RS-17-067, Sixth Six-Month Status Report for Phases 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.

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Sixth Six-Month Status Report for Phases 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.
ML17181A033
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 06/30/2017
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-17-067, TAC MF4481, TAC MF4482
Download: ML17181A033 (26)
v • d • e


Text

Exelon Generation Order No. EA-13-109 RS-17-067 June 30, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-41 O

Subject:

Sixth Six-Month Status Report For Phases 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)

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
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
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
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
5. Exelon Generation Company, LLC's Answer 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, 2013
6. Exelon Generation Company, 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 Severe Accident Conditions (Order Number EA-13-109), dated June 27, 2014
7. Exelon Generation Company, LLC First Six-Month Status Report 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 17, 2014 (FLL-14-035)
8. Exelon Generation Company, LLC Second Six-Month Status Report 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 June 30, 2015 (RS-15-153)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2017 Page 2

9. Exelon Generation Company, LLC Phase 1 (Updated) and Phase 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 15, 2015 (RS-15-302)
10. Exelon Generation Company, LLC Fourth Six-Month Status Report For Phases 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 June 30, 2016 (RS-16-111)
11. Exelon Generation Company, LLC Fifth Six-Month Status Report For Phases 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 14, 2016 (RS-16-236)
12. NRG letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 1 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4481), dated March 26, 2015

13. NRG letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, 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) (TAC No. MF4482}, dated February 11, 2015

14. NRG letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 1 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4481), dated August30,2016

15. NRG letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, 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) (TAC No. MF4482), dated August 25, 2016 On June 6, 2013, the Nuclear Regulatory Commission ("NRG" or "Commission") issued an Order (Reference 1) to Exelon Generation Company, LLC (EGG). Reference 1 was immediately effective and directs EGG to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities have 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 are outlined in Attachment 2 of Reference 1.

Reference 1 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 (References 2 and 3) provide direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions identified in References 2 and 3. Reference 5 provided the EGG initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 provided the Nine Mile Point Nuclear

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2017 Page 3 Station, Units 1 and 2, Phase 1 OIP pursuant to Section IV, Condition D.1 of Reference 1.

References 7 and 8 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Nine Mile Point Nuclear Station. Reference 9 provided the Nine Mile Point Nuclear Station, Units 1 and 2, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1. References 1O and 11 provided the fourth and fifth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Nine Mile Point Nuclear Station.

The purpose of this letter is to provide the sixth six-month update reports for Phases 1 and 2, pursuant to Section IV, Condition D.3 of Reference 1, that delineates progress made in implementing the requirements of Reference 1 for Nine Mile Point Nuclear Station, Units 1 and 2.

The enclosed reports provide an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed reports also address the NRC Interim Staff Evaluation open items contained in References 12, 13, 14, and 15.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David J. Distel at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30 1h day of June 2017.

Respectfully submitted,

~~ht:

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosures:

1. Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
2. Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2017 Page 4 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Project Manager, NRA - Nine Mile Point Nuclear Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC

Enclosure 1 Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (13 Pages)

Page 1 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 1 Introduction Nine Mile Point Unit 1 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 six month status report updates the milestone accomplishments based on the combined Phases 1 and 2 Overall Integrated Plan dated December 15, 2015 and last updated on December 14, 2016 (Reference 11 ).

Nine Mile Point Unit 1 developed an updated and combined Phases 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 Phases 1 and 2 Overall Integrated Plan and the last six month update, 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 last six-month update was submitted under Reference 11, and are current as of June 1, 2017.

  • Sixth Six-Month Update (complete with this submittal)
  • Phase 1 Design, Installation and Functional Testing Complete Page 2 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 3 Milestone Schedule Status The following provides an update to the Part 5 Milestone Schedule of 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. The revised Design Engineering Complete date shown below does not impact the order implementation date.

