ML18081A870
| ML18081A870 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/29/2018 |
| From: | Rajender Auluck Beyond-Design-Basis Engineering Branch |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Lee B | |
| References | |
| CAC MF4384, EPID L-2014-JLD-0046 | |
| Download: ML18081A870 (19) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 29, 2018 Mr. John Dent, Jr.
Vice President-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION- REPORT FOR THE AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO NRC ORDER EA-13-109 TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS (CAC NO. MF4384; EPID L-2014-JLD-0046)
Dear Mr. Dent:
On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," to all Boiling-Water Reactor licensees with Mark I and Mark II primary containments. The order requirements are provided in Attachment 2 to the order and are divided into two parts to allow for a phased approach to implementation. The order required licensees to submit for review overall integrated plans (OIPs) that describe how compliance with the requirements for both phases of Order EA-13-109 will be achieved.
By letter dated June 30, 2014 (ADAMS Accession No. ML14189A415), Nebraska Public Power District (NPPD, the licensee) submitted its Phase 1 OIP for Cooper Nuclear Station (CNS, Cooper). By letters dated December 19, 2014, June 30, 2015, December 21, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 28, 2016, June 19, 2017, and December 21, 2017 (ADAMS Accession Nos. ML14364A154, ML15189A047, ML15364A011, ML16196A058, ML17006A005, ML17177A091, and ML17362A037, respectively), the licensee submitted its 6-month updates to the OIP. The NRC staff reviewed the information provided by the licensee and issued interim staff evaluations
( IS Es) for Phase 1 and Phase 2 of Order EA-13-109 for Cooper by letters dated February 11, 2015 (ADAMS Accession No. ML15006A234), and September 29, 2016 (ADAMS Accession No. ML16266A066), respectively. When developing the ISEs, the staff identified open items where the staff needed additional information to determine whether the licensee's plans would adequately meet the requirements of Order EA-13-109.
The NRC staff is using the audit process described in letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328),
to gain a better understanding of licensee activities as they come into compliance with the order.
As part of the audit process, the staff reviewed the licensee's closeout of the ISE open items.
J. Dent The NRC staff conducted teleconferences with the licensee on July 13, 2017 and March 8, 2018. The enclosed audit report provides a summary of that aspect of the audit.
If you have any questions, please contact me at (301) 415-1025 or by e-mail at Rajender.Auluck@nrc.gov.
Sincerely, Rajender Auluck, Senior Project Manager Beyond-Design-Basis Engineering Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Audit report cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO ORDER EA-13-109 MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 BACKGROUND On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," to all Boiling-Water Reactor (BWR) licensees with Mark I and Mark II primary containments. The order requirements are divided into two parts to allow for a phased approach to implementation.
Phase 1 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a Hardened Containment Vent System (HCVS), using a vent path from the containment wetwell to remove decay heat, vent the containment atmosphere (including steam, hydrogen, carbon monoxide, non-condensable gases, aerosols, and fission products), and control containment pressure within acceptable limits. The HCVS shall be designed for those accident conditions (before and after core damage) for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of active containment heat removal capability or extended loss of alternating current (ac) power {ELAP). The order required all applicable licensees, by June 30, 2014, to submit to the Commission for review an overall integrated plan (OIP) that describes how compliance with the Phase 1 requirements described in Order EA-13-109 will be achieved.
Phase 2 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a system that provides venting capability from the containment drywell under severe accident conditions, or, alternatively, to develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. The order required all applicable licensees, by December 31, 2015, to submit to the Commission for Enclosure
review an OIP that describes how compliance with the Phase 2 requirements described in Order EA-13-109 Attachment 2 will be achieved.
By letter dated June 30, 2014 (ADAMS Accession No. ML14189A415), Nebraska Public Power District (NPPD, the licensee) submitted its Phase 1 OIP for Cooper Nuclear Station (CNS, Cooper). By letters dated December 19, 2014, June 30, 2015, December 21, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 28, 2016, June 19, 2017, and December 21, 2017 (ADAMS Accession Nos. ML14364A154, ML15189A047, ML15364A011, ML16196A058, ML17006A005, ML17177A091, and ML17362A037, respectively), the licensee submitted its 6-month updates to the OIP, as required by the order.
