NRC-16-0069, Fifth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Fifth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

ML16344A252
Person / Time
Site:	Fermi
Issue date:	12/09/2016
From:	Polson K DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NRC-16-0069
Download: ML16344A252 (12)

Text

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: keith.polson@dteenergy.com DTE Energy-December 9, 2016 10 CFR 50.54(f)

NRC-16-0069 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Order 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 (Accession No. ML13130A067)

3) NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 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)

4) NEI 13-02, "Industry Guidance for Compliance with Order EA 109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April 2015 (Accession No. ML15113B318)

5) DTE Electric Company Letter, NRC-14-0043, "DTE Electric Company's Phase 1 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 (Accession No. ML14182A203)

6) DTE Electric Company Letter, NRC-15-0105, "DTE Electric Company's Phase 1 and Phase 2 Overall Integrated Plan for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated December 23, 2015 (Accession No. ML15357A289)

USNRC NRC-16-0069 Page 2

7) NRC Letter to DTE Electric Company, "Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents),"

dated April 1, 2015 (Accession No. ML15077A574)

8) NRC Letter to DTE Electric Company, "Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents),"

dated August 30, 2016 (ML16231A443)

9) DTE Electric Company Letter, NRC-16-0039, "DTE Electric Company's Fourth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 20, 2016 (Accession No. ML16172A209)

Subject:

DTE Electric Company's Fifth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions On June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to take certain actions to ensure that Fermi 2 Nuclear Power Plant has a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure 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 were outlined in of Reference 2.

Reference 2 required submission of an Overall Integrated Plan (OIP) by June 30, 2014 for Phase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order.

The interim staff guidance (Reference 3) provided direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorsed industry guidance document NEI 13-02, Revision 1 (Reference 4), with certain clarifications and exceptions. References 5 and 6 provided the Phase 1 and Phase 2 OIPs. In References 7 and 8, NRC provided the Phase 1 and Phase 2 Interim Staff Evaluations for Fermi 2. Reference 9 provided the most recent six-month update.

The Enclosure to this letter provides the fifth six-month update for Phase 1 and Phase 2 of the Order.

USNRC NRC-16-0069 Page 3 This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Mr.

Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

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

Executed on December 9, 2016 Keith J. Polson Site Vice President

Enclosure:

DTE Electric Company's Fifth Six-Month Status Report cc: Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission, Regulated Energy Division (kindschl(michigan.gov)

Enclosure to NRC-16-0069 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Company's Fifth Six-Month Status Report

Enclosure to NRC-16-0069 Page 1 DTE Electric Company's Fifth 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 DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 8.1),

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 8.2. Updates of milestone accomplishments will be based on the combined Phase 1 and 2 OIP, dated December 23, 2015 (Reference 8.3).

This Enclosure provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, in accordance with Nuclear Energy institute (NEI) 13-02, Revision 1, "Industry Guidance for Compliance with Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (Reference 8.4).

2 Milestone Accomplishments [required by NEI 13-02 Section 7.3.1.21 The following milestone(s) have been completed since the development of the combined Phase 1 and 2 OIP (Reference 8.3), and are current as of November 8, 2016, for this status report.

• Fifth Six-Month Status Report (this submittal)

• Hold preliminary/conceptual design meeting for Phase 2

" Modifications Evaluation for Phase 2 3 Milestone Schedule Status [required by NEI 13-02 Section 7.3.1.11 The following provides an update to Part 5 of the combined Phase 1 and 2 OIP (Reference 8.3). It provides the activity status of each item. No expected completion dates have changed in this report.

Enclosure to NRC-16-0069 Page 2 Comments Target Activity (Include date Milestone Completion Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 [with Phase 2 OIP] Dec 2015 Complete Update 4 Jun 2016 Complete Update 5 Dec 2016 This submittal Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Modifications Hold preliminary/conceptual design Jun 2014 Complete meeting Modifications Evaluation Jul 2014 Complete Design Engineering On-site/Complete Apr 2017 Started Implementation Outage Apr 2017 Not Started Walk Through Ar21 o tre Demonstration/Functional Test Apr 2017 Not Started Phase 1 Procedure Changes Active Operations Procedure Changes Apr 2017 Started Developed Site Specific Maintenance Procedure Apr 2017 Started Developed Procedure Changes Active Apr 2017 Not Started Phase 1 Training Training Complete Apr 2017 Started Phase 1 Completion Submit Completion Report [60 days Jun 2017 Not Started after full site compliance]

Phase 2 Specific Milestones Phase 2 Modifications Hold preliminary/conceptual design Sept 2016 Complete meeting Modifications Evaluation Sept 2016 Complete Design Engineering On-site/Complete Sept 2017 Started Implementation Outage Oct 2018 Not Started

Enclosure to NRC-16-0069 Page 3 Comments Target Tapetin Activity {Include date Milestone Completion Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Phase 2 Specific Milestones (cont.

