PLA-7269, 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 No. EA-13-109)

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 No. EA-13-109)

ML15040A155
Person / Time
Site:	Susquehanna
Issue date:	12/23/2014
From:	Rausch T Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, PLA-7269
Download: ML15040A155 (7)

Text

Timothy S. Rausch PPL Susquehanna, LLC Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA '18603 +'~a~

Tel. 570.542.3345 Fax 570.542.1504 tsrausch@pplweb.com P

DEC 2 32014 .

t ,T U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION 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 Docket Nos. 50-387 (ORDER NUMBER EA-13-109) and 50-388 PLA-7269

References:

1. NRC OrderNumber EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with OrderEA-13-109, Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions, " Revision 0, datedNovember 2013 (Accession No. ML13304B836).

3. NRC Endorsement of industry "HardenedContainment Venting System (HCVS) Phase 1 Overall IntegratedPlan Template (EA-13-109)Rev 0" (Accession No. ML14128A219).

4. NEI 13-02, "Industiy Guidancefor Compliance with NRC Order EA-13-109, "To Modify Licenses with Regard to Reliable HardenedContainment Vents Capable of Operationunder Severe Accident Conditions,"Revision 0, dated November 2013.

5. PPL Letter (PLA- 7180), "Overall IntegratedPlan in Response to June 6, 2013 Commission OrderModifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-13-109), "dated June 26, 2014.

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to PPL Susquehanna, LLC (PPL). Reference 1 was immediately effective and directs PPL to install a venting capability in accordance with the requirements outlined in Attachment 2 of Reference 1.

Document Control Desk PLA-7269 Reference 1 required submission of a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 2.

Reference 5 provided PPL's initial Reliable Hardened Containment Vent Overall Integrated Plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan. References 2 and 4 provide direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition D, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed Status Report provides the first update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Jeffery N. Grisewood at 570-542-1330.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 1L2-. i i T. -I S.Rus

Enclosure:

P Susquehanna, LLC's First Six-Month Status Report in Response to the 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 Region I Mr. Rajender Auluck, NRR/JLD/PSB, NRC Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. W. D. Reckley, NRR/JLD/PSB, NRC Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP

Enclosure to PLA-7269 First Six-Month Status Report In Response to the 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)

Enclosure to PLA-7269 Page 1 of 4 PPL Susquehanna, LLC's First 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" Introduction PPL Susquehanna LLC developed an Overall Integrated Plan (Reference I in Section 8),

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

2 Milestone Accomplishments None 3 Milestone Schedule Status The following provides an update to the Milestone schedule included in the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

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

Phase 1 HCVS Milestone Table Hold preliminary/conceptual design June 2014 Complete meeting.

Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Status Report 1 Dec. 2014 Complete Submit 6 Month Status Report 2 June 2015 Not Started Submit 6 Month Status Report 3 -De .2 1 No Str d Simultaneous with Phase 2 OIP U2 Design Engineering Complete Mar. 2016 Not Started Submit 6 Month Status Report 4 June 2016 Not Started U2 Operations Procedure Changes Dec. 2016 Not Started Developed U2 Maintenance Procedure Changes Dec. 2016 Not Started Developed Submit 6 Month Status Report 5 Dec. 2016 Not Started U2 Training Complete Dec. 2016 Not Started U2 Implementation Outage Feb. 2017 Not Started

Enclosure to PLA-7269 Page 2 of 4 Comments Target Activity {Include date Milestone C~anpletion Status changes in this Date column)

Phase 1 HCVS Milestone Table U2 Procedure Changes Active Mar. 2017 Not Started U2 Walk Through Demonstration/Functional Test Mar. 2017 Not Started Ul Design Engineering Complete Mar. 2017 Not Started Submit 6 Month Status Report 6 June 2017 Not Started Submit 6 Month Status Report 7 Dec. 2017 Not Started Ul Operations Procedure Changes Dec. 2017 Not Started Developed U1 Maintenance Procedure Changes Dec. 2017 Not Started Developed Ul Training Complete Dec. 2017 Not Started Ul Implementation Outage Feb. 2018 Not Started Ul Procedure Changes Active Mar. 2018 Not Started U I Walk Through Mar. 2018' Not Started Demonstration/Functional Test II Submit Phase 1 Compliance Letter May 2019 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of thie open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Open Item Overall Integrated Plan Phase 1 Open Item Status 1 Confirm suppression pool heat capacity Not Started Deployment under severe accident conditions will be 2 confirmed for the deployment of the FLEX generators Not Started credited to re-energize battery chargers.

Enclosure to PLA-7269 Page 3 of 4 Open Item Overall Integrated Plan Phase 1 Open Item Status Deployment under severe accident conditions will be 3 confirmed for deployment of the supplemental nitrogen Not Started bottles.

The gas supply will be sized to support HCVS operation for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (a minimum of 12 valve cycles of valve operation is assumed, consistent with recommendations in HCVS-WP-02). This design Not Started assumption will require future validation in the design phase of this project.

An assessment of temperature and radiological conditions will be performed to ensure that operating personnel can 5 safely access and operate controls at the remote operating Not Started station, based on time constraints listed in Attachment.2 of the Overall Integrated Plan.

Evaluate viable options to address Hydrogen detonation concerns in HCVS piping to meet the requirements of EA-6 13-109, Section 1.2.11 and incorporate in HCVS design. Started

.SSES will determine the method to be deployed once NRC review of HCVS-WP-03 is complete.

An evaluation will be performed to confirm the HCVS 7 power supply can support HCVS operation for a minimum Not Started of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Interim Staff Evaluation Open Item Status None None identified.

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

Enclosure to PLA-7269 Page 4 of 4 8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. PPL Letter (PLA-7180), Susquehanna Steam Electric Station 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 26, 2014.

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.

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 0, dated November 2013.

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).

5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-l 3-109) Rev 0" (Accession No. ML14128A219).