ML16187A261

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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)
ML16187A261
Person / Time
Site: Duane Arnold 
(DPR-049)
Issue date: 06/30/2016
From: Vehec T
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-16-0130 EA-13-109
Download: ML16187A261 (11)
v • d • e


Text

-*--NEXTeraM ENERGY~

June 30, 2016 DUANE ARNOLD NG-16-0130 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 NextEra Energy Duane Arnold. LLC's Six-Month Status Report in Response to June~.

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.
2.
3.

Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions." dated June 6, 2013(ML13130A067)

NextEra Energy Duane Arnold 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-13-109, dated December 10; 2014(ML14349A324)

NextEra Energy Duane Arnold, LLC's Six-Month Status Report and Phase 1 and 2 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-1 3-109) dated December 22, 2015 (ML15358A043)

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an Order (Reference 1) to NextEra Energy Duane Arnold, LLC. Reference 1 was immediately effective and directs NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) 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 of Reference 1.

Reference 1 required submission of a Phase 1 Overall Integrated Plan (OIP) pursuant to Section IV, Condition D, and status reports at six-month intervals thereafter. NextEra NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 fr\\'S;

Document Control Desk NG-16-0130 Page 2of2 NextEra Energy Duane Arnold submitted the Phase 1 OIP by letter dated December 10, 2014 (Reference 2). Reference 3 included the required six-n:10nth status update, as well as the Phase 2 OIP submittal. The consolidated Phase 1 and 2 OIP document provided a list of the Phase 1 OIP open items, and addressed ttie NRG Interim Staff Evaluation open items for Phase 1. This letter is being submitted to satisfy the requirements for providing the six-month updates for Phase 1 and 2 of the Order in accordance with Section IV, Condition D.3, of Reference 1.

This letter contains no new regulatory commitments. If you have any questions regarding this submittal, please contact Tim Holt at 319-851-7345.

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

Exec ed on June 30, 2016.

.. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc:

Director, Office of Nuclear Reactor Regulation USNRC Regional Administrator Region Ill USNRC Project Manager, Duane Arnold Energy Center USNRC Resident Inspector, Duane Arnold Energy Center

' Enclosure to NG-16-0130 NextEra Energy Duane Arnold, LLC's 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) 8 pages follow

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions 1 Introduction NextEra Duane Arnold Energy Center, LLC developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the planned 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 22, 2015.

NextEra Duane Arnold Energy Center, LLC developed an updated and combined Phase 1 and 2 Overall Integrated Plan (Reference 7), documenting:

1. The planned 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 rE!actor vessel by molten core debris, in response to Reference 2.

This enclosure provides an update of milestone accomplishments since submittal of the combined Phas_e 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 (Reference 7), and are current as of June 1, 2016.

Design Complete Phase 1 Submit 6 Month Status Report (Complete with this submittal) 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.

Page 1 of 8

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder. Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions Phase 1 Milestone Schedule:

Mil~sfone Targ.~t Activity:

Comrt)ef1ts Cort)pl(2tiq~. Status

.{Includes date.

...Date changes}

Issue preliminary/conceptual design report June 2014 Complete Submit Overall Integrated Implementation Plan June 2014 Complete Initial Outage for Phase 1 Planning Nov. 2014

- Complete Submit 6 Month Status Report Dec. 2014 Complete Submit 6 Month Status Report June 2015 Complete Submit 6 Month Status Report Dec. 2015 Complete Design Complete Phase 1 Mar. 2016 Complete Submit 6 Month Status Report June 2016 Complete with this submittal Operations Procedure Changes Developed Oct. 2016 Started Site Specific Maintenance and Testing Oct. 2016 Started Procedures Developed Training Complete Oct. 2016

  • Started Implementation Outage End of Not RF025 Started Procedure Changes Active End of Not RF025 Started Walk Through Demonstration/Functional Test End of Not RF025 Started Submit Completion Report 60 days Not after Started RF025 Page 2 of 8

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions Phase 2 Milestone Schedule

  • Mileston~

, Targe~

. Ac;;tivJJy '

