RS-18-113, 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...

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...

ML18271A008
Person / Time
Site:	Peach Bottom
Issue date:	09/28/2018
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-18-113
Download: ML18271A008 (85)

Text

Exelon Generation" Order No. EA-13-109 RS-18-113 September 28, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277

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 September 28, 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) 1O. 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. Exelon Generation Company, LLC Seventh 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, 2017 (RS-17-155)

13. Exelon Generation Company, LLC Eighth 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 29, 2018 (RS-18-060)

14. NRC 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

15. NRC 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

16. NRC 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 NRC 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 {"NRC" 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 EGC to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 3 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 NRC 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 Bottom Atomic Power Station, Unit 2 Phase 1 Overall Integrated Plan (OIP), which was replaced with the Phase 1 (Updated) and Phase 2 OIP (Reference 8). References 14 and 15 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, 11, 12, and 13 provided the first, second, third, fourth, fifth, sixth, seventh, and eighth six-month status reports, respectively, pursuant to Section IV, Condition D.3, of Reference 1 for Peach Bottom Atomic Power Station, Unit 2.

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 2.

Peach Bottom Atomic Power Station, Unit 2 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 2 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 N RC Order EA-13-109. The information provided herein documents full compliance for Peach Bottom Atomic Power Station, Unit 2 with NRC Order EA-13-109.

Peach Bottom Atomic Power Station, Unit 2 Phase 1 OIP Open Items have been addressed and closed as documented in Reference 10, and are considered complete per Reference 16.

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 14 have been addressed and closed as documented in Reference 10, and are considered complete per Reference 16. The following table provides completion references for each OIP and ISE Phase 1 Open Item.

Reference 16 provided the results of the audit of ISE Open Item closure information provided in References 1O and 11. All Phase 1 and Phase 2 ISE Open Items are statused as closed in Reference 16.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 4 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.

OIP Phase 1 Open Item No. 3 Deleted (Closed to ISE Open Item No. 2 below)

Identify site specific controlling document for HCVS out of service and compensatory measures.

OIP Phase 1 Open Item No. 4 Deleted (Closed to ISE Open Item No. 8 below)

Determine the approach for combustible gases.

OIP Phase 1 Open Item No. 5 Closed per References 10 and 16.

Perform radiological evaluation for Phase 1 vent line impact on ERO response actions.

ISE Phase 1 Open Item No. 1 Closed per References 10 and 16.

Make available for NRG staff audit guidelines and procedures for HGVS operation. (Section 3.2.3.1)

ISE Phase 1 Open Item No. 2 Closed per References 10 and 16.

Make available for the NRC staff audit the site specific controlling document for HGVS out of service and compensatory measures. (Section 3.4.1)

ISE Phase 1 Open Item No. 3 Closed per References 10 and 16.

Make available for NRG staff audit a technical justification for use of jumpers in the HGVS strategy.

(Section 3.1.3)

ISE Phase 1 Open Item No. 4 Closed per References 10 and 16.

Make available for NRG staff audit analyses demonstrating that the HGVS 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 HGVS 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)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 5 ISE Phase 1 Open Item No. 5 Closed per References 10 and 16.

Make available for NRG staff audit descriptions or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee justification for the HVAG release point being below and 150 feet from the reactor building ventilation release point.

{Section 3.2.2.3)

ISE Phase 1 Open Item No. 6 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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, 3.2.2.10, 3.2.4.1, 3.2.4.2, 3.2.5.2, and 3.2.6)

ISE Phase 1 Open Item No. 10 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 6 ISE Phase 1 Open Item No. 12 Closed per References 10 and 16.

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)

ISE Phase 1 Open Item No. 13 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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 Closed per References 10 and 16.

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)

EGC's response to the NRC ISE Phase 2 Open Items identified in Reference 15 have been addressed and closed as documented in Reference 11, and are considered complete per Reference 16. 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 16 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 16 utilizing BWROG generic response Licensee to demonstrate that instrumentation template.

and equipment being used for SAWA and supportinq equipment is capable to perform for

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 7 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 16 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)

ISE Phase 2 Open Item No. 4 Closed per References 11 and 16 utilizing BWROG generic response Licensee shall demonstrate whether a site template.

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 Closed per References 11 and 16 utilizing BWROG generic response Licensee to demonstrate that there is adequate template.

communication between the MCR 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 Closed per References 11 and 16 utilizing BWROG generic response Licensee to demonstrate the SAWM flow template.

instrumentation qualification for the expected environmental conditions. (Section 3.3.3.4)

MILESTONE SCHEDULE - ITEMS COMPLETE Peach Bottom Atomic Power Station, Unit 2 - Phases 1 and 2 Specific Milestone Schedule Milestone Target Activity Comments Completion Status Date Submit Phase 1 Overall Integrated Jun.2014 Complete Plan

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 8 Milestone Target Activity Comments Completion Status Date 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 Update 8 Jun.2018 Complete Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual Apr. 2014 Complete design meeting Unit 2 Design Engineering On- Jun.2016 Complete site/Complete Unit 2 Implementation Outage Nov. 2016 Complete Unit 2 Walk Through Nov. 2016 Complete Demonstration/Functional Test Phase 1 Procedure Changes Operations Procedure Changes Nov. 2016 Complete Developed Site Specific Maintenance Nov. 2016 Complete Procedure Developed Procedure Changes Active Nov. 2016 Complete Phase 1 Training:

Training Complete Nov. 2016 Complete Phase 1 Completion Unit 2 HCVS Implementation Nov. 2016 Complete

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 9 Milestone Target Activity Comments Completion Status Date Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual design N/A N/A meeting Unit 2 Design Engineering On- Sept. 2017 Complete site/Complete Unit 2 Walk Through Aug.2018 Complete Demonstration/Functional Test Unit 2 Implementation Outage N/A N/A Phase 2 Procedure Changes Operations Procedure Changes Aug.2018 Complete Developed Site Specific Maintenance Aug.2018 Complete Procedure Developed Procedure Changes Active Aug.2018 Complete Phase 2 Training:

Training Complete Aug.2018 Complete Phase 2 Completion Unit 2 HCVS Implementation August 31, Complete 2018 Submit Unit 2 Phases 1 and 2 Sept. 2018 Complete Completion Report with this submittal.

ORDER EA-13-109 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Peach Bottom Atomic Power Station, Unit 2, 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, 1O, 11, 12, and 13), demonstrate compliance with NRG Order EA-13-109. The Peach Bottom Atomic Power Station, Units 2 and 3 Final Integrated Plan for reliable hardened containment vent Phase 1 and Phase 2 strategies is provided in the enclosure to this letter.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 10 HCVS PHASE 1 AND PHASE 2 FUNCTIONAL REQUIREMENTS AND DESIGN FEATURES - COMPLETE The Peach Bottom Atomic Power Station, Unit 2, 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 Peach Bottom Atomic Power Station, Unit 2, 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 2, 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 2, 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 2 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 2 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 2 Phase 1 and Phase 2 HCVS use provides adequate protection from applicable site hazards, and

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 11 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 2 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 2 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 5.4 and 6.2.

Peach Bottom Atomic Power Station, Unit 2 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 OIP for Order EA-13-109 (Reference 8).

Peach Bottom Atomic Power Station, Unit 2 has completed evaluations to confirm accessibility, habitability, staffing sufficiency, and communication capability in accordance with NEI 13-02, Revision 1, 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 281h day of September 2018.

Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 Final Integrated Plan Document- Hardened Containment Vent System NRC Order EA-13-109

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 September 28, 2018 Page 12 cc: Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region I NRG Senior Resident Inspector - Peach Bottom Atomic Power Station NRG Project Manager, NRR- Peach Bottom Atomic Power Station Mr. Peter J. Bamford, NRR/JLD/JOMB, NRG Mr. Brian E. Lee, NRR/JLD/JCBB, NRG Mr. Rajender Auluck, NRR/JLD/JCBB, NRG 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 D. Tancabel, State of Maryland

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Final Integrated Plan Document - Hardened Containment Vent System NRC Order EA-13-109 (69 pages)

Final Integrated Plan HCVS Order EA-13-109 for Peach Bottom Atomic Power Station (PBAPS)

Units 2 & 3 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Table of Contents Section I: Introduction ............................................................................................................................... 1 Section I.A: Summary of Compliance ................................................................................................ 3 Section l.A.1: Summary of Phase 1 Compliance ......................................................................... 3 Section l.A.2: Summary of Phase 2 Compliance .........................................................................4 Section 11: List of Acronyms ...................................................................................................................... 6 Section Ill: Phase 1 Final Integrated Plan Details ................................................................................. 9 Section II I.A: HCVS Phase 1 Compliance Overview ........................................................................ 9 Section 111.A.1: Generic Letter 89-16 Vent System (The info below came from the HCVS Phase 1 DAR "Existing Design Summary" for U2 ECR 15-00148/EC 556049 and U3 EC 556318.) ........ ................... .... ................................................................................................................ 9 Section 111.A.2: EA-13-109 Hardened Containment Vent System (HCVS) (The info below came from the HCVS Phase 1 DAR "Existing Design Summary" for U2 ECR 15-00148/EC 556049 and U3 EC 556318.) ..................... ........... ........................................................ .................. 10 Section 111.B: HCVS Phase 1 Evaluation Against Requirements: ....... ..................... ..................... 13

1. HCVS Functional Requirements ........................................................................ .................... 13

2. HCVS Quality Standards: ........................................................................................................ 29 Section IV: HCVS Phase 2 Final Integrated Plan ............................... .......... .................. ..................... 30 Section IV.A: The requirements of EA-13-109, Attachment 2, Section B for Phase 2 ............. 30

1. HCVS Drywell Vent Functional Requirements ..................................................................... 30

2. Containment Venting Strategy Requirements ...................................................................... 30 Section IV.B: HCVS Existing System ............................................................................................... 31 Section IV.C: HCVS Phase 2 SAWA System and SAWM Strategy ............................................ 31 Section IV.C.1: Detailed SAWA Flow Path Description .......................................... ................... 32 Section IV.C.2: Severe Accident Assessment of Flow Path ...................................................... 32 Section IV.C.3: Severe Accident Assessment of Safety-Relief Valves .................................... 32 Section IV.C.4: Available Freeboard Use (See 5th 6 month update, ISE-4 on Page 13.) ..... 33 Section IV.C.5: Upper range of wetwell level indication ............................................................. 33 Section IV.C.6: Wetwell vent service time .................................................... ................................ 33 Section IV.C.7: Strategy time line .................................................................................................. 33 Section IV.C.8: SAWA Flow Control ............................................................................................. 34 Section IV.C.9: SAWA/SAWM Element Assessment.. ............................................................... 34 Section IV.C.10: SAWA/SAWM lnstrumentation ........................................................................ 36 Section IV.C.11: SAWA/SAWM Severe Accident Considerations ........................................... 38 Section V: HCVS Programmatic Requirements .................................................................................. 40 Revision 0 Page ii September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Section V.A: HCVS Procedure Requirements ................................................................................ 40 Section V.B: HCVS Out of Service Requirements ......................................................................... 42 Section V.C: HCVS Training Requirements .................................................................................... 43 Section V.D: Demonstration with other Post Fukushima Measures ........................................... .43 Section VI: References ...........................................................................................................................45 : Phase 2 Freeboard diagram ........................................................................................ so : One Line Diagram of HCVS Vent Path ...................................................................... 51 : One Line Diagram of HCVS Electrical Power Supply - Units 2 & 3 ....................... 53 : One Line Diagram of SAWA Flow Path - Unit 2 ....................................................... 54 a: One Line Diagram of SAWA Flow Path - Unit 3 .................................................... 57 : One Line Diagram of SAWA Electrical Power Supply- Unit 2 .............................. 59 Attachment Sa: One Line Diagram of SAWA Electrical Power Supply- Unit 3 ............................ 60 : Plant Layout Showing Operator Action Locations .................................................... 61 Table 1: List of HCVS Component, Control and Instrument Qualifications .................................... 66 Table 2: Operator Actions Evaluation .................................................................................................. 68 Revision 0 Page iii September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Section I: Introduction In 1989, the NRC issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent,"

(Reference 1) to all licensees of BWRs with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the wetwell to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell.

On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff per Staff Requirements Memorandum (SRM) for SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments (References 2 and 3) to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Reference 4) with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013 (Reference 5). The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent to remove decay heat from the containment, and to maintain control of containment pressure within acceptable limits following events that result in the 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).

Peach Bottom Atomic Power Station (PBAPS) is required by NRC Order EA-13-109 to have a reliable, severe accident capable hardened containment venting system (HCVS).

Order EA-13-109 allows implementation of the HCVS Order in two phases.

• Phase 1 upgraded the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened vent to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. PBAPS achieved Phase 1 compliance in November 2016 for Unit 2 and in November 2017 for Unit 3.

• Phase 2 provided additional protections for severe accident conditions through the development of a reliable containment venting strategy that makes it unlikely that PBAPS would need to vent from the containment drywell during severe accident conditions. PBAPS achieved Phase 2 compliance in November 2017 for Unit 3 and August 2018 for Unit 2.

NEI developed guidance for complying with NRC Order EA-13-109 in NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, BWR Mark I & II Reliable Revision 0 Page 1 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision O (Reference 6) with significant interaction with the NRC and Licensees. NEI issued Revision 1 to NEI 13-02 in April 2015 (Reference 7) which contained guidance for compliance with both Phase 1 and Phase 2 of the order. NEI 13-02, Revision 1 also includes HCVS-Frequently Asked Questions (FAQs) 01 through 09 and reference to white papers (HCVS-WP-01 through 03 (References 8 through 10)). The NRC endorsed NEI 13-02 Revision 0 as an acceptable approach for complying with Order EA-13-109 through 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, issued in November 2013 (Reference 12) and 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 issued in April 2015 (Reference 13) for NEI 13-02 Revision 1 with some clarifications and exceptions. NEI 13-02 Revision 1 provides an acceptable method of compliance for both Phases of Order EA-13-109.

In addition to the endorsed guidance in NEI 13-02, the NRC staff endorsed several other documents that provide guidance for specific areas. HCVS-FAQs 10 through 13 (References 14 through 17) were endorsed by the NRC after NEI 13-02 Revision 1 on October 8, 2015. NRC staff also endorsed four White Papers, HCVS-WP-01 through 04 (References 8 through 11 ), which cover broader or more complex topics than the FAQs.

As required by the order, PBAPS submitted a phase 1 Overall Integrated Plan (OIP) in June of 2014 (Reference 18) and subsequently submitted a combined Phase 1 and 2 OIP in December 2015 (Reference 19). These OIPs followed the guidance NEI 13-02 Revision 0 and 1 respectively, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents. The NRC staff used the methods described in the ISGs to evaluate licensee compliance as presented in the Order EA-13-109 OIPs.

While the Phase 1 and combined Phase 1 and 2 OIPs where written to different revisions of NEI 13-02, PBAPS conform to NEI 13-02 Revision 1 for both Phases of Order EA-13-109.