NMP1 - Phase 1 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Hold preliminary/conceptual design November Complete meeting 2013 Submit Overall Integrated Implementation June 2014 Complete Plan Submit 6 Month Status Report December Complete 2014 Submit 6 Month Status Report June 2015 Complete Submit 6 Month Status Report December Complete Simultaneous with 2015 Phase 2 OIP Submit Combined Phase 1 & 2 Six-Month June 2016 Complete Status Report Design Engineering Complete January Complete 2017 Submit Combined Phase 1 & 2 Six-Month December Complete Status Report 2016 Submit Combined Phase 1 & 2 Six-Month June 2017 Complete Status Report with this submittal Maintenance and Operation Procedure February Complete Changes Developed , Training Complete 2017 Implementation Outage April 2017 Complete Procedure Changes Active, Walk-Through April 2017 Complete Demonstration/Functional Test Submit Completion Report June 2019 Not Started Page 3 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 NMP1 - Phase 2 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Submit Overall Integrated Plan December Complete Simultaneous with 2015 Phase 1 Updated OIP Hold preliminary/conceptual design meeting June 2015 Complete Submit 6 Month Status Report June 2016 Complete Submit 6 Month Status Report December Complete 2016 Submit 6 Month Status Report June 2017 Complete with th is submittal Submit 6 Month Status Report December Not 2017 Started Submit 6 Month Status Report June 2018 Not Started Submit 6 Month Status Report December Not 2018 Started Design Engineering Complete April 2018 Started Maintenance and Operation Procedure February Not Changes Developed , Training Complete 2019 Started Implementation Outage April 2019 Not Started Procedure Changes Active, Walk-Through April 2019 Not Demonstration/Functional Test Started Submit Completion Report June 2019 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phases 1 and 2 Overall Integrated Plan (Reference 7).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Nine Mile Point Unit 1 expects to comply with the order implementation date and no relief/relaxation is required at this time.

Page 4 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 6 Open Items from Combined Phases 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in Attachment 7 of the combined Phases 1 and 2 Overall Integrated Plan, the Reference 6 Interim Staff Evaluation (ISE) for Phase 1 and the Reference 10 ISE for Phase 2, and the status of each item. Phase 1 open item responses were discussed with the NRG on November 17, 2016, and all items were adequately addressed and resolved. All additional information has been provided, and the Phase 1 open items are considered closed based on NRG review.

Open Phase 1 Open Items from OIP Status Item 1 Perform final sizing evaluation for Deleted (closed to ISE open item HCVS batteries and battery number 7 below) charger and include in FLEX DG loading calculation .

2 Perform final vent capacity Deleted (closed to ISE open item calculation for the Torus HCVS number 2 below) piping confirming 1 % minimum capacity.

3 Perform final sizing evaluation for Deleted (closed to ISE open item pneumatic Nitrogen (N2) supply. number 8 below) 4 Perform confirmatory Deleted (closed to ISE open item environmental condition evaluation numbers 6 and 11 below) for the Turbine Building in the vicinity of the Remote Operating Station (ROS) and HCVS dedicated pneumatic supply and batteries.

5 State which approach or Deleted (closed to ISE open item combination of approaches the number 3 below) plant determines is necessary to address the control of combustible gases downstream of the HCVS control valve.

6 Complete evaluation for Deleted (closed to ISE open item environmental/seismic qualification numbers 9 and 11 below) of HCVS components.

7 Complete evaluation for Deleted (closed to ISE open item environmental conditions and number 6 below) confirm the travel path accessibility.

8 Perform rad iological evaluation for Complete with this update.

Phase 1 vent line impact on ERO response actions. Radiological Calculation H21 C115 has Page 5 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 been completed to provide assurance that personnel can safely operate the NMP1 HCVS and respond to required ERO response actions during severe accident conditions. Calculation was performed using NRC endorsed HCVS-WP-02 and HCVS-FAQ-12 methodologies. Calculation H21 C115 has been posted in ePortal for NRC's review.

Open ISE Phase 1 Open Items Status Item 1 Make available for NRC staff audit Submitted for Closure in Reference 9.

the seismic and tornado missile June 2017 Update:

final design criteria for the HCVS The final revisions of the referenced stack. pipe stress calculations have been added to the ePortal; however, there is no change to the closure summary provided in Reference 9.

2 Make available for NRC staff audit Submitted for Closure in Reference 9.

analyses demonstrating that HCVS June 2017 Update:

has the capacity to vent the The final revision of calculation S22.4-steam/energy equivalent of one 201.13F004 has been added to the percent of licensed/rated thermal ePortal; however, there is no change to power (unless a lower value is the closure summary provided in justified), and that the suppression Reference 9.

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.

3 Provide a description of the final Submitted for Closure in Reference 11.

design of the HCVS to address June 2017 Update:

hydrogen detonation and The final revision of calculation S22.4-deflagration. 201.13F001 has been added to the ePortal; however, there is no change to the closure summary provided in Reference 11 .

