NL-17-0778, Sixth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

Sixth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

ML17163A224
Person / Time
Site:	Hatch
Issue date:	06/12/2017
From:	Hutto J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NL-17-0778
Download: ML17163A224 (12)

Text

A Southern Nuclear J. J. Hutto Regulatory Affairs Director 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5872 tel 205 992 7601 fax ilhutto@southemco.com JUN 1 2 2017 Docket Nos.: 50-321 NL-17-0778 50-366 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-1 09)

References:

1. 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.

2. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated June 27, 2014.

3. SNC Letter, Edwin I. Hatch Nuclear Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 23, 2015.

Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs the Edwin I. Hatch Nuclear Plant - Units 1 and 2 (HNP) 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.

In addition, Reference 1 also required submission of a Phase 1 overall integrated plan pursuant to Section IV, Condition D, and status reports at six-month intervals thereafter. SNC submitted the Phase 1 overall integrated plan (OIP) by letter dated June 27, 2014 (Reference 2). The third six-month update for Phase 1 of the Order included the required HCVS Phase 2 OIP submittal, and was submitted on December 23, 2015 (Reference 3). The consolidated HCVS Phase 1 and 2 OIP document (Reference 3) provided a list of the Phase 1 OIP open items, and addressed the NRC Interim Staff Evaluation open items for Phase 1. This letter is being submitted to

U.S. Nuclear Regulatory Commission NL-17-0778 Page2 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 NRC commitments. If you have any questions, please contact Matt Euten at 205.992.7673.

Mr. J. J. Hutto states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, J.J. Hutto )'

Regulatory Affairs Director II JJH/JMG/GLS Sworn to and subscribed before me this / l. day of q1AAA-IL ' 2017.

V'~UMa, £ ~h-

~tary Public My commission expires: /6 ..E"" Zot1

Enclosure:

Sixth Six-Month Status Report Regarding Requirements for Reliable Hardened Containment Vents (EA-13-1 09) cc: Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Sixth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

Enclosure Sixth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation Edwin I. Hatch Nuclear Plant - Units 1 and 2 Sixth Six Month Status Report for the Implementation of Order EA-13-109 1 Introduction Southern Nuclear Operating Company developed an Overall Integrated Plan (References 1 and 8) for the Edwin I. Hatch Nuclear Plant- Units 1 and 2 (HNP) documenting the installation of a Hardened Containment Vent System (HCVS). Updates of milestone accomplishments are based on the combined Phase 1 and 2 Overall Integrated Plan dated December 23, 2015.

HNP developed an updated and combined Phase 1 and 2 Overall Integrated Plan (Reference 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 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.

HNP has elected to upgrade the existing HCVS to comply with the requirements of EA-13-1 09 for Phase 1 and 2 under Revision 1 of NEl 13-02. Revision 1 of NEl 13-02 addresses methodology to implement Phase 2 requirements of order EA-13-109 and additional clarifications and guidance for implementation of Phase 1.

This enclosure provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 Overall Integrated Plan (Reference 8), 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 8), and are current as of April 30, 2017.

Phase 1 Unit 1 Design Engineering On-site/Complete Phase 1 Unit 2 Walk Through Demonstration/Functional Test Phase 1 Unit 2 Implementation Outage Phase 1 Unit 2 Site Specific Maintenance Procedures Phase 1 Unit 2 Procedure Changes Active Phase 1 Unit 2 HCVS Implementation Phase 1 Unit 2 Training Complete Phase 2 Hold preliminary/conceptual design meeting Phase 2 Unit 1 Design Engineering On-site/Complete E-1

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation 3 Milestone Schedule Status The following provides an update to Attachment 2 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.

Phase 1 and 2 HCVS Milestone Table Milestone Target Activity Status Comments Completion Date Submit Overall Integrated Plan Jun.2014 Complete Submit 6 Month Updates:

Update 1 Dec.2014 Complete Update 2 Jun.2015 Complete Update 3 Dec.2015 Complete Simultaneous with Phase 2 OIP Update 4 Jun.2016 Complete Update 5 Dec.2016 Complete Update 6 Jun.2017 Complete with this submittal Update 7 Dec.2017 Not Started Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual Jun.2014 Complete design meeting Unit 1 Design Engineering Feb.2017 Complete Completed On-site/Complete April2017 Unit 1 Implementation Outage Mar. 2018 Not Started Unit 1 Walk Through Mar. 2018 Not Started Demonstration/Functional Test Unit 2 Design Engineering May2016 Complete On-site/Complete Unit 2 Walk Through Feb.2017 Complete Demonstration/ Functional Test E-2