The NRC performed a review of each OIP submittal and provided PBAPS with Interim Staff Evaluations (ISEs) (References 20 and 21) assessing the site's compliance methods. In the ISEs the NRC identified open items which the site needed to address before that phase of compliance was reached. Six-month progress reports (References 22 through 29) were provided consistent with the requirements of Order EA-13-109. These status reports were used to close many of the ISE open items. In addition, the site participated in NRC ISE Open Item audit calls where the information provided in the six-month updates and on the E-Portal were used by the NRC staff to determine whether the ISE Open Item appeared to be addressed.

By submittal of this Final Integrated Plan PBAPS has addressed all the elements of NRC Order EA-13-109 utilizing the endorsed guidance in NEI 13-02, Rev 1 and the related HCVS-FAQs and HCVS-WPs documents. In addition, the site has addressed Revision 0 Page 2 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 the NRG Phase 1 and Phase 2 ISE Open Items as documented in previous six-month updates.

Section Ill contains the PBAPS Final Integrated Plan details for Phase 1 of the Order.

Section IV contains the Final Integrated Plan details for Phase 2 of the Order.Section V details the programmatic elements of compliance.

Section I.A: Summary of Compliance Section l.A.1 : Summary of Phase 1 Compliance The plant venting actions for the EA-13-109, Phase 1, severe accident capable venting scenario can be summarized by the following:

The HCVS is initiated via manual action at the Remote Operating Station (ROS) combined with control from either the Main Control Room (MGR) or the ROS at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms.

• The vent utilizes containment parameters of pressure and level from the MGR instrumentation to monitor effectiveness of the venting actions.

• The vent operation is monitored by HCVS valve position, temperature and effluent radiation levels.

• The HCVS motive force is monitored and has the capacity to operate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with installed equipment. Replenishment of the motive force will be by use of portable equipment once the installed motive force is exhausted.

• Venting actions are capable of being maintained for a sustained period of at least 7 days.

The operation of the HCVS is designed to minimize the reliance on operator actions in response to external hazards. The screened in external hazards for PBAPS are seismic, external flooding, high winds, extreme cold, and extreme high temperature.

Initial operator actions are completed by plant personnel and include the capability for remote-manual initiation from the HCVS control station. Initial operator actions are completed by plant personnel to perform initial valve line-up at the ROS. Then, the primary location of vent operation is the MGR. The HCVS system can also be operated manually from the ROS. Attachment 2 contains a one-line diagram of the HCVS vent flowpath.

Revision 0 Page 3 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Section l.A.2: Summary of Phase 2 Compliance The Phase 2 actions can be summarized as follows:

• Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV).

• Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS Phase 1 wetwell vent will remain functional for the removal of heat from the containment.

• Heat can be removed from the containment for at least seven (7) days using the HCVS or until alternate means of heat removal are established that make it unlikely the drywell vent will be required for containment pressure control.

• The SAWA and SAWM actions can be manually activated and controlled from areas that are accessible during severe accident conditions.

• Parameters measured are Drywell pressure, Suppression Pool level, SAWA flowrate and the HCVS Phase 1 vent path parameters.

The locations of the SAWA equipment and controls, as well as ingress and egress paths have been evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period. Equipment has been evaluated to remain operational throughout the Sustained Operating period . Personnel radiological exposure, temperature and humidity conditions for operation of SAWA equipment will not exceed the limits for ERO dose or plant safety guidelines for temperature and humidity.

The SAWA flow path is the same as the FLEX primary injection flow path. Attachment 4 contains a one-line diagram of the SAWA flowpath.

For severe accident (SA) conditions, the operators will follow Emergency Operating Procedures (EOP) flowcharts (i.e., TRIP/SAMP) for various scenarios where one unit is under FLEX and the other under SA conditions or both units are under SA conditions.

FLEX procedures guide implementation of FLEX strategies for the FLEX unit. PBAPS will inject 500 gpm for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and then lower the injection rate to the 100 gpm wetwell preservation flow rate. A FLEX (SAWA) Pump for each unit is staged north of the Unit 3 Reactor Building (RB) between the Plant Services Building and the Unit 3 Startup Switchgear Building. The FLEX Pumps take suction from the Emergency Cooling Tower (ECT). To control the injection rate, the FLEX Pump discharge hoses are equipped with flow meters and flow rate is controlled by adjusting FLEX Pump rpm and/or throttling discharge valves. The location of the FLEX Pumps has been analyzed for hydraulics and dose rates.

All the hose connections, valve lineups, and the staging of the FLEX Pumps will be completed to allow RPV makeup within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the onset of the event. The FLEX Revision 0 Page 4 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Pump for each unit is capable of meeting all water makeup requirements for FLEX or SA conditions. As discussed in OIP (Reference 19), the total amount of water added will not completely fill up the torus to render wetwell venting inoperable.

The SAWA electrical loads are included in the FLEX Generator loading calculation reviewed for EA-12-049 compliance. The Unit 2 FLEX Generator is located south of the Unit 2 RB outside of the Unit's outer railroad door. The Unit 3 FLEX Generator is located north of the Unit 3 RB outside of the Unit's outer railroad door. See Attachment 6 for applicable locations. Refueling of the FLEX Generators is accomplished as described in FSG-50, "FLEX Equipment Fuel Oil Supply" (Reference 38).

Evaluations for projected SA conditions (radiation I temperature) indicate that personnel can complete the initial and support activities without exceeding the ERO-allowable dose for equipment operation or site safety standards.

Electrical equipment and instrumentation is powered from the existing station batteries, and from AC distribution systems that are powered from the FLEX Generators. The battery chargers are also powered from the FLEX Generators to maintain the battery capacities during the Sustained Operating period.

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Final Integrated Plan HCVS Order EA-13-109 Section II: List of Acronyms AC Alternating Current AOV Air Operated Valve BDBEE Beyond Design Basis External Event BWROG Boiling Water Reactor Owners' Group CAP Containment Accident Pressure OBA Design Basis Accident DBLOCA Design Basis Loss of Coolant Accident DC Direct Current ECCS Emergency Core Cooling Systems ECT Emergency Cooling Tow er ELAP Extended Loss of AC Power EOP Emergency Operating Procedure EPG/SAG Emergency Procedure and Severe Accident Guidelines EPRI Electric Power Research Institute ERO Emergency Response Organization FAQ Frequently Asked Question FB FLEX Building FIP Final Integrated Plan FLEX Diverse & Flexible Coping Strategy GPM Gallons per minute HCVS Hardened Containment Vent System ISE Interim Staff Evaluation Revision 0 Page 6 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 ISG Interim Staff Guidance JLD Japan Lessons Learned Project Directorate LOCA Loss of Coolant Accident LPCI Low Pressure Coolant Injection System MAAP Modular Accident Analysis Program MCR Main Control Room Nitrogen NEI Nuclear Energy Institute NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission OIP Overall Integrated Plan PBAPS Peach Bottom Atomic Power Station PCIV Primary Containment Isolation Valve PCPL Primary Containment Pressure Limit PCM Performance Centered Maintenance RB Reactor Building RBCCW Reactor Building Closed Cooling Water RHR Residual Heat Removal RM Radiation Monitor ROS Remote Operating Station RPV Reactor Pressure Vessel SA Severe Accident SAMG Severe Accident Management Guidelines Revision 0 Page 7 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 SAWA Severe Accident Water Addition SAWM Severe Accident Water Management SBGT Standby Gas Treatment System SFP Spent Fuel Pool SGIG Safety Grade Instrument Gas SRV Safety-Relief Valve TB Turbine Building UFSAR Updated Final Safety Analysis Report VAC Voltage AC voe Voltage DC WW Wetwell Revision 0 Page 8 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Section Ill: Phase 1 Final Integrated Plan Details Section Ill.A: HCVS Phase 1 Compliance Overview PBAPS modified the existing hardened wetwell vent path installed in response to NRG Generic Letter 89-16 to comply with NRG Order EA-13-109.

Section 111.A.1: Generic Letter 89-16 Vent System PBAPS installed a hardened Torus (i.e., wetwell) vent for each unit in response to NRG Generic Letter 89-16 under Mod 5236. The description of the vent system below is common to both units. The Torus hardened vent pipe provides venting capabilities for the Torus vapor space via Primary Containment Isolation Valves (PCIVs)

A0-2-07B-2511 (Unit 2) and A0-3-07B-3511 (Unit 3) [hereafter referred to as A0-2(3)511], Primary Containment Outboard Barrier Valve A0-2-07B-80290 (Unit 2) and A0-3-07B-90290 (Unit 3) [hereafter referred to as A0-8(9)0290], and Rupture Disc PSD-80293 (Unit 2) and PSD-90293 (Unit 3) [hereafter referred to as A0-8(9)0293] to above the RB roof. The purpose of the vent is to maintain the Primary Containment pressure below the design limit (PCPL, 60 psig) when shut down cooling is lost for an extended period. This containment emergency vent path will prevent a containment breach with the subsequent uncontrolled radioactivity release.

The hardened vent system for each unit is connected to the Standby Gas Treatment System (SGTS) by valve A0-2-0?B-2512 (Unit 2) and A0-3-07B-3512 (Unit 3)

[hereafter referred to as A0-2(3)512]. During venting, the Torus vent pipe is isolated from the SGTS by A0-2(3)512 which remains closed. This valve has T-ring boot seals which inflate to prevent potential leakage across the valve seat to the SGTS. The HCVS nitrogen supply is connected to the A0-2(3)512 actuator tubing to maintain the boot seal inflated.

The hardened vent pipe discharge point is positioned above all buildings in the PBAPS protected area. The RB roof parapet is at Elevation 294'. The Torus vent discharge point is at Elevation 300'. The only higher structure in the protected area is the RB ventilation exhaust discharge point at Elevation 305', on the east side of the RB, approximately 150 feet away (east-west). The RB ventilation exhaust fans are not powered during an Extended Loss of AC Power (ELAP); however, chimney effect would preclude an inward pressure gradient. The hardened vent pipe release point is away from MGR ventilation system intake, which is below Elevation 177'. The PBAPS Main Stack is positioned at a higher elevation and is not located in the PBAPS protected area.

As detailed in calculation PM-1190 (Reference 39), the hardened vent discharge does not adversely impact any ventilation intake or exhaust openings, MGR location, location of portable equipment, access routes required following an ELAP and Beyond Design Basis severe accident or emergency response facilities.

The A0-2(3)511 air operated valve (AOV) is normally closed/fail closed. The valve control switch and position indication (open/close) lights are located in the MGR on Revision 0 Page 9 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Panel 2(3)0C003-03. When the control switch is set to 'open', the 125 Vdc solenoid valve is energized. The solenoid opens a path for instrument air or Safety Grade Instrument Gas (SGIG) to the valve actuator, opening the AOV. The valve automatically closes under spring pressure on loss of air. The 125 Vdc control power supply is provided from a Class 1E station battery.

A0-8(9)0290 is the hardened vent outboard barrier valve. Instrument air opens the valve against spring pressure and the valve fails closed. SGIG Nitrogen backs up the Instrument Air supply. The valve is opened when venting is required using Procedures T-200-2(3) and T-200J-2(3) (References 40 and 41). This valve is normally closed/fails closed and has no auto-close feature or stroke time requirement. The key locked control switch and position indication lights (open/close) are located on MCR Panel 2(3)0C003-03. The 125 Vdc control power for the valve actuating solenoid is normally supplied from a Class 1E station battery. To guard against inadvertent actuation, the control power fuses are removed during normal operations. The control power fuses are installed per Procedure T-200-2(3) when the valve is to be stroked open.

Rupture Disc PSD-8(9)0293 is downstream of A0-8(9)0290 and precludes the occurrence of Secondary Containment bypass leakage. PSD-8(9)0293 guards against inadvertent venting of Secondary Containment. The rupture disc prevents radioactive releases caused by upstream valve leakage during design basis operation. The rupture disc burst pressure is set at 30 psig which is less than the Torus design pressure rating (56 psig). The disc set point precludes reaching the Primary Containment Pressure Limit (PCPL) of 60 psig. The portion of the vent pipe that is downstream of PSD-8(9)0293 penetrates the Torus Room roof which is at grade level on the west side of the RB El 135'-0". The downstream side of the rupture disc and the piping between the rupture disc and the Torus Room roof are part of Secondary Containment.

Section 111.A.2: EA-13-109 Hardened Containment Vent System (HCVS)

The EA-13-109 compliant HCVS system utilizes the existing GL-89-16 wetwell hardened vent system with the addition of a dedicated 125 Vdc battery, Nitrogen motive gas source, and Argon purge systems. In addition, new HCVS radiation monitoring and temperature sensors and new control switches have been added. After initial valve line-up at ROS located in the Radwaste Building 135 1 elevation, the vent system is initiated, operated and monitored from the MCR. The vent system can also be initiated and operated from the ROS. Table 2 contains the evaluation of the acceptability of the ROS location with respect to severe accident conditions.

The MCR is the primary operating station for the HCVS. During an ELAP, electric power to operate the vent valves will be provided by batteries with a capacity to supply required loads for at least the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Before the batteries are depleted, the FLEX Generator will supplement and recharge batteries to support operation of the vent valves. The ROS is designated as the alternate control location and method. Since the ROS does not require any electrical power to operate, the valve solenoids do not need any additional backup electrical power. Attachment 2 shows the HCVS vent flow path.

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Final Integrated Plan HCVS Order EA-13-109 A dedicated HCVS 125 Vdc battery supplies power to the actuating solenoid for Inner Primary Containment Isolation Valve (PCIV) A0-2(3)511 and Primary Containment Outboard Barrier Valve A0-8(9)0290. This battery also powers the new HCVS instrumentation via the Distribution Panel OOD508. With the exception of the HCVS Radiation Monitoring System, HCVS instrumentation (argon pressure and HCVS temperature loops) is de-energized during normal operating conditions.

A new dedicated motive gas (Nitrogen) source is installed for the valve actuators for A0-2(3)511 and A0-8(9)0290. Nitrogen bottles are staged at the ROS. In addition, a new Argon Purge System is installed at the ROS to allow anticipatory breach of the vent rupture disc and to purge the vent pipe after venting to suppress the potential for Hydrogen (H2) detonation. The Argon bottles and Nitrogen bottles are isolated from their respective headers because the valves for each bottle are maintained closed.

The control switches [RMS-2(3)-16A-S025 and RMS-2(3)-16A-S 116] and status lights for existing A0-2(3)511 and A0-8(9)0290 are re-used and remain at MCR Panel 2(3)0C003-03.

New switch RMS-2(3)-16A-S 118 is mounted on Panel 2(3)0C003-03 and controls power to the HCVS components, except for the new RMS components. This switch, when aligned to the HCVS power source, also bypasses the normal PCIS logic that locks out operation of A0-2(3)511. The need to install A0-8(9)0290 control power fuses is also bypassed.

If A0-2(3)511 or A0-8(9)0290 should fail to operate normally from Panel 2(3)0C003-03, manual 3-way valves at the ROS will be re-positioned to place Nitrogen on the valve actuators to open these valves.

Control of the Argon Purge System is from new control switch RMS-2(3)-07K-2(3)3472 at the existing MCR Panel OOC767. The Argon supply solenoid valve SV-2(3)-07K-2(3)3472 is installed at the ROS. This valve is opened to allow Argon to discharge into the Torus vent pipe and to rupture the Torus Vent Rupture Disc PSD-8(9)0293. The Argon flow rate is controlled by PCV-2(3)-07K-2(3)3477A/B. Argon header supply pressure indicator Pl-8(9)1406 is installed in the Panel OOC767 to allow Operator monitoring of purge gas supply pressure during purge or disc rupture operations.