4 Make available for NRC staff audit Submitted for Closure in Reference 9.

documentation that demonstrates adequate communication between Page 6 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

5 Provide a description of the Submitted for Closure in Reference 9.

strategies for hydrogen control that June 2017 Update:

minimizes the potential for The final revision of C18014C Sht. 7 hydrogen gas migration and has been added to the ePortal; ingress into the reactor building or however, there is no change to the other buildings. closure summary provided in Reference 9.

6 Make available for NRC staff audit Submitted for Closure in Reference 11.

an evaluation of temperature and June 2017 Update:

radiological conditions to ensure The final revision of the HCVS that operating personnel can safely Engineering Change Package access and operate controls and Assessment of Operator Access section support equipment. has been loaded on the ePortal; however, there is no change to the closure summary provided in Reference n.

7 Make available for NRC staff audit Submitted for Closure in Reference 9.

the final sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

8 Make available for NRC staff audit Submitted for Closure in Reference 9.

documentation of the HCVS nitrogen pneumatic system design including sizing and location.

10 Make available for NRC staff audit Submitted for Closure in Reference 11.

descriptions of all instrumentation June 2017 Update:

and controls (existing and planned) The final revision of the HCVS necessary to implement this order Engineering Change Package including qualification methods. Instrumentation and Control description has been loaded on the ePortal; however, there is no change to the closure summary provided in Reference 11 .

Page 7 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 The table below documents the status of the remaining open items and items considered complete with this submittal.

Phase 1 ISE Open Items Item Description Closure Summary Status ISE Phase 1 Open New components related to HCVS operation are Complete with Item No. 9 required to be designed to operate following a this submittal.

seismic event. Most equipment came qualified Make available for or evaluated by the vendor. Some equipment NRG staff audit was purchased as commercial grade (non-safety documentation of a related) and was shake tested in order to prove seismic the components' ability to withstand a bounding qualification seismic event.

evaluation of HCVS Qualification/evaluation documentation provided components. by the vendor, or test results from shake tests were compiled into a single report for HCVS dedicated equipment (Ref. VENRPT-15-000013) with the exception of separate seismic design report for the PCIVs and rupture disc. These reports are available in the ePortal for NRC review.

ISE Phase 1 Open The HCVS is located in the Reactor Building, Complete with Item No. 11 Turbine Building, Auxiliary Control Room , and this submittal.

outside the Reactor Building . Environmental Make available for conditions and impacts are evaluated in detail in NRG staff audit the descriptions of the Engineering Change Package (ECP) . The ECP includes a listing of the components in local conditions each area along with the corresponding (temperature, envi ronmental conditions including temperatu re, radiation and radiation and humidity. The complete listing and humidity) information from the ECP is available on the anticipated during ePortal for NRC review.

ELAP and severe accident for the On November 17, 2016 a teleconference components between Exelon and the NRC was held to (valves, review NMP2 Phase 1 closure of open items. In instrumentation, this call NMP clarified that consistent with NEI sensors, 13-02 Appendix C Section C.8.1 , no further transmitters, environmental qualification of existing indicators, containment parameter monitoring electronics, control instrumentation is required if the instrumentation devices, etc.) is already RG 1.97 qualified.

required for HCVS venting including confirmation that the components Page 8 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 Item Description Closure Summary Status are capable of performing their functions during ELAP and severe accident conditions.

Phase 2 OIP and ISE Open Items Item Description Closure Summary Status Phase 2 OIP Item Deleted (closed to ISE open item number 1 Complete No. 1 below) with this submittal.

Perform radiological evaluation to determine the SAW A flow control point location.

ISE Phase 2 Started Open Item No. 1 Licensee to confirm through analysis the temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment (ISE Section 3.3.2.1)

ISE Phase 2 Started Open Item No. 2 Licensee to evaluate the SAWA equipment and controls, as well as ingress Page 9 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 and egress paths for the expected severe accident conditions (temperature,

humidity, radiation) for the sustained operating period (ISE Section 3.3.2.3).

ISE Phase 2 Started Open Item No. 3 Licensee to demonstrate how instrumentation and equipment being used for SAWA and supporting equipment is capable to perform for the sustained operating period under the expected temperature and radiological conditions (ISE Section 3.3.2.3).