,. Comment~

qompletion Status

{(nclude date

",,. ~

clianges in this Date column}

Submit Overall Integrated Implementation Plan Dec. 2015 Complete Hold preliminary/conceptual design meeting June 2016 Not Started Submit 6 Month Status Report June 2016 Complete with this submittal Submit 6 Month Status Report Dec. 2016 Not Started Submit 6 Month Status Report June 2017 Not Started Design Engineering On-site/Complete Jan.2018 Not Started Submit 6 Month Status Report Dec. 2017 Not Started Submit 6 Month Status Report June 2017 Nnt Started Operations Procedure Changes Developed Oct. 2018 Not Started Site Specific Maintenance Procedure Oct. 2018 Not Developed Started Training Complete Oct. 2018 Not Started Implementation Outage RF026 Not Started Procedure Changes Active RF026 Not Started Walk Through Demonstration/Functional Test RF026 Not Started Submit Completion Report RF026 Not Started Page 3 of 8

1.
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3.
4.

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions 4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phase 1 and 2 Overall Integrated Plan (Reference 7). However, changes have been made to the design details which affect descriptions contained in Reference 7.

The HCVS "Nitrogen Supply Isolation at 1A3 ROS" (V43-0642) will be normally closed and locked to prevent inadvertent vent operation. This valve will have to be manually opened at the Remote Operating Station (ROS) in the 1A3 Essential Switchgear Room to supply nitrogen for CV operation and purging.

The.Uninterruptible Power Supply (UPS) originally had the normal power supply from 1832. Analysis identified that 1832 did not have adequate margin to add this load; therefore the normal power supply has been changed to 1815. A receptacle will be installed at the UPS for direct connection to the portable 480 VAC generator..

The power to 1B15 will be lost during an ELAP. The UPS will provide power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the FLEX 480 VAC generator will provide power beyond 24 hrs.

5 Need for Relief/Relaxation.and Basis for the Relief/Relaxation NextEra Duane Arnold Energy Center, LLC 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.

Combined Phase 1 and 2 OIP Open Item Status Phase 1 Open Items Confirm secondary containment bypass leakage is Completed. Appropriate rupture acceptable without an installed rupture.disk or retain disk is included in design of an appropriate disk.

modification.

Perform severe accident evaluation for FLEX DG and Started replacement gas to confirm accessibility for use for post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions.

Evaluate tornado/missile effects on HCVS components Complete above the protected area of the Reactor Building.

Evaluate the system design for H2/CO measures to be Complete taken.

Page 4 of 8

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions Interim Staff Evaluation Open Items Status Phase 1 ISE Items a e ava1 a e or sta au 1t ocumentat1on Started of licensee confirmation that secondary containment leakage is acceptable without an installed rupture disk or that an appropriate rupture disk, including procedures for rupture during HCVS operation, is included in the HCVS design.

(Section 3.1.2, Section 3.2.2.8)

2.

ake ava1 a e or NRG sta au 1t analyses Started demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one (1) 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 sliutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the J:>rimary containment pressure limit. (Section 3.2.2.1, Section 3.2.2.2) a e ava1 a e or sta au 1t a 1t1ona eta1 on the design features that minimize unintended cross flow of vented fluids within a unit, including a one line diagram containing sufficient detail to confirm the description in the OIP. (Section 3.2.2.7)

5.

rov1 e a escnpt1on o t e ma es1gn o t e to address hydrogen detonation and deflagration.

(Section 3.2.2.6)

Started Eliminated.

The design h;:is been modified

. since issuance of the ISE. The HCVS vent path is a dedicated path, eliminating the possibility of unintended cross flow.