A new HCVS strap-on temperature sensor TE-8(9)1407 is installed on the vent line in the Torus Room and the indicator Tl-8(9)1407 is added to Panel 2(3)0C003-03 to provide temperature indication of the vent pipe during venting.

A new HCVS vent pipe Radiation Monitoring System [RE/RT/Rl-8(9)1405] has been installed. Radiation detector assembly RE-8(9)1405 is installed in the Unit 2 RB El.

195'-011 and in the Unit 3 RB El.165'-0". The radiation processor RT-8(9)1405 is installed in Panel OOC1062 located in the ROS. Panel OOC1062 will house the Radiation processors for both Unit 2 and Unit 3, RT-8(9)1405, and their associated power supplies.

Radiation indication Rl-8(9) 1405 is provided in the MCR panel 2(3)0C010.

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Final Integrated Plan HCVS Order EA-13-109 The HCVS radiation monitor (RM) with an ion chamber detector is qualified for the ELAP and external event conditions. In addition to the RM, a temperature element is installed on the vent line to allow the operators to monitor operation of the HCVS.

Electrical and controls components are seismically qualified and include the ability to handle harsh environmental conditions (although they are not considered part of the site Environmental Qualification (EQ) program) .

Table 1 provides HCVS instrumentation and equipment environment and qualifications. and 3a contain a one-line diagram of the HCVS electrical distribution system.

The wetwell vent up to, and including, the second containment isolation barrier is designed consistent with the design basis of the plant. These items include piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication components. The maximum operating temperature in the Torus and Torus vent at the PCPL is 308°F based on saturated steam properties at 60 psig.

NEI 13-02 suggests a 350°F value for HCVS design temperature based on the highest Primary Containment Pressure Limit (PCPL) among the Mark I and II plants. Since 308°F corresponds to the saturation temperature for the PBAPS PCPL of 60 psig, it will be retained as the pipe design temperature. Per NEI 13-02, it is acceptable to assume saturation conditions in containment (2.4.3.1) so that these design parameters are acceptable.

To prevent leakage of vented effluent to the Standby Gas Treatment (SBGT) system, boundary valve A0-2(3)512 must close before wetwell venting. A0-2(3)512 is the only boundary between the HCVS and the interfacing SBGT system. This valve is normally closed, fail closed, and is not required to change state in order to perform its' safety related containment isolation function; therefore, it can be assumed to be closed when required. A0-2(3)512 is part of the IST program and is leak tested in accordance with 10CFR50, Appendix J. This is acceptable for prevention of inadvertent cross-flow of vented fluids per HCVS-FAQ-05.

HCVS features to prevent inadvertent actuation include a key lock switch at the primary control station and locked closed valves at the ROS which is an acceptable method of preventing inadvertent actuation per NEI 13-02.

Manual bypass valve HV-2(3)-07K-2(3)3476 has been installed around SV-2(3)-07K-2(3)3472. Exelon Position Paper EXC-WP-11 (Reference 46) Attachment 3, second paragraph indicates that use of the manual bypass valve around SV-2(3)-07K-2(3)3472 to inject Argon satisfies NRC Order EA 13-109 requirements and associated NEI 13-02 Revision 1 and HCVS-WP-03 Revision 1 guidance for hydrogen detonation control elements of the Order. Thus, if SV-2(3)-07K-2(3)3472 is inoperable, the HCVS is compliant with NRC requirements despite this condition.

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Final Integrated Plan HCVS Order EA-13-109 With the onset of ELAP, Operations will open each of the Argon bottle isolation valves, open the Nitrogen bottle isolation valves, align the Argon supply valve HV-2(3)-07K-2(3)3478, and, if conditions warrant, actuate SV-2(3)-07K-2(3)3472 via MCR control switch RMS-2(3)-07K-2(3)3472 to rupture the PSD-8(9)0293 rupture disc in preparation for venting. The MCR switch RMS-2(3)-16A-S118 in Panel 2(3)0C003 will be used to energize the HCVS instrumentation. If SV-2(3)-07K-2(3)3472 is not available, Operators will use bypass valve HV-2(3)-07K-2(3)3476 to inject Argon. Re-alignment of the HCVS Nitrogen header supply valves is necessary. Nitrogen from the bottles is supplied to the upstream side of the actuating solenoids for A0-2(3)511, A0-2(3)512 and A0-8(9)0290. If the normal instrument air supply and SGIG supply are lost, HCVS Nitrogen will be supplied to the actuators for these valves. The A0-2(3)511 valve is opened via MCR control switch RMS-2(3)-16A-S025 and is maintained opened. The outer vent valve A0-8(9)0290 will then be cycled open/closed via MCR control switch RMS-2(3)-16A-S116 as directed by operating procedures. After each time A0-8(9)0290 is closed, the vent pipe is purged with Argon within the period specified in calculation PM-1189. Argon will be injected to the vent pipe using control switch RMS-2(3)-07K-2(3)3472 at MCR Panel OOC767 or the manual bypass mentioned above.

If the solenoid for the vent valve actuator should fail to operate, Operators will access the ROS to perform manual stroking of the HCVS hardened vent valves. The pathway used to access the ROS is detailed in Calculation PM-1190 (Reference 39).

Section 111.B: HCVS Phase 1 Evaluation Against Requirements:

The functional requirements of Phase 1 of NRC Order EA-13-109 are outlined below along with an evaluation of the PBAPS response to maintain compliance with the Order and guidance from JLD-ISG-2015-01. Due to the difference between NEI 13-02, Revision 0 and Revision 1, only Revision 1 will be evaluated. Per JLD-ISG-2015-01, this is acceptable as Revision 1 provides acceptable guidance for compliance with Phase 1 and Phase 2 of the Order.

1. HCVS Functional Requirements 1.1 The design of the HCVS shall consider the following performance objectives:

1 .1 .1 The HCVS shall be designed to minimize the reliance on operator actions.

Evaluation:

The operation of the HCVS was designed to minimize the reliance on operator actions in response to hazards identified in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Reference 31 ), which are applicable to the plant site. Operator actions to initiate the HCVS vent path can be completed by plant personnel and include the capability for remote-manual initiation from the HCVS control station. A list of the remote manual actions performed by plant personnel to open the HCVS vent path is in the following table:

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Final Integrated Plan HGVS Order EA-13-109 Table 3-1: HCVS Operator Actions Primary Location/

Primary Action Notes Component

1. Valve in Argon gas bottles (16} ROS Radwaste 135' and Nitrogen gas bottles (2).

2. Open HV-2(3)-16G-2(3)3434A ROS Radwaste 135' "2(3)AS1108 N2 Btl to Gtmt Vent Sys lsol Vv".

3. Open HV-2(3}-16G-2(3)3434B ROS Radwaste 135' "2(3)BS1108 N2 Btl to Gtmt Vent Sys lsol Vv".

4. Adjust PGV-2(3)-16G-2(3)3435, ROS Radwaste 135' "Backup N2 SUP Press Reg To Gtmt Vent Hdr" if required.

5. Open HV-2(3)-16G-2(3)3436, ROS Radwaste 135' "B/U N2 to Gtmt Vent Sys Hdr lsol Vv"

6. Unlock and open ROS Radwaste 135' HV-2(3)-07K-2(3)3478, "Argon Gas Supply to Gtmt Vent Hdr lsol Valve".

7. Energize the system by placing MGR Panel Powered by the HGVS RMS-2(3)-16A-S 118, "HGVS 2(3)0G003-03 key lock 125 VDG batteries Power Transfer Switch", in switch "Bypass".

8. Rupture PSD-8(9)0293, "Gtmt MGR Panel OOG767 Open SV-2(3)3472, Emerg Vent Rupture Disc" "HGVS Argon Purge" Revision 0 Page 14 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Primary Location/

Primary Action Notes Component

9. Open A0-2(3)511, "lnbd 18" MCR Panel Vent" 2(3)0C003-03

10. Open A0-8(9)0290, "Ctmt MCR Panel This action starts Emerg Vent". 2(3)0C003-03 venting primary containment from the Torus.

Permanently installed electrical power and pneumatic supplies are available to support operation and monitoring of the HCVS for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No portable equipment needs to be moved in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, available personnel will be able to connect supplemental electric power and pneumatic supplies for sustained operation of the HCVS for a minimum of 7 days. The FLEX Generators and Nitrogen bottles provide this motive force. In all likelihood, these actions will be completed in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, the HCVS can be operated for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without any supplementation.

The above set of actions conform to the guidance in NEI 13-02 Revision 1 Section 4.2.6 for minimizing reliance on Operator actions and are acceptable for compliance with Order element A.1.1 .1. These were identified in the OIP and subsequent NRC ISE.

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Final Integrated Plan HCVS Order EA-13-109 Table 3-2: Failure Evaluation Failure with Alternate Action Impact Functional on Failure Alternate Containment Mode Failure Cause Action Ventina?

Fail to Vent Valves fail to Transfer No (Open) on open/close due power to Demand to loss of normal alternate DC DC power power from HCVS battery Fail to Vent Valves fail to Manually No (Open) on open/close due open valves Demand to loss of from ROS alternate DC Radwaste power 135' Fail to Vent Valves fail to Open valves No (Open) on open/close due using backup Demand to loss of normal nitrogen pneumatic system supply (SGIG)- no operator action required Fail to Vent Valve fails to Align HCVS No (Open) on open/close due nitrogen Demand to loss of bottles at backup ROS pneumatic Radwaste supply (SGIG) 135' 1.1.2 The HCVS shall be designed to minimize plant operators' exposure to occupational hazards, such as extreme heat stress, while operating the HCVS system.

Evaluation:

Primary control of the HCVS is accomplished from the MCR. Alternate control of the HCVS is accomplished from the ROS at Radwaste 135' elevation. FLEX actions that will maintain the MCR and ROS habitable were implemented in response to NRC Order EA-12-049 (Reference 32).

Actions specified in FSG-30, "Establishing Control Room Ventilation and Lighting" (Reference 47), include:

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Final Integrated Plan HCVS Order EA-13-109

1. Restoring MCR ventilation using the FLEX Generator. The MCR ventilation loads were included in FLEX Generator load calculations.

2. Opening MCR doors to the outside (if required).

3. Operating portable generators and fans to move outside air through the MCR (if required).

4. A ROS temperature of 120°F conservatively bounds the expected temperature response in the first 7 days following an ELAP.

5. For extreme cold temperatures, the ROS temperature will be a minimum of 50°F for the first 7 days following an ELAP.

Table 2 contains a thermal evaluation of all the operator actions that may be required to support HCVS operation. The relevant calculations (Reference 30) demonstrate that the final design meets the order requirements to minimize the plant operators' exposure to occupational hazards.

1.1 .3 The HCVS shall also be designed to minimize radiological consequences that would impede personnel actions needed for event response.

Evaluation:

Primary control of the HCVS is accomplished from the MCA. Under the postulated scenarios of order EA-13-109 the control room is adequately protected from excessive radiation dose and no further evaluation of its use is required. (Ref. HCVS-FAQ-06)

Alternate control of the HCVS is accomplished from the ROS. The ROS was evaluated for radiation effects due to a severe accident and determined to be acceptable. The ROS is located in a low dose area during normal operation. Calculation PM-1190 (Reference 39) provides a radiological evaluation of all the operator actions that may be required to support HCVS operation. The evaluation of radiological hazards demonstrates that the final design meets the order requirements to minimize the plant operators' exposure to radiological hazards.

Table 2 contains a radiological evaluation of the operator actions that may be required to support HCVS operation in a severe accident. There are no abnormal radiological conditions present for HCVS operation without core damage. The evaluation of radiological hazards demonstrates that the final design meets the order requirements to minimize the plant operators' exposure to radiological hazards.

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Final Integrated Plan HCVS Order EA-13-109 The HCVS vent is routed away from the MCR such that building structures provide shielding, thus per HCVS-FAQ-01 the MCR is the preferred control location. If venting operations create the potential for airborne contamination in the MCR, the ERO will provide personal protective equipment to minimize any operator exposure.

1.1 .4 The HCVS controls and indications shall be accessible and functional under a range of plant conditions, including severe accident conditions, extended loss of AC power, and inadequate containment cooling.

Evaluation:

Primary control of the HCVS is accomplished from the MCR. Under the postulated scenarios of order EA-13-109 the control room is adequately protected from excessive radiation dose and no further evaluation of its use is required (HCVS-FAQ-06).

Alternate control of the HCVS is accomplished from the ROS in Radwaste 135'. The ROS is in an area evaluated to be accessible before and during a severe accident.

For ELAP with injection, the HCVS wetwell vent will be opened to protect the containment from overpressure. The operator actions and timing of those actions to perform this function under ELAP conditions were evaluated as part of the PBAPS response to NRC Order EA-12-049 as stated in Reference 35.

Table 2 contains a thermal and radiological evaluation of all the operator actions at the MCR or alternate location that may be required to support HCVS operation during a severe accident. The relevant calculation (Reference 30) demonstrates that the final design meets the order requirements to minimize the plant operators' exposure to occupational and radiological hazards.

Table 1 contains an evaluation of the controls and indications that are or may be required to operate the HCVS during a severe accident. The evaluation demonstrates that the controls and indications are accessible and functional during a severe accident with a loss of AC power and inadequate containment cooling.

1.2 The HCVS shall include the following design features:

1.2.1 The HCVS shall have the capacity to vent the steam/energy equivalent of 1 percent of licensed /rated thermal power (unless a lower value is justified by analysis) and be able to maintain containment pressure below the primary containment design pressure.

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Final Integrated Plan HCVS Order EA-13-109 Evaluation Calculation PM-0546 (Reference 48) has evaluated the capability of the current Torus Hardened Vent for Unit 2 and Unit 3. The results of this analysis show that the torus hardened vent remains capable of its design function of removing 1% of decay heat at 4030 MWt while maintaining primary containment pressures below both the containment design pressure (56 psig) and PCPL (60psig).

The decay heat absorbing capacity of the suppression pool and the selection of venting pressure were made such that the HCVS will have sufficient capacity to maintain containment pressure at or below the lower of the containment design pressure (56 psig) or the PCPL (60 psig). This calculation of containment response is contained in PB-MISC-010 (Reference 49) that was submitted in Reference 35 and which shows that containment is maintained below the design pressure once the vent is opened, even if it is not opened until PCPL.

1.2.2 The HCVS shall discharge the effluent to a release point above main plant structures.

Evaluation The wetwell vent exits the Primary Containment through the 18" wetwell purge exhaust piping and associated inboard Primary Containment Isolation Valve A0-2(3)511. Between the inboard PCIV and SBGT isolation valve A0-2(3)512, the 16" wetwell vent piping with outboard PCIV A0-8(9)0290 and PSD-8(9)0293 rupture disc is installed.

