NRC-16-0039, Fourth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
| ML16172A209 | |
| Person / Time | |
|---|---|
| Site: | Fermi  (NPF-043) |
| Issue date: | 06/20/2016 |
| From: | Polson K DTE Electric Company, DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, NRC-16-0039 | |
| Download: ML16172A209 (12) | |
Text
Keith J. Poison Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, M1 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: polsonk@dteenergy.com DTE Energy-June 20, 2016 10 CFR 50.54(f)
NRC-16-0039 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013 (Accession No. ML13130A067)
- 3) NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 0, dated April 2015 (Accession No. ML15104A118)
- 4) NEI 13-02, "Industry Guidance for Compliance with Order EA 109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April 2015 (Accession No. ML15113B318)
- 5) DTE Electric Company letter, 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-13-109)," dated June 30, 2014 (Accession No. ML14182A203)
- 6) DTE Electric Company letter, NRC-14-0075, "DTE Electric Company's 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)," dated December 18, 2014 (Accession No. ML14352A174)
USNRC NRC-16-0039 Page 2
- 7) DTE Electric Company letter, NRC-15-0070, DTE Electric Companys Second 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), dated June 11, 2015 (Accession No. ML15162A729)
- 8) DTE Electric Company Letter, NRC-15-0105, DTE Electric Companys Phase 1 and Phase 2 Overall Integrated Plan for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated December 23, 2015 (Accession No. ML15357A289)
- 9) NRC Letter to DTE Electric Company, Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents),
dated April 1, 2015 (Accession No. ML15077A574)
Subject:
DTE Electric Companys Fourth Six-Month Status Report for Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions On June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to take certain actions to ensure that Fermi 2 Nuclear Power Plant has a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements were outlined in of Reference 2.
Reference 2 required submission of an Overall Integrated Plan (OIP) by June 30, 2014 for Phase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order.
The interim staff guidance (Reference 3) provided direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorsed industry guidance document NEI 13-02, Revision 1 (Reference 4), with certain clarifications and exceptions. Reference 5 provided the DTE Phase 1 OIP for Fermi 2. References 6 and 7 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 2 for Fermi 2.
USNRC NRC-16-0039 Page 3 Reference 8 provided both the third six-month update for Phase 1 of the Order pursuant to Section IV, Condition D.3, of Reference 2 and the OIP for Phase 2 of the Order pursuant to Section IV, Condition D.2 of Reference 2. Reference 8 also addressed the NRC Interim Staff Evaluation open items for Phase 1 contained in Reference 9. The Enclosure to this letter provides the combined six-month update for Phase 1 and Phase 2 of the Order.
This letter contains no new regulatory commitments.
Should you have any questions or require additional information, please contact Mr.
Scott A. Maglio, Licensing Manager, at (734) 586-5076.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 20, 2016 Keith J. Polson Site Vice President
Enclosure:
DTE Electric Company's Fourth Six-Month Status Report 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 (kindschl@michigan.gov)
Enclosure to NRC-16-0039 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Companys Fourth Six-Month Status Report
Enclosure to NRC-16-0039 Page 1 DTE Electric Companys Fourth Six-Month Status Report for the Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1 Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 8.1),
documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 8.2. Starting with this six-month status report, updates of milestone accomplishments will be based on the combined Phase 1 and 2 OIP, dated December 23, 2015 (Reference 8.3).
This Enclosure provides an update of milestone accomplishments since submittal of the combined Phase 1 and 2 OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any, in accordance with Nuclear Energy institute (NEI) 13-02, Revision 1, Industry Guidance for Compliance with Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, (Reference 8.4).
2 Milestone Accomplishments [required by NEI 13-02 Section 7.3.1.2]
The following milestone(s) have been completed since the development of the combined Phase 1 and 2 OIP (Reference 8.3), and are current as of May 27, 2016, for this status report.
- Fourth Six-Month Status Report (this submittal) 3 Milestone Schedule Status [required by NEI 13-02 Section 7.3.1.1]
The following provides an update to Part 5 of the combined Phase 1 and 2 OIP (Reference 8.3). It provides the activity status of each item, and whether the expected completion date has changed. Some dates were revised in this update to align the target completion dates to completion of refueling outages 18 and 19 (RF18 and RF19), which will implement Phase 1 and Phase 2, respectively. The dates are planning dates subject to change as design and implementation details are developed.
