Text

Resubmittal of Phase 1 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)
	ML15079A044
Person / Time
Site:	Fermi
Issue date:	03/19/2015
From:	Kaminskas V; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-13-109, NRC-15-0041
	Download: ML15079A044 (47)
	v • d • e

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy 10 CFR 2.202 March 19, 2015 NRC-15-0041 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) DTE Electric Company, "DTE Electric Company's Phase 1 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 (ML12053A340)

Subject:

Resubmittal of Phase 1 Integrated Plan for Hardened Containment Vents On June 30, 2014, DTE Electric Company (DTE) submitted its Phase 1 Integrated Plan in Response to the U.S. Nuclear Regulatory Commission (NRC) Order Number EA-13-109, "Issuance of Oder to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013.

Page 40 of the enclosure was inadvertently omitted from Reference 2. The attached enclosure contains the complete integrated plan. No changes were made to the previously submitted plan and no new regulatory commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr.

Christopher Robinson, Licensing Manager at (734) 586-5076.

US NRC NRC-15-0041 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 19, 2015 Vito A. Kaminskas Site Vice President

Enclosure:

DTE Electric Company's Phase 1 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) cc: Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission, Regulated Energy Division (kindschlamichigan.gov)

Enclosure to NRC-15-0041 DTE Electric Company's Phase 1 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)

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Table of Contents:

Part 1: General Integrated Plan Elements and Assumptions Part 2: Boundary Conditions for Wet Well Vent Part 3: Boundary Conditions for Dry Well Vent Part 4: Programmatic Controls, Training, Drills and Maintenance Part 5: Implementation Schedule Milestones : HCVS Portable Equipment : Sequence of Events : Conceptual Sketches : Failure Evaluation Table : References : Changes/Updates to this Overall Integrated Implementation Plan : List of Overall Integrated Plan Open Items Page 1 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Introduction In 1989, the NRC issued Generic Letter 89-16, Installation of a Hardened Wetwell Vent, 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 to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 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. 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 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).

The Order requirements are applied in a phased approach where:

Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened vents to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. (Completed no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first.)

Phase 2 involves providing additional protections for severe accident conditions through installation of a reliable, severe accident capable drywell vent system or the development of a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. (Completed no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.)

The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim Staff Guidance (JLD-ISG-2013-02) issued in November 2013. The ISG endorses the compliance approach presented in NEI 13-02 Revision 0, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA 109, the NRC staff will use the methods described in this ISG (NEI 13-02) to evaluate licensee compliance as presented in submittals required in Order EA-13-109.

The Order also requires submittal of an overall integrated plan which will provide a description of how the requirements of the Order will be achieved. This document provides the Overall Integrated Plan (OIP) for complying with Order EA-13-109 using the methods described in NEI Page 2 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan 13-02 and endorsed by NRC JLD-ISG-2013-02. Six month progress reports will be provided consistent with the requirements of Order EA-13-109.

Fermi 2 venting actions for the EA-13-109 severe accident capable venting scenario can be summarized by the following:

The HCVS will be initiated via manual action from the HCVS Control Panel or Main Control Room (MCR) at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms.

The vent will utilize Containment Parameters of Pressure, Level and Temperature from the HCVS Control Panel or MCR instrumentation to monitor effectiveness of the venting actions

The vent operation will be monitored by HCVS valve position, temperature, and effluent radiation levels.

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

Venting actions will be capable of being maintained for a sustained period of up to 7 days.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 1: General Integrated Plan Elements and Assumptions Extent to which the guidance, JLD-ISG-2013-02 and NEI 13-02, are being followed. Identify any deviations.

Include a description of any alternatives to the guidance. A technical justification and basis for the alternative needs to be provided. This will likely require a pre-meeting with the NRC to review the alternative.

Ref: JLD-ISG-2013-02 Compliance will be attained for Fermi 2 with no known deviations to the guidelines in JLD-ISG-2013-02 and NEI 13-02 for each phase as follows:

Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Currently scheduled for RF-18 planned for second quarter 2017.

Phase 2: by the startup no later than startup from RF-19. Currently scheduled for Fourth Quarter 2018.

If deviations are identified at a later date, then the deviations will be communicated in a future 6 month update following identification.

State Applicable Extreme External Hazard from NEI 12-06, Section 4.0-9.0 List resultant determination of screened in hazards from the EA-12-049 Compliance.

Ref: NEI 13-02 Section 5.2.3 and D.1.2 The following extreme external hazards screen-in for Fermi 2

Seismic, External Flooding, Extreme Cold, High Wind, Extreme High Temperature The following extreme external hazards screen out for Fermi 2

Hurricane Key Site assumptions to implement NEI 13-02 HCVS Actions.

Provide key assumptions associated with implementation of HCVS Phase 1 Actions Ref: NEI 13-02 Section 1 Mark I/II Generic HCVS Related Assumptions:

Applicable EA-12-049 (FLEX) assumptions:

049-1. Assumed initial plant conditions are as identified in NEI 12-06 section 3.2.1.2 items 1 and 2 049-2. Assumed initial conditions are as identified in NEI 12-06 section 3.2.1.3 items 1, 2, 4, 5, 6 and 8 049-3. Assumed reactor transient boundary conditions are as identified in NEI 12-06 section 3.2.1.4 items 1, 2, 3 and 4 049-4. No additional events or failures are assumed to occur immediately prior to or during the event, including security events except for failure of RCIC or HPCI. (Reference NEI 12-06, section 3.2.1.3 item 9) 049-5. At Time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP is occurring at any or all of the units. (NEI 12-06, section 3.2.1.3 item 9 and 3.2.1.4 item 1-4) 049-6. At 45 minutes (time sensitive at a time greater than 75 minutes) an ELAP is declared and actions begin as defined in EA-12-049 compliance 049-7. DC power and distribution can be credited for the duration determined per the EA-12-049 Page 4 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 1: General Integrated Plan Elements and Assumptions methodology for battery usage, (greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with a calculation limiting value of 14.5 hrs.)

(NEI 12-06, section 3.2.1.3 item 8). An additional dedicated HCVS battery will be installed at the HCVS primary control panel to provide the DC loading for the remainder of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

049-8. All activities associated with plant specific EA-12-049 FLEX strategies that are not specific to implementation of the HCVS, including such items as debris removal, communication, notifications, SFP level and makeup, security response, opening doors for cooling, and initiating conditions for the event, can be credited as previously evaluated for FLEX.

Applicable EA-13-109 generic assumptions:

109-1. Site response activities associated with EA-13-109 actions are considered to have no access limitations associated with radiological impacts while Reactor Pressure Vessel (RPV) level is above 2/3 core height (core damage is not expected).

109-2. Portable equipment can supplement the installed equipment after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the portable equipment credited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supply equipment that is credited to recharge air lines for HCVS components after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The FLEX portable air supply used must be demonstrated to meet the SA Capable criteria that are defined in NEI 13-02 Section 4.2.4.2 and Appendix D Section D.1.3.

109-3. SFP Level is maintained with either on-site or off-site resources such that the SFP does not contribute to the analyzed source term (Reference NEI HCVS-FAQ-07) 109-4. Existing containment components design and testing values are governed by existing plant containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (Reference NEI HCVS-FAQ-05 and NEI 13-02 section 6.2.2).

109-5. Classical design basis evaluations and assumptions are not required when assessing the operation of the HCVS. The reason this is not required is that the order postulates an unsuccessful mitigation of an event such that an ELAP progresses to a severe accident with ex-vessel core debris which classical design basis evaluations are intended to prevent. (Reference NEI 13-02 section 2.3.1).

109-6. HCVS manual actions that require minimal operator steps and can be performed in the postulated thermal and radiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation, valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality. (Reference NEI HCVS-FAQ-01) 109-7. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to function in an ELAP event that progresses to core melt ex-vessel. (Reference NEI HCVS-FAQ-02 and White Paper HCVS-WP-01) 109-8. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV water level, temperatures, etc.) assumed for Order EA-13-109 BDBEE and SA HCVS operation.

(reference FLEX MAAP Endorsement ML13190A201) Additional analysis using RELAP5/MOD 3, GOTHIC, PCFLUD, LOCADOSE and SHIELD are acceptable methods for evaluating environmental conditions in areas of the plant provided the specific version utilized is documented in the analysis.