Downstream of the rupture disc, the vent piping exits the Reactor Building through the Torus Room roof which is at grade level on the west side of the RB El 135'-0". The downstream side of the rupture disc and the piping between the rupture disc and the Torus Room roof are part of Secondary Containment. The vent traverses up the exterior of the RB to above the RB roof. The Torus vent pipe discharge point is positioned above all buildings in the PBAPS protected area. The RB roof parapet is at Elevation 294'. The Torus vent discharge point is at Elevation 300'. The only higher structure in the protected area is the RB ventilation exhaust discharge point at Elevation 305', on the east side of the RB, approximately 150 feet away (east-west). The RB ventilation exhaust fans are not powered during an Extended Loss of AC Power (ELAP); however, chimney effect would preclude an inward pressure gradient. The PBAPS Main Stack is positioned at a higher elevation and is not located in the PBAPS protected area. Part of the HCVS-FAQ-04 guidance is designed to ensure that vented fluids are not drawn immediately back into any emergency ventilation intakes. Such ventilation intakes should be below a level of the pipe by 1 foot for every 5 horizontal feet. The MCR Revision 0 Page 19 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 emergency intake in the ELAP event is below the 190 ft. elevation which is approximately 110 feet below the HCVS pipe outlet. This intake is approximately 73 feet from the Unit 2 vent pipe (farther than Unit 3), which would require the intake to be approximately 15 feet below the vent pipe.

Therefore, the vent pipe is appropriately placed relative to this air intake.

The vent pipe extends approximately 6 ft. above the parapet wall of the RB roof. This satisfies the guidance for height from HCVS-FAQ-04.

HCVS-WP-04 provides criteria that demonstrate robustness of the HCVS pipe. PBAPS meets all the requirements of this white paper. This evaluation documents that the HCVS pipe is adequately protected from all external events and no further protection is required.

PBAPS evaluated the vent pipe robustness with respect to wind-borne missiles against the requirements contained in HCVS-WP-04. This evaluation demonstrated that the pipe was robust with respect to external missiles per HCVS-WP-04 in that:

1. For the portions of exposed piping below 30 feet above grade.

On each unit, the exposed vent pipe rises from the Torus Room roof at El 135'-0" to El 300'-0" along the west side of the respective reactor building, which faces a steeply rising slope of exposed bedrock. The slope base begins at approximate El 135' and the top of the slope is at approximate El 270'; therefore, the entire exposed portion of vent pipe is considered to be below 30 feet above grade.

A TORM IS analysis (ARA-002611002611 was performed as a "reasonable protection evaluation" which calculated the damage probabilities to the external vent piping that would crimp the pipe to a point of not being able to perform as expected under SA conditions following an ELAP event. The damage probabilities are less than the numerical criterion stated in the NRC staff established position in the (TORMIS) SER dated May 7, 1983.

2. No portion of the exposed vent pipe is considered to be 30 feet above grade per Item 1 above.

3. Compensatory measures are available in the event the external vent piping becomes crimped.

4. PBAPS is not screened in for hurricanes.

Based on the above description of the vent pipe design, the PBAPS HCVS vent pipe design meets the order requirement to be robust with respect to all external hazards including wind-borne missiles.

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Final Integrated Plan HCVS Order EA-13-109 1.2.3 The HCVS shall include design features to minimize unintended cross flow of vented fluids within a unit and between units on the site.

Evaluation With respect to unintended cross flow of vented fluids, the HCVS for P BA P S Units 2 and 3 are fully independent of each other.

Therefore, the status at each unit is independent of the status of the other unit.

The HCVS for each unit interfaces with the SBGT system, which is common to both Units 2 and 3. The interface valve is A0-2(3)512 which is a normally closed/fail closed valve. During venting, the Torus vent pipe is isolated from the SGTS by A0-2(3)512 which remains closed. Inflation of the boot seal prevents potential leakage across the valve seat to the SGTS. The HCVS nitrogen supply, which is unit specific, is connected to the A0-2(3)512 actuator tubing to maintain the boot seal inflated. These valves are tested, and will continue to be tested, for leakage under 10CFR50 Appendix J as part of the containment boundary in accordance with HCVS-FAQ-05.

Based on the above description, the PB AP S design meets the requirements to minimize unintended cross-flow of vented fluids within a unit and between units on site.

1.2.4 The HCVS shall be designed to be manually operated during sustained operations from a control panel located in the main control room or a remote but readily accessible location.

Evaluation The existing wetwell vent will allow initiating and then operating and monitoring from a control panel located in the MGR. The system can be operated from the ROS.

1.2.5 The HCVS shall be capable of manual operation (e.g., reach-rod with hand wheel or manual operation of pneumatic supply valves from a shielded location), which is accessible to plant operators during sustained operations.

Evaluation To meet the requirement for an alternate means of operation a readily accessible alternate location called the ROS was added. The ROS contains manually operated valves that supply pneumatics to the HCVS flow path valve actuators so that these valves may be opened without Revision 0 Page 21 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 power to the valve actuator solenoids and regardless of any containment isolation signals that may be actuated. This provides a diverse method of valve operation improving system reliability.

The location for the ROS is on Radwaste EL. 135' and is common to both Units 2 and 3. The ROS is readily accessible from the MGR. Refer to the sketch provided in Attachment 6 for the HCVS site layout. The controls available at the ROS location are accessible and functional under a range of plant conditions, including severe accident conditions with due consideration to source term and dose impact on operator exposure, extended loss of AC power (ELAP), inadequate containment cooling, and loss of reactor building ventilation. Table 1 contains an evaluation of all the required controls and instruments that are required for severe accident response and demonstrates that all these controls and instruments will be functional during a loss of AC power and severe accident. Table 2 contains a thermal and radiological evaluation of all the operator actions that may be required to support HCVS operation during a loss of AC power and severe accident and demonstrates that these actions will be possible without undue hazard to the operators. Attachment 6 contains a site layout showing the location of these HCVS actions.

1.2.6 The HCVS shall be capable of operating with dedicated and permanently installed equipment for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the loss of normal power or loss of normal pneumatic supplies to air operated components during an extended loss of AC power.

Evaluation HCVS-WP-01 contains clarification on the definition of "dedicated and permanently installed" with respect to the order. In summary, it is acceptable to use plant equipment that is used for other functions, but it is not acceptable to credit portable equipment that must be moved and connected for the first 24-hour period of the ELAP.

The FLEX Generators will start and load, thus there will be no need to use other power sources for HCVS wetwell venting components during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, this order element does not allow crediting the FLEX Generators for HCVS wetwell venting components until after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Therefore, backup electrical power required for operation of HCVS components in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will come from dedicated 125 Vdc Battery 000510, which is common to both Units 2 and 3. This battery is permanently installed in the Turbine Building (TB) El.135' 3A/3C Battery Room where it is protected from screened in hazards, and has sufficient capacity to provide this power without recharging. Calculation PE-0308 (Reference 50) demonstrated that the 125 Vdc battery capacity is sufficient to supply HCVS wetwell venting components for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. At 24 Revision 0 Page 22 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 hours, FLEX Generators can be credited to repower the battery charger 000509 to recharge the 125 Vdc battery. Gas control during recharging and room temperature control is per the response to order EA-12-049.

Calculation PE-0301 (Reference 51) included the battery charger 000509 in the FLEX Generators loading calculation. The FLEX Generators are capable of carrying the additional HCVS wetwell venting components electrical loads. 125 Vdc battery voltage status will be indicated on battery charger 000509 located in the E33 Switchgear Room in the TB El.135' so that operators will be able to monitor the status of the 125 Vdc battery.

Attachment 3 and 3a contains a diagram of the HCVS electrical distribution system.

Pneumatic power for the HCVS valve actuators is normally provided by the instrument air system and the SGIG nitrogen system with backup nitrogen provided from the HCVS nitrogen backup system. Following an ELAP event, and the loss of instrument air and SGIG, the HCVS nitrogen backup system provides operating pneumatics to the hardened wetwell vent valves. Therefore, for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> post-ELAP initiation, pneumatic force will be supplied from the HCVS nitrogen backup system located at the ROS on Radwaste EL. 135'. Calculation PM-1188 (Reference 52) demonstrated that these installed bottles have the capacity to supply the required motive force to those HCVS valves needed to maintain flow through the HCVS effluent piping for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without replenishment. HCVS nitrogen backup system pressure indication will be provided locally (i.e., in the ROS) by pressure gauges. There are two HCVS nitrogen bottles, each with its' own pressure gauge. In addition, there is a pressure gauge upstream of the nitrogen pressure regulator and another gauge downstream.

1.2.7 The HCVS shall include a means to prevent inadvertent actuation.

Evaluation Emergency operating procedures provide clear guidance that the HCVS is not to be used to defeat containment integrity during any design basis transients and accidents. In addition, the HCVS was designed to provide features to prevent inadvertent actuation due to equipment malfunction or operator error.

The containment isolation valves must be open to permit vent flow. The physical features that prevent inadvertent actuation are the key lock switch for SV-2(3)-07K-2(3)3472 in the MCR and locked closed valves at the ROS. These design features meet the requirement to prevent inadvertent actuation of HCVS.

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Final Integrated Plan HCVS Order EA-13-109 1.2.8 The HCVS shall include a means to monitor the status of the vent system (e.g., valve position indication) from the control panel required by 1.2.4. The monitoring system shall be designed for sustained operation during an extended loss of AC power.

Evaluation The HCVS includes indications for HCVS valve position, vent pipe temperature, effluent radiation levels, and argon supply pressure in the MCA, as well as information on the status of supporting systems which are HCVS 125 VDC battery voltage in the E33 switchgear room and backup nitrogen pressure at the ROS.

This monitoring instrumentation provides the necessary indication from the MCR per Requirement 1.2.4. In the event that the FLEX Generators do not energize the emergency buses, the wetwell HCVS will be supplied by the HCVS 125 Vdc battery for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and sustained operation during an ELAP event can be accomplished using manual operations at the ROS.

Containment pressure and wetwell level instrumentation may be read by portable measuring equipment using FSG-045-2(3) (Reference 53) if the FLEX Generators do not energize the emergency buses.

HCVS instrumentation performance (e.g., accuracy and range) need not exceed that of similar plant installed equipment. Additionally, radiation monitoring instrumentation accuracy and range is sufficient to confirm flow of radionuclides through the HCVS.

The HCVS instruments, including valve position indication, vent pipe temperature, radiation monitoring, and support system monitoring, are seismically qualified as indicated on Table 1 and they include the ability to handle harsh environmental conditions (although they may not be considered part of the site Environmental Qualification (EQ) program).

1.2.9 The HCVS shall include a means to monitor the effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication from the control panel required by 1.2.4 and shall be designed for sustained operation during an extended loss of AC power.

Evaluation The HCVS radiation monitoring system consists of an ion chamber detector installed on Unit 2 RB EL. 195' and Unit 3 RB EL. 165', coupled to a process and control module. The process and control module for both Units 2 and 3 is installed in Panel OOC1062 in the ROS in Radwaste Building EL 135'. The MCR has a radiation indicator on Panel 2(3)0C010 Revision 0 Page 24 September 28, 2018

Final Integrated Plan HCVS Order EA-13-1 09 to verify venting operation. The RM detector is fully qualified for the expected environment at the vent pipe during accident conditions, and the process and control module is qualified for the environment in the Radwaste Building ROS. Both components are qualified for the seismic requirements. Table 1 includes a description and qualification information on the radiation monitor.

1.2.10 The HCVS shall be designed to withstand and remain functional during severe accident conditions, including containment pressure, temperature, and radiation while venting steam, hydrogen, and other non-condensable gases and aerosols. The design is not required to exceed the current capability of the limiting containment components.

Evaluation The wetwell vent up to, and including, the second containment isolation valve is designed consistent with the design basis of the plant. These items include piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication components.

The existing hardened vent piping, between the wetwell and the Torus Room roof is designed to meet the saturation temperature of 308°F at the PBAPS PCPL of 60 psig. A0-2(3)511, A0-2(3)512, and A0-8(9)0290, are also designed to 60 psig. Order EA-13-109 Section A.1.2.10 states that "the design is not required to exceed the current capability of the limiting Containment components". Thus, the 350°F design requirement is not mandatory for Peach Bottom. The 350°F requirement exceeds the current capability of A0-2(3)511, A0-2(3)512, and A0-8(9)0290.

Rupture disc PSD-8(9)0293 is designed to burst at 30 psi g. Wetwell vent piping and components installed downstream of the containment isolation boundary are designed for beyond design basis conditions.

HCVS piping and components have been evaluated for radiological impact due to HCVS system operation under severe accident conditions using the guidance provided in HCVS-FAQ-08 and HCVS-WP-02. The PBAPS HCVS OIP Fifth Six-Month Update (Reference 26) contains the response to Phase 1 ISE (Reference 20) open item 12 regarding the evaluation of HCVS components for severe accident conditions.

Refer to EA-13-109, requirement 1.2.11 for a discussion on designing for combustible gas.

1.2.11 The HCVS shall be designed and operated to ensure the flammability limits of gases passing through the system are not reached; otherwise, Revision O Page 25 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 the system shall be designed to withstand dynamic loading resulting from hydrogen deflagration and detonation.

Evaluation In order to prevent a detonable mixture from developing in the pipe, a purge system is installed to purge hydrogen from the pipe with argon after a period of venting. The purge system is described in EC 556049 (Reference 42) for Unit 2 and EC 556318 (Reference 43) for Unit 3. After an initial line-up of locked valve HV-2(3)-07K-2(3)3478 in ROS and opening argon bottle manifold valves, the system can be operated from MCR by energizing the solenoid valve SV-2(3)-0?K-2(3)3472. Per calculation PM-1189 (Reference 54), an 8-second purge time is required to burst the rupture disc. For purging the combustibles after a vent cycle, a 33-second purge time has been calculated.

Using the purge system described above meets the requirement to ensure the flammability limits of gases passing through the vent pipe will not be reached.

1.2.12 The HCVS shall be designed to minimize the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

Evaluation The response under Order element 1.2.3 explains how the potential for hydrogen migration into other systems, the reactor building or other buildings is minimized.

1.2.13 The HCVS shall include features and provisions for the operation, testing, inspection and maintenance adequate to ensure that reliable function and capability are maintained.

Evaluation:

As endorsed in the ISG, sections 5.4 and 6.2 of NEI 13-02 provide acceptable method(s) for satisfying the requirements for operation, testing, inspection, and maintenance of the HCVS.

Primary and secondary containment required leakage testing is covered under existing design basis testing programs. The HCVS outboard the containment boundary shall be tested to ensure that vent flow is released to the outside with minimal leakage, if any, through the interfacing boundaries with other systems or units.

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Final Integrated Plan HCVS Order EA-13-109 PBAPS has implemented the operation, testing and inspection requirements in Table 3-3 for the HCVS to ensure reliable operation of the system. These requirements are from the NEI 13-02 table under Section 6.2.4. The implementing modification packages contain these as well as additional testing required for post-modification testing with the following exception:

Per Exelon Performance Centered Maintenance (PCM) template, manual valves need to be cycled every 6 years if installed in severe environmental conditions or every 8 years if installed in mild environmental conditions for design basis PM requirements. Per Exelon's engineering judgement, it is deemed that cycling the manual valves (and motor operated valves, check valves within the HCVS pneumatic supply line, and solenoid/air operated valves) within the frequency of the design basis requirements is sufficient for Beyond Design Basis External Events (BDBEE) systems/programs such as HCVS. No new failure modes or degradation is expected for BDBEE systems/programs that is different from design basis. Valves that currently have procedural/programmatic requirements to be cycled on a higher frequency will continue to meet those requirements.