The NRG staff reviewed the information provided by the licensee and issued interim staff evaluations (ISEs) for Phase 1 and Phase 2 of Order EA-13-109 for Cooper by letters dated February 11, 2015 (ADAMS Accession No. ML15006A234), and September 29, 2016 (ADAMS Accession No. ML16266A066), respectively. When developing the ISEs, the staff identified open items where the staff needed additional information to determine whether the licensee's plans would adequately meet the requirements of Order EA-13-109.
The NRG staff is using the audit process in accordance with the letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328), to gain a better understanding of licensee activities as they come into compliance with the order. The staff reviews submitted information, licensee documents (via ePortals), and preliminary Overall Program Documents (OPDs)/OIPs, while identifying areas where additional information is needed. As part of this process, the staff reviewed the licensee closeout of the ISE open items.
AUDIT
SUMMARY
As part of the audit, the NRG staff conducted teleconferences with the licensee on July 13, 2017 and March 8, 2018. The purpose of these audit teleconferences was to continue the audit review and provide the NRG staff the opportunity to engage with the licensee regarding the closure of open items from the ISEs. As part of the preparation for these audit calls, the staff reviewed the information and/or references noted in the OIP updates to ensure that closure of ISE open items and the HCVS design are consistent with the guidance provided in Nuclear Energy Institute (NEI) 13-02, Revision 1 and related documents (e.g. white papers (ADAMS Accession Nos. ML14126A374, ML14358A040, ML15040A038 and ML15240A072, respectively) and frequently asked questions (FAQs), (ADAMS Accession No. ML15271A148))
that were developed and reviewed as part of overall guidance development. The NRG staff audit members are listed in Table 1. Table 2 is a list of documents reviewed by the staff. Table 3 provides the status of the ISE open item closeout for Cooper. The open items are taken from the Phase 1 and Phase 2 ISEs issued on February 11, 2015, and September 29, 2016, respectively.
FOLLOW UP ACTIVITY The staff continues to audit the licensee's information as it becomes available. The staff will issue further audit reports for Cooper, as appropriate.
Following the licensee's declarations of order compliance, the licensee will provide a final integrated plan (FIP) that describes how the order requirements are met. The NRG staff will
evaluate the FIPs, the resulting site-specific OPDs, as appropriate, and other licensee documents, prior to making a safety determination regarding order compliance.
CONCLUSION This audit report documents the staff's understanding of the licensee's closeout of the ISE open items, based on the documents discussed above. The staff notes that several of these documents are still preliminary, and all documents are subject to change in accordance with the licensee's design process. In summary, the staff has no further questions on how the licensee has addressed the ISE open items, based on the preliminary information. The status of the NRG staff's review of these open items may change if the licensee changes its plans as part of final implementation. Changes in the NRG staff review will be communicated in the ongoing audit process.
Attachments:
- 1. Table 1 - NRG Staff Audit and Teleconference Participants
- 2. Table 2 -Audit Documents Reviewed
- 3. Table 3- ISE Open Item Status Table
Table 1 - NRC Staff Audit and Teleconference Participants Title Team Member Oraanization Team Lead/Sr. Project Manaqer Raiender Auluck NRR/DLP Project Manager Support/Technical Support - Containment/ Ventilation Brian Lee NRR/DLP Technical Support - Containment/
Ventilation Bruce Heida NRR/DLP Technical Support - Electrical Kerby Scales NRR/DLP Technical Support- Balance of Plant Joshua Miller NRR/DLP Technical Suooort- l&C Steve Wyman NRR/DLP Technical Support - Dose John Parillo NRR/DRA Attachment 1