109-9. Utilization of NRC Published Accident evaluations (e.g. SOARCA, SECY-12-0157, and NUREG 1465) as related to Order EA-13-109 conditions is acceptable as references. (reference NEI 13-02 section 8) 109-10. Permanent modifications installed per EA-12-049 are assumed implemented and may be credited for use in EA-13-109 Order response.

109-11. This Overall Integrated Plan is based on Emergency Operating Procedure changes consistent with EPG/SAGs Revision 3 as incorporated per the sites EOP/SAMG procedure change process.

109-12. Under the postulated scenarios of order EA-13-109 the Control Room is adequately protected from excessive radiation dose per General Design Criterion (GDC) 19 in 10CFR50 Appendix A and no Page 5 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 1: General Integrated Plan Elements and Assumptions further evaluation of its use as the preferred HCVS control location is required. (Reference NEI HCVS-FAQ-01) In addition, adequate protective clothing and respiratory protection is available if required to address contamination issues.

Plant Specific HCVS Related Assumptions/Characteristics:

F2-1 The current Torus Hardened Vent stack on the Auxiliary Building (AB) roof can handle the HCVS flow.

F2-2 All load stripping is accomplished within one hour and fifteen minutes of event initiation and will occur at locations not impacted by a radiological event.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint.

HCVS Actions that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, action to open vent valves).

HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or High Dose areas) should be evaluated per guidance.

Describe in detail in this section the technical basis for the constraints identified on the sequence of events timeline attachment.

See attached sequence of events timeline (Attachment 2)

Ref: EA-13-109 Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02 Section 4.2.5, 4.2.6. 6.1.1 The operation of the HCVS will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Immediate operator actions will be completed by plant personnel and will 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 can be found in the following table (2-1). A HCVS Extended Loss of AC Power (ELAP) Failure Evaluation table, which shows alternate actions that can be performed, is included in Attachment 4.

Table 2-1 HCVS Remote Manual Actions Primary Action Primary Location / Notes Component

1. Energize the HCVS Control 2PB2-15 is located in Division Conducted as part of 45-75 Panel at 2PB2-15 Circuit #6. 2 Switchgear room at Grid H- minute Extended SBO Required to be done prior to 10.5 on AB3 South. actions.

operation of HCVS system (expected time is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months based on severe accident timelines).

If depletion of station battery occurs within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , operator action is required to transfer to the dedicated HCVS battery bank.

2. Brief and station Nuclear HCVS Control Panel is located Conducted either on Operator at HCVS Control in Division 2 Switchgear Room indication of core damage Panel. Required to be done at Grid G-9 on AB3 South. (SAG entry) OR when Torus prior to operation of the HCVS Temperature reaches 200 F system. during FLEX response.

3. Align Containment Isolation Relay Room Panels (H11P617 Conducted as part of 45-75 signal override key-lock and H11P618) located in AB2 minute Extended SBO bypass switches for HCVS North actions.

Operation (keylock switches in Relay room).

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent

4. Align Electrical supplies for Division 1 and Division 2 Conducted as part of alternate HCVS Operation Switchgear rooms for MPU Supplemental AC power (MPU #1 and MPU #2 #1 and MPU #2 respectively. using FLEX Generators startup for operation of AC Switchgear rooms located prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

solenoids from CR). AB2 South and AB3 South respectively.

5. Align pneumatic supplies FLEX Compressor is in Conducted as part of FLEX for alternate HCVS FLEX Building 1 in Yard actions prior to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Operation (NIAS supplied North of AB1. Connection from FLEX Compressor). points to NIAS are in AB1 North and TB1.

6. Align supplemental DC to HCVS Control Panel located Prior to depletion of station HCVS Control Panel (if in Division 2 Switchgear batteries.

required) based on Voltage Room at Grid G-9 on AB3 readings in Division 2 South.

Battery area.

7. Operate the HCVS System HCVS Control Panel located Required as contingency as directed from the HCVS in Division 2 Switchgear action for BDBEE Control Panel when Room at Grid G-9 on AB3 response when Torus required based on South. Temperature exceeds 220 EOP/SAGs. F.

Required for SAGs when DW Pressure exceeds Pressure Suppression Pressure (PSP) and prior to exceeding Primary Containment Pressure Limit (PCPL) values.

A timeline was developed to identify required operator response times and potential environmental constraints.

This timeline is based upon the following three Cases:

1. Case 1 is based upon the action response times developed for FLEX when utilizing anticipatory venting in a BDBEE without core damage. Case 1 is not applicable to Fermi 2 as the primary method (credited) for FLEX response is Feed and Bleed of the Torus with expected Torus Temperature of < 200F. Operation of the HCVS system is a Contingency Action that takes place at 220F.

2. Case 2 is based on a SECY-12-0157 long term station blackout (LTSBO) (or ELAP) with failure of RCIC after a black start where failure occurs because of subjectively assuming over injection.

3. Case 3 is based on NUREG-1935 (SOARCA) results for a prolonged SBO (or ELAP) with the loss of RCIC case without black start.

Discussion of time constraints identified in Attachment 2 for the three timeline Cases identified above

Contingency Actions, Initiate use of Hardened Containment Vent System (HCVS) for BDBEE per site procedures is required at 220 F (indicating Failure of FLEX Feed and Bleed strategy) to maintain Page 8 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent containment parameters below design limits and within the limits that allow continued use of RCIC. This is not expected to occur prior to 11.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months post event per the FLEX MAAP cases.

HCVS Power for Primary HCVS operation: The reliable operation of HCVS will be met because HCVS meets the seismic requirements identified in NEI 13-02 and will be powered by DC buses and dedicated batteries with motive force supplied to HCVS valves from installed nitrogen storage bottles. Critical HCVS controls and instruments associated with containment will be DC powered. The HCVS controls and instruments are operated from the HCVS Control Panel (primary location for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) or from the Main Control Room after AC power is available (within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). The DC power for HCVS will be available as long as the HCVS is required. Station batteries will provide power for greater than 14.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , HCVS battery capacity will be available to extend past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months via a new battery bank with a throw-over switch located at the HCVS Control Panel. This throw-over switch would be operated if required based on Division 2 Battery Voltage (available in the Division 2 battery area). In addition, Phase 2 FLEX Diesel Generator (DG) can provide power before the HCVS battery life is exhausted. Also, the FLEX supplemental Diesel Generator will supply 480 VAC to the Division 2 Battery chargers prior to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the event per the FLEX response. Thus initiation of the HCVS from the HCVS Control Panel as required is acceptable because the actions can be performed any time after declaration of an ELAP until the venting is needed. This action can also be performed for SA HCVS operation which occur at a time further removed from an ELAP declaration as shown in Attachment 2.

Required motive air for the primary method of HCVS operation: The local (Primary) nitrogen tank supplies will ensure sufficient nitrogen for 12 HCVS valve operations without makeup over the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Required 120 VAC power for alternate method of HCVS Operation is available prior to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The FLEX supplemental Diesel Generator will supply 480 VAC to the Division 2 Battery chargers prior to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the event per the FLEX response. Credit for this power is not allowed under the Order but the method of restoring 120 VAC is planned for < 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after the event and can be credited at the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months point.

Required Motive Air for alternate method of HCVS Operation is available prior to 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: NIAS will be supplied by FLEX Compressor to supplement the local (Primary) nitrogen tank supplies. The FLEX Compressor is expected to be started and NIAS supplied by the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months actions for FLEX response.

Site Specific actions that are time sensitive for HCVS initiation: Based on required actions and timing of FLEX actions, there are NO time sensitive actions for HCVS initiation.

Discussion of radiological and temperature constraints identified in Attachment 2

Heat Impact: Review of the actions required and location of the actions shows that all Remote Manual Actions (actions outside the Control Room) occur in the Auxiliary Building (AB), in a space outside the influence of the HCVS Piping heat impact, or in the Yard. The loss of Reactor Building (RB) and Auxiliary Building HVAC will result in an increase in temperatures in the affected areas (Switchgear Rooms, AB1, and Relay Room) but will also result in a significant loss of heat load (ELAP). These impacts can easily be countered via the FLEX Toolbox concept for areas impacted by loss of ventilation (yet not impacted by HCVS Piping heat impact).

