PLA-7345, Second Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying License with Regard to Reliable Hardened Under Severe Accident Conditions (Order Number EA-13-109)

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Second Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying License with Regard to Reliable Hardened Under Severe Accident Conditions (Order Number EA-13-109)
ML15174A052
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 06/23/2015
From: Rausch T
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, PLA-7345
Download: ML15174A052 (9)
v • d • e


Text

Timothy S. Rausch Susquehanna Nuclear, LLC President and Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 TALEN ~

Tel. 570.542.3445 Fax 570.542.1504 Timothy.Rausch@talenenergy.com ENERGY

  • JUN 2 3 2015 U.S. Nuclear Regulatory Commission 10 CFR2.202 ATTN: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION 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 Docket Nos. 50-387 (ORDER NUMBER EA-13-109) and 50-388 PLA-7345

References:

1. 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.
2. NRC Interim StaffGuidanceJLD-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 2013 (Accession No. ML13304B836).
3. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).
4. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, "To ModifY Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, " Revision 0, dated November 2013.
5. PPL Letter (PLA-7180), "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 26, 2014.
6. PPL Letter (PLA-7269) T. S Rausch (PPL Susquehanna, LLC) to U.S NRC, "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 109), dated December 23, 2014.

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to PPL Susquehanna, LLC (PPL). Reference 1 was immediately effective and directs Susquehanna to install a venting capability in accordance with the requirements outlined in Attachment 2 of Reference 1.

Document Control Desk PLA-7345 Reference 1 required submission of a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 2.

Reference 5 provided Susquehanna's initial Reliable Hardened Containment Vent Overall Integrated Plan.

Reference 1 requires submission of status reports at six-month intervals following submittal of the Overall Integrated Plan. References 2 and 4 provide direction regarding the content of the status reports. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition D, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed Status Report provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, 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 Mr. Jeffery N. Grisewood at 570-542-1330.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: Co{z3{t S:

T. S. Rausch

Enclosure:

Susquehanna Nuclear, LLC's Second Six-Month Status Report in Response to the 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) cc: Director, Office of Nuclear Reactor Regulation NRC Region I Mr. Rajender Auluck, NRR/JLD/PSB, NRC Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. W. D. Reckley, NRR/JLD/PSB, NRC Mr. J. A. Whited, NRC Project Manager Mr. B. R. Fuller, PA DEP/BRP

Enclosure to PLA-7345 Susquehanna Nuclear, LLC's Second Six-Month Status Report In Response to the 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)

Enclosure to PLA-7345 Page 1 of6 Susquehanna Nuclear, LLC's Second 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 Susquehanna Nuclear, LLC developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage 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 submittal of the Phase 1 Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments None 3 Milestone Schedule Status The following provides an update to the Milestone schedule included in 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.

Comments Target Activity {Include date Milestone Completion Status changes in Date this column}

Phase 1 HCVS Milestone Table Hold preliminary/conceptual design June 2014 Complete meeting Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Status Report 1 Dec. 2014 Complete Submit 6 Month Status Report 2 June 2015 Complete Submit 6 Month Status Report 3 -

Dec. 2015 Not Started Simultaneous with Phase 2 OIP U2 Design Engineering Complete Mar. 2016 In Progress Submit 6 Month Status Report 4 June 2016 Not Started U2 Operations Procedure Changes Dec. 2016 Not Started Developed U2 Maintenance Procedure Changes Dec. 2016 Not Started Developed

Enclosure to PLA-7345 Page 2 of6 Comments Target Activity {Include date Milestone Completion Status changes in Date this column}

Phase 1 HCVS Milestone Table Submit 6 Month Status Report 5 Dec. 2016 Not Started U2 Training Complete Dec. 2016 Not Started U2 Implementation Outage Feb.2017 Not Started U2 Procedure Changes Active Mar. 2017 Not Started U2 Walk Through Mar. 2017 Not Started Demonstration/Functional Test U1 Design Engineering Complete Mar. 2017 Not Started Submit 6 Month Status Report 6 June 2017 Not Started Submit 6 Month Status Report 7 Dec. 2017 Not Started U1 Operations Procedure Changes Dec. 2017 Not Started Developed U1 Maintenance Procedure Changes Dec. 2017 Not Started Developed U1 Training Complete Dec. 2017 Not Started U1 Implementation Outage Feb.2018 Not Started U1 Procedure Changes Active Mar. 2018 Not Started U1 Walk Through Mar. 2018 Not Started Demonstration/Functional Test Submit Phase 1 Compliance Letter May 2019 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Susquehanna expects to comply with the order implementation date and no relief/relaxation is required at this time.