Walk Through Oct 2018 Not Started Demonstration/Functional Test Phase 2 Procedure Changes Active Operations Procedure Changes Developed Oct 2018 Started Site Specific Maintenance Procedure Oct 2018 Not Started Developed Procedure Changes Active Oct 2018 Not Started Phase 2 Training Training Complete Oct 2018 Not Started Phase 2 Completion Submit Completion Report [60 days after Dec 2018 Not Started full site compliance]

4 Changes to Compliance Method [required by NEI 13-02 Section 7.3.1.3]

There are no changes to the compliance method as documented in the combined Phase 1 and 2 OIP (Reference 8.3).

5 Need and Basis for Relief/Relaxation [required by NEI 13-02 Section 7.3.1.4]

DTE expects to comply with the order implementation date.

6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluations [required by NEI 13-02 Section 7.3.1.5]

The following tables provide a summary of the open items documented in the combined Phase 1 and 2 OIP or the Interim Staff Evaluations (ISEs) (References 8.5 and 8.6) and the status of each item.

Enclosure to NRC-16-0069 Page 4 Combined Phase 1 and 2 OIP Status Open Items Phase 1 OIP Open Items OIP Action Comment Open Item 1 Confirm thermal environment for See Phase 1 ISE Open Item 2.

actions using GOTHIC.

2 Confirm radiological environment. See Phase 1 ISE Open Item 2.

3 Confirm suppression pool heat See Phase 1 ISE Open Item 3.

capacity.

4 Define tornado missile protection for Missile protection for HCVS components on RB 5 th floor components. the RB 5 th floor will be provided by following the guidance of NRC endorsed white paper, HCVS-WP-04 Missile Evaluationfor HCVS Components 30 Feet Above Grade.

Phase 2 OIP Open Items OIP Action Comment Open Item 1 Confirm that the thermal environment Added for Phase 2 per Table 3.1 and 3.1 .b of supports feasibility of staff actions. Reference 8.3 2 Confirm that the radiological Added for Phase 2 per Table 3.1 and 3.1 .b of environment supports feasibility of Reference 8.3 staff actions.

Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items 1 Make available for NRC staff audit Response to be documented in a future documentation confirming that all update load stripping will be accomplished within one hour and fifteen minutes of event initiation and will occur at locations not impacted by a radiological event.

2 Make available for NRC staff audit Response to be documented in a future an evaluation of Section 3.2.1 update temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

Enclosure to NRC-16-0069 Page 5 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 3 Make available for NRC staff audit, Response to be documented in a future analyses demonstrating that HCVS update 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.

4 Make available for NRC staff audit Response to be documented in a future the descriptions of local conditions update (temperature, radiation and humidity) anticipated during extended loss of alternating current (AC) power (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.

5 Make available for NRC staff audit Response to be documented in a future documentation of the HCVS nitrogen update pneumatic system design including sizing and location.

6 Make available for NRC staff audit Response to be documented in a future the final sizing evaluation for HCVS update batteries/battery charger including incorporation into FLEX diesel generator (DG) loading calculation.

Enclosure to NRC-16-0069 Page 6 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 7 Make available for NRC staff audit Response to be documented in a future documentation that demonstrates update adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

8 Provide a description of the final Response to be documented in a future design of HCVS to address hydrogen update detonation and deflagration.

9 Provide a description of the strategies Response to be documented in a future for hydrogen control that minimizes update the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

10 Make available for NRC staff review Response to be documented in a future design details to ensure the potential update for cross flow between HCVS and Standby Gas Treatment System (SGTS) is minimized.

11 Provide a justification for deviating Response to be documented in a future from the instrumentation seismic update qualification guidance specified in Nuclear Energy Institute (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 Response to be documented in a future description of all instrumentation and update controls (existing and planned) necessary to implement this order including qualification methods.

Enclosure to NRC-16-0069 Page 7 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 13 Make available for NRC staff audit Response to be documented in a future documentation of an evaluation update verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during beyond design basis external events (BDBEE) and severe accident wetwell venting.

Phase 2 ISE Open Items 1 Licensee to demonstrate that Response to be documented in a future containment failure as a result of update overpressure can be prevented without a drywell vent during severe accident conditions.

2 Licensee to provide the site-specific Response to be documented in a future MAAP evaluation that demonstrates update Severe Accident Water Addition (SAWA) / Severe Accident Water Management (SAWM) can be maintained for greater than 7 days.

3 Licensee to demonstrate that there is Response to be documented in a future adequate communication between update Main Control Room and the SAWM control location during severe accident conditions.

4 Licensee to demonstrate the SAWM Response to be documented in a future flow instrumentation qualification for update the expected environmental conditions.

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

8 References The following references support the updates to the combined Phase 1 and 2 OIP described in this Enclosure.

8.1 DTE Electric Company Letter, NRC-14-0043, "DTE Electric Company's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses

Enclosure to NRC-16-0069 Page 8 with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014 (ML14182A203) 8.2 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 (ML13130A067) 8.3 DTE Electric Company Letter, NRC-15-0105, "DTE Electric Company's 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 23, 2015 (ML15357A289) 8.4 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 2015 (ML15113B318) 8.5 NRC Letter to DTE Electric Company, "Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents)," dated April 1, 2015 (ML15077A574) 8.6 NRC Letter to DTE Electric Company, "Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents)," dated August 30, 2016 (ML16231A443)