Table 2 - Audit Documents Reviewed Calculation NEDC 15-020, "HCVS Flow Rate and Vent Size," Revision O Calculation NEDC 14-026, "MAAP Analysis to Support Cooper FLEX Strategy," Revision 0 Calculation NEDC 15-028, "Analysis of the HCVS Piping," Revision 1 Calculation NEDC 96-0258, "Review of Advent LCA Calculation 96007TR-41 B, Rev. 1 for PC-MOV-232MV and -233MV," Revision 1C1 Calculation NEDC 95-003, "Determination of Allowable Operating Parameters for CNS MOV Program MOVs," Revision 31C1 Calculation NEDC 00-110, "MOV Program Valve Margin Determination," Revision 10C1 Calculation NEDC 00-065, "Functional and MEDP Evaluation for PC-AOV-237AV," Revision 1C2 Calculation NEDC 05-013, "AOV Component Level Calculation for PC-AOV-237AV," Revision 1C1 Calculation NEDC 15-002, "Review of Tetra Portable Equipment Calculations in support of CNS FLEX Strategy," Revision O Calculation NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS,"
Revision 1 Calculation NEDC 15-047, "HCVS Radiological Source Term," Revision 0 Calculation NEDC 15-023, "Calculation of the Pressure Gradient Across the HCVS Line and HCVS Maximum Operational Temperature," Revision 0 Caclulation NEDC 15-030, "HCVS UPS Sizing Analysis," Revision 1 Calculation NEDC 15-033, "Review of Tetra Tech Calculation CALC-CNS001-194-4933-013 Rev 3," Revision 0 Calculation NEDC 15-025, "Mechanical ROS Civil/Structural Design," Revision O Calculation NEDC 15-026, "Mechanical ROS Nitrogen Calculation," Revision O Calculation NEDC 92-073, "Accumulator Sizing and Recharge Time for PC-237AV and PC-A032," Revision 1 NLS2013028 - "CNS Communications Assessment," Revision 1 Attachment 2
Cooper Nuclear Station Vent Order Interim Staff Evaluation Open Items:
Table 3 - ISE Open Item Status Table ISE Open Item Number Licensee Response - Information NRG Staff Close-out notes Safety Evaluation (SE) provided in 6 month updates and on the status Requested Action ePortal Closed; Pending; Open (need additional information from licensee)
Phase 1 ISE 01 1 Complete. The NRG staff reviewed the Closed information provided in the 6-Make available tor NRG staff 1% of RTP is demonstrated in NEDC 15- month updates and on the [Staff evaluation to be audit analyses demonstrating 020,"Calculation of HCVS Flow Rate and ePortal. included in SE Section that HCVS has the capacity to Vent Size." 3.1.2.1]
vent the steam/energy Calculation NEDC 15-020, "HCVS equivalent of one percent of The MAAP [modular accident analysis Flow Rate and Vent Size,"
licensed/rated thermal power program] Analysis was documented in EC Revision O calculates that the (i.e., unless a lower value is14-027, "Acceptance of MAAP Analysis to mass flow rate required to vent justified), and that the Support Initial FLEX Strategy," which 1% of rated thermal power (RTP) suppression pool and the implements calculation NEDC 14-026, of 2419 MWt is 7.55x104 lbm/hr.
HCVS together are able to "MAAP Analysis to Support Cooper FLEX The calculation further absorb and reject decay heat, Strategy." demonstrates that a 12" diameter such that following a reactor pipe will vent 1% RTP flow rate at shutdown from full power 20.3 psig and will have 105,000 containment pressure is lbm/hr margin at 56 psig restored and then maintained containment design pressure.
below the primary containment design pressure and the No follow-up questions.
primary containment pressure limit.
Phase 1 ISE 01 2 Complete. The NRG staff reviewed the Closed information provided in the 6-Make available tor NRG staff NEDC 15-028, "Analysis of the HCVS month updates and on the [Staff evaluation to be audit seismic and tornado Piping," performed the pipe stress ePortal. included in SE Section missile final design criteria tor analysis for the HCVS pipe, including the 3.2.2]
the HCVS stack. seismic and tornado wind design analysis. Calculation NEDC 15-028, CED 6036742, Tab 6, Section 6.5.6 (E3 - "Owner Acceptance of TetraTech External Hazard),"E3.4 - Tornado and Calculation CNS001-194-4933-Tornado-Generated Missile," evaluated 009 "Analysis of the HCVS Attachment 3
the tornado missile for the HCVS pipe. Piping" for the Hardened The evaluation was written in the CED Containment Vent System (and not in a calculation), since the vast Project, Revision O" classified majority of the pipe is inside a Class I HCVS as Seismic Class 11/1 and structure analyzed to safe shutdown earthquake forces and operating basis earthquake allowables.
