CNL-16-098, Fourth 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

Fourth 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

ML16182A517
Person / Time
Site:	Browns Ferry   (DPR-033, DPR-052, DPR-068)
Issue date:	06/30/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-16-098, EA-13-109
Download: ML16182A517 (13)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-098 June 30, 2016 10 CFR 50.4 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Tennessee Valley Authoritys Browns Ferry Nuclear Plant Fourth 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)

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 (ML13143A321)

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 (ML13304B836)

3. NEI 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 1, dated April 23, 2015 (ML15113B318)

4. Letter from TVA to NRC, Tennessee Valley Authoritys 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 (Order Number EA-13-109), dated June 30, 2014 (ML14181B169)

5. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant First 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), dated December 19, 2014 (ML14353A428)

U.S. Nuclear Regulatory Commission CNL-16-098 Page 2 June 30, 2016

6. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents)

(TAC Nos. MF4540, MF4541 and MF4542), dated February 11, 2015 (ML14356A362)

7. NRC Interim Staff Guidance JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated April 29, 2015 (ML15104A118)

8. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant 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), dated June 29, 2015 (ML15181A338)

9. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Third Six-Month Status Report and Phase 1 and Phase 2 Overall Integrated Plan 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),

dated December 29, 2015 (ML15365A554)

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directed TVA to install 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. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of a Phase 1 and Phase 2 Overall Integrated Plan (OIP) pursuant to Section IV, Condition D for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3.

References 2 and 7 endorse industry guidance document Nuclear Energy Institute (NEI) 13-02, Revision 1 (Reference 3) with clarifications and exceptions identified in References 2 and 7.

Reference 3 provides direction regarding the content of the Phase 1 and Phase 2 OIPs and includes guidance for combining the OIPs.

Reference 4 provided TVAs Phase 1 OIP. The NRC issued its Interim Staff Evaluation relating to the BFN Phase 1 OIP on February 11, 2015 (Reference 6).

Reference 1 also requires submission of status reports at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. TVA submitted the first six-month status report on December 19, 2014 (Reference 5), the second six-month status report on June 29, 2015 (Reference 8), and the third six-month status report on December 29, 2015 (Reference 9).

U.S. NuClear Regulatory Commission CNL-16-098 Page 3 June 30, 2016 The purpose of this letter is to provide the combined Phase 1 and Phase 2 OIP 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 Enclosure provides an update of milestone accomplishments since submittal of the Phase 1 OIP (Reference 4) and previous updates (References 5, 8, and 9), and the initial Phase 2 OIP (Reference 9) including any changes to the compliance method, schedule, or need for relief and the basis, if any.

There are no new regulatory commitments resulting from this submittal. If you have any question regarding this submittal, please contact Mike Oliver at (256) 729-7874.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of June 2016.

Respectfully, J. W. Shea Vice President, Nuclear Licensing

Enclosure:

Tennessee Valley Authority Browns Ferry Nuclear Plant's Fourth Six-Month Status Report for the Implementation of Order EA-13-109, "Issuance of Order to Modify Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc (w/Enclosure):

NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRR JLD Director - NRC Headquarters NRC Regional Administrator - Region II NRR Project Manager - Browns Ferry Nuclear Plant NRR JLD Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

E1 CNL16098 ENCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plants Fourth Six Month Status Report for the Implementation of Order EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1

Introduction Browns Ferry Nuclear Plant (BFN) 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. Starting with this six month status report, updates of milestone accomplishments will be based on the combined Phase 1 and 2 Overall Integrated Plan dated December 29, 2015.

BFN developed an updated and combined Phase 1 and 2 Overall Integrated Plan (Reference 7 in Section 8) documenting:

1. 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.

2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2 This enclosure provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the combined Phase 1 and 2 Overall Integrated Plan, and are current as of June 1, 2016.

None 3

Milestone Schedule Status The following provides an update to Part 5 of the combined Phase 1 and 2 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.