Enclosure to PLA-7345 Page 3 of6 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 Overall Integrated Plan and the Interim Staff Evaluation (ISE).

Open Item Overall Integrated Plan Phase 1 Open Item Status 1 Confirm suppression pool heat capacity Not Started Deployment under severe accident conditions will be 2 confirmed for the deployment of the FLEX generators In Progress credited to re-energize battery chargers.

Deployment under severe accident conditions will be 3 confirmed for deployment of the supplemental In Progress nitrogen bottles.

The gas supply will be sized to support HCVS operation for a minimum of24 hours (a minimum of 12 valve cycles of valve operation is assumed, 4 consistent with recommendations in HCVS-WP-02). In Progress This design assumption will require future validation in the design phase of this project.

An assessment of temperature and radiological conditions will be performed to ensure that operating 5 personnel can safely access and operate controls at the In Progress remote operating station, based on time constraints listed in Attachment 2 of the Overall Integrated Plan.

Evaluate viable options to address Hydrogen detonation concerns in HCVS piping to meet the requirements ofEA-13-109, Section 1.2.11 and 6 incorporate in HCVS design. SSES will determine the In Progress method to be deployed once NRC review ofHCVS-WP-03 is complete.

An evaluation will be performed to confirm the HCVS power supply can support HCVS operation for a 7 minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In Progress

Enclosure to PLA-7345 Page 4 of6 Interim Staff Evaluation Open Item Status Open Action Comment Status Item

1. Make available for NRC staff audit an evaluation Section 3.1.2 Not Started that confirms that all load stripping to support HDVS operation can be accomplished within forty five minutes of event initiation.
2. Make available for NRC staff audit the final sizing Section 3.2.1 Not Started evaluation for HCVS batteries/battery charger Section 3.2.2.4 including incorporation into FLEX DG loading Section 3.2.3.1 calculation. Section 3.2.3.2 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6
3. Make available for NRC staff audit documentation Section 3.2.1 Not Started of the HCVS nitrogen pneumatic system design Section 3.2.2.4 including sizing and location. Section 3.2.3.1 Section 3.2.3.2 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6
4. Make available for NRC staff audit an evaluation of Section 3.2.1 Not Started temperature and radiological conditions to ensure Section 3.2.2.3 that operating personnel can safely access and Section 3.2.2.4 operate controls and support equipment, Section 3.2.2.5 Section 3.2.2.10 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.2 Section 3.2.6
5. Make available for NRC staff audit analyses Section 3.2.2.1 Not Started demonstrating that HCVS has the capacity to vent Section 3.2.2.2 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.

Enclosure to PLA-7345 Page 5 of6 Interim Staff Evaluation Open Item Status Open Action Comment Status Item

6. Make available for NRC staff audit the seismic and Section 3.2.2.3 Not Started tornado missile final design criteria for the HCVS stack
7. Make available for NRC staff audit the descriptions Section 3.2.2.3 Not Started of local conditions (temperature, radiation and Section 3.2.2.5 humidity) anticipated during ELAP and severe Section 3.2.2.9 accident for the components (valves, Section 3 .2.2.1 0 instrumentation, sensors, transmitters, indicators, electronic, control devices, and etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
8. Make available for NRC staff audit documentation Section 3.2.2.5 Not Started that demonstrates adequate communication between Section 3.2.2.10 the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.
9. Provide a description of the final design of the Section 3.2.2.6 Not Started HCVS to address hydrogen detonation and deflagration.
10. Provide a description of the strategies for hydrogen Section 3.2.2.6 Not Started control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.
11. Provide a justification for deviating from the Section 3.2.2.9 Not Started instrumentation seismic qualification guidance specified in NEI 13-02, endorsed, in part, by JLD-ISG-2013-02 as an acceptable means for implementing applicable requirements of Order EA-13-109.
12. Make available for NRC staff audit descriptions of Section 3.2.2.10 Not Started all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

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

Enclosure to PLA-7345 Page 6 of6 8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. PPL Letter (PLA-7180), Susquehanna Steam Electric Station 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 26, 2014.
2. NRC Order Number 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.

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 0, 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 2013 (Accession No. ML13304B836).
5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).
6. Susquehanna Steam Electric Station Units 1 And 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase One of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4364 AND MF4365), dated April1, 2015 (ML15090A300).
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