NL-14-1839, E. I. Hatch, Units 1 and 2, First Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

E. I. Hatch, Units 1 and 2, First Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

ML15049A513
Person / Time
Site:	Hatch
Issue date:	12/30/2014
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NL-14-1839
Download: ML15049A513 (7)

Text

Charles A. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Tel 205 .992.7872 Fax 205.992.7601 SOUTHERN .. \

COMPANY December 30, 2014 Docket Nos.: 50-321 NL-14-1839 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant- Units 1 and 2 First Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-1 09)

References:

1. NRC Order Number EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

2. NRC Interim Staff Guidance JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013.

3. NEI 13-02, Industry Guidance for Compliance with NRC Order EA-13-1 09, To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013.

4. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents ( EA-13-1 09), dated June 27, 2014.

Ladies and Gentlemen:

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs the Edwin I. Hatch Nuclear Plant- Units 1 and 2 (HNP) to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of Reference 1.

In addition, Reference 1 also required submission of a Phase 1 overall integrated plan pursuant to Section IV, Condition D, and status reports at six-month intervals thereafter.

SNC submitted the overall integrated plan by letter dated June 27, 2014 (Reference 4).

Enclosed is the first six-month status report pursuant to Section IV, Condition D, of Reference 1, reflecting: (1) progress associated with implementation of the requirements of Reference 1, and (2) milestone accomplishments subsequent to issuance of the

U.S. Nuclear Regulatory Commission NL-14-1839 Page2 Phase 1 overall integrated plan (Reference 4), consistent with the guidance provided in References 2 and 3.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. C. A. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully s~itted, ,:..~---

c.~.r~ _:- x* .r C. A. Pierce Regulatory Affairs Director CRP/JMG/TWS Sw rn to and subscribed before me this 30~ay of f/Jece.bu- ,2014.

My commission expires: 1/z./z.olt

Enclosure:

First Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. A. Vineyard, Vice President- Hatch Mr. B. L. lvey, Vice President- Regulatory Affairs Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. A. Madison, Vice President- Fleet Operations RType: CHA02.004 U. S. Nuclear Regulatorv Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. A. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch Ms. J. A. Kratchman, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPRIPGCB State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Edwin I. Hatch Nuclear Plant- Units 1 and 2 First Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents CEA-13-109)

Enclosure First Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents {EA-13-109)

Enclosure- NL-14-1839 First Six-Month Status Report of Vent Order Implementation Enclosure Edwin I. Hatch Nuclear Plant - Units 1 and 2 First Six Month Status Report for the Implementation of Order EA-13-109 1 Introduction Southern Nuclear Operating Company developed an Overall Integrated Plan (Reference 1) for the Edwin I. Hatch Nuclear Plant - Units 1 and 2 (HNP) documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan (OIP).

2 Milestone Accomplishments In addition to the submittal of status reports, the following milestone(s) directly related to the vent Order implementation have been completed since the submittal of the 01 P, and are current as of October 31, 2014:

• None 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Target Activity Revised Target/

Milestone Completion Status Completion Date Date Submit Overall Integrated Implementation Plan Jun 2014 Complete N/A Submit 6 Month Status Report Dec 2014 Complete N/A Hold preliminary/conceptual design meeting Mar 2015 On Schedule N/A Submit 6 Month Status Report Jun 2015 On Schedule N/A Submit 6 Month Status Report Dec 2015 On Schedule N/A U2 Design Engineering On-site/Complete Mar 2016 On Schedule N/A Submit 6 Month Status Report Jun 2016 On Schedule N/A E-1

Enclosure- NL-14-1839 First Six-Month Status Report of Vent Order Implementation Target Activity Revised Target/

Milestone Completion Status Completion Date Date Operations Procedure Changes Developed Dec 2016 On Schedule N/A Site Specific Maintenance Procedure Developed Dec 2016 On Schedule N/A Submit 6 Month Status Report Dec 2016 On Schedule N/A Training Complete Dec 2016 On Schedule N/A U2 Implementation Outage Feb 2017 On Schedule N/A Procedure Changes Active Mar2017 On Schedule N/A U2 Walk Through Demonstration/Functional Test Mar2017 On Schedule N/A U1 Design Engineering On-site/Complete Mar2017 On Schedule N/A Submit 6 Month Status Report Jun 2017 On Schedule N/A Submit 6 Month Status Report Dec 2017 On Schedule N/A U1 Implementation Outage Feb 2018 On Schedule N/A U1 Walk Through Demonstration/Functional Test Mar2018 On Schedule N/A Submit Completion Report May2018 On Schedule N/A 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant - Units 1 and 2, expect to comply with the order implementation date and no relief/relaxation is required at this time.

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Enclosure- NL-14-1839 First Six-Month Status Report of Vent Order Implementation 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (IS E) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status/Comment 1 Determine location of Dedicated HCVS Battery transfer switch In progress 2 Determine location of back-up nitrogen bottles In progress Evaluate location of Portable DG for accessibility under Severe Confirmatory action 3

Accident HCVS use In progress Confirmatory action 4 Confirm suppression pool heat capacity In progress 5 Determine location of HCVS Remote Operating Station (ROS) In progress State which approach or combination of approaches Plant Hatch decides to take to address the control of flammable gases, clearly 6 In progress demarcating the segments of vent system to which an approach applies Evaluate SGTS Valve Leakage utilizing criteria from NEI HCVS- Confirmatory action 7

FAQ-05 In progress 8 Identify qualification method used for HCVS instruments In progress Evaluate HCVS monitoring location for accessibility, habitability, Confirmatory action 9 staffing sufficiency, and communication capability with Vent-use In progress decision makers Perform severe accident evaluation for FLEX DG use post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Confirmatory action 10 actions In progress Determine the control document for HCVS out of service time Confirmatory action 11 criteria In progress Interim Staff Evaluation Open Item Status None to date N/A 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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Enclosure- NL-14-1839 First Six-Month Status Report of Vent Order Implementation 8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure:

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

2. NRC Order Number EA-13-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

3. NEI 13-02, Industry Guidance for Compliance with NRC Order EA-13-1 09, To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013.

4. NRC Interim Staff Guidance JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013 (Accession No. ML133048836).

5. NRC Endorsement, Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) RevO(Accession No. ML14128A219).

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