RS-18-001, Report of Full Compliance with Phase 1 and Phase 2 of 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)
| ML18005A636 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/05/2018 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, RS-18-001 | |
| Download: ML18005A636 (11) | |
Text
Exelon Generation..
RS-18-001 January 5, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278 Order No. EA-13-109
Subject:
Report of Full Compliance with Phase 1 and Phase 2 of 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. 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
- 3. NRC Interim Staff Guidance JLD-ISG-2015-01, "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 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 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, 2014 (RS-14-062)
- 6. 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 19, 2014 (RS-14-305)
- 7. 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-15-151)
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 2
- 8. 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-15-303)
- 9. 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-16-109)
- 10. 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 15, 2016 (RS-16-235)
- 11. Exelon Generation Company, LLC 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), dated June 30, 2017 (RS-17-068)
- 12. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos.
MF4416 and MF4417), dated February 12, 2015
- 13. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos.
MF4416 and MF4417), dated August 2, 2016
- 14. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRG Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated November 30, 2017 On June 6, 2013, the Nuclear Regulatory Commission ("NRG" or "Commission") issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," (Reference 1) to Exelon Generation Company, LLC (EGC). 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 2 provided EGC's initial answer to the Order.
Reference 3 provided the NRG interim staff guidance on methodologies for compliance with Phases 1 and 2 of Reference 1 and endorsed industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions. Reference 5 provided the Peach
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 3 Bottom Atomic Power Station, Unit 3 Phase 1 Overall Integrated Plan (OIP), which was replaced with the Phase 1 (Updated) and Phase 2 OIP (Reference 8). References 12 and 13 provided the NRC review of the Phase 1 and Phase 2 OIP, respectively, in an Interim Staff Evaluation (ISE).
Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 6, 7, 8, 9, 10, and 11 provided the first, second, third, fourth, fifth, and sixth six-month status reports, respectively, pursuant to Section IV, Condition D.3, of Reference 1 for Peach Bottom Atomic Power Station, Unit 3.
The purpose of this letter is to provide the report of full compliance with Phase 1 and Phase 2 of the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) (Reference 1) pursuant to Section IV, Condition D.4 of the Order for Peach Bottom Atomic Power Station, Unit 3.
Peach Bottom Atomic Power Station, Unit 3 has designed and installed a venting system that provides venting capability from the wetwell during severe accident conditions in response to Phase 1 of NRC Order EA-13-109. Peach Bottom Atomic Power Station, Unit 3 has implemented a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywell before alternative reliable containment heat removal and pressure control is reestablished in response to Phase 2 of NRC Order EA-13-109. The information provided herein documents full compliance for Peach Bottom Atomic Power Station, Unit 3 with NRC Order EA-13-109.
Peach Bottom Atomic Power Station, Unit 3 Phase 1 OIP Open Items have been addressed and closed as documented in Reference 10, and are considered complete per Reference 14.
It is noted that there were no Phase 2 OIP Open Items.
EGC's response to the NRC Interim Staff Evaluation (ISE) Phase 1 Open Items identified in Reference 12 have been addressed and closed as documented in Reference 10, and are considered complete per Reference 14. The following table provides completion references for each OIP and ISE Phase 1 Open Item.
Reference 14 provided the results of the audit of ISE Open Item closure information provided in References 1 O and 11. All Phase 1 and 2 ISE Open Items are statused as closed in Reference
- 14.
OIP Phase 1 Open Item No. 1 Deleted (Closed to ISE Open Item No. 9 below)
Confirm that the Remote Operating Station (ROS) will be in an accessible area following a Severe Accident (SA).
OIP Phase 1 Open Item No. 2 Deleted (Closed to ISE Open Item No. 1 below)
Provide procedures for HCVS Operation.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 4 OIP Phase 1 Open Item No. 3 Identify site specific controlling document for HCVS out of service and compensatory measures.
OIP Phase 1 Open Item No. 4 Determine the approach for combustible gases.