This calclulation uses the AutoPIPE computer program.
Change Evaluation Document (CED) 6036742, "Reliable Hardened Containment Venting System", Tab 6 states that the HCVS is routed through the interior of the Reactor Building from the Torus Room and out through the roof.
No follow up questions.
Phase 1 ISE 01 3 Complete. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff CED 6036742, Section 6.5.14 (12 - month updates and on the [Staff evaluation to be audit descriptions of all Instrumentation & Control (l&C)) ePortal. included in SE Section instrumentation and controls describes the instrumentation and 3.1.2.8]
(i.e., existing and planned) controls (existing and planned) necessary CED 6036742, TAB 6, including necessary to implement this to implement this Order. The majority of Sections 6.5.8 and 6.5.14 and order including qualification the equipment for the HCVS is non- Tables 6-1 O and 6-1 Oa shows that methods. essential. Environmental Qualification is the radiation qualification appears limited to those components in the to be in order for all the electrical system that interface with and instruments. The temperature provide isolation between Class 1 E and appears reasonable. Most non-Class 1 E circuits. temperatures are under 70 degrees Celsius. The licensee clarified the comment regarding elements that require qualification. They are referring specifically to isolation switches tied to 1 E systems. They are referring to qualification for the
regular operating licensing basis because these impact 1E. They appear to be still in the process to address the necessary "meets environmental conditions" review for the remaining HCVS order related items. Critical channels of wetwell level and containment pressure are Regulatory Guide (RG) 1.97 variables and are accepted based on the existing RG 1.97 qualification.
The staff's review indicates that the l&C components are consistent with the guidance in NEI 13-02 and its qualifications meet the order requirements.
No follow-up questions.
Phase 1 ISE 01 4 Complete. The N RC staff reviewed the Closed information provided in the 6-Make available for NRC staff CED 6036742,Tab 4, Section 4.2.1.3 month updates and on the [Staff evaluation to be audit a determination of the ("Control Valve PC-AOV-A032, ePortal. included in SE Section number of required valve Accumulator IA-ACC-A032, and new 3.1.2.6]
cycles during the first 24 Pressure Switch IA-PS04") determines 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. valve cycles during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on NEI White Paper HCVS-WP-02 No follow-up questions.
and the MAAP analysis results (EC 14-027,"Acceptance of MAAP Analysis to Support Initial FLEX Strategy" and NEDC 74-026, "MAPP Analysis to Support Cooper FLEX Strategy"). CED 6036742, Tab 6, Section 6.5.5 (82 - Environmental Features), states that NEDC 92-073, "Accumulator Sizing and Recharge Time for PC-237AV and PC-A032," performs the calculation that sizes the accumulators, and accounts for leakage for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Phase 1 ISE 01 5 Complete. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC audit The out-of-service time criteria for HCVS month updates and on the [Staff evaluation to be the control document for will be maintained in the Technical ePortal. included in SE)Section HCVS out of service time Requirements Manual. 3.1.2.13]
criteria. The Technical Requirements Manual contains the HCVS out of service time criteria, which is consistent with the guidance in NEI 13-02.
No follow-up questions.
Phase 1 ISE 01 6 Complete. The NRC staff reviewed the Closed information provided in the 6-Make available for N RC staff The HCVS operational temperature has month updates and on the [Staff evaluation to be to audit, an evaluation been updated to 310°F per NEDC 15-023, ePortal. included in SE Section verifying the existing "Owner Acceptance of TetraTech 3.2.1]
containment isolation valves, Calculation CNS001-194-4933-004 - The NRC staff reviewed the relied upon for the HCVS, will Calculation of the Pressure Gradient various AOV and MOV open under the maximum Across the HCVS Line and HCVS calculations and verified in each expected differential pressure Maximum Operation Temperature." case that the actuator can during severe accident wetwell Change Notice #28 to CED 60367 42, develop greater torque than venting. "Reliable Hardened Containment Venting Primary Containment Isolation System, " authorized corresponding Valves unseating torque.
changes to the following air operated valve (AOV) and motor operated valve No follow-up questions.
