NL-18-0200, Unit 1, Completion of Required Action for NRC Order EA-13-109 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Unit 1, Completion of Required Action for NRC Order EA-13-109 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

ML18102B148
Person / Time
Site:	Hatch
Issue date:	04/12/2018
From:	Wheat J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NL-18-0200
Download: ML18102B148 (11)

Text

~ Southern Nuclear Justin T. Wheat Nuclear Licensing Manager 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5998 tel 205 992 7601 fax APR 1 2 2018 jtwheat@ southernco.com Docket No.: 50-321 NL-18-0200 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant- Unit 1 Completion of Required Action for NRC Order EA-13-109 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109, Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directs the Edwin I. Hatch Nuclear Plant (HNP)- Units 1 and 2 to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. This letter, along with the Enclosure, provides the notification required by Item IV.D.4 of Order EA-13-109 that full compliance (Phase 1 and Phase 2) with the requirements described in Attachment 2 of the Order has been achieved for HNP Unit 1.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments. If you have any questions, please contact Matt Euten at 205.992.7673.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 21~ay of March 2018.

Respectfully submitted,

~.;#8---c~

Justin T. Wheat Nuclear Licensing Manager Southern Nuclear Operating Company JTW/MRE

U.S. Nuclear Regulatory Commission NL-18-0200 Page2

Enclosure:

HNP Unit 1 Compliance with Order EA-13-1 09 cc: Director of the Office of Nuclear Reactor Regulations Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant- Unit 1 Completion of Requir.ed Action for NRC Order EA-13-1 09 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Enclosure HNP Unit 1 Compliance with Order EA-13-109 (8 pages)

Enclosure to N L 0200 HNP Unit 1 Compliance to Order EA-13-109 BACKGROUND On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109, Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Reference 1), to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directs the Edwin I.

Hatch Nuclear Plant (HNP) - Units 1 and 2 to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris (HCVS) in response to Order EA-13-109. SNC developed an Overall Integrated Plan (OIP) (Reference 6) to provide HCVS. The information provided herein, as well as the implementation of the OIP (Phase 1 Reference 5 and Phase 2 in Reference 6), documents full compliance for the HNP Unit 1 in response to the Order (Reference 1).

OPEN ITEM RESOLUTION The Phase 1 and 2 NRC Interim Staff Evaluation (ISE) Open Items (Reference 14 and Reference 15) have been addressed and documented in subsequent Order EA-13-1 09 six-month status reports (References 6 - 12) and are considered complete per Reference 15.

The following table provides completion references for each ISE Phase 1 and 2 Open Item and a summary of the closure action for Open Items not previously completed.

HNP 1 & 2 HCVS Phase 1 ISE Open Items Response 1 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit location of the ROS's call on March 7, 2017. Closure concurrence per Reference 15.

2 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit location of the dedicated HCVS call on March 7, 2017. Closure concurrence per battery transfer switch Reference 15.

3 Make available for NRC staff audit Closed per Reference 10 and verified in NRC Audit documentation of the HCVS nitrogen call on March 7, 2017. Closure concurrence per pneumatic system design including Reference 15.

sizing and location 4 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit deployment location of the portable call on March 7, 2017. Closure concurrence per diesel generators Reference 15.

5 Make available for NRC staff audit an Closed per Reference 10 and verified in NRC Audit evaluation of temperature and call on March 7, 2017. Clarification in Reference radiological conditions to ensure that 11. Closure concurrence per Reference 15.

operating personnel can safely access and operate controls and support equipment E-1

Enclosure to N L-18-0200 HNP Unit 1 Compliance to Order EA-13-109 HNP 1 & 2 HCVS Phase 1 ISE Open Items Response 6 Make available for NRC staff audit Closed per Reference 10 and verified in NRC Audit analyses demonstrating that HCVS call on March 7, 2017. Closure concurrence per has the capacity to vent the Reference 15.

steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit 7 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit descriptions of local conditions call on March 7, 2017. Closure concurrence per (temperature, radiation and humidity) Reference 15.

anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions 8 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit final sizing evaluation for HCVS call on March 7, 2017. Clarification in Reference batteries/battery charger including 11. Closure concurrence per Reference 15.

incorporation into FLEX DG loading calculation 9 Make available for NRC staff audit Closed per Reference 10 and verified in NRC Audit documentation that demonstrates call on March 7, 2017. Closure concurrence per adequate communication between the Reference 15.

remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions 10 Provide a description of the final Closed per Reference 10 and verified in NRC Audit design of the HCVS to address call on March 7, 2017. Closure concurrence per hydrogen detonation and deflagration Reference 15.

11 Provide a description of the strategies Closed per Reference 10 and verified in NRC Audit for hydrogen control that minimizes call on March 7, 2017. Closure concurrence per the potential for hydrogen gas Reference 15.

migration and ingress into the reactor buildin g or other buildings E-2

Enclosure to NL-18-0200 HNP Unit 1 Compliance to Order EA-13-109 HNP 1 & 2 HCVS Phase 1 ISE Open Items Response 12 Make available descriptions of design Closed per Reference 10 and verified in NRC Audit details that minimize unintended cross call on March 7, 2017. Closure concurrence per flow of vented fluids within a unit and Reference 15.

between units 13 Make available for NRC staff audit Closed per Reference 10 and verified in NRC Audit descriptions of all instrumentation and call on March 7, 2017. Closure concurrence per controls (existing and planned) Reference 15.

necessary to implement this order including qualification methods 14 Make available for NRC staff audit Closed per Reference 10 and verified in NRC Audit documentation of an evaluation call on March 7, 2017. Closure concurrence per verifying the existing containment Reference 15.

isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting 15 Make available for NRC staff audit the Closed per Reference 10 and verified in NRC Audit control document for HCVS out of call on March 7, 2017. Closure concurrence per service time criteria Reference 15.