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Final Integrated Plan HCVS Order EA-13-109 T abl e 3-3 T esf 1nQ an di nspec1on f ReqU1rement s Description Frequency Cycle the HCVS valves 1 and the Once per every2 operating cycle.

interfacing system valves not used to maintain containment integrity during operations.

Cycle the HCVS check valves not Once per every other4 operating used to maintain containment cycle.

integrity during unit operations. 3 Perform visual inspections and a Once per operating cycle.

walk down of HCVS components Functionally test the HCVS Once per operating cycle.

radiation monitors.

Leak test the HCVS. (1) Prior to first declaring the system functional; (2) Once every three operating cycles thereafter; and (3) After restoration of any breach of system boundary within the buildings.

Validate the HCVS operating Once per every other operating procedures by conducting an cycle.

open/close test of the HCVS control logic from its control panel (primary and alternate) and ensuring that all interfacing system boundary5 valves move to their proper (intended) positions.

1 Not required for HCVS check valves.

2 After two consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle.

3 Not required if integrity of check function (open and closed) is demonstrated by other plant testing requirements.

4 After two consecutive successful performances, the test frequency may be reduced by one operating cycle to a maximum of once per every fourth operating cycle.

5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (loss of power and/or air) do not require control function testing under this section. Performing existing plant design basis function testing or system operation that reposition the valve(s) to the HCVS required position will meet this requirement without the need for additional testing.

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Final Integrated Plan HCVS Order EA-13-109

2. HCVS Quality Standards:

2.1. The HCVS vent path up to and including the second containment isolation barrier shall be designed consistent with the design basis of the plant. Items in this path include piping, piping supports, containment isolation valves, containment isolation valve actuators, and containment isolation valve position indication components.

Evaluation:

The HCVS upstream of and including the second containment isolation valve (A0-8(9)0290) and penetrations are not being modified for order compliance so that they continue to be designed consistent with the design basis of primary containment including pressure, temperature, radiation, and seismic loads.

2.2. All other HCVS components shall be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. These items include electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components.

Evaluation:

The HCVS components downstream of the outboard containment isolation valve and components that interface with the HCVS are routed in seismically qualified structures or supported from seismically qualified structures.

The HCVS downstream of the outboard containment isolation valve, including piping and supports, electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components, have been designed and analyzed to conform to the requirements consistent with the applicable design codes for the plant and to ensure functionality following a design basis earthquake. This includes environmental qualification consistent with expected conditions at the equipment location.

Table 1 contains a list of components, controls and instruments required to operate HCVS, their qualification and evaluation against the expected conditions. All instruments are fully qualified for the expected seismic conditions so that they will remain functional following a seismic event.

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Final Integrated Plan HCVS Order EA-13-109 Section IV: HCVS Phase 2 Final Integrated Plan Section IV.A: The requirements of EA-13-109, Attachment 2, Section B for Phase 2 Licensees with BWRs Mark I and Mark II containments shall either:

(1) Design and install a HCVS, using a vent path from the containment drywall, that meets the requirements in section B.1 below, or (2) Develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywall before alternate reliable containment heat removal and pressure control is reestablished and meets the requirements in Section B.2 below.

1. HCVS Drywall Vent Functional Requirements 1.1 The drywall venting system shall be designed to vent the containment atmosphere (including steam, hydrogen, non-condensable gases, aerosols, and fission products), and control containment pressure within acceptable limits during severe accident conditions.

1.2 The same functional requirements (reflecting accident conditions in the drywall),

quality requirements, and programmatic requirements defined in Section A of this Attachment for the wetwell venting system shall also apply to the drywall venting system.

2. Containment Venting Strategy Requirements Licensees choosing to develop and implement a reliable containment venting strategy that does not require a reliable, severe accident capable drywall venting system shall meet the following requirements:

2.1 The strategy making it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions shall be part of the overall accident management plan for Mark I and Mark II containments.

2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing needed instrumentation.

Because the order contains just three requirements for the containment venting strategy, the compliance elements are in NEI 13-02, Revision 1. NEI 13-02, Revision 1, endorsed by NRG in JLD-ISG-2015-01, provides the guidance for the Revision 0 Page 30 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 containment venting strategy (B.2) of the order. NEI 13-02, Revision 1, provides SAWA in conjunction with Severe Accident Water Management (SAWM), which is designed to maintain the wetwell vent in service until alternate reliable containment heat removal and pressure control are established, as the means for compliance with part B of the order.

PBAPS has implemented Containment Venting Strategy (B.2), as the compliance method for Phase 2 of the Order and conforms to the associated guidance in NEI 13-02 Revision 1 for this compliance method.

Section IV.B: HCVS Existing System There previously was neither a hardened drywell vent nor a strategy at PBAPS that complied with Phase 2 of the order.

Section IV.C: HCVS Phase 2 SAWA System and SAWM Strategy The HCVS Phase 2 SAWA system and SAWM strategy utilize the FLEX mitigation equipment and strategies to the extent practical. This approach is reasonable because the external hazards and the event initiator (ELAP) are the same for both FLEX mitigation strategies and HCVS. For SAWA, it is assumed that the initial FLEX response actions are unsuccessful in providing core cooling such that core damage contributes to significant radiological impacts that may impede the deployment, connection and use of FLEX equipment. These radiological impacts, including dose from containment and HCVS vent line shine were evaluated and modifications made as necessary to mitigate the radiological impacts such that the actions needed to implement SAWA and SAWM are feasible in the timeframes necessary to protect the containment from overpressure related failure . To the extent practical, the SAWA equipment, connection points, deployment locations and access routes are the same as the FLEX primary strategies so that a Unit that initially implements FLEX actions that later degrades to severe accident conditions can readily transition between FLEX and SAWA strategies. This approach further enhances the feasibility of SAWA under a variety of event sequences including timing.

PBAPS has implemented the containment venting strategy utilizing SAWA and SAWM. The SAWA system consists of a FLEX (SAWA) Pump injecting into the Reactor Pressure Vessel (RPV) and SAWM consists of flow control at the FLEX (SAWA) Pump along with instrumentation and procedures to ensure that the wetwell vent is not submerged (SAWM). Procedures have been issued to implement this strategy including revision 3 to the Severe Accident Management Guidelines (SAMG). This strategy has been shown via Modular Accident Analysis Program (MAAP) analysis to protect containment without requiring a drywell vent for at least seven days which is the guidance from NEI 13-02 for the period of sustained operation.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.1: Detailed SAWA Flow Path Description The SAWA flow path is the same as the FLEX primary injection path. The SAWA system, shown on Attachment 4, consists of a FLEX Pump injecting into the Reactor Pressure Vessel (APV) and SAWM consists of flow control at the FLEX Pump along with wetwell level indication to ensure that the wetwell vent is not submerged (SAWM). The SAWA injection path, starts at the Emergency Cooling Tower (ECT), goes to the FLEX Pump via suction hoses, goes through the FLEX Pump to a flexible discharge hose, then to a Residual Heat Removal (AHA)_

connection in the Unit's Reactor Building Closed Cooling Water (RBCCW) room to the Reactor Pressure Vessel (RPV). The hoses and pumps are stored in the FLEX Building (FB) which is protected from all hazards. BWROG generic assessment, BWROG-TP-15-008 (Reference 36), provides the principles of Severe Accident Water Addition to ensure protection of containment. This SAWA injection path is qualified for the all the screened in hazards (Section Ill) in addition to severe accident conditions.

Section IV.C.2: Severe Accident Assessment of Flow Path The actions inside the RB where there could be a high radiation field due to a severe accident will be to open valves at the AHR connection in the RBCCW room at EL. 116' that is accessed via doors and a stairwell from outside of the RB at EL. 135'. The action to open valves inside the RB will be performed before the dose is unacceptable after the loss of RPV injection. In this event, radiation levels and heat related concerns in the RB when the valves are operated were evaluated and determined to be acceptable per PM-1207 (Reference 55). The other SAWA actions all take place outside the RB at the MCA, ECT, FB, and the deployment pathways. Since these locations are outside the RB, they are shielded from the severe accident radiation by the thick concrete walls of the RB and other structures. Once SAWA is initiated, the operators will monitor the response of containment from the MCA to determine that venting and SAWA are operating satisfactorily, maintaining containment pressure low to avoid containment failure .

Stable or slowly rising trend in wetwell level with SAWA at the minimum flow rate indicates water on the drywell floor up to the vent pipe or downcomer openings.

After some period of time, as decay heat levels decrease, the operators will be able to reduce SAWA flow to keep the core debris cool while avoiding overfilling the torus to the point where the wetwell vent is submerged.

Section IV.C.3: Severe Accident Assessment of Safety-Relief Valves PBAPS has methods available to extend the operational capability of manual pressure control using SRVs as provided in the plant specific order EA-12-049 submittal. Assessment of manual SRV pressure control capability for use of SAWA during the Order defined accident is unnecessary because RPV depressurization is directed by the EPGs in all cases prior to entry into the SAGs.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.4: Available Freeboard Use The freeboard between 14.7' to 21' elevation in the wetwell provides approximately 525,000 gallons of water volume before the level instrument would be off scale high. BWROG generic assessment BWROG-TP-15-011, provides the principles of Severe Accident Water Management to preserve the wetwell vent for a minimum of seven days. After containment parameters are stabilized with SAWA flow, SAWA flow will be reduced to a point where containment pressure will remain low while wetwell level is stable or very slowly rising. As shown in PB-MISC-023 (Reference 64), the wetwell level will not reach the wetwell vent for at least seven days. A diagram of the available freeboard is shown on Attachment 1.

Section IV.C.5: Upper range of wetwell level indication The upper range of wetwell level indication [Ll-8(9)123A] provided for SAWA/SAWM is 21 feet elevation. This defines the upper limit of wetwell indicated level that will preserve the wetwell vent function as shown in Attachment 1.

Section IV.C.6: Wetwell vent service time EPRI Technical Report 3002003301 and BWROG-TP-15-011 demonstrate that throttling SAWA flow after containment parameters have stabilized, in conjunction with venting containment through the wetwell vent will result in a stable or slowly rising wetwell level. The references demonstrate that, for the scenario analyzed, wetwell level will remain below the wetwell vent pipe for greater than the seven days of sustained operation allowing significant time for restoration of alternate containment pressure control and heat removal.

Section IV.C.7: Strategy time line The overall accident management plan for PBAPS is developed from the BWR Owner's Group Emergency Procedure Guidelines and Severe Accident Guidelines (EPG/SAG). As such, the SAWA/SAWM implementing procedures are integrated into the PBAPS SAMGs. In particular, EPG/SAG Revision 3, when implemented with Emergency Procedures Committee Generic Issue 1314, allows throttling of SAWA in order to protect containment while maintaining the wetwell vent in service. The SAMG flow charts direct use of the hardened vent as well as SAWA/SAWM when the appropriate plant conditions have been reached.

Using NEI 12-06, PBAPS has validated that the SAWA pump can be deployed and commence injection in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The studies referenced in NEI 13-02 demonstrated that establishing flow within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will protect containment. The initial SAWA flow rate will be at least 500 gpm. After a period of time, estimated to be about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, in which the maximum flow rate is maintained, the SAWA flow will be reduced. The reduction in flow rate and the timing of the reduction will be based on stabilization of the containment parameters of drywell pressure and wetwell level.

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Final Integrated Plan HCVS Order EA-13-109 NEI 13-02 generic analysis per EPRI Technical Report 3002003301 demonstrated that, SAWA flow could be reduced to 100 gpm after four hours of initial SAWA flow rate and containment would be protected. At some point wetwell level will begin to rise indicating that the SAWA flow is greater than the steaming rate due to containment heat load such that flow can be reduced. While this is expected to be 4-6 hours, no time is specified in the procedures because the SAMGs are symptom-based guidelines.

Section IV.C.8: SAWA Flow Control PBAPS will accomplish SAWA flow control by the use of throttle valves and/or adjusting FLEX/SAWA Pump speed. The operators at the FLEX/SAWA Pump will be in communication with the MCR via radios and the exact time to throttle flow is not critical since there is a large margin between normal wetwell level and the level at which the wetwell vent will be submerged. The communications capabilities that will be used for communication between the MGR and the SAWA flow control location are the same as that evaluated and found acceptable for FLEX strategies.

The communications capabilities have been tested to ensure functionality at the SAWA flow control and monitoring locations. PBAPS utilizes FSG-020, "Deploying Alternate Radio Communications Antenna" (Reference 57) to place a spare radio repeater in service to facilitate radio communications between the MCR and remote locations such as the FLEX/SAWA Pump.

Section IV.C.9: SAWA/SAWM Element Assessment Section IV.C.9.1: SAWA Pump PBAPS uses two portable diesel-driven pumps for FLEX and SAWA, one pump for each Unit. Each pump is capable of meeting the required flowrates at the pressures required for RPV injection during an ELAP. Each of these pumps has been shown to be capable of supplying the required flow rate to the RPV and the SFP for FLEX and for SAWA scenarios. The pumps are stored in the FLEX Building where they are protected from all screened-in hazards and are rugged, over the road, trailer-mounted units, and therefore will be available to function after a seismic event.

Section IV.C.9.2: SAWA analysis of flow rates and timing PBAPS SAWA flow is 500 gpm which is the amount assumed in NEI 13-02 Section 4.1.1.2.1. The initial SAWA flow will be injecting to the RPV within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of injection. The reference power level is 3514 MWth, equivalent to the reference plant rated thermal power level used in NUREG-1935, State of the Art Reactor Consequence Analysis (SOARCA). NUREG 1935 is Reference 9 of NEI 13-02 Revision 1.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.9.3: SAWA Pump Hydraulic Analysis Calculation PM-1205 (Reference 56) analyzed the FLEX pumps and the lineup for RPV injection that would be used for SAWA. This calculation showed that the pumps have adequate capacity to meet the SAWA flow rate required to protect containment.

Section IV.C.9.4: SAWA Method of backflow prevention The PBAPS SAWA flow path goes through a FLEX/SAWA Pump check valve that is integral with the pump skid and will close and prevent leakage when the FLEX/SAWA Pump is secured. The SAWA flow path also includes existing station Primary Containment Isolation Valve (PCIV) check valve A0-2(3)-10-046A whose integrity of check function (open and closed) is demonstrated by other plant testing requirements such that additional testing per NEI 13-02 Revision 1 Section 6.2 is not required for the valve per NEI 13-02 Revision 1 Table 6-1 Note 3. Thus, backflow is prevented by check valves in the SAWA flow path.

Section IV.C.9.5: SAWA Water Source The initial source of water for SAWA is the ECT which can provide at least 3.55 million gallons of water sufficient for approximately 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> of water injection without makeup based on the FLEX analysis. Before this initial supply of water is depleted, arrangements will be made for obtaining water makeup to the ECT via the Emergency Response Organization or the Nuclear Duty Officer (NDO).

Makeup water can be obtained through contact with the National SAFER Response Centers (NSRC). This long-term strategy of water supply was qualified for order EA-12-049 response and is available during a severe accident.

