NRC-17-0043, DTE Electric Company'S Sixth 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
| ML17178A343 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/27/2017 |
| From: | Polson K DTE Electric Company, DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, NRC-17-0043 | |
| Download: ML17178A343 (17) | |
Text
Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: kceith.polson~(dteenergy.com DYE Energy-June 27, 2017 10 CFR 50.54(f)
NRC-17-0043 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-15-0105, "DTE Electric Company's 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)
USNRC NRC-17-0043 Page 2
- 7) 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)
- 8) NRC Letter to DTE Electric Company, Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents),
dated August 30, 2016 (Accession No. ML16231A443)
Subject:
DTE Electric Companys Sixth 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 Venting 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. References 5 and 6 provided the Phase 1 and Phase 2 OIPs. In References 7 and 8, NRC provided the Phase 1 and Phase 2 Interim Staff Evaluations for Fermi 2.
The Enclosure to this letter provides the sixth six-month update for Phase 1 and Phase 2 of the Order.
This letter contains no new regulatory commitments.
USNRC NRC-17-0043 Page 3 Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager -Nuclear Licensing, at (734) 586-5076.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 27, 2017 Keith J. Polson Site Vice President
Enclosure:
DTE Electric Company's Sixth 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-17-0043 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Companys Sixth Six-Month Status Report
Enclosure to NRC-17-0043 Page 1 DTE Electric Companys Sixth 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 Venting 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 NRC Order Number EA-13-109 (Reference 8.2). 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 last status report, 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 The following milestone(s) have been completed since November 8, 2016, the previous completion date given in the Fifth Six-Month Status Report (Reference 8.8), and are current as of June 23, 2017, for this status report.
Sixth Six-Month Status Report (this submittal)
Design Engineering On-site/Complete for Phase 1 Implementation Outage for Phase 1 Walk Through Demonstration/Functional Test for Phase 1 Operations Procedure Changes Developed for Phase 1 Site Specific Maintenance Procedure Developed for Phase 1 Procedure Changes Active for Phase 1 Training Complete for Phase 1 3 Milestone Schedule Status 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. No target completion dates have changed in this report. The dates are planning dates subject to change as design and implementation details are developed.
Enclosure to NRC-17-0043 Page 2 Comments Target
{Include date Milestone Completion Activity 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 Complete Update 5 Dec 2016 Complete Update 6 Jun 2017 This Submittal 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 Apr 2017 Complete On-site/Complete Implementation Outage Apr 2017 Complete Walk Through Apr 2017 Complete Demonstration/Functional Test Phase 1 Procedure Changes Active Operations Procedure Changes Apr 2017 Complete Developed Site Specific Maintenance Procedure Apr 2017 Complete Developed Procedure Changes Active Apr 2017 Complete Phase 1 Training Training Complete Apr 2017 Complete Phase 1 Completion Submit Completion Report [60 days Not required for Jun 2017 Not Required after full site compliance] Phase 1 Phase 2 Specific Milestones Phase 2 Modifications Hold Preliminary/Conceptual Design Sept 2016 Complete Meeting Modifications Evaluation Sept 2016 Complete
Enclosure to NRC-17-0043 Page 3 Comments Target
{Include date Milestone Completion Activity Status changes in this Date column}
Phase 2 Specific Milestones (cont.)
No Modifications Design Engineering Sept 2017 Not Required Required for Phase On-site/Complete 2
No Modifications Implementation Outage Oct 2018 Not Required Required for Phase 2
Walk Through Oct 2018 Not Started Demonstration/Functional Test Phase 2 Procedure Changes Active Operations Procedure Changes Oct 2018 Started Developed Site Specific Maintenance Procedure Oct 2018 Not Started Developed Procedure Changes Active Oct 2018 Not Started Phase 2 Training Training Complete Oct 2018 Not Started Phase 2 Completion Submit Completion Report [60 days Dec 2018 Not Started after full site compliance]
4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phase 1 and 2 OIP (Reference 8.3).
