NL-15-0698, Second Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

Second Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

ML15177A353
Person / Time
Site:	Hatch
Issue date:	06/26/2015
From:	Pierce C Southern Co, Southern Nuclear Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NL-15-0698
Download: ML15177A353 (8)

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 << rt COMPANY June 26, 2015 Docket Nos.: 50-321 NL-15-0698 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 Second 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. NEI13-02, Industry Guidance for Compliance with NRC Order EA-13-109, 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-13-109), 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 second 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-15-0698 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. R. 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.

Respectful~bmitted, c.f{r~

C. R. Pierce Regulatory Affairs Director 'I CRP/JMG/GLS

' 2015.

My commission expires: I ?..,CJ I g

Enclosure:

Second Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-1 09) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch RType: CHA02.004 U.S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. 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, Director- Environmental Protection Division

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

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

Enclosure - NL-15-0698 Second Six-Month Status Report of Vent Order Implementation Enclosure Edwin I. Hatch Nuclear Plant- Units 1 and 2 Second 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 OIP, and are current as of April 30, 2015:

• Hold preliminary/conceptual design meeting 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 Complete N/A Submit 6 Month Status Report Jun 2015 Complete 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-15-0698 Second 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 Mar 2017 On Schedule N/A U2 Walk Through Demonstration/Functional Test Mar 2017 On Schedule N/A U1 Design Engineering On-site/Complete Mar 2017 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 Mar 2018 On Schedule N/A Submit Completion Report May 2018 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.

E-2

Enclosure- NL-15-0698 Second 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 (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status/Comment 1 Determine location of Dedicated HCVS Battery transfer switch Complete 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

1. Make available for NRC staff audit the location of the ROSs. In progress (same as 5 above)

2. Make available for NRC staff audit the location of the dedicated Available (same as 1 above)

HCVS battery transfer switch.

3. Make available for NRC staff audit documentation of the HCVS In progress (part of 2 above) nitrogen pneumatic system design including sizing and location.

E-3

Enclosure - NL-15-0698 Second Six-Month Status Report of Vent Order Implementation

4. Make available for NRC staff audit the deployment location of the In progress (same as 3 above) portable diesel generators.

5. Make available for NRC staff audit an evaluation of temperature In progress and radiological conditions to ensure that operating personnel can safely_ access and operate controls and support equipment.

6. Make available for NRC staff audit analyses demonstrating that In progress (part of 4 above)

HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

7. Make available for NRC staff audit the descriptions of local In progress (part of 8 above) 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 HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

8. Make available for NRC staff audit the final sizing evaluation for In progress (part of 10 above)

HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

9. Make available for NRC staff audit documentation that In progress (same as 9 above) demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

10. Provide a description of the final design of the HCVS to address In progress (same as 6 above) hydrogen detonation and deflagration.

11. Provide a description of the strategies for hydrogen control that In progress (same as 7 above) minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

12. Make available descriptions of design details that minimize In progress (same as 5 above) unintended cross flow of vented fluids within a unit and between units.

13. Make available for NRC staff audit descriptions of all In progress (same as 8 above) instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

14. Make available for NRC staff audit documentation of an In progress evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

15. Make available for NRC staff audit the control document for In progress (same as 11 HCVS out of service time criteria.

above) 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

E-4

Enclosure - NL-15-0698 Second 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-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

3. NEI13-02, Industry Guidance for Compliance with NRC Order EA-13-109, 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) Rev 0 (Accession No. ML14128A219).

6. 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-13-109), Revision 0, dated June 27, 2014.

7. SNC Letter, First Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109),

dated December 30, 2014.

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

E-5