Therefore, there will be sufficient water for injection to protect containment during the period of sustained operation.

Section IV.C.9.6: SAWA/SAWM Motive Force Section IV.C.9.6.1: SAWA Pump Power Source The FLEX/SAWA Pumps are stored in the FLEX Building where they are protected from screened-in hazards or pre-deployed, if necessary. The FLEX/SAWA Pumps are commercial pumps rated for long-term outdoor use in emergency scenarios.

The pumps are diesel-driven by an engine mounted on the skid with the pump.

The pumps will be refueled by the FLEX refueling equipment that has been qualified for long-term refueling operations per EA-12-049. The action to refuel the FLEX/SAWA Pumps was evaluated under severe accident conditions in Table 2, and demonstrated to be acceptable. Since the pumps are stored in a protected structure(s), are qualified for the environment in which they will be used, and will be refueled by a qualified refueling strategy, they will perform their function to maintain SAWA flow needed to protect primary containment per EA-13-109.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.9.6.2: DG loading calculation for SAWA/SAWM equipment Table 1 shows the electrical power source for the SAWA/SAWM instruments. For the instruments powered by the HCVS 125VDC battery, calculation PE-0308 (Reference 50) demonstrates that the batteries can provide power until the FLEX Generator restores power to the battery charger.

The FLEX load on the FLEX Generator per EA-12-049 was evaluated in calculation PE-0301 (Reference 51 ). This calculation demonstrated that the total kW and kVA loading is less than machine rating of 500 kW and 625 kVA, and therefore, the loading meets the acceptance criteria of the calculation. The additional load on the FLEX Generator for SAWA and SAWM consist of the HCVS 125 VDC battery charger 000509. This additional load was evaluated in calculation PE-0301 and determined to be acceptable. The FLEX Generator was qualified to carry the rest of the FLEX loads as part of Order EA-12-049 compliance.

Section IV.C.10: SAWA/SAWM Instrumentation

1) The instruments credited for SAWA are:

• PT/PRn-R-4(5)805 used to measure containment pressure

• Ll-8(9)123A used to measure wetwell level

• SAWA/SAWM flow meter used to measure flow to the RPV

2) The SAWA/SAWM flow meter is required to determine the flow of water going to the Reactor Pressure Vessel. The flow meter is a Badger M5000 Electronic Remote Monitor Flow Meter (reference EC 618957 Attachment 4, Reference 45) that will measure and display flow rate directly. The instrument is designed around a digital meter with an electromagnetic flow sensor.

3) Recorders PRn-R-4(5)805 are currently relied upon to obtain containment pressure indication under FLEX Strategies.

Components PRn-R-4(5)805 are Regulatory Guide (RG) 1.97 qualified (Class 2) and therefore do not require further evaluation; however, not all components that are either in the associated instrument loop or that may affect the loop are RG 1.97 qualified and were evaluated against RG 1.97 criteria for both dose and thermal effects. These components include PT-4(5)805 and Panel 2(3)DC834. Per EC 618957 Attachment 09A (Reference 45), these components are determined to be either acceptable or have no adverse effect on the PRn-R-4(5)805 instrument loop if failure occurred.

The SAWA/SAWM flow meter, installed with 300-lb flanges, is capable of withstanding pressure up to 740 psi, which is considerably Revision 0 Page 36 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 greater than FLEX/SAWA Pump discharge pressure. The temperature range is -4°F to 140°F. The flow meter is stored in the FB which is a seismically qualified building and temperature controlled. In the FB, radiation exposure will be kept minimal based on the storage location. When deployed for BDB event, the SAWA/SAWM flow meters will be placed on the ground in close proximity to the FLEX/SAWA Pumps that are located north of the Unit 3 RB in an area where dose is analyzed as acceptable by calculation PM-1190 (Reference 39). Per Exelon White Paper EXC-WP-06, Documenting ELAP Design Bases, Attachment 2 (Reference 58), a reasonable conservative outside ambient temperature that is not exceeded more than 1% of the time is considered reasonably conservative for a BDBEE. Therefore, based on the ASH RAE Handbook, temperatures do not drop lower than 15.5°F more than 1% of the time in Lancaster, PA, and is used to establish an approximate low end ambient temperature for Peach Bottom, which is well above the -4°F lower temperature limit of the Badger M5000 flow meter. The 140°F upper temperature limit is not an issue as the flow meter is located outside the plant.

4) The SAWA/SAWM flow meter is powered by a local lithium ion battery pack. The life of the battery pack is dependent on the frequency that the flow meter measures flow. At the shortest sampling frequency of 0.25 seconds, the battery pack will last 3 months.

5) Containment pressure and wetwell level instrumentation will be repowered through their respective electrical buses by the use of the FLEX Generator.

Section IV.C.10.1: SAWA/SAWM instruments Table 1 contains a listing of all the instruments needed for SAWA and SAWM implementation. This table also contains the expected environmental parameters for each instrument, its qualifications, and its power supply for sustained operation.

Section IV.C.10.2: Describe SAWA instruments and guidance The drywall pressure and wetwell level instruments, used to monitor the condition of containment, are pressure and differential pressure detectors that are safety-related and qualified for post-accident use. These instruments are referenced in Severe Accident Guidelines for control of SAWA flow to maintain the wetwell vent in service while maintaining containment protection. These instruments are powered by batteries for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and will be re-powered by FLEX Generator systems for the sustained operating period. These instruments are on buses included in the FLEX generator loading calculations for EA-12-049. Note Revision O Page 37 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 that other indications of these parameters may be available depending on the exact scenario.

The SAWA flow meter is an electromagnetic flow meter installed in the FLEX/SAWA Pump discharge hose in close proximity to the pump and is powered by a local lithium ion battery pack.

No containment temperature instrumentation is required for compliance with HCVS Phase 2. However, most FLEX electrical strategies repower other containment instruments that include drywell temperature, which may provide information for the Operations staff to evaluate plant conditions under a severe accident and provide confirmation to adjust SAWA flow rates. SAMG strategies will evaluate and use drywell temperature indication if available consistent with the symptom-based approach. NEI 13-02 Revision 1 Section C.8.3 discusses installed drywell temperature indication.

Section IV.C.10.3: Qualification of SAWA/SAWM instruments The drywell pressure and wetwell level instruments are pressure and differential pressure detectors that are safety-related and qualified for post-accident use.

The SAWA flow meter is rated for continuous use under the expected ambient conditions and so will be available for the entire period of sustained operation.

Furthermore, since the FLEX/SAWA Pump is deployed outside the RB, and in a low dose area as analyzed by calculation PM-1190 (Reference 39), there is no concern for any effects of radiation exposure to the flow instrument.

Section IV .C.10.4: Instrument Power Supply through Sustained Operation PBAPS FLEX strategies will restore the containment instruments, containment pressure and wetwell level, necessary to successfully implement SAWA. The strategy will be to use the FLEX Generator to re-power battery chargers before the batteries supplying the instruments are depleted. Since the FLEX Generators are refueled per FLEX strategies for a sustained period of operation, the instruments will be powered for the sustained operating period.

Section IV.C.11: SAWA/SAWM Severe Accident Considerations The most important Severe Accident consideration is the radiological dose as a result of the accident and operation of the HCVS. Calculation PM-1207 (Reference 55) analyzed dose at different locations and times where operator actions will take place during FLEX/SAWA/SAWM activities. Tables 8-1 and 8-2 of PM-1207 provide this dose information. FSG-030, FSG-031, FSG-032-2(3), and FSG-033-2(3) (References 47, 59, 60, and 61) provide guidance for ventilation strategies at various locations to mitigate high temperature conditions.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.11.1: Severe Accident Effect on SAWA Pump and Flowpath Since the FLEX/SAWA Pumps are stored in the FLEX Building and will be operated from outside the RB north of the Unit 3 RB in an area shielded from the vent pipes, there will be no issues with radiation dose rates at the SAWA pump control location and there will be no significant dose to the SAWA pump.

Inside the RB the SAWA flow path consists of piping that will be unaffected by the radiation dose and hoses that will be run only in locations that are shielded from significant radiation dose or that have been evaluated for the integrated dose effects over the period of Sustained Operation. These hoses are qualified for the temperatures expected in the areas they will be run. Therefore, the SAWA flow path will not be affected by radiation or temperature effects due to a severe accident.

Section IV.C.11.2: Severe Accident Effect on SAW A/SAWM instruments The SAWA/SAWM instruments are described in section IV.C.9.3; that section provides severe accident effects.

Section IV.C.11.3: Severe Accident Effect on personnel actionsSection IV.C.2 describes the RB actions within the first 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The actions including access routes outside the Reactor Building that will be performed after the first use of the vent during severe accident conditions (assumed to be 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per HCVS-FAQ-12) are located such that they are either shielded from direct exposure to the vent line or are a significant distance from the vent line so that expected dose is maintained below the ERO exposure guidelines.

As part of the response to Order EA-12-049, PBAPS performed 02493544-28, Technical Evaluation to Document PBAPS ELAP Temperature (Reference 62) for the temperature response of the Reactor Building during the ELAP event. Since, in the severe accident, the core materials are contained inside the primary containment, the temperature response of the RB is driven by the loss of ventilation and ambient conditions and therefore will not change. Thus, the FLEX technical evaluation is acceptable for severe accident use as evaluated in EC 618957 Attachment 09B, "Temp Eval during a SA" (Reference 45).

Table 2 provides a list of SAWA/SAWM operator actions as well as an evaluation of each for suitability during a severe accident. Attachment 6 shows the approximate locations of the actions.

After the SAWA pipe is aligned inside the RB, the operators can control SAWA/SAWM as well as observe the necessary instruments from outside the RB.

The thick concrete RB walls as well as the distance to the core materials means that there is no radiological concern with any actions outside the RB. Therefore, Revision O Page 39 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 all SAWA controls and indications are accessible during severe accident conditions.

The FLEX/SAWA Pump and flow monitoring equipment can all be operated from outside the RB at ground level. The PBAPS FLEX response ensures that the FLEX/SAWA Pump, FLEX Generators, and other equipment can all be run for a sustained period by refueling. All the refueling locations are located in shielded or protected areas so that there is no radiation hazard from core material during a severe accident. The monitoring instrumentation includes SAWA flow at the FLEX/SAWA Pump, and wetwell level and containment pressure in the MCR.

Section V: HCVS Programmatic RequirementsSection V.A: HCVS Procedure Requirements Licensees shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power.

Evaluation:

Procedures have been established for system operations when normal and backup power is available, and during ELAP conditions. The implementing design change documents contain instructions for modifying the HCVS specific procedures.

The HCVS and SAWA procedures have been developed and implemented following PBAPS process for initiating and/or revising procedures and contain the following details:

• appropriate conditions and criteria for use of the system

• when and how to place the system in operation,

• the location of system components,

• instrumentation available,

• normal and backup power supplies,

• directions for sustained operation, including the storage location of portable equipment,

• training on operating the portable equipment, and

• testing portable equipment Revision 0 Page 40 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 PBAPS has implemented the BWROG Emergency Procedures Committee Issue 1314 that implements the Severe Accident Water Management (SAWM) strategy in the Severe Accident Management Guidelines (SAMGs). The following general cautions, priorities and methods have been evaluated for plant specific applicability and incorporated as appropriate into the plant specific SAMGs using administrative procedures for EPG/SAG change control process and implementation. SAMGs are symptom-based guidelines and therefore address a wide variety of possible plant conditions and capabilities. While these changes are intended to accommodate those specific conditions assumed in Order EA-13-109, the changes were made in a way that maintains the use of SAMGs in a symptom-based mode while at the same time addressing those conditions that may exist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris.

Cautions

• Adding water to hot core debris may pressurize the containment by rapid steam generation.

• Raising Torus level above 21 ft. will prevent use of the Torus vent path Priorities - With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases as follows:

• Stabilize core debris in the containment (SAWA)

• Operate Drywall sprays

• Cool core debris in the containment (SAWM)

• Preserve Torus vent capability

• Operate Core Spray

• Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting)

Methods - Identify systems and capabilities to add water to the RPV or drywall, with the following generic guidance:

• Use any available injection source

• Raise injection slowly

• Inject into the RPV if possible Revision 0 Page 41 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109

• Maintain injection from external sources of water as low as practicable Section V.B: HCVS Out of Service Requirements Provisions for out-of-service requirements for FLEX and HCVS are provided in CC-PB-118, Attachment 7 (Reference 63).

Programmatic controls have been implemented to document and control the following:

NOTE: Out of service times and required actions noted below are for HCVS and SAWA functions. Equipment that also supports a FLEX function that is found to be non-functional must also be addressed using the out of service times and actions in accordance with the FLEX program.

The provisions for out-of-service requirements for HCVS and SAWA functionality are applicable in Modes 1, 2, and 3 per NEI 13-02, 6.3.

• If for up to 90 consecutive days, the primary or alternate means of HCVS operation are non-functional, no compensatory actions are necessary.

• If up for to 30 days, the primary and alternate means of HCVS operation or SAWA are non-functional, no compensatory actions are necessary.

• If the out of service times projected to exceed 30 or 90 days as described above, the following actions will be performed through the corrective action system determine:

o The cause(s) of the non-functionality, o The actions to be taken and the schedule for restoring the system to functional status and prevent recurrence, o Initiate action to implement appropriate compensatory actions, and o Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle.

The HCVS system is functional when piping, valves, instrumentation and controls including motive force necessary to support system operation are available. Since the system is designed to allow a primary control and monitoring or alternate valve control by Order criteria 1.2.4 or 1.2.5, allowing for a longer out of service time with either of the functional capabilities maintained is justified. A shorter length of time when both primary control and monitoring and alternate valve control are unavailable is needed to restore system functionality in a timely manner while at the same time allowing for component repair or replacement in a time frame consistent with most high priority maintenance scheduling and repair programs, not Revision 0 Page 42 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 to exceed 30 days unless compensatory actions are established per NEI 13-02 Section 6.3.1.3.3.

SAWA is functional when piping, valves, motive force, instrumentation and controls necessary to support system operation are functional.

The system functionality basis is for coping with beyond design basis events and therefore plant shutdown to address non-functional conditions is not warranted.

However, such conditions should be addressed by the corrective action program and compensatory actions to address the non-functional condition should be established. These compensatory actions may include alternative containment venting strategies or other strategies needed to reduce the likelihood of loss of fission product cladding integrity during design basis and beyond design basis events even though the severe accident capability of the vent system is degraded or non-functional. Compensatory actions may include actions to reduce the likelihood of needing the vent but may not provide redundant vent capability.

Applicability for allowed out of service time for HCVS and SAWA for system functional requirements is limited to startup, power operation and hot shutdown conditions when primary containment is required to be operable and containment integrity may be challenged by decay heat generation.

Section V .C: HCVS Training Requirements Licensee shall train appropriate personnel in the use of the HCVS. The training curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power.

Evaluation:

Personnel expected to perform direct execution of the HCVS have received necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS. The personnel trained and the frequency of training was determined using a systematic analysis of the tasks to be performed using the Systems Approach to Training (SAT) process.

In addition, per NEI 12-06, any non-trained personnel on-site will be available to supplement trained personnel.