5 Need and Basis for Relief/Relaxation DTE expects to comply with the order implementation date and no relief/relaxation is required at this time.
6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phase 1 and 2 OIP and the Interim Staff Evaluations (ISEs) (References 8.5 and 8.6) and the status of each item. All Phase 1 open items have been completed.
Enclosure to NRC-17-0043 Page 4 Combined Phase 1 and 2 OIP Status Open Items Phase 1 OIP Open Items OIP Action Comment Open Item 1 Confirm thermal environment for Complete.
actions using GOTHIC.
Conducted under Design Calculation DC-6639, Loss of HVAC-Room Environmental Analysis in Support of Hardened Vent.
2 Confirm radiological environment. Complete.
Conducted under Design Calculation DC-6645, HCVS Radiological Assessment.
3 Confirm suppression pool heat Complete.
capacity.
Conducted under Design Calculation DC-6668, Torus Capacity to Absorb Decay Heat Generated During First Three Hours After Shutdown.
4 Define tornado missile protection for Complete.
RB 5th floor components.
Missile protection for HCVS components on the RB 5th floor was provided by following the guidance of NRC endorsed white paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade. Fermi 2 also conducted an evaluation of actions and timeframes for actions in the event of a tornado and have placed steps in 29.400.01 for FLEX Venting and 29.400.03 for HCVS Venting to ensure proper checks for HCVS function after a tornado.
Phase 2 OIP Open Items OIP Action Comment Open Item 1 Confirm that the thermal environment New actions added for Phase 2 per Table 3.1 supports feasibility of staff actions. and 3.1.b of Reference 8.3 2 Confirm that the radiological New actions added for Phase 2 per Table 3.1 environment supports feasibility of and 3.1.b of Reference 8.3 staff actions.
Enclosure to NRC-17-0043 Page 5 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items 1 Make available for NRC staff audit Complete.
documentation confirming that all load stripping will be accomplished Validation of times needed for load stripping within one hour and fifteen minutes is contained in the FLEX Validation Program of event initiation and will occur at results that are documented in TMII-15-0008 locations not impacted by a which will be posted on the e-portal.
radiological event.
2 Make available for NRC staff audit Complete.
an evaluation of Section 3.2.1 temperature and radiological The evaluation of temperature conditions is conditions to ensure that operating contained in DC-6639 and the evaluation of personnel can safely access and radiological conditions is contained in DC-operate controls and support 6645.
equipment.
These design calculations will be posted on the e-portal.
3 Make available for NRC staff audit, Complete.
analyses demonstrating that HCVS has the capacity to vent the HCVS vent capacity evaluation is contained steam/energy equivalent of one in DC-6646, Torus Hardened Vent Sizing percent of licensed/rated thermal Analysis and Dynamic Analysis.
power (unless a lower value is Suppression pool heat capacity is contained in justified), and that the suppression DC-6668.
pool and the HCVS together are able to absorb and reject decay heat, such These design calculations will be posted on that following a reactor shutdown the e-portal.
from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
Enclosure to NRC-17-0043 Page 6 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
4 Make available for NRC staff audit Complete.
the descriptions of local conditions (temperature, radiation and humidity) The evaluation of HCVS components anticipated during extended loss of capability during ELAP and severe accident alternating current (AC) power conditions was performed by review of (ELAP) and severe accident for the vendor test reports and plant design basis components (valves, instrumentation, environmental qualification material in sensors, transmitters, indicators, comparison to local conditions determined by electronics, control devices, etc.) the design calculations discussed in the required for HCVS venting including response to Phase 1 ISE Item 2 above.
confirmation that the components are Results of these comparisons are documented capable of performing their functions in DC-6639 and DC-6645 for areas during ELAP and severe accident containing new components.
conditions.
DC-6639 and DC-6645 will be posted on the e-portal.