OIP Phase 1 Open Item No. 5 Perform radiological evaluation for Phase 1 vent line impact on ERO response actions.
ISE Phase 1 Open Item No. 1 Make available for NRC staff audit guidelines and procedures for HCVS operation. (Section 3.2.3.1)
ISE Phase 1 Open Item No. 2 Make available for the NRC staff audit the site specific controlling document for HCVS out of service and compensatory measures. (Section 3.4.1)
ISE Phase 1 Open Item No. 3 Make available for NRC staff audit a technical justification for use of jumpers in the HCVS strategy.
(Section 3.1.3)
ISE Phase 1 Open Item No. 4 Make available for NRC staff audit analyses demonstrating that the HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit. (Sections 3.2.2.1 and 3.2.2.2)
ISE Phase 1 Open Item No. 5 Make available for NRC staff audit descriptions or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee justification for the HVAC release point being below and 150 feet from the reactor building ventilation release point.
(Section 3.2.2.3)
Deleted (Closed to ISE Open Item No. 2 below)
Deleted (Closed to ISE Open Item No. 8 below)
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 5 ISE Phase 1 Open Item No. 6 Make available for NRG staff audit details to justify the deviation from tornado protection standards provided in NEI 13-02 or make available a description of how the HGVS will comply with the tornado protection standards provided in NEl-13-02. (Section 3.2.2.3)
ISE Phase 1 Open Item No. 7 Make available for NRG staff audit documentation that demonstrates adequate communication between the remote HGVS operation locations and HGVS decision makers during ELAP and severe accident condition.
(Section 3.2.2.5)
ISE Phase 1 Open Item No. 8 Provide a description of the final design of the HGVS to address hydrogen detonation and deflagration. (Section 3.2.2.6)
ISE Phase 1 Open Item No. 9 Make available for NRG staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. (Sections 3.2.1, 3.2.2.3, 3.2.2.4, 3.2.2.5, 3.2.2.1 O, 3.2.4.1, 3.2.4.2, 3.2.5.2, and 3.2.6)
ISE Phase 1 Open Item No. 10 Make available for NRG staff audit descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods. (Sections 3.2.2.9 and 3.2.2.10)
ISE Phase 1 Open Item No. 11 Make available for NRG staff audit the final sizing evaluation for HGVS batteries/battery charger including incorporation into FLEX DG loading calculation.
(Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 3.2.4.2, 3.2.5.1, 3.2.5.2, and 3.2.6)
ISE Phase 1 Open Item No. 12 Make available for NRG staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.)
required for HGVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions. (Sections 3.2.2.3, 3.2.2.5, 3.2.2.9, and 3.2.2.10)
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 6 ISE Phase 1 Open Item No. 13 Make available for NRG staff audit documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HGVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)
ISE Phase 1 Open Item No. 14 Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings. (Section 3.2.2.6 and 3.2.2.7)
ISE Phase 1 Open Item No. 15 Make available for NRG audit documentation confirming that HGVS will remain isolated from standby gas treatment system during ELAP and severe accident conditions. (Section 3.2.2.7)
Closed per References 10 and 14.
Closed per References 10 and 14.
Closed per References 10 and 14.
EGC's response to the NRC ISE Phase 2 Open Items identified in Reference 13 have been addressed and closed as documented in Reference 11, and are considered complete per Reference 14. The following table provides completion references for each ISE Phase 2 Open Item.
ISE Phase 2 Open Item No. 1 Closed per References 11 and 14 utilizing BWROG generic response Licensee to demonstrate the SAWA equipment template.
and controls, as well as ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) remain operational throughout the sustained operating period. (Section 3.3.2.3)
ISE Phase 2 Open Item No. 2 Closed per References 11 and 14 utilizing BWROG generic response Licensee to demonstrate that instrumentation template.
and equipment being used for SAWA and supporting equipment is capable to perform for the sustained operating period under the expected temperature and radioloqical conditions. (Section 3.3.2.3)
ISE Phase 2 Open Item No. 3 Closed per References 11 and 14 utilizing BWROG generic response Licensee to demonstrate that containment failure template.
as a result of overpressure can be prevented without a drywell vent during severe accident conditions. (Section 3.3.3)
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 7 ISE Phase 2 Open Item No. 4 Licensee shall demonstrate whether a site specific MAAP evaluation will be used to determine an initial SAWA flow rate. If the evaluations performed in BWROG TP-15-011 is considered, provide a description of how the plant is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed.