Section V.D: Demonstration with other Post Fukushima Measures PBAPS will demonstrate use of the HCVS and SAWA systems in drills, tabletops or exercises as follows:

1. Hardened containment vent operation on normal power sources (no ELAP)

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Final Integrated Plan HCVS Order EA-13-109

2. During FLEX demonstrations (as required by EA-12-049: Hardened containment vent operation on backup power and from primary or alternate locations during conditions of ELAP/loss of UHS with no core damage.)

System use is for containment heat removal AND containment pressure control.

3. HCVS operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with core damage. System use is for containment heat removal AND containment pressure control with potential for combustible gases.

Evaluation NOTE: Items 1 and 2 above are not applicable to SAWA.

The use of the HCVS and SAWA capabilities will be demonstrated during drills, tabletops or exercises consistent with NEI 13-06 and on a frequency consistent with 10 CFR 50.155(e)(4). PBAPS will perform the first drill demonstrating at least one of the above capabilities by November 6, 2021 which is within four years of the first unit compliance with Phase 2 of Order EA-13-109, or consistent with the next FLEX strategy drill or exercise. Subsequent drills, tabletops or exercises will be performed to demonstrate the capabilities of different elements of Items 1, 2 and/or 3 above that is applicable to PBAPS in subsequent eight-year intervals.

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Final Integrated Plan HCVS Order EA-13-109 Section VI: References Number Rev Title Location6

1. GL-89-16 0 Installation of a Hardened Wetwell Vent ML031140220 (Generic Letter 89-16), dated September 1, 1989.

2. SECY-12-0157 0 Consideration of Additional Requirements for ML12345A030 Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments

3. SRM-SECY 0 Staff Requirements - SECY-12-0157 - ML13078A017 0157 Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments

4. EA-12-050 0 Order to Modify Licenses with Regard to ML12054A694 Reliable Hardened Containment Vents

5. EA-13-109 0 Order to Modify Licenses with Regard to ML13143A321 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

6. NEI 13-02 0 Industry Guidance for Compliance with Order ML13316A853 EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

7. NEI 13-027 1 Industry Guidance for Compliance with Order ML15113B318 EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

8. HCVS-WP-01 0 Hardened Containment Vent System ML14120A295 Dedicated and Permanently Installed Motive ML14126A374 Force, Revision 0, April 14, 2014

9. HCVS-WP-02 0 Sequences for HCVS Design and Method for ML14358A038 Determining Radiological Dose from HCVS ML14358A040 Piping, Revision 0, October 23, 2014

10. HCVS-WP-03 1 Hydrogen/Carbon Monoxide Control ML14302A066 Measures Revision 1, October 2014 ML15040A038 11 . HCVS-WP-04 0 Missile Evaluation for HCVS Components 30 ML15244A923 Feet Above Grade ML15240A072 6

Where two ADAMS accession numbers are listed, the first is the reference document and the second is the NRC endorsement of that document.

7 NEI 13-02 Revision 1 Appendix J contains HCVS-FAQ-01 through HCVS-FAQ-09.

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Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location 6

12. JLD-ISG-2013- 0 Compliance with Order EA-13-109, Order ML13304B836 02 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

13. JLD-ISG-2015- 0 Compliance with Order EA-13-109, Order ML15104A118 01 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

14. HCVS-FAQ-10 1 Severe Accident Multiple Unit Response ML15273A141 ML15271A148

15. HCVS-FAQ-11 0 Plant Response During a Severe Accident ML15273A141 ML15271A148

16. HCVS-FAQ-12 0 Radiological Evaluations on Plant Actions ML15273A141 Prior to HCVS Initial Use ML15271A148

17. HCVS-FAQ-13 0 Severe Accident Venting Actions Validation ML15273A141 ML15271A148

18. Phase 1 OIP 0 HCVS Phase 1 Overall Integrated Plan (OIP) ML14181A301

19. Combined OIP 0 Combined HCVS Phase 1 and 2 Overall ML15364A015 Integrated Plan (OIP), Dec. 2015

20. Phase 1 ISE 0 HCVS Phase 1 Interim Staff Evaluation (ISE) ML15026A469

21. Phase 2 ISE 0 HCVS Phase 2 Interim Staff Evaluation (ISE) ML16099A272

22. 1st Update 0 First Six-Month Update, Dec. 2014 ML14353A125

23. 2nd Update 0 Second Six-Month Update, June 2015 ML15181A018

24. 3rd Update 0 Third Six-Month Update (same as Ref 19) ML15364A015

25. 4th Update 0 Fourth Six-Month Update, June 2016 ML16182A012

26. 5th Update 0 Fifth Six-Month Update, Dec. 2016 ML16350A265

27. 6th Update 0 Sixth-Six Month Update, June 2017 ML17181A034

28. 7th Update 0 Seventh-Six Month Update, Dec. 2017 ML17349A038

29. 8th Update 0 Eighth-Six Month Update, June 2018 ML18180A032

30. Radwaste ROS 4 ECR 15-00148 (EC 556049) Attachments N/A Temp Eval 46A and 46B

31. NEl12-06 0 Diverse and Flexible Coping Strategies ML12221A205 (FLEX) Implementation Guide

32. EA-12-049 0 Issuance of Order to Modify Licenses With ML12054A735 Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.

Revision 0 Page 46 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location6

33. AG 1.97 3 Instrumentation for Light-Water-Cooled ML003740282 Nuclear Power Plants to Assess Conditions During and Following an Accident

34. TR-1026539 0 EPRI Investigation of Strategies for Mitigating N/A Radiological Releases in Severe Accidents BWR, Mark I and Mark II Studies, October 2012

35. RS-18-002 0 PBAPS FLEX Final Integrated Plan ML18005A701 Document, January 5, 2018

36. BWROG-TP 0 BWROG Fukushima Response Committee, N/A 008 Severe Accident Water Addition Timing, Sept. 2015

37. BWROG-TP 0 BWROG Fukushima Response Committee, N/A 011 Severe Accident Water Management Supporting Evaluations, Oct. 2015

38. FSG-050 3 FLEX Equipment Fuel Oil Supply N/A

39. PM-1190 1 HCVS Dose Assessment N/A

40. T-200-2(3) 14 Primary Containment Venting N/A (17)

41. T-200J-2(3) 5 Containment Venting via the Torus Hardened N/A (4) Vent

42. EC 556049 4 Fukushima Modification - U2 Hardened N/A Containment Vent System

43. EC 556318 4 Fukushima Modification - U3 Hardened N/A Containment Vent System

44. EC 620431 0 Fukushima Modification - U2 HCVS Phase 2 N/A (SAWA/SAWM)

45. EC 618957 1 Fukushima Modification - U3 HCVS Phase 2 N/A (SAWA/SAWM)

Revision 0 Page 47 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location6

46. EXC-WP-11 2 Prevention of Hydrogen Deflagration and N/A Detonation in HCVS Piping

47. FSG-030 1 Establishing Control Room Ventilation and N/A Lighting

48. PM-0546 6 Torus Hardened Vent-Flow Calculation N/A

49. PB-MISC-010 6 Peach Bottom MAAP Analysis to Support N/A FLEX Initial Strategy

50. PE-0308 1 HCVS Battery Sizing and Selection N/A

51. PE-0301 Oc FLEX Electrical Loading and Voltage Drop N/A

52. PM-1188 2 HCVS Compressed Nitrogen Bottle Sizing N/A Calculation

53. FSG-045-2(3) 0 Obtaining Transmitter Instrument Readings N/A (0)

54. PM-1189 2 Hardened Containment Vent System Purge N/A System Design Calculation

55. PM-1207 1 HCVS Phase II Dose Assessment N/A

56. PM-1205 0 Severe Accident Water Addition SAWA N/A Makeup Analysis in Response to NRC Order EA-13-109

57. FSG-020 0 Deploying Alternate Radio Communications N/A Antenna

58. EXC-WP-06 2 Documenting ELAP Design Bases N/A

59. FSG-031 0 Establishing Battery Room and Switchgear N/A Room Ventilation Revision 0 Page 48 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location 6

60. FSG-032-2(3) 0 Establishing HPCl/RCIC/Sump Room N/A (0) Ventilation, Lighting and Water Removal

61. FSG-033-2(3) 0 Establishing Natural Circulation of the N/A (0) Secondary Containment Atmosphere

62. 02493544-28 - Technical Evaluation to Document PBAPS N/A ELAP Temperature (Passport Action Item)

63. CC-PB-118 6 Peach Bottom Implementation of Diverse and N/A Flexible Coping Strategies (FLEX) and Spent Fuel Pool Instrumentation Program

64. PB-MISC-023 1 MAAP Analysis to Support HCVS Design N/A Revision 0 Page 49 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 1 : Phase 2 Freeboard diagram Bottom of vent pipe 29.5' pmover height 28' -0" Spillover depth =2' -7" Additional freeboard height = 8.5' Drywell floor 25'-5" Freeboard height = 14.7' to 21 '

Level Instrument span 0 to 21' Normal Torus (level} 14.7' At 500 GPM SAWA flow, rate of rise is 0.37 feet/hour * "Does not consider mass loss At 100 GPM SAWA flow, rat e of rise is 0.07 feet/hour* rate of steam leaving conta inment through wetwell vent path Torus bottom (level) o*

Revision 0 Page 50 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 2: One Line Diagram of HCVS Vent Path I ~.:.._J \.""""¥ I I< ll-367 I ~- -* - ~

SllT. Z tF-,1 - ,--VACUlllol BREAICER FRllll LT-912ltl I SKT.

11*365 >-

I II ~ OPEN ~WEl.rJC 9e-20":~

CAP>>

( '-'-. . , r.;:

I IB-81 TO I _.. ,....- I '-1:::

I FRiii TE-3501-3& I

_________ ~_J

.....,[ 0-3 J i 70-5003 SEE DET All. 0-1 If J) ..fl

~I ~I

~.. I ......

21 i:;

!'---------------------------+-----

~

-**-**- **J Continued at C-7 next page. This drawing for Unit 3, Unit 2 similar.

N2 lllTTLE

~

Revision 0 Page 51 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 2: One Line Diagram of HCVS Vent Path (continued)

---

&.A6089 NZ BOTTLE Sll'f't.Y M-367 i--11 SECURITY SCREENING Ii.: HH6'

...:.:..- 11__ _ _ _

SHT. 6 CH-SJ C003

.!!::ll!.

N2 SUPPLY e-a 168-33425 16&-33426

---

't-1 LA C003 ;----- -* ___!!)_1:_E 1:1

' i .::*

L_i

~. 3L*

w @.. i VENT N

~~

o.c.

II C.O. \ '-n1u ./

r I

~

!i 368- 3~ 368-33451 j0 JS C616B C6166 *or I i* ( * - )

! 'I ' /(JCOO:I y

9HBEH6' LVENT 30F348

---

----NC-

o IL_-'J ,c CRW TES~ ,..- 'J~IBB~~l&~*---::----_J

_.1

, ,, FC TB-334Bl - I I __

Continued from A-6 I:: it..

l' WC)( CD-6]

on previous page.

Revision 0 Page 52 September 28, 2018

Final Integrated Plan HCVS Order EA-13-1 09 Attachment 3: One Line Diagram of HCVS Electrical Power Supply - Units 2 & 3 HCYS 125VOC BUS DISTRIBUTION PANEL~

ClMSO'M;)=.t. I

('1HIS DWO) DmlODIB BUS BUS BUS BUS BK BK

---

*--1 I

NOfWAL 30CI 056 l \ oosoeos ~c e- 103 ,..1 r::©; - BUS BUS BUS BUS BUS I ALTIRNATE HCVS 125VOC BATlDIY OCARGER I

__ J w . ,. ,,.,. I I zc*-*Cl340>

20C10Y (E:-10340) 12 AWO BARE CHO (MS DtG)

Hil

........... 12 A'MO 8ARE GND tllllE5:

+ PC ulMM(lltS 0001 1. 1HE BUS IS n:RE> BY ~ INSJAU.ED

.lnlPERS fRCM 1HE LOAD S>t: CF 1HC WMN BAENCDt 10 1HE I.IE SIDE f1F EAOt pc -....~ (MS DWO) -... '"'°"'......,.,

2. SWTOt AS SHOWif ts frll ~* POS'DOH BILUll!i:

£-20 E-1821

[-17t5 p AWC BARE CND 00 COi - Z SUQC RADfBX BArg l!p HQH f"S' HCVS 125V DC BANRY 000510 w SJm>tC;:EAR ROOM. 11.. us*

L.~.ll!L.--. --

-::,.. --====--***l mt ...... "

~~

• ~~:;::i._, -

---,-- ~ -----.----- l

• • I 1 lt l Revision 0 Page 53 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4: One Line Diagram of SAWA Flow Path - Unit 2 BLITZFIRE MON I TOR W/

FUEL POOL SPRAY

~

?. .. ""'-- ...

REDUCER

... _ DOOR#397 2.Sax2.5"x2.S" GATED WYE 234' EL 2.5" HOSE - 2<JO" / * * * - - - . . . . . . . . . . . . *** t**-------------- ------*"<:*, 1/' El. 2.'::o/D~~~~E 4 ""2.S-'2.S" FUEL POOL MAKEUP EACH

---

~-

~----------------------------------:?-"-------- - ------ - -

SECURITY GATE

\*,*...

~

,./>--~-

---

~:

~ ... ...

--*~-}.

I GATEDWYE SW STAIRWELL ....~- .. -;

234' EI. VENT ......._ "":~::!,.- ..,---..........,

~. '

4a DISCHARGE /

HOSE - 950' \ _*** -'"

ECT 6"x6" x6" GATED

,..,..------:~o~::~~-~------

WYE OUTSIDE ECTWATER @ECT 4 " x4"x4" GATED V~E WYE ON PUM P / 135' El. 4"x4"X4* GATED Dl5CHARG~ .*' [ WYE - LAST HOSE

_,.--'S\L I

6" SUCTION JOINT PRIOR RB HOSE

• 70'  :.._; """"

.... -~ :..: /" FLOW METER

.- - --~~-=-*L

.. ~..

...... ~

ASSEM BLI ES J~:------ *.. ..

,,-., Use to vent

---

t:-*;:---

\ } "\;-..__ ___.f_, / *..._ hose w hen

.I __.:'>-- *-... -** *-. .*** *** --* --.<".\. ------

HV-3 HV-3 \ In it ia ti ng 33426 33427 '- ** _.-'1*_.: FLEX Pump ---------4***** '...1'----- **** flow

~

ECT LETDOWN TOU3HPSW BAY 6" SUCTION I

HOSE - 40'

~.7~---------.. TO FLEX PUMP FOR UNIT 3 4 " DISCHARGE / '

HOSE - 650' 4" DISCHARGE >:\

L_**'/

\

HOSE - 100' DOOR #188 TO 28 RHR LOOP ~

HV-2-10-234 68 ------ --- - * - - - - -- * -- -- - - --- - --- - - ~ 13S' El.

DOOR#070 RBCCW 116' El. 116' El .

Revision 0 Page 54 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4: One Line Diagram of SAWA Flow Path - Unit 2 (continued)

ECT TO FUEL POOL ECTWATE FLEX Pump With

~

VQ!,!LM E Suction From .... ....

ECT

,,---.. .~-.:f".............