5 Make available for NRC staff audit Complete.
documentation of the HCVS nitrogen pneumatic system design including The HCVS pneumatic design and location is sizing and location. included in Engineering Design Package (EDP) 37115, Reliable Severe Accident Capable Containment Wetwell Venting System Modification for NRC Order EA 109, for all the pneumatic tubing runs to the valves and for T46P410/P411. The sizing is included in DC-6636, Hardened Containment Vent System Bottle Sizing.
The requested information will be provided on the e-portal.
6 Make available for NRC staff audit Complete.
the final sizing evaluation for HCVS batteries/battery charger including The sizing evaluation for the HCVS battery is incorporation into FLEX diesel included in DC-6584 Rev A, FLEX DC generator (DG) loading calculation. Calculations.
The requested information will be provided on the e-portal.
Enclosure to NRC-17-0043 Page 7 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
7 Make available for NRC staff audit Complete.
documentation that demonstrates adequate communication between the The primary method of communications will remote HCVS operation locations be via satellite phone per 29.FSG.06.
and HCVS decision makers during Adequate communication is provided by face ELAP and severe accident to face communication for commencement of conditions. venting per 29.FSG.13 (HCVS prior to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) and by face to face continuous communication for HCVS Operation from the Main Control Room (MCR) after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
8 Provide a description of the final Complete.
design of HCVS to address hydrogen detonation and deflagration. The plant is using the guidance from NEI 13-02 and white paper HCVS-WP-03, Hydrogen/Carbon Monoxide Control Measures, Rev 1. Fermi 2 is using the check valve option. Check Valve testing and design is per EDP 37115 with evaluation of leakage in EDP 37115.B103.
The requested information will be provided on the e-portal.
Enclosure to NRC-17-0043 Page 8 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
9 Provide a description of the strategies Complete.
for hydrogen control that minimizes the potential for hydrogen gas By use of the HCVS in conjunction with the migration and ingress into the reactor EPG/SAGs, the containment will be building or other buildings. maintained below pressure limits (with the exception that short excursions may occur and are acceptable). Maintaining containment within failure limits will minimize containment leakage to secondary containment; therefore, minimizing the potential for hydrogen gas migration and ingress outside of containment and the HCVS piping. Valves that directly connect to the Reactor Building air space (T4600F407/
F410) have been leak tested per 47.000.94, Local Leakage Rate Testing for Hardened Vent.
In addition, cross flow is addressed in Phase 1 ISE Item 10 for leakage between HCVS and Standby Gas Treatment System.
Fermi 2 utilizes leak tight valves as a strategy for hydrogen control to minimize hydrogen gas migration and ingress into the Reactor Building per NEI 13-02 Sections 4.1.4.1.2, 4.1.4.1.5, 4.1.4.1.8 (testing). All applicable valves have been tested per 10 CFR 50 Appendix J or new procedure 47.000.94 to ensure proper leak tight integrity.
Test results will be posted on the e-portal.
Enclosure to NRC-17-0043 Page 9 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
10 Make available for NRC staff review Complete.
design details to ensure the potential for cross flow between HCVS and The expected differential pressure is within Standby Gas Treatment System the scope of containment design for (SGTS) is minimized. compliance with GL 89-16.
HCVS and SGTS cross flow is minimized by use of the auto close on loss of Non-Interruptible Air Supply (NIAS)/ 120 VAC to T4600F408/ F409 valves between HCVS pipe and SGTS. Additionally, both the T4600F408/ F409 valves were tested under 47.000.94 procedure for leak tight integrity.
Test results will be posted on the e-portal.
Enclosure to NRC-17-0043 Page 10 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
11 Provide a justification for deviating Complete.
from the instrumentation seismic qualification guidance specified in The Fermi 2 existing design basis instrument Nuclear Energy Institute (NEI) 13- seismic qualification standard is IEEE 344-02, endorsed, in part, by JLD-ISG- 1975.
