NL-18-0870, Eighth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)

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Eighth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109)
ML18178A403
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 06/27/2018
From: Gayheart C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NL-18-0870
Download: ML18178A403 (12)
v • d • e


Text

~ Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7795 fax cagayhea@ southernco.com JUN 2 7 2018 Docket Nos.: 50-321 NL-18-0870 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 Eighth 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. 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.
3. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Third Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-1 09), dated December 23, 2015.

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 Phase 1 overall integrated plan (OIP) by letter dated June 27, 2014 (Reference 2) . The third six-month update for Phase 1 of the Order included the required Hardened Containment Ventilation System (HCVS) Phase 2 OIP submittal, and was submitted on December 23, 2015 (Reference 3). The consolidated HCVS Phase 1 and 2 OIP document (Reference 3) provided a list of the Phase 1 OIP open items, and addressed the NRC Interim Staff Evaluation open items for Phase 1. This letter is being submitted to satisfy the requirements for providing the six-

U.S. Nuclear Regulatory Commission NL-18-0870 Page2 month updates for Phase 1 and 2 of the Order in accordance with Section IV, Condition D.3, of Reference 1.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments. If you have any questions, please contact Tim Enfinger at 205.992.7924.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the v1\P day of June 2018.

Respectfully submitted, Cheryl A. G e Regulatory Affairs Director Southern Nuclear Operating Company CAG!TLE

Enclosure:

Eighth Six-Month Status Report Regarding Requirements for Reliable Hardened Containment Vents (EA-13-1 09) cc: Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch State of Georgia, Director- Environmental Protection Division RType: CHA02.004

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Eighth Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-1 09)

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

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Eighth Six Month Status Report for the Implementation of Order EA-13-109 1 Introduction Southern Nuclear Operating Company developed an Overall Integrated Plan (References 1 and 8) for the Edwin I. Hatch Nuclear Plant- Units 1 and 2 (HNP) documenting the installation of a Hardened Containment Vent System (HCVS). Updates of milestone accomplishments are based on the combined Phase 1 and 2 Overall Integrated Plan dated December 23, 2015.

HNP developed an updated and combined Phase 1 and 2 Overall Integrated Plan (Reference 8), documenting:

1. 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.
2. An alternative strategy that makes it unlikely that a drywall vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2.

HNP has elected to upgrade the existing HCVS to comply with the requirements of EA-13-109 for Phase 1 and 2 under Revision 1 of NEI 13-02. Revision 1 of NEI13-02 addresses methodology to implement Phase 2 requirements of Order EA-13-1 09 and additional clarifications and guidance for implementation of Phase 1.

This enclosure provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 Overall Integrated Plan (Reference 8), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the combined Phase 1 and 2 Overall Integrated Plan (Reference 8), and are current as of May 31, 2018.

Phase 1 Unit 1&2 Design Engineering On-site/Complete Phase 1 Unit 1&2 Walk Through Demonstration/Functional Test Phase 1 Unit 1&2 Implementation Outage Phase 1 Unit 1&2 Site Specific Maintenance Procedures Phase 1 Unit 1&2 Operations Procedure Changes Developed Phase 1 Unit 1&2 Procedure Changes Active Phase 1 Unit 1&2 HCVS Implementation Phase 1 Unit 1&2 Training Complete Phase 2 Unit 1&2 Hold preliminary/conceptual design meeting Phase 2 Unit 1&2 Design Engineering On-site/Complete E-1

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Phase 2 Unit 1 Walk Through Demonstration/Functional Test Phase 2 Unit 1 Implementation Outage Phase 2 Unit 1&2 Operations Procedure Changes Developed Phase 2 Unit 1&2 Site Specific Maintenance Procedure Developed Phase 2 Unit 1&2 Procedure Changes Active Phase 2 Unit 1&2 Training Complete Phase 2 Unit 1 HCVS Implementation Submit Unit 1 Phase 1 and 2 Compliance Letter 3 Milestone Schedule Status The following provides an update to Attachment 2 of the combined Phase 1 and 2 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.

Phase 1 and 2 HCVS Milestone Table Milestone Target Activity Comments Completion Status Date Submit Overall Integrated Plan Jun.2014 Complete 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 with this submittal Update 9 Dec.2018 Not Started E-2

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Milestone Target Activity Comments Completion Status Date Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual Jun.2014 Complete design meeting Unit 1 Design Engineering On- Feb.2017 Complete site/Complete Unit 1 Implementation Outage Mar. 2018 Complete Unit 1 Walk Through Mar. 2018 Complete Demonstration/Functional Test Unit 2 Design Engineering On- May2016 Complete site/Complete Unit 2 Walk Through Feb.2017 Complete Demonstration/Functional Test Unit 2 Implementation Outage Feb.2017 Complete Phase 1 Procedure Changes Operations Procedure Changes Dec.2017 Complete Developed Site Specific Maintenance Jan.2017 Complete Procedure Developed Procedure Changes Active Feb.2017 Complete Phase 1 Training:

Training Complete Dec.2016 Complete Phase 1 Completion Unit 2 HCVS Implementation Feb.2017 Complete Unit 1 HCVS Implementation Mar. 2018 Complete Full Site HCVS Implementation Mar. 2018 Complete Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual design Apr. 2016 Complete meeting Unit 1 Design Engineering On- Feb.2017 Complete No modifications site/Complete required.