Enclosure to NRC-16-0039 Page 2 Milestone Target Completion Date Activity Status Comments
{Include date changes in this column}
Phase 1 and 2 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 [with Phase 2 OIP]
Dec 2015 Complete Update 4 Jun 2016 This submittal Update 5 Dec 2016 Not Started Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Modifications Hold preliminary/conceptual design meeting Jun 2014 Complete Modifications Evaluation Jul 2014 Complete Design Engineering On-site/Complete Apr 2017 Started Implementation Outage Apr 2017 Not Started Walk Through Demonstration/Functional Test Apr 2017 Not Started Changed from Jun 2017 to align with the completion of RF18 Phase 1 Procedure Changes Active Operations Procedure Changes Developed Apr 2017 Started Changed from Dec 2016 to align with the completion of RF18 Site Specific Maintenance Procedure Developed Apr 2017 Not Started Changed from Dec 2016 to align with the completion of RF18 Procedure Changes Active Apr 2017 Not Started Changed from May 2017 to align with the completion of RF18
Enclosure to NRC-16-0039 Page 3 Milestone Target Completion Date Activity Status Comments
{Include date changes in this column}
Phase 1 and 2 HCVS Milestone Table Phase 1 Specific Milestones (continued)
Phase 1 Training Training Complete Apr 2017 Not Started Changed from Feb 2017 to align with the completion of RF18 Phase 1 Completion Submit Completion Report [60 days after full site compliance]
Jun 2017 Not Started Phase 2 Specific Milestones Phase 2 Modifications Hold preliminary/conceptual design meeting Sept 2016 Not Started Modifications Evaluation Sept 2016 Not Started Design Engineering On-site/Complete Sept 2017 Not Started Implementation Outage Oct 2018 Not Started Changed from Sep 2018 to align with the completion of RF19 Walk Through Demonstration/Functional Test Oct 2018 Not Started Changed from Jan 2019 to align with the completion of RF19 Phase 2 Procedure Changes Active Operations Procedure Changes Developed Oct 2018 Started Changed from Mar 2018 to align with the completion of RF19 Site Specific Maintenance Procedure Developed Oct 2018 Not Started Changed from Mar 2018 to align with the completion of RF19 Procedure Changes Active Oct 2018 Not Started Changed from Aug 2018 to align with the completion of RF19
Enclosure to NRC-16-0039 Page 4 Milestone Target Completion Date Activity Status Comments
{Include date changes in this column}
Phase 1 and 2 HCVS Milestone Table Phase 2 Specific Milestones (continued)
Phase 2 Training Training Complete Oct 2018 Not Started Changed from Aug 2018 to align with the completion of RF19 Phase 2 Completion Submit Completion Report [60 days after full site compliance]
Dec 2018 Not Started Changed from Jan 2019 to align with the completion of RF19 + 60 days 4 Changes to Compliance Method [required by NEI 13-02 Section 7.3.1.3]
There are no changes to the compliance method as documented in the combined Phase 1 and 2 Overall Integrated Plan (Reference 8.3).
5 Need and Basis for Relief/Relaxation [required by NEI 13-02 Section 7.3.1.4]
DTE expects to comply with the order implementation date.
6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluations [required by NEI 13-02 Section 7.3.1.5]
The following tables provide a summary of the open items documented in the combined Phase 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) (Reference 8.5) and the status of each item.
Enclosure to NRC-16-0039 Page 5 Combined Phase 1 and 2 OIP Open Items Status Phase 1 OIP Open Items OIP Open Item Action Comment 1
Confirm thermal environment for actions using GOTHIC.
See Phase 1 ISE Open Item 2.
2 Confirm radiological environment.
See Phase 1 ISE Open Item 2.
3 Confirm suppression pool heat capacity.
See Phase 1 ISE Open Item 3.
4 Define tornado missile protection for RB 5th floor components.
Missile protection for HCVS components on the RB 5th floor will be provided by following the guidance of NRC endorsed white paper, HCVS-WP-04 Missile Evaluation for HCVS Components 30 Feet Above Grade.
Phase 2 OIP Open Items OIP Open Item Action Comment 1
Confirm that the thermal environment supports feasibility of staff actions.
Added for Phase 2 per Table 3.1 and 3.1.b of Reference 8.3 2
Confirm that the radiological environment supports feasibility of staff actions.
Added for Phase 2 per Table 3.1 and 3.1.b of Reference 8.3 Combined Phase 1 and 2 ISE Open Items Status Phase 1 ISE Open Items 1
Make available for NRC staff audit documentation confirming that all load stripping will be accomplished within one hour and fifteen minutes of event initiation and will occur at locations not impacted by a radiological event.
Response to be documented in a future update 2
Make available for NRC staff audit an evaluation of Section 3.2.1 temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.
Response to be documented in a future update
Enclosure to NRC-16-0039 Page 6 Combined Phase 1 and 2 ISE Open Items Status Phase 1 ISE Open Items (continued) 3 Make available for NRC staff audit, analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
Response to be documented in a future update 4
Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during extended loss of alternating current (AC) power (ELAP) and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.)
required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
Response to be documented in a future update 5
Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location.
Response to be documented in a future update 6
Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX diesel generator (DG) loading calculation.
Response to be documented in a future update
Enclosure to NRC-16-0039 Page 7 Combined Phase 1 and 2 ISE Open Items Status Phase 1 ISE Open Items (continued) 7 Make available for NRC staff audit documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.
Response to be documented in a future update 8
Provide a description of the final design of HCVS to address hydrogen detonation and deflagration.
Response to be documented in a future update 9
Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.
Response to be documented in a future update 10 Make available for NRC staff review design details to ensure the potential for cross flow between HCVS and Standby Gas Treatment System (SGTS) is minimized.
Response to be documented in a future update 11 Provide a justification for deviating from the instrumentation seismic qualification guidance specified in Nuclear Energy Institute (NEI) 13-02, endorsed, in part, by JLD-ISG-2013-02 as an acceptable means for implementing applicable requirements of Order EA-13-109.
Response to be documented in a future update 12 Make available for NRC staff audit description of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.
Response to be documented in a future update
Enclosure to NRC-16-0039 Page 8 Combined Phase 1 and 2 ISE Open Items Status Phase 1 ISE Open Items (continued) 13 Make available for NRC staff audit documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during beyond design basis external events (BDBEE) and severe accident wetwell venting.
Response to be documented in a future update Phase 2 ISE Open Items Phase 2 ISE Not Yet Received 7
Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation(s) identified at this time.
8 References The following references support the updates to the combined Phase 1 and 2 Overall Integrated Plan described in this Enclosure.
8.1 DTE Electric Company Letter, NRC-14-0043, DTE Electric Companys Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (ML14182A203) 8.2 NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions dated June 6, 2013 (ML13130A067) 8.3 DTE Electric Company Letter, NRC-15-0105, DTE Electric Companys Combined Phase 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 23, 2015 (ML15357A289) 8.4 NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, BWR Mark I
& II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, dated April 2015 (ML15113B318) 8.5 NRC Letter to DTE Electric Company, Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated April 1, 2015 (ML15077A574)