ISE Phase 2 The wetwell vent has been designed and Complete Open Item No. 4 installed to meet NEI 13-02 Rev 1 guidance, with this Licensee to which will ensure that it is adequately sized to submittal.

demonstrate that prevent containment overpressure under severe containment accident conditions.

failure as a result of overpressure The SAWM strategy will ensure that the wetwell can be prevented vent remains functional for the period of without a drywell sustained operation. Nine Mile Point Unit 1 will vent during severe follow the guidance (flow rate and timing) for accident SAWA/SAWM described in BWROG-TP-15-008 conditions (ISE and BWROG-TP-15-011. The wetwell vent will Section 3.3.3). be opened prior to exceeding the PCPL value of 43 PSIG. Therefore, containment over pressurization is prevented without the need for Page 10 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 a drywall vent.

ISE Phase 2 Reference Plant Complete Nine Mile Point U1 Open Item No. 5 with this Licensee to Torus freeboard Total freeboard submittal.

demonstrate how volume is 525,000 1 volume is 862,288 the plant is gallons gallons bounded by the reference plant SAWA flow is 500 SAWA flow is 263 analysis that GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shows the SAWM followed by 100 GPM followed by 54 GPM*

strategy is from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 successful in hours hours making it unlikely that a drywall vent NMP1 has performed a plant specific MAAP is needed (ISE analysis to establish an initial SAWA flow rate Section 3.3.3.1 ). using the above parameters of 263 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed by 54 GPM* from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. The MAAP analysis demonstrates that the plant is bounded by the reference plant analysis and that the SAWM strategy is successful in making it unlikely that a drywall vent is needed to prevent containment failure (N1-MISC-004).

(*Note that 53 GPM was quoted in the OIP but NMP1 will use 54 GPM in its procedures consistent with the flowrate used in MAAP) 1 Peach Bottom available freeboard volume in gallons is estimated from nominal water level of 14. 7 feet to 21 feet.

21 feet is the upper range of the wide range torus level instrument and the assumed loss of wetwell vent function.

The Peach Bottom torus is 31 feet in diameter.

ISE Phase 2 NMP1 utilizes the installed sound powered Complete Open Item No. 6 headset system and/or the 450 MHz radios in with this the talk around mode to communicate between submittal.

Licensee to demonstrate that the MCR and the SAWA flow control location.

This communication method is the same as there is adequate accepted in Order EA-12-049. These items will communication be powered and remain powered using the same between the MCR methods as evaluated under EA-12-049 for the and the operator period of sustained operation, which may be at the FLEX longer than identified for EA-12-049.

manual valve durinQ severe Page 11 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 accident conditions (ISE Section 3.3.3.4).

ISE Phase 2 Started Open Item No. 7 Licensee to demonstrate the SAWMflow instrumentation qualification for the expected environmental conditions (ISE Section 3.3.3.4).

7 Interim Staff Evaluation (ISE) Impacts There are no new ISE impacts that are in addition to those already described in the Fifth Six-Month status report. Refer to the Reference 11 Six-month status report for the previously described ISE impacts.

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

1. Nine Mile Point Unit 1's 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 27, 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," Revision 1, dated April 2015.
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. 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).

Page 12 of 13

Nine Mile Point Nuclear Station, Unit 1 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2

6. NRG Interim Staff Evaluation "Nine Mile Point Nuclear Station, Unit 1 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO. MF4481)", dated March 26, 2015.
7. Nine Mile Point Unit 1's Combined Phases 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 15, 2015.
8. NRG 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).

9. Nine Mile Point's Fourth Six-Month Status Report Update for Phases 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 June 30, 2016.
10. NRG Interim Staff Evaluation "Nine Mile Point Nuclear Station, Unit 1 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO. MF4481)", dated August 30, 2016.
11. Nine Mile Point's Fifth Six-Month Status Report Update for Phases 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 14, 2016 (RS-16-236).

Page 13 of 13

Enclosure 2 Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (9 pages)

Page 1 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 1 Introduction Nine Mile Point Unit 2 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 six month status report updates the milestone accomplishments based on the combined Phases 1 and 2 Overall Integrated Plan dated December 15, 2015 and last updated on December 14, 2016 (Reference 12).

Nine Mile Point Unit 2 developed an updated and combined Phases 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 Phases 1 and 2 Overall Integrated Plan and the last six month update, 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 last six-month update was submitted under Reference 12, and are current as of June 1, 2017.