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Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Milestone Target Activity Comments Completion Status Date Unit 1 Walk Through Mar. 2018 Complete Demonstration/Functional Test Unit 1 Implementation Outage Mar. 2018 Complete Unit 2 Design Engineering On- Feb.2018 Complete No modifications site/Complete expected.

Unit 2 Walk Through Mar. 2019 Started Current Projection Demonstration/Functional Test Feb.2019 Unit 2 Implementation Outage Mar. 2019 Not Started Current Projection Feb.2019 Phase 2 Procedure Changes Operations Procedure Changes Sep.2017 Complete Developed Site Specific Maintenance Dec.2017 Complete Procedure Developed Procedure Changes Active Mar. 2018 Complete Phase 2 Training:

Training Complete Dec.2017 Complete Phase 2 Completion Unit 1 HCVS Implementation Mar. 2018 Complete Submit Unit 1 Phase 1 and 2 May 2018 Complete Compliance Letter Unit 2 HCVS Implementation Mar. 2019 Started Current Projection Feb.2019 Full Site HCVS Implementation Mar. 2019 Started Current Projection Feb.2019 Submit Unit 2 Compliance Letter May2019 Not Started Current Projection and site Final Integrated Plan Apr. 2019

[60 days after full site compliance]

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Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109) 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 and 2 Overall Integrated Plan (Reference 8) and as described in the fifth six-month status report submitted December 14, 2016 (Reference 9).

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.

6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the combined Phase 1 and 2 Overall Integrated Plan, the Phase 1 Interim Staff Evaluation (ISE) and the Phase 2 Staff Evaluation and an updated response to each item beyond that supplied in the fifth six-month status report submitted December 14, 2016 (Reference 9). Additional clarification was provided for some items in the sixth six-month status report submitted June 12, 2017 (Reference 10). Closure concurrence from the NRC ISE Audit process was received on September 19, 2017 (Reference 11 ).

Hatch 1 & 2 HCVS Phase 1 and 2 OIP Open Response Items 1 Determine location of Dedicated HCVS Documented Closed in Reference 9 Battery transfer switch -

2 Determine location of back-up nitrogen Documented Closed in Reference 9 bottles 3 Evaluate location of Portable DG for Documented Closed in Reference 9 accessibility under Severe Accident HCVS use 4 Confirm suppression pool heat capacity Documented Closed in Reference 9 5 Determine location of HCVS Remote Documented Closed in Reference 9 Operating Station 6 State which approach or combination of Documented Closed in Reference 9 approaches Plant Hatch decides to take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies 7 Evaluate SGTS Valve Leakage utilizing Documented Closed in Reference 9 criteria from NEI HCVS-FAQ Audit item per ISE 8 Identify qualification method used for HCVS Documented Closed in Reference 9 instruments - Audit item per ISE 9 Evaluate HCVS monitoring location of Documented Closed in Reference 9 Portable DG for accessibility, habitability, staffing sufficiency, and communication capability with Vent under Severe Accident HCVS use decision makers - Audit item per ISE E-5

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Hatch 1 & 2 HCVS Phase 1 and 2 OIP Open Response Items 10 Perform severe accident evaluation for FLEX Documented Closed in Reference 9 DG use post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions - Confirmatory Action 11 Determine the control document for HCVS Documented Closed in Reference 9 out of service time criteria - Audit item per ISE Hatch 1 & 2 HCVS Phase 1 ISE Open Response Items 1 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit location of the ROS's call on March 7, 2017. Closure concurrence per Reference 11.

2 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit location of the dedicated HCVS call on March 7, 2017. Closure concurrence per battery_ transfer switch Reference 11.

3 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation of the HCVS nitrogen call on March 7, 2017. Closure concurrence per pneumatic system design including Reference 11.

sizing and location 4 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit deployment location of the portable call on March 7, 2017. Closure concurrence per diesel generators Reference 11.

5 Make available for NRC staff audit an Closed per Reference 9 and verified in NRC Audit evaluation of temperature and call on March 7, 2017. Clarification in Reference radiological conditions to ensure that 10. Closure concurrence per Reference 11.

operating personnel can safely access and operate controls and support equipment 6 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit analyses demonstrating that HCVS call on March 7, 2017. Closure concurrence per has the capacity to vent the Reference 11.