Started

6. Provide a descnpt1on o the strategies or y rogen Started control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings. (Section 3.2.2.6)
7.

a e ava1 a e or sta au 1t ocumentat1on Started that demonstrates adequate communication between the remote HCVS operation locations and*

HCVS decision makers during ELAP and severe accident conditions. (Section 3.2.2.5)

8.

a e ava1 able or sta au 1t an eva uat1on o Started temperature and radiological conditions to ensure that operating personnel can safely access and o erate controls and su ort e ui ment. Section Page 5 of 8

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions 3.2., ection 3.2.2.3, Section 3.2.2.4, 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 and Section 3.2.6) a e ava1 a e or sta au 1t.t e 1na *sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation. (Section 3.2.2.4, 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 and Section 3.2.5.2)

10. Make ava1la le or RC sta au 1t the inal sizing evaluation for pneumatic N2 supply. (Section 3.2.2.4, 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 and Section 3.2.5.2)

. a e ava1 a e or R sta au 1t ocumentat1on of an evaluation verifying the ex.isting containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

3.

a e ava1 a e or sta au 1t t e

. 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 capabre of performing their functions during ELAP and severe accident conditions. (Section 3.2.2.3, Section 3.2.2.5, Section 3.2.2.9, Section 3.2.2.10)

Page 6 of 8 Started Started As stated in NG-15-0169, Six Month Status Update, due to design changes in vent location and routing, existing containment isolation valves will no longer be used for venting. New vent design will utilize a spare torus penetration with two new primary containment isolation valves and a rupture disk.

An evaluation will be done to ensure the two new containment isolation valves.

will open under the maximum expected differential pressure during BDBEE and severe accident wet well ventin.

Started Started

Enclosure to NG-16-0130 - NextEra Energy Duane Arnold, LLC's Six Month Status Report for the l'mplementation of Order EA-13-109,0rder Modifying Licenses with Regard to, Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

14. Provide a 1ust1 icat1on or ev1atmg rom t e 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. (Section 3.2.2.9)

Phase 2 Interim Staff Evaluation Open Item T8D 7

Interim Staff Evaluation Impacts itnmate.

As stated in NG-15-0169, Six Month Status Update, the qualification method used for each HCVS instrument will be to the IEEE 344-2004 standard or a substantially similar industrial standard and therefore will not be deviating from NEI 13-02 or JLD-ISG-2013-02.

Status N/A The June 2015 six-month update (Reference 6) noted the following two potential impacts to the Interim Staff Evaluation:

1)

One ISE Open Item will be eliminated because the Hardened Pipe Vent will no longer use existing, containment isolation valves. The revised vent pipe routing will instead use an existing spare torus penetration and install two new containment isolation valves and a rupture disk. An evaluation will be done to ensure the two new containment isolation valves will open under the maximum expected differential pressure during 8D8EE and severe accident wetwell venting.

2)

The Interim Staff Evaluation (ISE) inadvertently listed a vent pipe process pressure indicator which will not be part of the Duane Arnold design.,

In addition, as discussed previously in Section 4:

The HCVS "Nitrogen Supply Isolation at 1A3 ROS" (V43-0642) will be normally closed and locked to prevent inadvertent vent operation. This valve will have to be manually opened at the Remote Operating Station (ROS) in the 1A3 Essential Switchgear Room-to supply nitrogen for CV operation and purging.

The Uninterruptible Power Supply (UPS) originally had the normal power supply from 1832. Analysis identified that 1832 did not have adequate margin to add this load; therefore the normal power supply has been changed to 1815. A receptacle will be installed at the UPS for direct connection to the portable 480 VAC generator.

The power to 1815 will be lost during an ELAP. The UPS will provide power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the FLEX 480 VAC generator will provide power beyond 24 hrs.

Page 7 of 8

Enclosure to NG-16-0130 -.NextEra Energy Duane Arnold, LLC's Six Month Status Report for the Implementation of Order EA-13-109,0rder Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions 8 References The following references support the updates to the combined Phase 1 and 2

  • Overall Integrated Plan described in this Enclosure.
1. NextEra Duane Arnold Energy Center, 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 S~vere Acc;ident Conditions (Order Number EA-13-109)," dated December 10, 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 Capable of Operation Under Severe Accident Conditions," Rev!sion 1, dated April 2015.

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 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. ML133048836).
5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS)

Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. ML14128A219).

6. NextEra Energy Duane Arnold, LLC's 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), dated June 18, 2015(ML15170A333)
7. NextEra Duane Arnold Energy Center, LLC Combined Phase 1 and 2 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 December 22: 2015.
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 (Accession No. ML15104A118).

Page 8 of 8

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