HNP1 & 2 HCVS Phase 2 ISE Open Items Generic Response 1 Licensee to demonstrate that Closed per Reference 10, consistent with the containment failure as a result of BWROG generic closure criteria for Order EA overpressure can be prevented 109 Phase 2 Open Items. Closure concurrence per without a drywall vent during severe Reference 15.

accident conditions Section 3.3.3 2 Licensee shall demonstrate how the Closed per Reference 10, consistent with the plant is bounded by the reference BWROG generic closure criteria for Order EA plant analysis that shows the SAWM 109 Phase 2 Open Items. Closure concurrence per strategy is successful in making it Reference 15.

unlikely that a drywall vent is needed Section 3.3.3.1 3 Licensee to demonstrate that there is Closed per Reference 10, consistent with the adequate communication between the BWROG generic closure criteria for Order EA MCR and the Intake Structure 109 Phase 2 Open Items. Closure concurrence per operator at the FLEX manual valve Reference 15.

during severe accident conditions.

Section 3.3.3.4 E-3

Enclosure to N L-18-0200 HNP Unit 1 Compliance to Order EA-13-109 MILESTONE SCHEDULE

• ITEMS COMPLETE 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 Update 4 Jun.2016 Complete Update 5 Dec.2016 Complete Update 6 Jun.2017 Complete Update 7 Dec.2017 Complete Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual Jun.2014 Complete design meeting Unit 1 Design Engineering On- Feb.2017 Complete site/Complete Unit 1 Implementation Outage Feb.2018 Complete Unit 1 Walk Through Feb.2018 Complete Demonstration/Functional Test Phase 1 Procedure Changes Operations Procedure Changes Dec.2017 Complete Developed Site Specific Maintenance Jan.2017 Complete Procedure Developed Procedure Changes Active Feb.2018 Complete Phase 1 Training:

Training Complete Feb.2018 Complete Phase 1 Completion E-4

Enclosure to NL-18-0200 HNP Unit 1 Compliance to Order EA-13-1 09 Milestone Target Activity Comments Completion Status Date Unit 1 HCVS Implementation Feb.2018 Complete Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual design Apr. 2016 Complete meeting Unit 1 Design Engineering On- Feb.2017 Complete site/Complete Unit 1 Walk Through Feb.2018 Complete Demonstration/Functional Test Unit 1 Implementation Outage Feb.2018 Complete Phase 2 Procedure Changes Operations Procedure Changes Dec.2017 Complete Developed Site Specific Maintenance Dec.2017 Complete Procedure Developed Procedure Changes Active Feb.2018 Complete Phase 2 Training:

Training Complete Feb.2018 Complete Phase 2 Completion Unit 1 HCVS Implementation Feb.2018 Complete Submit Unit 1 Phase 1 and 2 March 2018 Complete Completion Report ORDER EA-13-109 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for HNP Unit 1 as well as the HCVS Phase 1 and Phase 2 OIP (Reference 6), the 6-Month Status Reports (References 6- 12) and additional docketed correspondence, demonstrate compliance with Order EA-13-1 09.

E-5

Enclosure to NL-18-0200 HNP Unit 1 Compliance to Order EA-13-109 HCVS PHASE 1 AND PHASE 2 FUNCTIONAL REQUIREMENTS AND DESIGN FEATURES-COMPLETE The HNP Unit 1, 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 active containment heat removal capability during an extended loss of alternating current power.

The HNP Unit 1, Phase 2 HCVS provides a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywall before alternative reliable containment heat removal and pressure control is reestablished. The HNP Unit 1, 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 HNP Unit 1, Phase 1 and Phase 2 HCVS strategies are in compliance with Order EA-13-109. The modifications required to support the HCVS strategies for HNP Unit 1 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 HNP Unit 1 complies with the requirements specified in the Order and described in NEI 13-02, Revision 1, "Industry Guidance for Compliance with Order EA-13-1 09". 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 HNP Unit 1 Phase 1 and Phase 2 HCVS 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 HNP Unit 1 has been completed in accordance with an accepted training process as recommended in NEI 13-02, Revision 1, Section 6.1.3.

E-6

Enclosure to NL-18-0200 HNP Unit 1 Compliance to Order EA-13-109 Operating and maintenance procedures for HNP Unit 1 have been developed and integrated with existing procedures to ensure safe operation 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 6.1.2 and 6.2.

HNP Unit 1 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 Phase 1 and 2 OIP for Order EA-13-109 (References 5 and 6).

HNP Unit 1 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.

REFERENCES:

The following references support the HNP Unit 1 compliance with the requirements of Order EA-13-109:

1. NRC Order EA-13-1 09, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013 (ML13143A321 ).

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, dated November 14, 2013 (ML133048836).

3. NRC Interim Staff Guidance JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, dated November 14, 2013 (ML15104A118).

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 April2015.

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

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

E-7

Enclosure to NL-18-0200 HNP Unit 1 Compliance to Order EA-13-109

7. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 First Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 30, 2014.

8. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Second Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated June 26,2015.

9. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fourth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated June 13,2016.

10. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fifth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 16, 2016.

11. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Sixth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated June 12, 2017.

12. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Seventh Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 5, 2017.

13. NRC Letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-1 09 (Severe Accident Capable Hardened Vents) {TAG Nos. MF4479 and MF4480), dated March 25, 2015 (ML14335A137).

14. NRC Letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2-lnterim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (GAG NOS. MF4479 and MF4480), dated August 2, 2016.

15. NRC Letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2- Report for the Audit of Licensee Responses to Interim Staff Evaluation Open Items Related to NRC Order EA-13-1 09 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (GAG NOS. MF4479 and MF4480), dated September 19, 2017.

E-8