[Open Item-1: Confirm thermal environment]

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent

Radiological Impact: Review of the actions required and location of the actions shows that all Remote Manual Actions (actions outside the Control Room) occur in the AB in area that has significant shielding between the RB and AB. The Control Room/Relay Room areas meet GDC 19 requirements for Radiological conditions and the wall thickness in the area of the HCVS Control Panel and Division 1 Switchgear rooms provide similar shielding. Specific application of severe accident doses from the hardened vent will be analyzed as part of the designed modifications. The AB1 location also has significant shielding and the Yard location is accessed significantly before any potential Severe Accident dose consequences.

[Open Item-2: Confirm radiological environment]

Specific action locations:

Division 2 Switchgear Room: Actions 1, 2, 4, 6, 7.

Relay Room: Action 3 Control Room: Action 4 Yard: Action 5 Auxiliary Building First Floor: Action 5 Turbine Building First Floor: Action 5 Provide Details on the Vent characteristics Vent Size and Basis (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1)

What is the plants licensed power? Discuss any plans for possible increases in licensed power (e.g. MUR, EPU).

What is the nominal diameter of the vent pipe in inches/ Is the basis determined by venting at containment design pressure, Primary Containment Pressure Limit (PCPL), or some other criteria (e.g. anticipatory venting)?

Vent Capacity (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1)

Indicate any exceptions to the 1% decay heat removal criteria, including reasons for the exception. Provide the heat capacity of the suppression pool in terms of time versus pressurization capacity, assuming suppression pool is the injection source.

Vent Path and Discharge (EA-13-109 Section 1.1.4, 1.2.2 / NEI 13-02 Section 4.1.3, 4.1.5 and Appendix F/G)

Provides a description of Vent path, release path, and impact of vent path on other vent element items.

Power and Pneumatic Supply Sources (EA-13-109 Section 1.2.5 & 1.2.6 / NEI 13-02 Section 4.2.3, 2.5, 4.2.2, 4.2.6, 6.1)

Provide a discussion of electrical power requirements, including a description of dedicated 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months power supply from permanently installed sources. Include a similar discussion as above for the valve motive force requirements. Indicate the area in the plant from where the installed/dedicated power and pneumatic supply sources are coming Indicate the areas where portable equipment will be staged after the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the dose fields in the area, Page 10 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent and any shielding that would be necessary in that area. Any shielding that would be provided in those areas Location of Control Panels (EA-13-109 Section 1.1.1, 1.1.2, 1.1.3, 1.1.4, 1.2.4, 1.2.5 / NEI 13-02 Section 4.1.3, 4.2.2, 4.2.3, 4.2.5, 4.2.6, 6.1.1 and Appendix F/G)

Indicate the location of the panels, and the dose fields in the area during severe accidents and any shielding that would be required in the area. This can be a qualitative assessment based on criteria in NEI 13-02.

Hydrogen (EA-13-109 Section 1.2.10, 1.2.11, 1.2.12 / NEI 13-02 Section 2.3,2.4, 4.1.1, 4.1.6, 4.1.7, 5.1, &

Appendix H)

State which approach or combination of approaches the plant will take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies Unintended Cross Flow of Vented Fluids (EA-13-109 Section 1.2.3, 1.2.12 / NEI 13-02 Section 4.1.2, 4.1.4, 4.1.6 and Appendix H)

Provide a description to eliminate/minimize unintended cross flow of vented fluids with emphasis on interfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakage through interfacing valves or Appendix J type testing features?

Prevention of Inadvertent Actuation (EA-13-109 Section 1.2.7/NEI 13-02 Section 4.2.1)

The HCVS shall include means to prevent inadvertent actuation Component Qualifications (EA-13-109 Section 2.1 / NEI 13-02 Section 5.1, 5.3)

HCVS components including instrumentation should be designed, as a minimum, to meet the seismic design requirements of the plant.

Components including instrumentation that are not required to be seismically designed by the design basis of the plant should be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. (reference ISG-JLD-2012-01 and ISG-JLD-2012-03 for seismic details.)

The components including instrumentation external to a seismic category 1 (or equivalent building or enclosure should be designed to meet the external hazards that screen-in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-01 for Order EA-12-049.

Use of instruments and supporting components with known operating principles that are supplied by manufacturers with commercial quality assurance programs, such as ISO9001. The procurement specifications shall include the seismic requirements and/or instrument design requirements, and specify the need for commercial design standards and testing under seismic loadings consistent with design basis values at the instrument locations.

Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-1975, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard could be used.

Demonstration that the instrumentation is substantially similar in design to instrumentation that has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the Page 11 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performed for the plant licensing basis.

Vent Size and Basis The HCVS wetwell path is designed to vent steam/energy at a nominal capacity of greater than 1% of the current licensed power of 3486 MWt at a pressure of 53.9 psig. The pressure of 53.9 psig is lower than the containment design pressure (56 psig) and the PCPL value (58.8 psig). The size of the wetwell portion of the HCVS is 20 and 24 inches in diameter until it reduces to a HCVS dedicated 10 inch pipe on RB5, which provides adequate capacity to meet or exceed the Order criteria.

Vent Capacity The 1% of 3486 MWt value at Fermi 2 assumes that the suppression pool pressure suppression capacity is sufficient to absorb the decay heat generated during the first 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . HCVS venting would then be able to prevent containment pressure from increasing above the containment design pressure. As part of the detailed design, the duration of suppression pool decay heat absorption capability will be confirmed.

[Open Item-3: Confirm suppression pool heat capacity]

Vent Path and Discharge The existing HCVS vent path at Fermi 2 consists of a wetwell and drywell vent. The wetwell vent rises using Standby Gas Treatment System piping from the torus, joins the drywell vent on RB 3rd floor, connects to the SGTS system inlet piping on RB 5th floor then exhausts through a dedicated 10 inch vent stack.

HCVS has its own discharge path. The HCVS discharge path is routed to a point above the Reactor Building roof. The cooling towers have a higher elevation than HCVS discharge point but they are not adjacent to the Reactor Building. The Reactor Building ventilation system vent stack is at a higher elevation and is 67 feet south of HCVS stack. The vent stack will be extended to discharge 3 feet above the RB roof parapet. The HCVS discharge will vent away from emergency ventilation system intake and exhaust openings, main control room location, location of HCVS portable equipment, access routes required following an ELAP and BDBEE, and emergency response facilities.

The detailed design will provide appropriate missile protection on RB 5th floor in accordance with NEI guidance.

[Open Item-4: Define tornado missile protection for RB 5th floor components.]

Power and Pneumatic Supply Sources For the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the ELAP event, power for the HCVS is provided from either the station battery or a dedicated HCVS battery for operation from HCVS Control Panel H21P101 (primary controls location). After 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power is available from FLEX sources through existing MPU #1, MPU #2, and the station battery chargers for HCVS operation from the Control Room and Relay Room (alternate controls location). Battery power will be provided from the station batteries during the coping period and from the dedicated HCVS battery for the remaining period until the use of FLEX power sources. After 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power is available and credited from a FLEX Phase 2 480V generator for both the station batteries and 120VAC distribution equipment, to allow HCVS operation from the either the HCVS Control Panel or Control Room.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent Pneumatic power is provided by the local Nitrogen bottles for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Alternate method of operation used the non-interruptible air system with backup air provided from the FLEX Compressor. Following an ELAP event, station air system is lost. The Primary pneumatic power is supplied by the local Nitrogen bottles until NIAS is restored via FLEX. The alternate method is expected to be in service based on FLEX actions conducted prior to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months post event but is not credited until > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months post event.

1. The existing HCVS flow path valves are either air-operated valves (AOV) with air-to-open and spring-to-shut (i.e., the wet well containment isolation valves and the torus hardened vent isolation valves) or AOV air-to-shut and spring-to-open (RBHVAC isolation from RB 3rd and RB 5th floor). Operating the valves to their required positions for HCVS requires energizing an AC or DC powered solenoid operated valve (SOV) and providing motive air/gas. The initial stored motive air/gas will allow for a minimum of 12 valve operating cycles for the HCVS control valve for the first 24-hours. After the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , FLEX generators and compressor will be available to maintain electric power and pneumatic supply for HCVS components.