2013-02 as an acceptable means for Fermi 2 Design Basis for Containment implementing applicable Isolation Valves (CIVs) (T4600F400, requirements of Order EA-13-109. T4600F401, T4803F602, T4600F402, T4600F411) is IEEE 344-1975 based on original design. Upgrading to IEEE 344-2004 for these components (valves, AC solenoids, limit switches) is not required by Order EA-13-109 as design basis for CIVs is exempted.
Non CIV valves using existing hardware for operation (T4600F407, T4600F408, T4600F409, T4600F410, T4600F420, T4600F421) that are design basis valves (QA-
- 1) installed prior to 2004 would similarly not require upgrade to IEEE 344-2004.
Design basis instruments (Drywell Pressure, Torus Pressure, Torus Level) were also installed prior to 2004 and thus would not require upgrade to IEEE 344-2004.
New DC solenoids for HCVS (for T4600F407, T4600F410, T4600F420, T4600F421) were upgraded to IEEE 344-2004 as were new instrumentation (HCVS Radiation Monitor, HCVS Thermal monitor).
New operating shuttles for T4600F400/T4600F401 have no electrical parts and thus IEEE 344 does not apply.
Enclosure to NRC-17-0043 Page 11 Combined Phase 1 and 2 ISE Status Open Items Phase 1 ISE Open Items (cont.)
12 Make available for NRC staff audit Complete.
description of all instrumentation and controls (existing and planned) The instrumentation planned and existing is necessary to implement this order listed in the OIP (Reference 8.3). The including qualification methods. selected qualification methods for the instruments is defined in EDP 37115 Index Item 004 Section 5.14 (I & C Scope) and 5.32 where EQ Program impact was defined.
The requested information will be posted on the e-portal.
13 Make available for NRC staff audit Complete.
documentation of an evaluation verifying the existing containment The expected differential pressure is within isolation valves, relied upon for the the scope of containment design for HCVS, will open under the maximum compliance with GL 89-16. This evaluation expected differential pressure during is contained in EDP 37115 Index Item 004 beyond design basis external events Section 5.12 (Valves) and evaluated under (BDBEE) and severe accident DC-5938 Vol I, DC-5951 Vol I, DC-6170 Vol wetwell venting. I, DC-5937 Vol I, DC-5989 Vol I, DC-6292, and Thrust Torque Calculations 2206C, 2406C, 2744C, 3612C, 3613C, 3590C.
The requested Design Calculations and Thrust Torque Calculations will be posted on the e-portal.
Enclosure to NRC-17-0043 Page 12 Combined Phase 1 and 2 ISE Status Open Items Phase 2 ISE Open Items 1 Licensee to demonstrate that Response to be documented in a future update containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.
2 Licensee to provide the site-specific Response to be documented in a future update MAAP evaluation that demonstrates Severe Accident Water Addition (SAWA) / Severe Accident Water Management (SAWM) can be maintained for greater than 7 days.
3 Licensee to demonstrate that there is Response to be documented in a future update adequate communication between Main Control Room and the SAWM control location during severe accident conditions.
4 Licensee to demonstrate the SAWM Response to be documented in a future update flow instrumentation qualification for the expected environmental conditions.
7 Interim Staff Evaluation Impacts Items identified in the Phase 1 ISE (Reference 8.5) and Phase 2 ISE (Reference 8.6) are addressed in Section 6 above. There are no other impacts to the ISE identified at this time.
Enclosure to NRC-17-0043 Page 13 8 References The following references support the updates to the combined Phase 1 and 2 OIP 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) 8.6 NRC Letter to DTE Electric Company, Fermi Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated August 30, 2016 (ML16231A443) 8.7 DTE Electric Company Letter, NRC-16-0039, 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, dated June 20, 2016 (ML16172A209) 8.8 DTE Electric Company Letter, NRC-16-0069, DTE Electric Companys Fifth 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, dated December 9, 2016 (ML16344A252)