(Section 3.3.3.1)
ISE Phase 2 Open Item No. 5 Licensee to demonstrate that there is adequate communication between the MCA and the Intake Structure operator at the FLEX manual valve during severe accident conditions. (Section 3.3.3.4)
ISE Phase 2 Open Item No. 6 Licensee to demonstrate the SAWM flow instrumentation qualification for the expected environmental conditions. (Section 3.3.3.4)
Closed per References 11 and 14 utilizing BWROG generic response template.
Closed per References 11 and 14 utilizing BWROG generic response template.
Closed per References 11 and 14 utilizing BWROG generic response template.
MILESTONE SCHEDULE - ITEMS COMPLETE Peach Bottom Atomic Power Station, Unit 3 - Phases 1 and 2 Specific Milestone Schedule Milestone Target Activity Comments Completion Status Date Submit Phase 1 Overall Integrated Jun.2014 Complete Plan Submit Phase 2 Overall Integrated Dec.2015 Complete Plan Submit 6 Month Updates:
Update 1 Dec.2014 Complete Update 2 Jun.2015 Complete Update 3 Dec.2015 Complete Simultaneous with Phase 2 OIP
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 8 Milestone Target Completion Date Update 4 Jun.2016 Update 5 Dec.2016 Update 6 Jun.2017 Activity Status Complete Complete Complete Phase 1 Specific Milestones Phase 1 Modifications:
Hold preliminary/conceptual Jun.2014 Complete design meeting Unit 3 Design Engineering On-Feb.2017 Complete site/Complete Unit 3 Implementation Outage Nov. 2017 Complete Unit 3 Walk Through Nov. 2017 Complete Demonstration/Functional Test Phase 1 Procedure Changes Operations Procedure Changes Nov. 2017 Complete Developed Site Specific Maintenance Nov. 2017 Complete Procedure Developed Procedure Changes Active Nov. 2017 Complete Phase 1 Training:
Training Complete Nov. 2016 Complete Phase 1 Completion Unit 3 HCVS Implementation Nov. 2017 Complete Phase 2 Specific Milestones Phase 2 Modifications:
Hold preliminary/conceptual design May 2016 Complete meeting Unit 3 Design Engineering On-Jul. 2017 Complete site/Complete Unit 3 Walk Through Nov. 2017 Complete Demonstration/Functional Test Comments
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 9 Milestone Target Completion Date Unit 3 Implementation Outage Nov. 2017 Phase 2 Procedure Changes Operations Procedure Changes Nov. 2017 Developed Site Specific Maintenance Nov. 2017 Procedure Developed Procedure Changes Active Nov. 2017 Phase 2 Training:
Training Complete Nov. 2017 Phase 2 Completion Unit 3 HCVS Implementation Nov.2017 Submit Unit 3 Phases 1 and 2 Jan.2018 Completion Report Activity Status Complete Complete Complete Complete Complete Complete Complete with this submittal.
ORDER EA-13-109 COMPLIANCE ELEMENTS
SUMMARY
Comments The elements identified below for Peach Bottom Atomic Power Station, Unit 3, as well as the Phase 1 (Updated) and Phase 2 OIP response submittal (Reference 8), and the 6-Month Status Reports (References 6, 7, 8, 9, 10, and 11 ), demonstrate compliance with NRC Order EA 109. The Peach Bottom Atomic Power Station, Units 2 and 3 Final Integrated Plan for reliable hardened containment vent Phase 1 and Phase 2 strategies will be provided upon full compliance for Peach Bottom Atomic Power Station, Unit 2 (Fall 2018).