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation Milestone Target Activity Status Comments Completion Date Unit 2 Implementation Outage Feb.2017 Complete Phase 1 Procedure Changes Operations Procedure Dec.2017 Complete Unit 2 Current Projection Changes Developed Unit 1 Mar. 2018 Site Specific Maintenance Jan.2017 Complete Unit 2 Current Projection Procedure Developed Unit 1 Mar. 2018 Procedure Changes Active Feb.2017 Complete Unit 2 Current Projection Unit 1 Mar. 2018 Phase 1 Training:

Training Complete Dec.2016 Complete Unit 2 Current Projection Unit 1 Mar. 2018 Phase 1 Completion Unit 2 HCVS Implementation Feb.2017 Complete Unit 1 HCVS Implementation Mar. 2018 Started Current Projection Feb. 2018 Full Site HCVS Implementation Mar. 2018 Started Current Projection Feb. 2018 Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual Apr. 2016 Complete No modifications design meeting expected.

Engineering evaluations and associated non-modification changes scope definition by Mar 2017 Unit 1 Design Engineering On- Feb.2017 Complete No modifications site/Complete expected.

Engineering evaluations and associated non-modification changes by Oct 2017 Unit 1 Walk Through Mar. 2018 Not Started Current Projection Demonstration/ Functional Test Feb. 2018 Unit 1 Implementation Outage Mar. 2018 Not Started Current Projection Feb. 2018 E-3

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation Milestone Target Activity Status Comments Completion Date Unit 2 Design Engineering On- Feb.2018 Not Started No modifications site/Complete expected.

Engineering evaluations and associated non-modification changes by Oct 2018 Unit 2 Walk Through Mar. 2019 Not Started Current Projection Demonstration/Functional Test Feb.2019 Unit 2 Implementation Outage Mar. 2019 Not Started Current Projection Feb.2019 Phase 2 Procedure Changes Operations Procedure Changes Sep.2017 Not Started Current Projection Developed Feb. 2018 Site Specific Maintenance Dec.2017 Not Started Procedure Developed Procedure Changes Active Mar. 2018 Not Started Current Projection Mar. 2019 Phase 2 Training:

Training Complete Dec.2017 Not Started Phase 2 Completion Unit 1 HCVS Implementation Mar. 2018 Not Started Current Projection Feb. 2018 Submit Unit 1 Phase 1 and 2 May 2018 Not Started Current Projection Completion Report Apr. 2018 Unit 2 HCVS Implementation Mar. 2019 Not Started Current Projection Feb. 2019 Full Site HCVS Implementation Mar. 2019 Not Started Current Projection Feb.2019 Submit Unit 2 and site May 2019 Not Started Current Projection Completion Report [60 days Apr. 2019 after full site compliance]

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Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 and 2 Overall Integrated Plan (Reference 8) and as described in the fifth six-month status report submitted December 14, 2016 (Reference 9).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant- Units 1 and 2, expect 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 Evaluation The following tables provide a summary of the open items documented in the combined Phase 1 and 2 Overall Integrated Plan, the Phase 1 Interim Staff Evaluation (ISE) and the Phase 2 Staff Evaluation and an updated response to each item beyond that supplied in the fifth six-month status report submitted December 14, 2016 (Reference 9).

Hatch 1 & 2 HCVS Phase 1 and 2 OIP Open Response Items 1 Determine location of Dedicated HCVS Documented Closed in Reference 9 Battery transfer switch -

2 Determine location of back-up nitrogen Documented Closed in Reference 9 bottles 3 Evaluate location of Portable DG for Documented Closed in Reference 9 accessibility under Severe Accident HCVS use 4 Confirm suppression pool heat capacity Documented Closed in Reference 9 5 Determine location of HCVS Remote Documented Closed in Reference 9 Operating Station 6 State which approach or combination of Documented Closed in Reference 9 approaches Plant Hatch decides to take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies 7 Evaluate SGTS Valve Leakage utilizing Documented Closed in Reference 9 criteria from NEI HCVS-FAQ Audit item per ISE 8 Identify qualification method used for HCVS Documented Closed in Reference 9 instruments - Audit item per ISE 9 Evaluate HCVS monitoring location of Documented Closed in Reference 9 Portable DG for accessibility, habitability, staffing sufficiency, and communication capability with Vent under Severe Accident HCVS use decision makers - Audit item per ISE 10 Perform severe accident evaluation for FLEX Documented Closed in Reference 9 DG use post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions- Confirmatory Action E-5

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation 11 Determine the control document for HCVS Documented Closed in Reference 9 out of service time criteria - Audit item per ISE Hatch 1 & 2 HCVS Phase 1 ISE Open Response Items 1 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit location of the ROS's call on March 7, 2017 2 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit location of the dedicated HCVS call on March 7, 2017 battery transfer switch 3 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation of the HCVS nitrogen call on March 7, 2017 pneumatic system design including sizing and location 4 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit deployment location of the portable call on March 7, 2017 diesel generators 5 Make available for NRC staff audit an Closed per Reference 9 and verified in NRC Audit evaluation of temperature and call on March 7, 2017 radiological conditions to ensure that Provided references in NEI 13-02, Rev 1, HNP operating personnel can safely access HCVS Phase 1 and 2 OIP (Reference 8) and HNP and operate controls and support FSAR for shielding. Provided updated figures 1-2 equipment and 1-2 of HCVS Phase 1 and 2 OIP (Reference 8) showing locations of DGs and Control Panel operations on the e-Portal.