  • Sixth Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to the Part 5 Milestone Schedule of 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.

NMP2 - Phase 1 Specific Milestone Schedule Target Activity Comments Milestone Completion Status Date Hold preliminary/conceptual design meeting November Complete 2013 Submit Overall Integrated Implementation June 2014 Complete Page 2 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 Plan Submit 6 Month Status Report December Complete 2014 Design Engineering Complete March 2015 Complete Submit 6 Month Status Report June 2015 Complete Operations Procedure Changes Developed December Complete 2015 Submit 6 Month Status Report December Complete Simultaneous with 2015 Phase 2 OIP Training Complete February Complete 2016 NMP2 Implementation Outage April 2016 Complete Procedure Changes Active April 2016 Complete Walk Through Demonstration/Functional Test April 2016 Complete Submit Fourth 6-Month Status Report June 2016 Complete Submit Completion Report June 2018 Not Started NMP2 - Phase 2 Specific Milestone Schedule Target Activity Comments Milestone Completion Status Date Submit Overall Integrated Implementation December Complete Plan 2015 Hold preliminary/conceptual design meeting January Complete 2016 Submit 6 Month Status Report June 2016 Complete Submit 6 Month Status Report December Complete 2016 Design Engineering On-site/Complete September Started Changed from 2017 March 2017 Submit 6 Month Status Report June 2017 Complete with this submittal Operations Procedure Changes Developed December Not 2017 Started Page 3 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 Site Specific Maintenance Procedure December Not Developed 2017 Started Submit 6 Month Status Report December Not 2017 Started Training Complete February Not 2018 Started Implementation Outage April 2018 Not Started Procedure Changes Active April 2018 Not Started Walk Through Demonstration/Functional Test April 2018 Not Started Submit Completion Report June 2018 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phases 1 and 2 Overall Integrated Plan (Reference 7).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Nine Mile Point Unit 2 complied with the Phase 1 order implementation date and expects to comply with the Phase 2 order implementation date and no relief/relaxation is required at this time.

6 Open Items from Combined Phases 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phases 1 and 2 Overall Integrated Plan, the Reference 6 Interim Staff Evaluation (ISE) for Phase 1, and the Reference 11 ISE for Phase 2 and the status of each item. Phase 1 open item responses were discussed with the NRC on November 17, 2016, and all items were adequately addressed and resolved . All additional information has been provided, and the Phase 1 open items are considered closed based on NRC review.

Phase 1 Open Items from OIP Status OIP Phase 1 Open Item No. 1 Deleted (closed to ISE open item number 8 below)

OIP Phase 1 Open Item No. 2 Deleted (closed to ISE open item number 3 below)

OIP Phase 1 Open Item No. 3 Deleted (closed to ISE open item number 9 below)

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Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 OIP Phase 1 Open Item No. 4 Deleted (closed to ISE open item number 2 below)

OIP Phase 1 Open Item No. 5 Deleted (closed to ISE open item number 4 below)

OIP Phase 1 Open Item No. 6 Deleted (closed to ISE open item numbers 10 and 12 below)

OIP Phase 1 Open Item No. 7 Deleted (closed to ISE open item number 7 below)

OIP Phase 1 Open Item No. 8 Deleted (closed to ISE open item number 7 below)

OIP Phase 1 Open Item No. 9 Submitted for closure in Reference 10 ISE Phase 1 Open Items Status ISE Phase 1 Open Item No. 1 Submitted for closure in Reference 10 ISE Phase 1 Open Item No. 2 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 3 Submitted for closure in Reference 10 ISE Phase 1 Open Item No. 4 Submitted for Closure in Reference 7.

June 2017 Update:

A minor revision to calculation A 10.1-P-053 has been added to the ePortal; however, there is no change to the closure summary provided in Reference 7.

ISE Phase 1 Open Item No. 5 Submitted for closure in Reference 10 ISE Phase 1 Open Item No. 6 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 7 Submitted for closure in Reference 10 ISE Phase 1 Open Item No. 8 Submitted for closure in Reference 10 ISE Phase 1 Open Item No. 9 Submitted for Closure in Page 5 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 Reference 7 ISE Phase 1 Open Item No. 10 Submitted for closure in Reference 10.

June 2017 Update: A final revision of VENRPT-15-000013 and the seismic reports for PCIVs have been uploaded to ePortal; however, there is no change to the closure summary provided in Reference 10.