(MOV) related calculations to address HCVS flow rate and temperature increase:
- NEDC 91-242, "Review of ERIN's System Level Design Basis Review for the Primary Containment System MOV's,"
Revision 2C 1
- NEDC 96-0258, "Review of ADVENT LCA Calculation 96007TR-41 B, Rev. 1 for
PCMOV-232MV and -233MV,"
Revision 1C 1
- NEDC 95-003, "Determination of Allowable Operating Parameters for CNS MOV Program MOVs,"
Revision 31 C1
- NEDC 00-110, "MOV Program Valve Margin Determination,"
Revision 1OC1
- NEDC 00-065, "Functional and MEDP Evaluation for PC-AOY -
237 AV," Revision 1C2 NEDC 05-013, "AOV Component Level Calculation for PC-AOV -237 AV,"
Revision 1C1 Phase 1 ISE 01 7 Complete The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff The Main Control Room (MGR) is the month updates and on the [Staff evaluation to be audit documentation that normal monitoring and operating location ePortal. included in SE Section demonstrates adequate for HCVS. The Mechanical ROS has the 3.1.1.1]
communication between the capability to operate the HCVS if needed. The communication methods are remote HCVS operation Hand held radios will be used for the same as accepted in Order locations and the HCVS communications between the MGR and EA-12-049.
decision makers during ELAP ROS.
and severe accident No follow-up questions.
conditions. The communications assessment performed in response to Near Term Task Force Recommendation 9.3 (NLS2013028) documented the acceptability of this communications channel.
Phase 1 ISE 01 8 Complete. The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff CED 6036742,Tab 6, Section 6.5.5 (E2 - month updates and on the [Staff evaluation to be audit an evaluation of Environmental Features), discusses the ePortal. included in SE Sections temperature and radiological temperature and radiological conditions, 3.1.1 .2 and 3.1.1.31
conditions to ensure that as well as CED 6036742,Tab 6, Section Main Control Room temperatures operating personnel can safely 6.5.7 (E4 - Emergency Preparedness, have been addressed as part of access and operate controls Planning and Response). the FLEX order and were found to and support equipment. acceptable by the NRC staff.
NEDC 15-002, "Review of Tetra Tech Portable Equipment Calculations in No calculations were identified support of CNS FLEX Strategy," related to evaluation of calculates the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up environmental conditions for the temperature profile in the Reactor mechanical remote operating Building and Control Building during an station (MROS). During the audit ELAP. call, the licensee indicated that the M ROS is open to the The site-specific radiological conditions atmosphere. The temperature for the HCVS are evaluated in NEDC 15- will be ambient conditions. The 024, "Radiological Conditions Resulting licensee does have cold weather from the Operation of the HCVS," based gear available for operators, if on the bounding CNS -specific in- needed.
containment source term during the first seven days following an ELAP (NEDC 15- Calculation NEDC 15-024 047, "HCVS Radiological Source Term"). evaluates the radiological conditions in areas where operators are needed for HCVS operation. Radiological conditions result in low operator dose.
Based on the these evaluations, the temperature and radiological conditions should not inhibit operator actions needed to initiate and operate the HCVS during an ELAP with severe accident conditions.
No follow-up questions.
Phase 1 ISE 01 9 Complete. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff CED 6036742, Tab 6, Section 6.5.4 (El - month updates and on the [Staff evaluation to be audit the final sizing evaluation Electrical Features), discusses the ePortal. included in SE Section for HCVS batteries/Batterv electrical power requirements and sizing. 3.1.2.61
charger including incorporation NEDC 15-030, "HCVS UPS Inverter, The licensee stated that all into FLEX DG loading Battery, and Battery Charger Sizing electrical power required for calculation. Analysis," documents the load and sizing operation of HCVS components is analysis for the Hardened Containment provided by the HCVS Venting System Uninterruptable Power batteries/battery chargers.