2. An assessment of temperature and radiological conditions will be confirmed acceptable to ensure that operating personnel can safely access and operate controls at the HCVS Control Panel based on time constraints listed in Attachment 2.

3. All permanently installed HCVS equipment, including any connections required to supplement the HCVS operation during an ELAP (i.e., electric power, N2/air) will be located in areas reasonably protected from defined hazards listed in Part 1 of this report.

4. All valves required to open the flow path will be designed for remote manual operation following an ELAP, such that the primary means of valve manipulation does not rely on use of a hand wheel, reach-rod or similar means that requires close proximity to the valve (reference FAQ HCVS-03). The operating mechanisms are routed to the HCVS Control Panel located in the Division 2 Switchgear room (AB 3rd Floor). This location is outside the heat influence zone for the HCVS discharge pipe (located in the Reactor Building) and ventilation is supplemented by the FLEX Battery Exhaust fans.

This location is also east of the concrete shield wall between the Reactor Building and the Auxiliary Building for adequate shielding from the expected HCVS pipe source term. DC power supplemental system is located at the HCVS Control Panel and will be designed to minimize man-power resources.

Required portable equipment for the alternate HCVS operation is all required FLEX mitigating strategies support equipment and is protected to the standards in NEI-12-06 (Attachment 1). Based on this, required portable equipment will be reasonably protected from screened in hazards listed in Part 1 of this OIP.

5. Access to the locations described above will not require temporary ladders or scaffolding.

6. Following the initial 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, alternate motive force will be supplied from the FLEX Compressor to the NIAS header for operation of the HCVS valves via their normally designed operators from the Control Room. The FLEX compressor can be started prior to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following the event but will not be credited for < 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the event. Vital 120 VAC power for HCVS Valve and Radiation Monitor operation from the Control Room (alternate operation) will be supplied via the FLEX Generators 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after event initiation. This alternate AC power will not be credited 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the event.

Location of Control Panels The HCVS design allows initiating and then operating and monitoring the HCVS from the HCVS Control Panel located in the Division 2 Switchgear Room (Primary controls location) and the Main Control Room (MCR) (alternate controls location). Both the HCVS Control Panel and the MCR location are protected from Page 13 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent adverse natural phenomena and will be evaluated as a normal control point for Plant Emergency Response actions. The HCVS Control Panel location is outside the heat influence zone for the HCVS discharge pipe (located in the Reactor Building). This location is also east of the concrete shield wall between the Reactor Building and the Auxiliary Building for adequate shielding from the expected HCVS pipe source term.

Hydrogen As is required by EA-13-109, Section 1.2.11, the HCVS must be designed such that it is able to either provide assurance that oxygen cannot enter and mix with flammable gas in the HCVS (so as to form a combustible gas mixture), or it must be able to accommodate the dynamic loading resulting from a combustible gas detonation.

Fermi 2 is considering a discharge check valve in combination with a purge system as required installed after the last HCVS Isolation Valve. The evaluation of the purge system and operation of the purge valve connecting to the HCVS piping will be described in the detailed design.

Unintended Cross Flow of Vented Fluids The HCVS uses the Containment Purge System containment isolation valves for containment isolation. These containment isolation valves are AOVs and they are air-to-open and spring-to-shut. An SOV must be energized to allow the motive air to open the valve. Although these valves are shared between the Containment Purge System and the HCVS, separate control circuits are provided to each valve for each function.

Specifically:

The Containment Purge System control circuit will be used during all design basis operating modes including all design basis transients and accidents.

Cross flow potential exists between the HCVS and the Standby Gas Treatment System (SGTS). Resolution involves evaluation of SGTS boundary valve leakage. Testing and maintenance will be performed to ensure that the valves remain leak tight with established leakage criteria.

Prevention of Inadvertent Actuation EOP/EPG operating procedures will 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 will be designed to provide features to prevent inadvertent actuation due to a design error, equipment malfunction, or operator error.

The features that prevent inadvertent actuation are:

Key lock switches will be provided to prevent inadvertent operation of the HCVS control valves.

The HCVS Control Panel override capability of Containment isolation function is not powered to allow this override without operator action.

Energizing the HCVS Control Panel will be annunciated in the MCR per the IEEE-279 standards.

Procedures will also provide clear guidance to not circumvent containment integrity by simultaneously opening torus and drywell vent valves during any design basis transient or accident.

Component Qualifications The HCVS components downstream of the second containment isolation valve and components that interface with the HCVS are routed in seismically qualified structures. HCVS components that directly interface with the pressure boundary will be designed in accordance with existing safety system boundaries. The containment system limits the leakage or release of radioactive materials to the environment to prevent offsite exposures from exceeding the guidelines of 10CFR100. During normal or design basis operations, this means serving as a pressure boundary to prevent release of radioactive material. Newly installed components will be seismically Page 14 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent qualified back to their isolation boundaries.

Any electrical or controls component that interfaces with Class 1E power sources will be considered safety related up to and including appropriate isolation devices such as fuses or breakers, as their failure could adversely impact containment isolation and/or a safety-related power source. The remaining installed components will be considered Augmented Quality. Electrical and controls components will be seismically qualified and will include the ability to handle harsh environmental conditions (although they will not be considered part of the site Environmental Qualification (EQ) program).

HCVS instrumentation performance (e.g., accuracy and precision) need not exceed that of similar plant installed equipment. Additionally, radiation monitoring instrumentation accuracy and range will be sufficient to confirm flow of radionuclides through the HCVS. The HCVS instruments, including valve position indication, process instrumentation, radiation monitoring, and support system monitoring, will be qualified by using one or more of the three methods described in the ISG, which includes:

1. Purchase of instruments and supporting components with known operating principles from manufacturers with commercial quality assurance programs (e.g., ISO9001) where the procurement specifications include the applicable seismic requirements, design requirements, and applicable testing.

2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-1975

3. Demonstration that instrumentation is substantially similar to the design of instrumentation previously qualified.

Instrument Qualification Method*

HCVS Process Temperature ISO9001 / IEEE 344-1975 / Demonstration HCVS Process Radiation Monitor ISO9001 / IEEE 344-1975 / Demonstration HCVS Process Valve Position ISO9001 / IEEE 344-1975 / Demonstration HCVS Electrical Power Supply Availability ISO9001 / IEEE 344-1975 / Demonstration

The specific qualification method used for each required HCVS instrument will be reported in future 6 month status reports.

Monitoring of HCVS The Fermi 2 wetwell HCVS will be capable of being manually operated during sustained operations from an HCVS Control panel located in the Division 2 Switchgear Room. The Division 2 Switchgear Room location is in the Auxiliary Building and is in a separate ventilation zone from the Reactor Building area and is not directly impacted by the HCVS piping heat load. On loss of power, the Division 2 Switchgear Room ventilation is isolated from the Reactor Building ventilation. A 4.3 thick concrete shield wall separates the HCVS piping from the HCVS Control Panel, providing protection equivalent to GDC 19/Alternate Source Term (AST). This operating location meets the requirements of Order element 1.2.4. The controls and indications at the HCVS location will be 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), and inadequate containment cooling. The Fermi 2 wetwell HCVS will also be capable of being manually operated during sustained operations from a control panel located in the MCR (alternate controls location). The MCR is a readily accessible location with no further evaluation required. Control Room dose associated with HCVS operation conforms to GDC 19/Alternate Source Term (AST). This location meets the intent for an alternate control location of section 1.2.5 of the Order as described in NEI 13-02 section Page 15 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent 4.2.2.1.2.1. The controls and indications at the MCR location will be 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), and inadequate containment cooling. An evaluation will be performed to confirm accessibility to the location, habitability, staffing sufficiency, and communication capability with Vent-use decision makers.

The wetwell HCVS will include means to monitor the status of the vent system at both the HCVS Control panel and the MCR. The HCVS Control panel includes valve position indications for the seven (7) operating valves and the two SGTS Isolation valves. HCVS pneumatic capability is provided by bottle sizing for 7 days in addition to pneumatic capability from the NIAS system after first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The wetwell HCVS operation will be indicated by valve position and gas flow (indicated by temperature).

