013
- 5. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 1 09, Order Modifying License$ with Regaro to Reliable H.ardened Containment Vents Capable of Operation under Severe Accident Conditions," dated November 14, 2013
- 6. NRC Letter to PSEG, "Hope Creek Generating Station-Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-1 09 (Severe Accident Capable Hardened Vents) (TAC NO. MF4458)," dated February 12, 2015
- 7. 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 6 of 6