HCVS PHASE 1 AND PHASE 2 FUNCTIONAL REQUIREMENTS AND DESIGN FEATURES-COMPLETE The Peach Bottom Atomic Power Station, Unit 3, Phase 1 HCVS provides a vent path from the wetwell to remove decay heat, vent the containment atmosphere, and control containment pressure within acceptable limits. The Phase 1 HCVS will function for those accident conditions for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 10 active containment heat removal capability during an extended loss of alternating current power.
The Peach Bottom Atomic Power Station, Unit 3, Phase 2 HCVS provides a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywell before alternative reliable containment heat removal and pressure control is reestablished. The Peach Bottom Atomic Power Station, Unit 3, Phase 2 HCVS strategies implement Severe Accident Water Addition (SAWA) with Severe Accident Water Management (SAWM) as an alternative venting strategy. This strategy consists of the use of the Phase 1 wetwell vent and SAWA hardware to implement a water management strategy that will preserve the wetwell vent path until alternate reliable containment heat removal can be established.
The Peach Bottom Atomic Power Station, Unit 3, Phase 1 and Phase 2 HCVS strategies are in compliance with Order EA-13-109. The modifications required to support the HCVS strategies for Peach Bottom Atomic Power Station, Unit 3 have been fully implemented in accordance with the station processes.
HCVS PHASE 1 AND PHASE 2 QUALITY STANDARDS - COMPLETE The design and operational considerations of the Phase 1 and Phase 2 HCVS installed at Peach Bottom Atomic Power Station, Unit 3 complies with the requirements specified in the Order and described in NEI 13-02, Revision 1, "Industry Guidance for Compliance with Order EA-13-109". The Phase 1 and Phase 2 HCVS has been installed in accordance with the station design control process.
The Phase 1 and Phase 2 HCVS components including piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication have been designed consistent with the design basis of the plant. All other Phase 1 and Phase 2 HCVS components including electrical power supply, valve actuator pneumatic supply and instrumentation have been designed for reliable and rugged performance that is capable of ensuring Phase 1 and Phase 2 HCVS functionality following a seismic event.
HCVS PHASE 1 AND PHASE 2 PROGRAMMATIC FEATURES - COMPLETE Storage of portable equipment for Peach Bottom Atomic Power Station, Unit 3 Phase 1 and Phase 2 HCVS use provides adequate protection from applicable site hazards, and identified paths and deployment areas will be accessible during all modes of operation and during severe accidents, as recommended in NEI 13-02, Revision 1, Section 6.1.2.
Training in the use of the Phase 1 and Phase 2 HCVS for Peach Bottom Atomic Power Station, Unit 3 has been completed in accordance with an accepted training process as recommended in NEI 13-02, Revision 1, Section 6.1.3.
Operating and maintenance procedures for Peach Bottom Atomic Power Station, Unit 3 have been developed and integrated with existing procedures to ensure safe operation
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 January 5, 2018 Page 11 of the Phase 1 and Phase 2 HCVS. Procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the Phase 1 and Phase 2 HCVS is tested and maintained as recommended in NEI 13-02, Revision 1, Sections 5.4 and 6.2.
Peach Bottom Atomic Power Station, Unit 3 has completed validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for HCVS strategies are feasible and may be executed within the constraints identified in the HCVS Phases 1 and 2 01 P for Order EA-13-109 (Reference 8).
Peach Bottom Atomic Power Station, Unit 3 has completed evaluations to confirm accessibility, habitability, staffing sufficiency, and communication capability in accordance with NEI 13-02, Sections 4.2.2 and 4.2.3.
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 5th day of January 2018.
Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc:
Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Project Manager, NRR-Peach Bottom Atomic Power Station Mr. Peter J. Bamford, NRR/JLD/JOMB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. Rajender Auluck, NRR/JLD/JCBB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection S. T. Gray, State of Maryland