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

E2 CNL16098 Milestone Target Completion Date Activity Status Comments

{Include date changes in this column}

Phase 1 and 2 HCVS Milestone Table Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Updates:

Update 1 December 2014 Complete Update 2 June 2015 Complete Update 3 [Simultaneous with Phase 2 OIP]

December 2015 Complete Update 4 June 2016 Complete with this submittal Update 5 December 2016 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Update 8 June 2018 Not Started Update 9 December 2018 Not Started Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual design meeting November 2014 Complete Modifications Evaluation November 2015 Complete Unit 1 Design Engineering On-site/Complete April 2016 In Progress June 2016 Unit 1 Implementation Outage November 2016 Not Started

E3 CNL16098 Milestone Target Completion Date Activity Status Comments

{Include date changes in this column}

Unit 1 Walk Through Demonstration/Functional Test November 2016 Not Started Unit 2 Design Engineering On-site/Complete June 2016 In Progress October 2016 Unit 2 Implementation Outage March 2017 Not Started Unit 2 Walk Through Demonstration/Functional Test April 2017 Not Started Unit 3 Design Engineering On-site/Complete July 2017 Not Started Unit 3 Implementation Outage March 2018 Not Started Unit 3 Walk Through Demonstration/Functional Test April 2018 Not Started Phase 1 Procedure Changes Active Operations Procedure Changes Developed July 2016 In Progress Site Specific Maintenance Procedure Developed July 2016 In Progress Procedure Changes Active November 2016 Not Started Phase 1 Training:

Training Complete September 2016 Not Started Phase 1 Completion Unit 1 HCVS Implementation December 2016 Not Started Unit 2 HCVS Implementation April 2017 Not Started Unit 3 HCVS Implementation March 2018 Not Started Full Site HCVS Implementation March 2018 Not Started Submit Completion Report [60 days after full site compliance]

June 2018 Not Started

E4 CNL16098 Milestone Target Completion Date Activity Status Comments

{Include date changes in this column}

Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual design meeting January 2017 Not Started Modifications Evaluation April 2017 Not Started Unit 3 Design Engineering On-site/Complete May 2017 Not Started Unit 3 Implementation Outage March 2018 Not Started Unit 3 Walk Through Demonstration/Functional Test March 2018 Not Started Unit 1 Design Engineering On-site/Complete December 2017 Not Started Unit 1 Implementation Outage October 2018 Not Started Unit 1 Walk Through Demonstration/Functional Test October 2018 Not Started Unit 2 Design Engineering On-site/Complete May 2018 Not Started Unit 2 Implementation Outage March 2019 Not Started Unit 2 Walk Through Demonstration/Functional Test March 2019 Not Started Phase 2 Procedure Changes Active Operations Procedure Changes Developed September 2017 Not Started Site Specific Maintenance Procedures Developed December 2017 Not Started Procedure Changes Active March 2018 Not Started Phase 2 Training:

Training Complete December 2017 Not Started Phase 2 Completion Unit 3 HCVS Implementation March 2018 Not Started

E5 CNL16098 Milestone Target Completion Date Activity Status Comments

{Include date changes in this column}

Unit 1 HCVS Implementation October 2018 Not Started Unit 2 HCVS Implementation March 2019 Not Started Full Site HCVS Implementation March 2019 Not Started Submit Completion Report [60 days after full site compliance]

May 2019 Not Started 4

Changes to Compliance Method The following is a list of changes made to the information provided in the Combined Phase 1 and 2 Overall Integrated Plan (Reference 7). These changes were performed to clarify the OIP and provide more accurate information due to being further along in the design process.

These changes eet the NEI 13-02 compliance method.

• Page 3 of 80. Removed words core from from the 2nd bullet under The Phase 2 actions can be summarized as follows. These words were removed for clarification.

• Page 24 of 80. Second paragraph changed Following load shed to Following realignment which is a more accurate description.

• Page 48 of 80. Completed the sentence in the 3rd bullet for out of service times to state the following: The cause(s) of the non-functionality will be entered in the corrective action program.

• Page 52 and 53 of 80. Updated the Phase 1 and Phase 2 milestone schedule

• Page 79 of 80. Updated Interim Staff Evaluation Phase 1 Open item 7 to closed due to the performance of an evaluation that concluded the containment isolation valves will open under the maximum expected differential pressure and is documented in FLOWSERVE Report RAL-70181, Design Review Report of Size 14 Class 150 Wafer Butterfly Valve with Pneumatic Actuator, Rev. 1 There are no changes to the compliance method as documented in the combined Phase 1 and 2 Overall Integrated Plan (Reference 7).

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

6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phase 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

E6 CNL16098 Combined Phase 1 and 2 OIP Open Item Status Phase 1 Open Items

1. Perform an assessment of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls at the Remote Operating Station based on time constraints listed in Attachment 2.

Open

2. Perform an evaluation for HCVS ability to operate from the MCR and has the ability to be supplied adequate amounts of pneumatic pressure for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions.

Closed - Evaluation has been completed and documented in Calculation MDQ0000322015000347 R0, HCVS Nitrogen System Sizing Analysis, and DCN 71389.

3. Perform an evaluation for FLEX portable generators and nitrogen cylinders use past 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions.