6 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit analyses demonstrating that HCVS call on March 7, 2017 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 7 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit descriptions of local conditions call on March 7, 2017 (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control E-6

Enclosure to N L-17-0778 Sixth Six-Month Status Report for Vent Order Implementation devices, 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 the Closed per Reference 9 and verified in NRC Audit final sizing evaluation for HCVS call on March 7, 2017 batteries/battery charger including Clarification with DOEJ-HDSNC598056-M002 and incorporation into FLEX DG loading calculation SENH-16-003 on battery discharge calculation temperature limitations:

The RPS battery room ventilation is sufficient to keep the temperature in the room below the maximum design space temperature of 100°F.

The addition of the new equipment raises the temperature from 90°F to 98.25°F. This calculation used the max battery heat output and during normal operation the output will be less. Battery discharge assumption 7.4 assumes the room temperature increases to 122F and assumption 7.1 assumes the discharge occurs at 65F.

9 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation that demonstrates call on March 7, 2017 adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions 10 Provide a description of the final Closed per Reference 9 and verified in NRC Audit design of the HCVS to address call on March 7, 2017 hydrogen detonation and deflagration 11 Provide a description of the strategies Closed per Reference 9 and verified in NRC Audit for hydrogen control that minimizes call on March 7, 2017 the potential for hydrogen gas migration and ingress into the reactor building or other buildings 12 Make available descriptions of design Closed per Reference 9 and verified in NRC Audit details that minimize unintended cross call on March 7, 2017 flow of vented fluids within a unit and between units 13 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit descriptions of all instrumentation and call on March 7, 2017 controls (existing and planned) necessary to implement this order including qualification methods 14 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation of an evaluation call on March 7, 2017 verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during E-7

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation BDBEE and severe accident wetwell ventin g 15 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit control document for HCVS out of call on March 7, 2017.

service time criteria Hatch 1 & 2 HCVS Phase 2 ISE Open Response Items 1 Licensee to demonstrate that Closed per Reference 9, consistent with the containment failure as a result of BWROG generic closure criteria for Order EA overpressure can be prevented 109 Phase 2 Open Items.

without a drywell vent during severe accident conditions Section 3.3.3 2 Licensee shall demonstrate how the Closed per Reference 9, consistent with the plant is bounded by the reference BWROG generic closure criteria for Order EA plant analysis that shows the SAWM 109 Phase 2 Open Items.

strategy is successful in making it unlikely that a drywell vent is needed Section 3.3.3.1 3 Licensee to demonstrate that there is Closed per Reference 9, consistent with the adequate communication between the BWROG generic closure criteria for Order EA MCR and the Intake Structure 109 Phase 2 Open Items.

operator at the FLEX manual valve during severe accident conditions.

Section 3.3.3.4 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8 Additional Information No changes since fifth six-month status report submitted December 14, 2016 (Reference 9).

9 References The following references support the updates to the Phase 1 and 2 Overall Integrated Plan (Reference 8) described in this enclosure:

1. SNC Letter, Edwin I. Hatch Phase I Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 27, 2014 (ML141788464).

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 (ML13143A321 ).

3. NRC Endorsement, Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Revision 0, dated May 14, 2014 (ML14128A219).

4. NRC Letter, Edwin I. Hatch Nuclear Plant Units, 1 and 2 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-1 09 (Severe E-8

Enclosure to NL-17-0778 Sixth Six-Month Status Report for Vent Order Implementation Accident Capable Hardened Vents) (TAG Nos. MF4479 and MF4480), dated March 25, 2015 (ML14335A137).

5. NEI13-02, 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 (ML151138318).

6. 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 1, dated April 2015 (ML15104A118).

7. NRC Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision 1, dated September 22, 2015, and Frequently Asked Questions (FAQs) 10, 11, 12, and 13, dated October 8, 2015 (ML15271A148).

8. SNC Letter with Combined Phase 1 and 2 Overall Integrated Plan, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Third Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 23, 2015 (ML15357A212).

9. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fifth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-1 09), dated December 16, 2016.

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