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 E-6

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Hatch 1 & 2 HCVS Phase 1 ISE Open Response Items 7 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit descriptions of local conditions call on March 7, 2017. Closure concurrence per (temperature, radiation and humidity) Reference 11.

anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions 8 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit final sizing evaluation for HCVS call on March 7, 2017. Clarification in Reference batteries/battery charger including 10. Closure concurrence per Reference 11.

incorporation into FLEX DG loading calculation 9 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation that demonstrates call on March 7, 2017. Closure concurrence per adequate communication between the Reference 11.

remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions 10 Provide a description of the final Closed per Reference 9 and verified in NRC Audit design of the HCVS to address call on March 7, 2017. Closure concurrence per hydrogen detonation and deflagration Reference 11.

11 Provide a description of the strategies Closed per Reference 9 and verified in NRC Audit for hydrogen control that minimizes call on March 7, 2017. Closure concurrence per the potential for hydrogen gas Reference 11.

migration and ingress into the reactor building or other buildings 12 Make available descriptions of design Closed per Reference 9 and verified in NRC Audit details that minimize unintended cross call on March 7, 2017. Closure concurrence per flow of vented fluids within a unit and Reference 11.

between units 13 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit descriptions of all instrumentation and call on March 7, 2017. Closure concurrence per controls (existing and planned) Reference 11.

necessary to implement this order including qualification methods 14 Make available for NRC staff audit Closed per Reference 9 and verified in NRC Audit documentation of an evaluation call on March 7, 2017. Closure concurrence per verifying the existing containment Reference 11.

isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting E-7

Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

Hatch 1 & 2 HCVS Phase 1 ISE Open Response Items 15 Make available for NRC staff audit the Closed per Reference 9 and verified in NRC Audit control document for HCVS out of call on March 7, 2017. Closure concurrence per service time criteria Reference 11.

Hatch 1 & 2 HCVS Phase 2 ISE Open Response Items 1 Licensee to demonstrate that Closed per Reference 9, consistent with the containment failure as a result of BWROG generic closure criteria for Order EA overpressure can be prevented 109 Phase 2 Open Items. Closure concurrence per without a drywall vent during severe Reference 11 .

accident conditions Section 3.3.3 2 Licensee shall demonstrate how the Closed per Reference 9, consistent with the plant is bounded by the reference BWROG generic closure criteria for Order EA plant analysis that shows the SAWM 109 Phase 2 Open Items. Closure concurrence per strategy is successful in making it Reference 11.

unlikely that a drywall vent is needed Section 3.3.3.1 3 Licensee to demonstrate that there is Closed per Reference 9, consistent with the adequate communication between the BWROG generic closure criteria for Order EA MCR and the Intake Structure 109 Phase 2 Open Items. Closure concurrence per operator at the FLEX manual valve Reference 11.

during severe accident conditions.

Section 3.3.3.4 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8 Additional Information No changes since seventh six-month status report submitted December 5, 2017 (Reference 12).

9 References The following references support the updates to the Phase 1 and 2 Overall Integrated Plan (Reference 8) 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 (ML141788464).
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 (ML13143A321).

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Enclosure to NL-18-0870 Eighth Six-Month Status Report Regarding Requirement for Reliable Hardened Containment Vents (EA-13-109)

3. NRC Endorsement, Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Revision 0, dated May 14, 2014 (ML14128A219).
4. NRC Letter, Edwin I. Hatch Nuclear Plant Units, 1 and 2 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-1 09 (Severe Accident Capable Hardened Vents) (TAG Nos. MF4479 and MF4480), dated March 25, 2015 (ML14335A137).
5. NE113-02, 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 1, dated April2015 (ML15113B318).
6. 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 1, dated April2015 (ML15104A118).
7. NRC Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision 1, dated September 22, 2015, and Frequently Asked Questions (FAQs) 10, 11, 12, and 13, dated October 8, 2015 (ML15271A148).
8. SNC Letter with Combined Phase 1 and 2 Overall Integrated Plan, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Third Six-Month Status Report of the Implementation of the Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 23,2015 (ML15357A212}.
9. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fifth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 16, 2016.
10. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Sixth Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated June 12, 2017.
11. NRC Letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2- Report for the Audit of Licensee Responses to Interim Staff Evaluation Open Items Related to NRC Order EA-13-1 09 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (GAG NOS. MF4479 and MF4480), dated September 19, 2017 (ML17254A042)
12. SNC Letter, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Seventh Six-Month Status Report of the Implementation of Commission Order with Regard to Requirements for Reliable Hardened Containment Vents (EA-13-109), dated December 5, 2017.
13. SNC Letter, Edwin I. Hatch Nuclear Plant- Unit 1 Completion of Required Action for NRC Order EA-13-1 09 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated April 12, 2018.

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