Supply (HCVS UPS) and distribution panel. The HCVS UPS inverter, battery, and battery charger sizing NEDC 15-033, "HCVS PC233MV UPS calculation (NEDC 15-030)
Sizing Analysis," documents the size of confirmed that the HCVS the UPS for PC-MOV-233MV, which is batteries have a minimum located near MCC-RA on RB elevation capacity capable of providing 958'-3". power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without recharging, and therefore is The FLEX diesel generator (DG) is adequate.
discussed in: CED 6036742,Tab 4, Section 4.4.3.1 HCVS UPS; CED The licensee provided CED 6036742,Tab 6, Section 6.5.14 (12 - 6037041 , which discusses re-Instrumentation & Control (l&C), 12.3 powering of the HCVS UPS using (System/Controls); and CED a FLEX DG.
6036142,Tab 6, Section 6.5.26 (S3 -
System Interfaces). The hardened vent No follow-up questions.
modification (CED 6036742) interfaces with CED 6037041, "FLEX Electrical Connections," with respect to the use of the FLEX DG (per Tab 11) to power the HCVS UPS after the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event.
Phase 1 ISE 01 10 Complete. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff The nitrogen station is located in the month updates and on the [Staff evaluation to be audit the final sizing evaluation mechanical ROS enclosure. NEDC 15- ePortal. included in SE Section for pneumatic N2 supply. 025, "Mechanical ROS Civil / Structural 3.1.2.6]
Design," documents the MROS design. Calculation NEDC 15-026 The mechanical ROS enclosure is located evaluates the pneumatic design in the yard adjacent to the south wall of and sizing to support the the Reactor Building. operation of HCVS following a beyond design basis external NEDC 15-026, "Mechanical ROS Nitrogen event (BDBEE). The evaluation Calculation," determines the amount of discusses the required number of
nitrogen required to support operation of nitrogen cylinders needed for vent PC-AOV-237AV and PC-AOV-A032 for operation for sustained operation.
operation between 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 7 days The number of nitrogen cylinders following a beyond design basis external installed and available is sufficient event (BDBEE). to operate the HCVS for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as well as 7 days following a BDBEE.
No follow-up questions.
Phase 1 ISE 01 11 Complete. The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff CED 6036742, Tab 6, Section 6.5.5 (E2 - month updates and on the [Staff evaluation to be audit the descriptions of local Environmental Features), provides a ePortal. included in SE Section conditions (temperature, description of the local conditions 3.1.1.4]
radiation and humidity) (temperature, radiation, and humidity) for Calculation CED 6036742 anticipated during ELAP and the HCVS components. discusses the environmental severe accident for the conditions during an accident at components (valves, NEDC 15-002, "Review of Tetra Tech the locations containing l&C instrumentation, sensors, Portable Equipment Calculations in components. The staff's review transmitters, indicators, support of CNS FLEX Strategy," indicated that the environmental electronics, control devices, calculates the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up qualification met the order and etc.) required for HCVS temperature profile in the Reactor requirements.
venting including confirmation Building and Control Building during an that the components are ELAP. No follow-up questions.
capable of performing their functions during ELAP and The site-specific radiological conditions severe accident conditions. for the HCVS are evaluated in NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS," based on the bounding CNS-specific in containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").
NEDC 15-023, "Calculation of the Pressure Gradient Across the HCVS Line and HCVS Maximum Operational Temperature," determines the HCVS pressure and temperature conditions for the HCVS pipe.
Phaes 2 ISE 01 1 Complete. The NRC staff reviewed the Closed information provided in the 6-Licensee to demonstrate that ER 1252, "NRC Order EA-13-109 Phase month updates and on the [Staff evaluation to be containment failure as a result 2 Reliable Hardened Containment Vent ePortal. included in SE Section of overpressure can be Engineering Study," evaluated Phase 2 4.2]
prevented without a drywell Order requirements. In this ER, CNS The N RC staff reviewed vent during severe accident referred to the MAAP analysis that was Engineering Study ER-1252 conditions. performed for the reference Mark I plant Revision 1, "NRC Order EA (Peach Bottom). An evaluation of the 109 Phase 2 Reliable Hardened plant parameters between CNS and Containment Vent Engineering Peach Bottom was performed to ensure Study". SAWA provides cooling that the MAAP analysis for Peach Bottom of core debris limiting the drywall would be a bounding evaluation for CNS temperature. SAWA permits and confirms that the Severe Accident venting containment through the Water Addition/Severe Accident Water wetwell vent without the necessity Management strategy endorsed by the of having a drywall vent (see nuclear industry (NRC, Nuclear Energy discussion for Phase 1 ISE 1 for Institute and Boiling Water Reactor wetwell vent capacity). SAWM Owner's Group) would preserve the use manages the water addition into of a wetwell vent path to ensure the wetwell such that the wetwell containment integrity. vent does not become blocked by the water level and remains Calculation NEDC 15-020, "Owner operational. SAWA and SAWM Acceptance of Tetra Tech Calculation related industry study was based CNSOOI -1 94-4933-001 r - Calculation of on a reference plant which has HCVS Flow Rate and Vent Size," the most limiting containment performs the analysis to ensure that the heat capacity in the U.S. fleet and wetwell vent can achieve the required therefore is conservative.