Open

4. Revise 1/2/3-EOI Appendix 13 to include venting for loss of DC power.

Open

5. Perform an evaluation for FLEX portable generators use for post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions in Severe Accident conditions.

Open

6. Electrical load shedding will be performed in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the event.

Closed (Reference 6) - Calculation EDQ0009992013000202 R3, 250V DC Unit Batteries, 1, 2, & 3 Evaluation for the Beyond Design Basis External Event (BDBEE) Extended Loss of AC Power (ELAP), has been issued to determine load shedding impact on the unit batteries.

7. The implementation of the HCVS DCNs will be staged so that there is no effect on the operating units.

Closed (Reference 6) - A conceptual meeting was held in November 2014, and a staging plan was used to separate the existing HWWV from the HCVS.

8. The wetwell vent will be designed to remove 1%

of rated thermal power at EPU conditions.

Closed (Reference 6) - The existing wetwell vent (CLTP) and the HCVS (EPU) have been designed for 1 percent of rated thermal power at EPU conditions.

9. Implement the Harris Radio System for communication between the MCR and the ROS.

Closed - A communication system has been implemented that uses hand held radios for communication between the main control room and the remote operating station. (DCN 70852)

E7 CNL16098 Combined Phase 1 and 2 OIP Open Item Status Phase 2 Open Items

1. Perform an evaluation for the locations of the SAWA equipment and controls, as well as ingress and egress paths for the expected Severe Accident conditions (temperature, humidity, radiation) for the Sustained Operating period.

Open

2. Perform an hydraulic evaluation to ensure flow adequacy can be met for all 3 units using 1 FLEX pump to support SAWA flow requirement Open Phase 1 Interim Staff Evaluation Open Item Status

1. 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.

In Progress

2. Make available for NRC audit documentation that procedure 1/2/3-EOI Appendix 13 to has been revised to include venting for loss of dc power.

In Progress

3. Make available for NRC staff audit documentation demonstrating that all load sheds will be accomplished within one hour of event initiation and will occur in an area not impacted by a possible radiological event.

Closed (Reference 6) - Calculation EDQ0009992013000202 R3, 250V DC Unit Batteries, 1, 2, & 3 Evaluation for the Beyond Design Basis External Event (BDBEE) Extended Loss of AC Power (ELAP), has been issued to determine load shedding impact on the unit batteries.

4. Make available for NRC staff audit documentation that demonstrates that operating units that have not implemented the order will be able to vent through the existing vent system unaffected by the implementation of HCVS on other units.

Closed (Reference 6) - A conceptual meeting was held in November 2014, and a staging plan was used to separate the existing HWWV from the HCVS.

5. Make available for NRC staff audit analyses 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 Closed (Reference 6) - The existing wetwell vent (CLTP) and the HCVS (EPU) have been designed for 1 percent of rated thermal power at EPU conditions.

E8 CNL16098 containment pressure limit.

6. Make available for NRC staff audit documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

Closed - A communication system has been implemented that uses hand held radios for communication between the main control room and the remote operating station. (DCN 70852)

7. Make available for NRC staff audit documentation of 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.

Closed-An evaluation was performed and concluded that the containment isolation valves will open under the maximum expected differential pressure and is documented in FLOWSERVE Report RAL-70181, Design Review Report of Size 14 Class 150 Wafer Butterfly Valve with Pneumatic Actuator R1

8. Make available for NRC staff audit documentation of a seismic qualification evaluation of HCVS components.

In Progress

9. Make available for NRC staff audit descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

In Progress

10. 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, and etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

In Progress

11. Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location.

In Progress

12. Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location.

In Progress

13. Make available for NRC staff audit the seismic and tornado missile final design criteria for the HCVS stack.

In Progress

14. Provide a description of the final design of the HCVS to address hydrogen detonation and deflagration.

In Progress

E9 CNL16098

15. 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.

In Progress

16. Provide design details that minimize unintended cross flow of vented fluids within a unit and between units on the site.

In Progress Phase 2 Interim Staff Evaluation Open Item Status TBD NA 7

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

E10 CNL16098 8

References The following references support the updates to the combined Phase 1 and 2 Overall Integrated Plan described in this enclosure.

1. Letter from TVA to NRC, Tennessee Valley Authoritys 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 (Order Number EA-13-109), dated June 30, 2014 (ML14181B169)

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. (ML13143A321)

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 1, dated April 2015. (ML15113B318)

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 (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. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012 (ML12229A174)

7. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Third Six-Month Status Report and Phase 1 and Phase 2 Overall Integrated Plan 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), dated December 29, 2015 (ML15365A554)

8. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated April 2015 (ML15104A118).