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

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
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 Comments Target Activity {Include date Milestone Completion Status changes in this Date 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 Jun 2014 Complete meeting Modifications Evaluation Jul 2014 Complete Design Engineering On-site/Complete Apr 2017 Started Implementation Outage Apr 2017 Not Started Changed from Jun Walk Through 2017 to align with Apr 2017 Not Started Demonstration/Functional Test the completion of RF18 Phase 1 Procedure Changes Active Changed from Dec Operations Procedure Changes 2016 to align with Apr 2017 Started Developed the completion of RF18 Changed from Dec Site Specific Maintenance Procedure 2016 to align with Apr 2017 Not Started Developed the completion of RF18 Changed from May 2017 to align with Procedure Changes Active Apr 2017 Not Started the completion of RF18

Enclosure to NRC-16-0039 Page 3 Comments Target Activity {Include date Milestone Completion Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Phase 1 Specific Milestones (continued)

Phase 1 Training Changed from Feb 2017 to align with Training Complete Apr 2017 Not Started the completion of RF18 Phase 1 Completion Submit Completion Report [60 days Jun 2017 Not Started after full site compliance]

Phase 2 Specific Milestones Phase 2 Modifications Hold preliminary/conceptual design Sept 2016 Not Started meeting Modifications Evaluation Sept 2016 Not Started Design Engineering On-site/Complete Sept 2017 Not Started Changed from Sep 2018 to align with Implementation Outage Oct 2018 Not Started the completion of RF19 Changed from Jan Walk Through Demonstration/Functional 2019 to align with Oct 2018 Not Started Test the completion of RF19 Phase 2 Procedure Changes Active Changed from Mar 2018 to align with Operations Procedure Changes Developed Oct 2018 Started the completion of RF19 Changed from Mar Site Specific Maintenance Procedure 2018 to align with Oct 2018 Not Started Developed the completion of RF19 Changed from Aug 2018 to align with Procedure Changes Active Oct 2018 Not Started the completion of RF19

Enclosure to NRC-16-0039 Page 4 Comments Target Activity {Include date Milestone Completion Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Phase 2 Specific Milestones (continued)

Phase 2 Training Changed from Aug 2018 to align with Training Complete Oct 2018 Not Started the completion of RF19 Phase 2 Completion Changed from Jan Submit Completion Report [60 days after 2019 to align with Dec 2018 Not Started full site compliance] 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 Status Open Items Phase 1 OIP Open Items OIP Action Comment Open Item 1 Confirm thermal environment for See Phase 1 ISE Open Item 2.

actions using GOTHIC.

2 Confirm radiological environment. See Phase 1 ISE Open Item 2.

3 Confirm suppression pool heat See Phase 1 ISE Open Item 3.

capacity.

4 Define tornado missile protection for Missile protection for HCVS components on RB 5th floor components. 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 Action Comment Open Item 1 Confirm that the thermal environment Added for Phase 2 per Table 3.1 and 3.1.b of supports feasibility of staff actions. Reference 8.3 2 Confirm that the radiological Added for Phase 2 per Table 3.1 and 3.1.b of environment supports feasibility of Reference 8.3 staff actions.

Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items 1 Make available for NRC staff audit Response to be documented in a future documentation confirming that all update 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.

2 Make available for NRC staff audit Response to be documented in a future an evaluation of Section 3.2.1 update temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

Enclosure to NRC-16-0039 Page 6 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 3 Make available for NRC staff audit, Response to be documented in a future analyses demonstrating that HCVS update 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.

4 Make available for NRC staff audit Response to be documented in a future the descriptions of local conditions update (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.

5 Make available for NRC staff audit Response to be documented in a future documentation of the HCVS nitrogen update pneumatic system design including sizing and location.

6 Make available for NRC staff audit Response to be documented in a future the final sizing evaluation for HCVS update batteries/battery charger including incorporation into FLEX diesel generator (DG) loading calculation.

Enclosure to NRC-16-0039 Page 7 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 7 Make available for NRC staff audit Response to be documented in a future documentation that demonstrates update adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

8 Provide a description of the final Response to be documented in a future design of HCVS to address hydrogen update detonation and deflagration.

9 Provide a description of the strategies Response to be documented in a future for hydrogen control that minimizes update the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

10 Make available for NRC staff review Response to be documented in a future design details to ensure the potential update for cross flow between HCVS and Standby Gas Treatment System (SGTS) is minimized.

11 Provide a justification for deviating Response to be documented in a future from the instrumentation seismic update 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.

12 Make available for NRC staff audit Response to be documented in a future description of all instrumentation and update controls (existing and planned) necessary to implement this order including qualification methods.

Enclosure to NRC-16-0039 Page 8 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (continued) 13 Make available for NRC staff audit Response to be documented in a future documentation of an evaluation update 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.

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)