capacity to vent the steam/energy equivalent of 1% of the licensed/rated No follow-up questions.
thermal power.
Phase 2 ISE 01 2 Complete. The NRC staff reviewed the Closed information provided in the 6-Licensee to demonstrate that The Main Control Room (MCR) is the month updates and on the [Staff evaluation to be there is adequate normal monitoring and operating location ePortal. included in SE Section communication between the for HCVS. Hand held radios will be used 4.1]
MCR and the operator at the for communications between the MCR The communication methods are FLEX pump during severe and the operator at the FLEX pump. the same as accepted in Order accident conditions. EA-12-049.
Base station repeaters (Base 1 and Base No follow-up questions.
- 2) were upgraded to 24-hour battery life.
Both bases are capable of being powered via FLEX generator and one base station will be powered from a FLEX generator after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The communications assessment performed in response to Near Term Task Force Recommendation 9.3 (NLS2013028) documented the acceptability of this communications channel.
Phae 2 ISE 01 3 Complete. The NRC staff reviewed the Closed Per CNS' Final Integrated Plan for Order information provided in the 6-Licensee to demonstrate the EA-12-049, the following environmental month updates and on the [Staff evaluation to be SAWM flow instrumentation conditions exist: ePortal. included in SE Section qualification for the expected
- Snow, ice, and extreme cold 4.4.1 .3 and 4.5.1.2]
environmental conditions. (minus 5 degrees Fahrenheit) The NRC staff reviewed and
- Extreme heat (97 degrees confirmed the site temperatures Fahrenheit) given in the Cooper FLEX FIP (-5 The severe accident water management to 97 degrees Fahrenheit (°F))
(SAWM) pump that will be used to provide and confirmed the flow meter make-up water for HCVS Phase 2 actions performance in the certificate of is rated for 925 gpm and 378 feet of conformance and calibration from discharge head. As such, the pump's Sure Flow Products, LLC, which maximum discharge pressure is stated accuracy of +/- 2 to 5%
approximately 165 psig. The selected depending on the pressure. The flow meter is normally supplied with manufacturer also stated that polyvinyl chloride (PVC) piping; however, operation to -5 °will not impact for this application, CNS will use accuracy.
chlorinated polyvinyl chloride (CPVC) piping. CPCV material (4-inch diameter, No follow-up questions.
schedule 80) has a pressure rating of approximately 320 psig. However, this pressure rating is reduced when accounting for elevated temperatures. An operating temperature of 100 degrees Fahrenheit has a derating factor of 0.82.
Therefore, the selected CPVC material
has a pressure rating of approximately 260 psig which exceeds the maximum discharge pressure of the SAWM pump.
The selected flow meter has a listed operating ambient temperature range of 0-150 degrees Fahrenheit, although the vendor confirmed that the meter will function and provide accurate readings at the required minus 5 degrees Fahrenheit.
Additionally, the selected flow meter is listed for applications such as lake or river water, potable water, deionized water, etc. These types of fluids meet the applications that CNS may be pumping through the flow meter.
ML18081A870 OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA NRR/DLP/PBEB/BC (A) NRR/DLP/PBEB/PM NAME RAuluck SLent TBrown RAuluck DATE 3/29/18 3/28/18 3/29/18 3/29/18