HCVS effluent radiation level will be indicated by the radiation monitor. Indication of HCVS electrical capability will be provided by Division II station battery voltage and HCVS battery voltage, These indicators will provide compliance with Requirement 1.2.4 and will be designed for sustained operation during an ELAP event.

Component reliable and rugged performance The HCVS downstream of the second containment isolation valve, including piping and supports, electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components, will be designed/analyzed to conform to the requirements consistent with the applicable design codes (e.g., Non-safety, Cat 1, SS and 300# ASME or B31.1, NEMA 4, etc.) for the plant and to ensure functionality following a design basis earthquake.

Additional modifications required to meet the Order will be reliably functional at the temperature, pressure, and radiation levels consistent with the vent pipe conditions for sustained operations. The instrumentation/power supplies/cables/connections (components) will be qualified for temperature, pressure, radiation level, and total integrated dose for the vent pipe effluent.

Torus vent design temperature and pressure will be increased from 300°F and 62 psig to 340°F and 80 psig.

Containment and isolation valves T4600F400, T4600F401 and T4600F412 are currently qualified for 340°F.

NEI 13-02 guidance section 2.4.3 and 5.1.1 recommends 350°F and 80 psig. The Fermi 2 hardened vent will be opened to protect the PCPL of 58.8 psig and containment design pressure of 56 psig, which equates to a saturation temperature of 303oF. 340°F provides adequate margin to ensure the torus vent containment isolation valves will perform their hardened vent and isolation functions.

Conduit will be installed to Seismic Class 1 criteria. Both existing and new barriers will be used to provide a level of protection from missiles when equipment is located outside of seismically qualified structures.

Augmented quality requirements will be applied to the components installed in response to this Order.

If the instruments are purchased as commercial-grade equipment, they will be qualified to operate under severe accident environment as required by NRC Order EA-13-109 and the guidance of NEI 13-02. The equipment will be qualified seismically (IEEE 344), environmentally (IEEE 323), and for electro-magnetic compatability (per RG 1.180). These qualifications will be bounding conditions for Fermi 2.

For the instruments required after a potential seismic event, the following methods will be used to verify that the design and installation is reliable / rugged and thus capable of ensuring HCVS functionality following a seismic event. Applicable instruments are rated by the manufacturer (or otherwise tested) for seismic impact at Page 16 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2: Boundary Conditions for Wet Well Vent levels commensurate with those of postulated severe accident event conditions in the area of instrument component use, using one or more of the following methods:

Demonstration of seismic motion will be consistent with that of existing design basis loads at the installed location;

Substantial history of operational reliability in environments with significant vibration with a design envelope inclusive of the effects of seismic motion imparted to the instruments proposed at the location;

Adequacy of seismic design and installation is demonstrated based on the guidance in IEEE Standard 344-1975, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, (Reference 27) or a substantially similar industrial standard;

Demonstration that proposed devices are substantially similar in design to models that have been previously tested for seismic effects in excess of the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges); or

Seismic qualification using seismic motion consistent with that of existing design basis loading at the installation location.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: BDBEE Venting Determine venting capability for Beyond Design Bases External Event (BDBEE) Venting, such as may be used in an ELAP scenario to mitigate core damage.

BDBEE Venting is NOT being used at Fermi 2 as the primary success path for ELAP induced by the BDBEEs. This section is describes contingency use of the BDBEE Venting.

Ref: EA-13-109 Section 1.1.4 / NEI 13-02 Section 2.2 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 The operation of the HCVS in the FLEX Contingency mode will be designed to minimize the reliance on operator actions for response to a ELAP and BDBEE hazards identified in part 1 of this OIP. Immediate operator actions can be completed by Operators from the HCVS control station and include remote-manual initiation. The operator actions required to open a vent path are as described in table 2-1.

Remote-manual is defined in this report as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting under the guiding procedural protocol.

The HCVS will be designed to allow initiation, control, and monitoring of venting from the HCVS Control Panel.

This location minimizes plant operators exposure to adverse temperature and radiological conditions and is protected from hazards assumed in Part 1 of this report.

Permanently installed power and motive air/gas capability will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Permanently installed equipment will supply air and power to HCVS for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

System control:

i. Active: Control valves and/or PCIVs are operated in accordance with EOPs/SOPs to control containment pressure. The HCVS is designed for 12 open/close cycles under ELAP conditions over the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following an ELAP. Controlled venting as a contingency action under FLEX will be permitted in the revised EPGs and associated implementing EOPs.

ii. Passive: Inadvertent actuation protection is provided by a normally de-energized HCVS Control Panel with energization annunciated in the MCR. A key-lock is provided to prevent inadvertent operation at the HCVS Control Panel.

Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 After 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , available personnel will be able to power 120 VAC and NIAS air supplies to allow operation of the HCVS Valves from the Control Room. FLEX Generators are credited for re-energizing MPU #1 and MPU

2 electrical supplies to restore normal HCVS valve operations. FLEX actions will bypass the required Containment Isolation logic to allow HCVS Valve positioning. As stated previously, operation of the HCVS system after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is only a contingency if the credited FLEX method of Feed and Bleed of the Torus fails to Page 18 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: BDBEE Venting maintain Torus Temperature below 220 F.

These actions provide long term support for HCVS operation for the period beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 7 days (sustained operation time period) because on-site and off-site personnel and resources will have access to the unit to provide needed action and supplies.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidance exists or will be developed to support implementation.

Primary Containment Control Flowchart exists to direct operations in protection and control of containment integrity, including use of the existing Hardened Vent System. Other site procedures for venting containment using the HCVS include: 29.ESP.ExtendedSBO (pending), Technical Support Guidelines, 29.100.01 Sheet 2, 29.ESP.07, 29.ESP.22, 29.200.01 Sheet 1 Identify modifications:

List modifications and describe how they support the HCVS Actions.

EA-12-049 Modifications

EDP 37037(completed in RF16): Installed containment isolation trip signal bypass switches to permit operation of the containment vent valves through the existing valve control circuits (alternate controls).

Installed divisional cabling between the Auxiliary Building and Reactor Building to provide electrical control of vent valves and instrumentation valves from the new HCVS Control Panel (primary controls).

EDP 37122(Cycle 17): FLEX DC and AC Support Modifications. Supplies 480 VAC to DC Chargers, 480 VAC loads and 120 VAC for alternate HCVS controls (alternate controls).

EDP 37114 (Cycle 17 and RF17): Opens T5000F420B and T4600F421B with DC operated SOVs to restore DW/WW instrumentation following loss of NIAS for Containment indications. This modification supports FLEX instrumentation for Decision Maker on use of HCVS.

EDP 37084 (Cycle 17 and RF17): FLEX RHR cross-tie modification which supplies water from alternate source.

EA-13-109 Modifications

EDP 37037: (complete in RF16): Installed containment isolation trip signal bypass switches to permit operation of the containment vent valves through the existing valve control circuits. Installed divisional cabling between the Auxiliary Building and Reactor Building to provide electrical control of vent valves and instrumentation valves from the new HCVS Control Panel (primary controls).

EDP 37114 (Cycle 17 and RF17): Opens T5000F420B and T4600F421B with DC operated SOVs to restore DW/WW instrumentation following loss of NIAS for Containment indications. This modification supports Decision Maker on use of HCVS. Abandoned Panel H21P101 will be designed to mount the controls necessary for primary control of HCVS during ELAP.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: BDBEE Venting

EDP 37115/37116 (Cycle 18 and RF18): Installs portable bottles and DC solenoids for HCVS Primary controls. Installs the valve position indications and controls on HCVS Control Panel. Revise power feed to T46F420/F421 and to the hardened vent Rad Monitor. Adds a dedicated battery to ensure power to H21P101 for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

EDP 37295 (Cycle 17 and RF17): Installs leak rate test capability of HCVS and NIAS connection for a portable compressor. Supplies FLEX Compressor for NIAS supplies for alternate HCVS controls.