ISE Phase 1 Open Item No. 11 Submitted for closure in Reference 10 and updated in Reference 12.

ISE Phase 1 Open Item No. 12 Submitted for closure in Reference 10.

ISE Phase 1 Open Item No. 13 Submitted for closure in Reference 10 The table below documents the status of the remaining open items and items considered complete with this submittal.

Phase 2 OIP and ISE Open Items Item Description Closure Summary Status OIP Phase 2 Started Open Item No. 1 Perform rad iological evaluation to determine feasibility of reactor building actions.

ISE Phase 2 Reference Plant Nine Mile Point U2 Complete with Open Item No. 1 Torus freeboard Total free board this submittal.

Licensee to volume is 525,000 1 volume is 782,000 provide the site- gallons gallons specific MAAP SAWA flow is 500 SAWA flow is 300 evaluation that GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> establishes the followed by 100 followed by 100 initial SAWA flow GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> GPM from 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> rate (ISE Section to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> Page 6 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 3.3.2.2) NMP2 has performed a plant specific MAAP analysis to establish an initial SAWA flow rate using the above parameters of 300 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed by 100 GPM from 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. The MAAP analysis demonstrates that the plant is bounded by the reference plant analysis and that the SAWM strategy is successful in making it unlikely that a drywell vent is needed to prevent containment failure (N2-MISC-003 Rev 2). The MAAP analysis is loaded on the ePortal for NRC review.

1 Peach Bottom available freeboard volume in gallons is estimated from nominal water level of 14.7 feet to 21 feet. 21 feet is the upper range of the wide range torus level instrument and the assumed loss of wetwell vent function . The Peach Bottom torus is 31 feet in diameter.

ISE Phase 2 The wetwell vent has been designed and Complete with Open Item No. 2 installed to meet NEI 13-02 Rev 1 guidance, this submittal.

which will ensure that it is adequately sized to Licensee to prevent containment overpressure under demonstrate that severe accident conditions.

containment failure as a result The SAWM strategy will ensure that the of overpressure wetwell vent remains functional for the period can be prevented of sustained operation . Nine Mile Point Unit 2 without a drywell will follow the guidance (flow rate and timing) vent during severe for SAWA/SAWM described in BWROG-TP-accident 15-008 and BWROG-TP-15-011 . The wetwell conditions (ISE vent will be opened prior to exceeding the Section 3.3.3) . PCPL value of 45 PSIG . Therefore, containment over pressurization is prevented without the need for a drywell vent.

ISE Phase 2 NMP2 utilizes the installed sound powered Complete with Open Item No. 3 headset system and/or the 450 MHz radios in this submittal.

the talk around mode to communicate Licensee to between the MCA and the SAWA flow control demonstrate that location. This communication method is the there is adequate same as accepted in Order EA-12-049.

communication These items will be powered and remain between the MCA powered using the same methods as and the operator evaluated under EA-12-049 for the period of at the FLEX sustained operation , which may be longer manual valve than identified for EA-12-049 .

during severe accident Page 7 of 9

Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2 conditions (ISE Section 3.3.3.4).

ISE Phase 2 Started Open Item No. 4 Licensee to demonstrate the SAWM flow instrumentation qualification for the expected environmental conditions (ISE Section 3.3.3.4).

7 Interim Staff Evaluation Impacts There are no new ISE impacts that are in addition to those already described in the Fifth Six-Month status report. Refer to the Reference 12 Six-month status report for the previously described ISE impacts.

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

1. Nine Mile Point Unit 2's 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 27, 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," Revision 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).

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Nine Mile Point Nuclear Station, Unit 2 Sixth Six-Month Status Report for Implementation of HCVS Phases 1 and 2

6. NRC Interim Staff Evaluation "Nine Mile Point Nuclear Station, Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO.

MF4482)", dated February 11, 2015.

7. Nine Mile Point Unit 2'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 15, 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).

9. Letter from M.G. Korsnick (CENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013.
10. Nine Mile Point's Fourth Six-Month Status Report Update for Phases 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 June 30, 2016.
11. NRC Interim Staff Evaluation "Nine Mile Point Nuclear Station, Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO.

MF4482)", dated August 25, 2016.

12. Nine Mile Point's Fifth Six-Month Status Report Update for Phases 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 14, 2016 (RS-16-236).

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