1- I \ ""

. . -----"'=-,.,--- ,I ....,

.;.""!. ....... __ ... ' ~

~*<>-

• ____,,----***.)*~--- -'il TO FLEX PUMP

' I I

/,, .. HV-2 23426 165' El. HV-2 24457A FUEL POOL MAKEUP ECT FOR UN113  : 165' El.

LETDOWN I'

' FUEL POOL MAKEUP HV-2 180 HV-2 244576 2 A RHR NIVR135 ' El. 165' El.

HV-2 2346 LOOP 116' El.

RPV M0-2-10-20 INJECTION HV 10- 2346 M0-2 M0-2 A0-2* 10-116' EI. 1546 256 468 TORUS HV- 2 23446 HV- 2 23445 HV 10-66 MAKEUP HV-2-10-57 M0-2-10-398 M0-2-10-348 U 2 HPSW116' El. RBCCW116' El.

TORUS SPRAY (NOT USEQ M0 10-388 M0 10-176 M0 10-174

( HPSW CROSSTIE)

FROM26/ 2 D DRYWELL RHR HX SPRAY( NOT U2 HPSW M0-2* 10-268 M0-2-10-318 USED)

PUMPS Revision 0 Page 55 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4: One Line Diagram of SAWA Flow Path - Unit 2 (continued)

SDC CONDENSATE RV-2-10-2676 SERVICES/ SUCTION

{GAGGED)

STAYFULU NO LINE RBCCW116' El.

FL0\.'0 HV-2 21576 HV-2-10-70A RPV HEAD SPRAY,

( ISOLATEQ RB313S'EI.

HV-2-10-70B RB313S'EI.

HV-2 21596 HV-2-10-71C RBCCW116' TOSBLCAND FUEL POOL

. -~,

r~~

~ ~

• ~

RPV I

,_, 2 B RHR LOOP INJECTION

\

M0-2 M0-2 M0-2 A0-2 ..c-:i:,~ STAYFULL

\

\.:,p_____/ *---------------~ 020 I 154A 25A 46A 2 B RHR

\\ LOOP I f l>lc::J M0-2-10-39A I l>lc::J M0 10-34A

~

TORUS MAKEUP ECT ECTWATE ','\

V.QW..,ME \

I I

I I

FROM2A/2C (NOT USE[)

I RHR HX M0-2-10-38A I

I

- , I

... -~~--:t-"'

,, ' \

--ii?------*:-\,____ ,/J

,- I ---

DRYWELL HV-3 HV-3 SPRAY(

33426 33427 ECT FLEX Pump With M0 10-26A M0-2-10-31A USED)

LETDOWN Suction From ECT Revision 0 Page 56 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4a: One Line Diagram of SAWA Flow Path - Unit 3 BUTZFIRE MONITORW/

...,_~ REDUCER FUEL POOL 2.5" x2 .5 " x2.5 "

SPRAY  :,_.'----------------... D OOR #408 GATED WYE

~

~---------

234' EL j

195' El

• 2.5" DISCHARGE j

HOSE - 100' 4"x2 .5~ x2. 5"

---

~---------------- --t-------------------- I 2 S" HOSE - 200' **---- ------ .. ----*-----,... ..

. EACH .......... ~-- -- -----*-*

- . . ';""-.. ... , __ GATED WYE FUEL POOL MAKEUP

• -----~ .

, r- ..

SECURITY GATE

• -*'}.

SW STAI RWE LL I.;-.

234' El. .::;._ .. _:- ----.

VENT > v;;:' ':

4" DISCHARGE /

6"x6"x6" GATED HOSE - 500' \

ECT WYE OUTSIDE ----- ----------:ji .. -**

ECTWATER VOLUME

@ECT 4 " x4" x4 "' GATED ,.,.--------:~R#244 ~u-WYE ON PUMP / 135' El. 4 "'x4. X4" GATE D DISCHARG~ ~-* [ W Y E

• LAST HOSE

I.

6" SUCTION ,.-** JOINT PRIOR RB HOSE - 80 ' ,,.:~,;

___ ,, -:: FLOW M ETER

, ,---..~--~ .. - - ... .. >, ASSEMBLIES  ; ... ------~

1--'

__ ,* , -*-, ,~. '*."- Use to vent

, _____\ . . --.. ---*----t:-\___ } ""~:;"....... . . .........:-- l hose when HV-3 HV-3 \ I . 1:-..- - - *-----* --- ___ .-**** --.<(":__ ____ Initiating 33426 33427 *** _ ,.)iv.._.:

-.. FLEX Pump *---------,- --*-* \..:<------

--.,, flow ECT LETDOWN TO U3 HPSW BAY

/

6 " SUCTION HOSE* 40'

• -*.t':.

~~

• ~------- .... TO FLEX PUMP FOR U N IT 2 4" D ISCHARGE HOSE* 600' 4 " DISCHARGE ~

L_****  :

l HOSE - 100' \ DOOR #239 l 13S' EL

~ HV- ~~~~J ---------------------------------~

TO 3A RHR LOOP 3

RBCCW 116' El. DOOR # 137 116' EI.

Revision 0 Page 57 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4a: One Line Diagram of SAWA Flow Path - Unit 3 (continued)

BLITZFIRE MONITOR..

4"x4"x4" ,, ,----<"£ FUEL POOL GATED WYE __ /.<>

• SPRAY

---:::...-~' ........ ,'

( ... ----_.~-- ....:

,----' -1~.~--,

i .,<------* FUEL POOL

MAKEUP HV-3-19-33426 FUEL POOL 165' El. MAKEUP HV-3-19-34457 A 165' El.

FUEL POOL FLEX Pump With MAKEUP Suction From ECT or HV-3-10-180 HV-3-19-344576 3B RHR NIVR 135' EL 165' El.

Intake ,--..~-3---.

' \ \

HV-3-10-33468 LOOP

[--{,--- ,I \

' .. __ . , 116' El.

RPV M0 10-20 INJECTION HV-3-10-33467 M0-3 M0-3 A0 10-116' El. 154A 25A 46A TORUS HV-3-32-33445 MAKEUP HV-3-10-57 HV-3-10-66 M0-3-10-39A M0-3-10-34A U3 H PSW 116 ' El.

RBCCW 116' El.

I *** .. TORUS SPRAY (NOT USED)

M0-3-10-38A M0-3-10-176 M0-3-10-174 (HPSW CROSS-TIE)

FROM 3A/3C DRYWELL RHR HX SPRAY (NOT U3 HPSW M0-3-10-26A M0-3-10-31A USED)

PUMPS Revision 0 Page 58 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 5: One Line Diagram of SAWA Electrical Power Supply- Unit 2 FLEX Generator 2AS1061 (east inside wall Unit 2 Rx Bldg. El 135')

, (Rx Bldg. El 165')

E124 E324 I) E124 (1024)

(480V LC E124)

) E124 (1013)

MCC E124-R-C

) E124 (1014)

MCC E124-T-B

)

E324 (1222)

MCC E324-T-B I) E324 (1213)

MCC E324-R-B I )E324 (1224)

(480V LC E324)

E124-R-C E324-R-B E124-T-B E324-T-B Revision 0 Page 59 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment Sa: One Line Diagram of SAWA Electrical Power Supply- Unit 3 FLEX Generator 3AS1061 (east inside wall Unit 3 Rx Bldg. El 135')

(Rx Bldg. El 165')

E134 E334

~ E134 (1021)

FLEX Feed

~ E134 {1014)

MCC E134-T-B I> E334 {1213)

MCC E334-R-B

~ E334 {1221)

FLEX Feed E134-T-B E334-R-B Revision 0 Page 60 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6: Plant Layout Showing Operator Action Locations Attachment 6A Outside Locations for FLEX Pump, Hoses, and FLEX Generator (continued next page)

?..

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CONrD(Al t Si-~ic;;H 7

( NEXT PAGE

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Revision 0 Page 61 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6A (continued)

Outside Locations for FLEX Pump, Hoses, and FLEX Generator t-:~ ----~-"  :-0-'*+.-.--'~~7-:~--::;:=:!?.:e_,_

n.~

~--l'"

IC> *.*~fl--; ,.,- ,

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Revision 0 Page 64 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 60 Pathway to ROS

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Final Integrated Plan HCVS Order EA-13-109 Table 1: List of HCVS Component, Control and Instrument Qualifications Local Local Local Component Equipment Qualification Qualification Qualification Power Range Location Event Event Radiation Qualification Name ID Temp Humidity Radiation Supply Temp Humidity Level Wetwell Vent Instruments and Components HCVS effluent TE-8(9)1407 o-500°F Torus 303.4°F 100% 4.0E+07 IEEE-323-1974 & o - 500°F No electronics, not 300 Mrad None temperature Room Rads over 1983, IEEE-344- susceptible required sensor life of plant 1975 & 1987 HCVS effluent TT-8(9)1407 0-400°F ROS 120°F 90% 5.6 mr/hr IEEE-323-1974 & 185°F 100% 1 Mrad 24VDC temperature during 1983, IEEE-344- power supply transmitter accident 1975 & 1987 E/S-8(9)1408 and 350 powered by Rad over 125VDC plant life HCVS Batterv HCVS effluent Tl-8(9)1407 o-400°F MCA 11 2.?°F 90% *CR IEEE-344-1987, 150°F 100% N/A 24VDC temperature IEEE-420-1973 power supply indication E/S-8(9)1408 powered by 125VDC HCVS Battery Wetwell Vent RE-8(9)1405 10*2 to 104 RB El. 146°F U2 100% 5.0 x 106 I EEE-323-1983, 40- 350°F 100% 2 x 108 Rad 125 VDC line radiation R/hr 195' (U2) 185°F U3 Rads I EEE-344-1987 HCVS detector 165' (U3) Battery Wetwell Vent RT-8(9)1405 10*2 to 104 ROS 120°F 90% 5.6 mr/hr IEEE-323-1983, 40-131°F 95% 1 x 103 Rad 125 VDC line radiation R/hr during IEEE-344-1987 HCVS processor/ accident Battery transmitter and 350 Rad over olant life Wetwell Vent Rl-8(9)1405 10*2 to 104 MCA 112.7°F 90% *CR I EEE-344-1987, 150°F 100% N/A 125 VDC line radiation A/hr IEEE-420-1973 HCVS indicator Battery N2 supply Pl-8(9)1429 0-3000 ROS 120°F 90% 5.6 mr/hr N/A 200°F 100% N/A None pressure gages and psig and during required Pl-8(9)1430 0-160 psig accident and 350 Rad over olant life Revision 0 Page 66 September 28, 2018

Final Integrated Plan HCVS Order EA-13-1 09 Local Local Local Component Equipment Qualification Qualification Qualification Power Range Location Event Event Radiation Qualification Name ID Temp Humidity Radiation Supply Temp Humidity Level Argon supply Pl-8(9)1431 0-3000 ROS 120°F 90% 5.6 mrlhr NIA 200°F 100% NIA None pressure gages and psig and during required Pl-8(9)1428 0-400 psig accident and 350 Rad over olant life Argon supply PT-8(9)1406 0-4000 ROS 120°F 90% 5.6 mrlhr IEEE-323-1974, 40- 200°F 100% 6.5 Mrad 24VDC pressure psig during 1983 & 2003, power supply transmitter accident I EEE-344-1975, EIS-8(9)1408 and 350 1987 & 2004 powered by Rad over 125VDC olant life HCVS Batterv Drywell Pressure PT-4(5)805 Oto70 RB El. 300°F 100% 2.00E+03 IEEE 323-1974, **200°F 100% 2.2E+07 Rads FLEX transmitter psig 116' Rads TIO Generator IEEE 344-1975 Drywell Pressure PR/TR- Oto 70 MCR 112.7°F 90% *CR NIA-AG 1.97 RG 1.97 RG 1.97 RG 1.97 FLEX indication 4(5)805 psig qualified Generator Wetwell Level LT-8(9)123A 20 ft H20 RB El. 300°F 100% 2.00E+03 NIA- RG 1.97 RG 1.97 RG 1.97 RG 1.97 FLEX transmitter 91'-6" Rads qualified Generator Wetwell Level Ll-8(9)123A 1 to 21 ft MCA 112.7°F 90% *CR NIA- RG 1.97 RG 1.97 RG 1.97 AG 1.97 FLEX indication H20 qualified Generator SAWAflow NIA 3.3 - 1100 Outside NIA NIA Outside, Commercial 140°F NIA NIA Internal instrument and gpm close to (outside) (outside) radiation instrument Battery readout FLEX/ not a qualified for over SAWA concern the road use, Pump therefore qualified per NEI 12-06

• Denotes Control Room where local radiation levels are not applicable. Building has no significant radiation sources.

• • 200 °F for normal operating limits, with +/-(0. 75% upper range limit +0.5% span) per 100 °F (55.6 °C) ambient temperature change. Analyzed as acceptable in EC 618957 Attachment 09A.

Revision 0 Page 67 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Table 2: Operator Actions Evaluation Evaluation Validation Radiological Operator Action Location Thermal conditions Evaluation Time8 Time Conditions 1 Open RB roof ~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 00:26:10 RB refueling floor Done in the first hour, so Done in the first hour, so no Acceptable hatch for no concerns. concerns.

ventilation 2 Align HCVS to :5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 00:32:10 ROS (AW Done in the first hour, so Done in the first hour, so no Acceptable support venting Building 135') no concerns. concerns.

capability 3 FLEX Generator :5 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> 02:16:08 The Unit 2 FLEX Outside - outdoor ambient Action will be complete prior Acceptable connection and (from start of Generator is conditions do not cause a to venting start so no alignment located south of temperature concern. radiological concern deployment; the Unit 2 RB will be outside of the complete Unit's outer within 8 railroad door.

hours) The Unit 3 FLEX Generator is located north of the Unit 3 RB outside of the Unit's outer railroad door.

4 SAWApump :5 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 02:30:54 North of the Unit Outside - outdoor ambient Action will be complete prior Acceptable staging and (from start of 3 Reactor conditions do not cause a to venting start so no hose connection Building (RB) temperature concern. radiological concern deployment; between the Plant will be Services Building complete and the Unit 3 within 8 Startup hours) Switchgear Buildinq.

8 Evaluation timing is from NEI 13-02 to support radiological evaluations.

Revision 0 Page 68 September 28, 2018

Final Integrated Plan HCVS Order EA-13-109 Evaluation Validation Radiological Operator Action Location Thermal conditions Evaluation Time8 Time Conditions 5 SAWA manual .::: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 02:30:54 RBCCW Room 125°F Max. per Ref. 45 1.71 E+04 mRlhr per Ref. 55 Acceptable valve alignment (from start of 116' Attachment 09B and Ref.

in RB 62 deployment; will be complete within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) 6 FLEX Generator 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> - NIA East of DG Outside - outdoor ambient 1.85E+03 mRlhr per Ref. 55 Acceptable operation and event duration Building and at conditions do not cause a refueling pump and temperature concern.

generator staging locations 7 SAWApump 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> - NIA East of DG Outside - outdoor ambient 5.60E+02 mRlhr per Ref. 55 Acceptable operation and event duration Building and at conditions do not cause a refueling pump and temperature concern.

generator staging locations Revision 0 Page 69 September 28, 2018