Key Venting Parameters:

List instrumentation credited for this venting actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

Initiation, operation and monitoring of the HCVS venting will rely on the following key parameters and indicators:

Key Parameter Component Identifier Indication Location HCVS Effluent temperature TBD HCVS Control Panel HCVS valve position indication TBD HCVS Control Panel/MCR HCVS Effluent Radiation RE-D11-N551 HCVS Control Panel/MCR Initiation, operation and monitoring of the HCVS system will rely on several existing Main Control Room key parameters and indicators which are qualified or evaluated to Regulatory Guide 1.97 per the existing plant design:

Key Parameter Component Identifier Indication Location Drywell pressure T50N401A/B (NR), MCR T50N415A/B (WR)

T50R802A/B Recorders Torus pressure T50N499A/B (NR) MCR T50N414A/B (WR)

T50R802A/B Recorders Torus water temperature T50N404A/B MCR T50N405A/B T50R800A/B Recorders Torus level T50N406A/B MCR T50R804A/B Recorders Reactor pressure B21N051A/B MCR B21R623A/B Recorders Drywell radiation D11N443A/B MCR D11R810 Recorder Indications for HCVS valve position, HCVS effluent temperature, HCVS effluent radiation will be installed in HVCS primary control panel to comply with EA-13-109. Final configuration of the HCVS control panel is still under consideration.

Notes:

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109 Section 1.2.10 / NEI 13-02 Section 2.3 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 The operation of the HCVS will be designed to minimize the reliance on operator actions for response to an ELAP and severe accident events. Severe accident event assumes that specific core cooling actions from the FLEX strategies identified in the response to Order EA-12-049 were not successfully initiated. Access to the Reactor Building will be restricted as determined by the RPV water level and core damage conditions. Actions will be completed by Operators at the HCVS Control Panel and will include remote-manual actions to operate HCVS valves using the locally installed operating bottles and DC solenoids. The operator actions required to open a vent path were previously listed in the BDBEE Venting Part 2 section of this report (Table 2-1). Operator actions required are limited to DC load shedding (Relay Room), energizing the HCVS Control Panel, and operation of the HCVS Control Panel.

Permanently installed power and motive air/gas capable will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Specifics are the same as for BDBEE Venting Part 2.

System control:

I. Active: Primary method: Control valves and/or PCIVs are operated in accordance with EOPs/SOPs to control containment pressure. The HCVS will be designed for 12 open/close cycles under ELAP conditions over the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following an ELAP. Controlled venting will be permitted in the revised EPGs and associated implementing EOPs.

II. Passive: Same as for BDBEE Venting Part 2.

Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 Specifics are the same as for BDBEE Venting Part 2.

These actions provide long term support for HCVS operation for the period beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 7 days (sustained operation time period) because on-site and off-site personnel and resources will have access to the unit to provide needed action and supplies.

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidance exists or will be developed to support implementation.

The operation of the HCVS is governed by SAMGs for severe accident operation. EPG/SAG Rev. 3 directs (29.200.01 Sheet 1 & 2), that containment pressure be controlled less than PSP pressure (17-25 psig) prior to RPV breach by degraded core to protect containment integrity from a high pressure melt ejection. Wetwell venting will be used to accomplish this. Following, RPV breach by the degraded core, containment pressure will be maintained within PCPL limits (< 58.8 psig) and containment design pressure (56 psig) to protect containment integrity.

Identify modifications:

List modifications and describe how they support the HCVS Actions.

The same as for BDBEE Venting Part 2 Key Venting Parameters:

List instrumentation credited for the HCVS Actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

The same as for BDBEE Venting Part 2 Notes:

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Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions Determine venting capability support functions needed Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.4, 6.1.2 BDBEE Venting Provide a general description of the BDBEE Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109 Section 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 Containment integrity is initially maintained by permanently installed equipment. All containment venting functions will be performed from the HCVS Control Panel or MCR.

Venting will require support from DC power and pneumatic supplies from permanently installed local bottles (Primary operating mechanism for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). Existing safety related station batteries will provide sufficient electrical power for HCVS operation for greater than 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months . Before station batteries are depleted, installed HCVS dedicated batteries will be placed in service using a throw over switch located at the HCVS Control panel to attain > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months capacity for HCVS Operation with DC Load Shedding accomplished via the FLEX actions.

Severe Accident Venting Provide a general description of the Severe Accident Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 The same support functions that are used in the BDBEE scenario would be used for severe accident venting. To ensure power for the 12 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , dedicated HCVS batteries will be available to feed HCVS loads via a manual transfer switch to attain > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months capacity for HCVS Operation with DC Load Shedding accomplished via the FLEX actions.

At 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power will be available at the station service batteries which, at that point, will be backed up by FLEX generators evaluated for SA capability. FLEX generators supplying the DC Battery chargers are located outside the Reactor Building in a FLEX rated structure so issues of thermal or radiological impacts are minimized. This allows them to be used under Severe Accident conditions based on available distance and shielding provide by the Reactor Building exterior walls.

Multiple sources of compressed air will be available (FLEX compressor, FLEX generator supplied NIAS compressors) to tie-in supplemental pneumatic sources to the NIAS system for HCVS valve operation.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidance exists or will be developed to support implementation.

Most of the equipment used in the HCVS is permanently installed. Portable equipment is only used to support the alternate operating method of HCVS (FLEX generators to supply 120 VAC, FLEX compressors) to run pneumatic supplies for HCVS valve operation.

Identify modifications:

List modifications and describe how they support the HCVS Actions.

Page 23 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions See Section Part 2 Boundary Conditions for WW Vent: DBDEE Venting, Identify Modifications HCVS connections required for portable equipment will be protected from all applicable screened-in hazards and located such that Operator exposure to radiation and occupational hazards will be minimized. HCVS connections are located inside the AB 1st floor flood protected area in a Seismic Class 1/Tornado qualified structure and on the west wall of the Turbine Building 1st floor. Connection is not required until after the flood recedes; therefore, the Turbine Building and Auxiliary Building are accessible and connection points meet the requirements identified in NEI-12-06 section 11 for screened in hazards.

Key Support Equipment Parameters:

List instrumentation credited for the support equipment utilized in the venting operation. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

Controls and instruments associated with the FLEX DG electrical load and fuel supply (to be stored on-site).

Controls and instruments associated with the FLEX compressor (to be stored on-site).

Pressure gauges on permanently installed local Nitrogen bottles to verify proper standby conditions (to be installed on local bottles). Bottles installed in inaccessible locations will be sized for sufficient capacity beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months such that no makeup is needed.

Operation of the portable equipment is the same as for compliance with Order EA-12-049.

Notes:

Page 24 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 2 Boundary Conditions for WW Vent: HCVS Venting Portable Equipment Deployment Provide a general description of the venting actions using portable equipment including modifications that are proposed to maintain and/or support safety functions.

Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.2, D.1.3.1 Deployment pathways for compliance with Order EA-12-049 are acceptable without further evaluation needed except in areas around the Reactor Building or in the vicinity of the HCVS piping. At Fermi 2, no deployment is required in the areas around the Reactor Building or in the vicinity of the HCVS piping for access, operation and replenishment of consumables related to HCVS operation.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidance exists or will be developed to support implementation.

Operation of the portable equipment is the same as for compliance with Order EA-12-049 thus they are acceptable without further evaluation HCVS Actions Modifications Protection of connections Per compliance with Order EA- N/A Per compliance with Order EA-12-049 12-049 (FLEX) (FLEX)

Notes:

Page 25 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 3: Boundary Conditions for Dry Well Vent Provide a sequence of events and identify any time constraint required for success including the basis for the time constraint.

HCVS Actions that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, a walk-through of deployment).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events timeline Attachment 2B See attached sequence of events timeline (Attachment 2B).

Ref: EA-13-109 Section X.X.X / NEI 13-02 Section X.X.x This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109 Section X.X.X / NEI 13-02 Section X.X.x First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section X.X.X / NEI 13-02 Section X.X.x This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109 Section X.X.X / NEI 13-02 Section X.X.x This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidance exists or will be developed to support implementation.

This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Identify modifications:

List modifications and describe how they support the HCVS Actions.

Page 26 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 3: Boundary Conditions for Dry Well Vent This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Key Venting Parameters:

List instrumentation credited for the venting HCVS Actions.

This section will be completed with the Phase 2 OIP submittal by December 31, 2015 Notes:

Page 27 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 4: Programmatic Controls, Training, Drills and Maintenance Identify how the programmatic controls will be met.

Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality addressing the impact of temperature and environment Ref: EA-13-109 Section 3.1, 3.2 / NEI 13-02 Section 6.1.2, 6.1.3, 6.2 Program Controls:

The HCVS venting actions will include:

Site procedures and programs are being developed in accordance with NEI 13-02 to address:

operation of HCVS System in both standby and operating conditions, maintenance of HCVS permanent equipment, interface with NRC Order EA-12-049 equipment, connection points and timing for alternate HCVS control equipment being used, protection of HCVS equipment relative to the Severe Accident defined in NRC Order EA-13-109, and the hazards applicable to the site per Part 1 of this OIP.

Procedures:

Procedures will be established for system operations when normal and backup power is available, and during ELAP conditions. The HCVS procedures will be developed and implemented following the plant process for initiating or revising procedures and will contain the following details:

appropriate conditions and criteria for use of the HCVS,

when and how to place the HCVS 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,

testing of portable equipment,

performance or surveillance testing Provisions for out-of-service requirements of the HCVS and compensatory measures will be documented in the Beyond-Design-Bases Event Coping Strategies Program Document (pending MOP25):

The provisions for out-of-service requirements for HCVS functionality are applicable in Modes 1, 2 and 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 for up to 30 days, the primary and alternate means of HCVS operation are non-functional, no compensatory actions are necessary.

If the out of service times exceed 30 or 90 days as described above, the following actions will be performed:

o The condition will be entered into the corrective action system o The HCVS functionality will be restored in a manner consistent with plant procedures o A cause assessment will be performed to prevent future loss of function for similar causes o The appropriate compensatory actions will be implemented Page 28 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 4: Programmatic Controls, Training, Drills and Maintenance Describe training plan List training plans for affected organizations or describe the plan for training development Ref: EA-13-109 Section 3.2 / NEI 13-02 Section 6.1.3 Personnel expected to perform direct execution of the HVCS will receive 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. Training content and frequency will be established using the Systematic Approach to Training (SAT) process.

In addition, personnel on-site will be available to supplement trained personnel (reference NEI 12-06).

Identify how the drills and exercise parameters will be met.

Alignment with NEI 13-06 and 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking Use of the HCVS system in drills, tabletops, or exercises will be aligned with the pending rulemaking as follows:

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

During FLEX demonstrations (as required by EA-12-049): Hardened containment vent operation using backup power, from the primary or alternate location, during conditions of ELAP/loss of UHS with no core damage based on Torus temperature. System use is for containment heat removal and containment pressure control.

HCVS operation on backup power and from the 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. Demonstration may be in conjunction with SAG change.

Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.3 The site will utilize the guidance provided in NEI 13-06 and 14-01 for guidance related to drills, tabletops, or exercises for HCVS operation. In addition, the site will integrate these requirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9.

Describe maintenance plan:

The HCVS maintenance program should ensure that the HCVS equipment reliability is being achieved in a manner similar to that required for FLEX equipment. Standard industry templates (e.g., EPRI) and associated bases may be developed to define specific maintenance and testing.

o Periodic testing and frequency should be determined based on equipment type, expected use and manufacturers recommendations (further details are provided in Section 5 of NEI 13-02).

o Testing should be done to verify design requirements and/or basis. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.

o Preventive maintenance should be determined based on equipment type and expected use. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.

o Existing work control processes may be used to control maintenance and testing.

Page 29 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 4: Programmatic Controls, Training, Drills and Maintenance

HCVS permanent installed equipment should be maintained in a manner that is consistent with assuring that it performs its function when required.

o HCVS permanently installed equipment should be subject to maintenance and testing guidance provided to verify proper function.

HCVS non-installed equipment should be stored and maintained in a manner that is consistent with assuring that it does not degrade over long periods of storage and that it is accessible for periodic maintenance and testing.

Ref: EA-13-109 Section 1.2.13 / NEI 13-02 Section 5.4, 6.2 The site will utilize the standard EPRI industry PM process (similar to the Preventive Maintenance Basis Database) for establishing the maintenance, calibration and testing actions for HCVS components. The control program established in accordance with guidance in Fermi 2 Conduct Manual MES51, Preventative Maintenance will include maintenance guidance, testing procedures and frequencies established based on type of equipment and considerations made within the EPRI guidelines.

Fermi 2 will implement the following operation, testing and inspection requirements for the HCVS to ensure reliable operation of the system.

Table 4-1: Testing and Inspection Requirements Description Frequency Cycle the HCVS valves and the interfacing Once per operating cycle system valves not used to maintain containment integrity during operations.

Perform visual inspections and a walk down of Once per operating cycle HCVS components Test and calibrate the HCVS radiation Once per operating cycle 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 procedures by Once per every other operating cycle conducting an open/close test of the HCVS control logic from its control panel and ensuring that all interfacing system valves move to their proper (intended) positions.

Page 30 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 4: Programmatic Controls, Training, Drills and Maintenance Notes:

Page 31 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 5: Implementation Schedule Milestones Provide a milestone schedule. This schedule should include:

Modifications timeline

Procedure guidance development complete o HCVS Actions o Maintenance

Storage plan (reasonable protection)

Staffing analysis completion

Long term use equipment acquisition timeline

Training completion for the HCVS Actions The dates specifically required by the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

Ref: EA-13-109 Section D.1, D.3 / NEI 13-02 Section 7.2.1 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent 6 month status reports.

Milestone Target Activity Comments Completion Status {Include date Date changes in this column}

Hold preliminary/conceptual design meeting June 2014 Complete Submit Overall Integrated Implementation Plan June 2014 Complete Design Change Package issued for Cycle 17/RF17 Sept. 2014 In progress Submit 6 Month Status Report Dec. 2014 Submit 6 Month Status Report June 2015 Design Change implementation Cycle 17 Aug. 2015 Design Change implementation RF17 Nov. 2015 Submit 6 Month Status Report Dec. 2015 Simultaneous with Phase 2 OIP Design Change Package issued for RF18 Mar. 2016 Submit 6 Month Status Report June 2016 Operations Procedure Changes Developed Dec. 2016 Site Specific Maintenance Procedure Developed Dec. 2016 Submit 6 Month Status Report Dec. 2016 Training Complete Feb. 2017 Submit 6 Month Status Report June 2017 Design Change implementation RF18 Apr. 2017 Page 32 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Part 5: Implementation Schedule Milestones Procedure Changes Active May 2017 Walk Through Demonstration/Functional Test June 2017 Submit Completion Report June 2017 Page 33 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 1: HCVS Portable Equipment BDBEE Severe Performance Maintenance / PM requirements List portable equipment Venting Accident Criteria Venting FLEX Compressor X X TBD Periodically run for functional testing per response to EA-12-049 FLEX Generator X X TBD Periodically run for functional testing per response to EA-12-049 Phase I OIP Template Page 34 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 2: Sequence of Events Timeline Table 2A: Wet Well HCVS Timeline Fermi 2 Venting Timelines RCIC SBO starts Case 1 S

S 0FLEX Successful Ret Fermi 2 FLEX t=Os t -5 m t - 5 hrs t 12-18 hrs-t18 ts. Containment Venting SA Containment OIP Feed and Contingency (anticipatory venting Venting Bleed Torus Anticipatory not represented in (based on No Injection ; Cooling, FLEX Venting SECY-12-0157) exceeding PCPL)

Feed/HPCI Torus at 220 No Injection Bleed F 1 core Level at TAF

" RCIC Late Failure t 23 hrs t 24 hrs t 34 hrs Ref SECY-12-0157 SA Containment Venting (based on t- 18 hrs t 24 hrs exceeding PCPL) Begin monitoring at Verify or place in service HCVS CP area battery NIAS with FLEX status. No replenishment Compressor and 120

- expected to be required VAC Loads for Secondary before t = 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months HCVS Operation from y MCR Case 3 RCIC Early Failure t l 1 hr t- 8 hr Ref SOARCA Legend References

- Adequate core cooling maintained Case 1: Reference Plant FLEX Overall Integrated Plan Injection Lost Case 2 SECY-12-0157-ML12344A030

- Increased shine and leakage of radionuclides primarily from Case 3 SOARCA - ML13150A053

-- Wetwell HCVS Post Core Damage Dose Evaluation Required E Not to scale Phase T OTP Temnlate Page 35 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 3: Conceptual Sketches (Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the HCVS Actions)

Plant layout with egress and ingress pathways

Piping routing for vent path

Instrumentation Process Flow

Electrical Connections

Include a piping and instrumentation diagram of the vent system. Demarcate the valves (in the vent piping) between the currently existing and new ones.

Sketch 1: HCVS Control Panel (DC) Electrical Layout of System (preliminary)

Sketch 2: MCR (AC) Electrical Layout of System (preliminary)

Sketch 3: Layout of HCVS (preliminary)

Piping routing for vent path

Demarcate the valves (in the vent piping) between the currently existing and new ones

HCVS Instrumentation Process Flow Diagram Phase I OIP Template Page 36 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan HCVS PRIMAPY CONTROL NRC EA-3-1O3 ORDER i2A 2VA DI.-T.-CA-- .1-'

H ANEL REAP)

( HCVS BATTERY CHARGER I1ERTER

'VENT INTRUMENTATION VENT FF R

_____________ ____________ MONITOR DETEkTIR OFF PLANT EATT. PANEL H21-P 01 HCVS BTT, i

POF~WER TORUS TOROS DRYWELL VENT VENT PRESS. LEVEL PRESS. TE!P RAD VMNITOR ND. IND. IND ND.

DIV, II IIIV. I LS r~PN1- - L NOVER POWER C LOSEI 1

LL F4 LOK~~ OP~EN F420

'CLOSE F421 PEN . L

~SOL ( KTETTHTCPEN1 F4O7 rLOSE SOL. -

F4LS PEN CLDSE C5L S;LOSE: F-(R OPEN ~F400 F424 OPEN R SOL..

F41 OPE~f CLOSE)~ CS LS GS CLO SE SLL F41 PEN TORUS LEVEL/PRES _

URYWELL PRESS. LOOP INVERTER R31KD'o Dr POWER SKETCH Sketch 1: HCVS Control Panel (DC) Electrical Layout of System Phase I OIP Template Page 37 of 44

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan H "VS ALTERNATE CONTROL F UK-TI.NAL Ij1A '~A.I NRC EV-i3-IQFfDE 1 _

40V FLEA SVGRf FLEX X-TIE ?NL MCC-72BEA MCC 72'A DIv4i 4:60VAC DIVi II 48QVAC P U# j MVAC - M'J#ri' 12VA C 1-"F, PNL-PI-7 CURRENTLY CLRRENTLY POWERED ?OEREP FROM RPS FROM RPS IN"VERTER BATT, M~PO01A C3P4 R-1KDQ5 .T PPP

- CONTMOL CCS csCS FAI F-Ii :rs E]V. C F4T -L C-J RSSOOM T46 T446 4 T6 T46 T46 746 T5 T F407 FA0 F42 F4 F41 F42IJB F421B Sketch 2: MCR (AC) Electrical Layout of System Phase I OIP Template Page 38 of 44

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan HARDENED CON TA INMENT VENT SYSTEM CONCEPTUAL DESIGN a, a

K 16 A C M N~4NM/p t DDETALAi, 1.0. ". t flfl. P2L 1LtT VA b PTMW ff_____L)M N fi"l 10 - _________________________________

V4i' ° ~ l kNib AWR la MlA*

oftw rd97+>Cu o Cr WR IM t$7 K ' IT~4 '-

Fl O KTt4) kth 3:LyuCfHV e "VF niae hne X

Phase~ Ic GIPL Teplt Pae3Nf44Rvso

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 4: Failure Evaluation Table Table 4A: Wet Well HCVS Failure Evaluation Table Functional Failure Failure with Alternate Action Mode Failure Cause Alternate Action Impact on Containment Venting?

Failure of Vent to Open Valves fail to open/close Power will be tied into station battery or No on Demand due to loss of normal AC dedicated battery for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

power Operator to switch power from station battery to HCVS dedicated battery when necessary.

Failure of Vent to Open Valves fail to open/close Connect station batteries to FLEX generator No on Demand due to loss of alternate within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

AC power (long term)

Failure of Vent to Open Valves fail to open/close Operate valves from MCR with AC power with No on Demand due to complete loss of FLEX provided generators.

batteries (long term)

Failure of Vent to Open Valves fail to open/close No action needed, air will be supplied by locally No on Demand due to loss of normal installed gas bottles, which is sufficient for at pneumatic air supply least 12 cycles of valve T4600F420 over first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Replace bottles as appropriate.

Failure of Vent to Open Valves fail to open/close FLEX provided compressor connected to charge No on Demand due to loss of alternate NIAS system.

pneumatic air supply (long term)

Failure of Vent to Open Valves fail to open due Redundant capability to open SOVs (AC and No on Demand to SOV failure DC) to supply motive force.

Failure of Vent to close Valves fail to close due Any of four independent valves fail close to No on demand to SOV or motive force isolate vent (T4600F400, T4600F401, failure T4600F420, T4600F421)

Phase I OIP Template Page 40 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 5: References

1. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989

2. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

3. Order EA-12-050, Reliable Hardened Containment Vents, dated March 12, 2012

4. Order EA-12-051, Reliable SFP Level Instrumentation, dated March 12, 2012

5. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 2013

6. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012

7. JLD-ISG-2012-02, Compliance with Order EA-12-050, Reliable Hardened Containment Vents, dated August 29, 2012

8. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated November 14, 2013

9. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-02: Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012

10. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 1, dated August 2012

11. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 0, Dated November 2013

12. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014

13. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014

14. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations

15. NEI HCVS-FAQ-02, HCVS Dedicated Equipment

16. NEI HCVS-FAQ-03, HCVS Alternate Control Operating Mechanisms

17. NEI HCVS-FAQ-04, HCVS Release Point

18. NEI HCVS-FAQ-05, HCVS Control and Boundary Valves Phase I OIP Template Page 41 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan

19. NEI HCVS-FAQ-06, FLEX Assumptions/HCVS Generic Assumptions

20. NEI HCVS-FAQ-07, Consideration of Release from Spent Fuel Pool Anomalies

21. NEI HCVS-FAQ-08, HCVS Instrument Qualifications

22. NEI HCVS-FAQ-09, Use of Toolbox Actions for Personnel

23. NEI White Paper HCVS-WP-01, HCVS Dedicated Power and Motive Force

24. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach

25. NEI White Paper HCVS-WP-03, Hydrogen/CO Control Measures

26. NEI White Paper HCVS-WP-04, FLEX/HCVS Interactions

27. IEEE Standard 344-1975, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations,

28. Fermi 2 Correspondence NRC-13-0009, EA-12-049 (FLEX) Overall Integrated Plan, Rev 0, February 2013

29. Fermi 2 Correspondence NRC-13-0008, EA-12-050 (HCVS) Overall Integrated Plan, Rev 0, February 2013

30. Fermi 2 Correspondence NRC-13-0006, EA-12-051 (SFP LI) Overall Integrated Plan, Rev 0, February 2013 Phase I OIP Template Page 42 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 6: Changes/Updates to this Overall Integrated Implementation Plan Any significant changes to this plan will be communicated to the NRC staff in the 6 Month Status Reports Phase I OIP Template Page 43 of 44 Revision 0

Fermi 2 June 2014 HCVS Phase 1 Overall Integrated Plan Attachment 7: List of Overall Integrated Plan Open Items Open Action Comment Item 1 Confirm thermal environment for actions using Gothic.

2 Confirm radiological environment 3 Confirm suppression pool heat capacity.

4 Define tornado missile protection for RB 5th floor components.

Phase I OIP Template Page 44 of 44 Revision 0

v t e Letter Sequence Other
TAC:MF4362, (Open)
Initiation Acceptance... Administration Questions Answers Results Approval... Other: ML15077A574, NRC-14-0043, DTE Electric Company'S Phase 1 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-13-1, NRC-14-0075, First Six Month Status Report 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), NRC-15-0041, Resubmittal of Phase 1 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)
MONTHYEAR2014-06-30 [Table View]

NRC-15-0041, Resubmittal of Phase 1 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)

Text

References:

Subject:

Enclosure:

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