RS-13-129, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML13241A287
Person / Time
Site:	Quad Cities
Issue date:	08/28/2013
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-13-129
Download: ML13241A287 (13)

Text

1 Exelon Generation ~

Order No. EA-12-049 RS-13-129 August 28, 2013 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049)

References:

1. NRC Order Number EA-12-049, " Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events," dated March 12,2012

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events," Revision 0, dated August 29,2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated October 25, 2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for 8eyond-Design-8asis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-025)

6. NRC Order Number EA-12-050, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012

7. NRC Order Number 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28,2013 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Quad Cities Nuclear Power Station, Units 1 and 2 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides 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 C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

As described in Reference 5, full implementation of NRC Order EA-12-049 required mitigation strategies is dependent upon implementation of reliable hardened containment venting capability established in accordance with NRC Order EA-12-050 (Reference 6). NRC Order EA-13-109 (Reference 7) issued by the NRC on June 6, 2013, rescinded the requirements of Order EA-12-050 and established revised schedule time lines and implementation dates for reliable hardened containment vents capable of operation under severe accident conditions.

The revised schedule and implementation timeline contained in Order EA-13-1 09 delays the ability to achieve full implementation of the mitigation strategy requirements of Order EA 049. This need for relaxation from the implementation requirements of Order EA-12-049 is described in Section 5 of the enclosed update report. The request for relaxation of the full implementation schedule requirements of Order EA-12-049 will be submitted separately.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2013.

Respectfully submitted,

~ I.~~

Glen T. Kaegi Director - Licensing & ;egu:or; Affairs Exelon Generation Company, LLC

u.s. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28,2013 Page 3

Enclosure:

1. Quad Cities Nuclear Power Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station, Units 1 and 2 NRC Project Manager, NRR - Quad Cities Nuclear Power Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Robert J. Fretz, Jr, NRR/JLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Eric E. Bowman, NRRlDPRlPGCB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (9 pages)

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Quad Cities Nuclear Power Station, Units 1 and 2 developed an Overall Integrated Plan (Reference I in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the 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 Attachment 2 of 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.

The revised target completion dates impact the order implementation date. An explanation of the impact of these changes is provided in Section 5 of this enclosure.

Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Contract with RRC Complete Submit 6 Month Updates:

Update I Aug 2013 Complete with this submittal Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Page I of9

Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Target Revised Target Milestone Completion Activity Status Completion Date Date Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Submit Completion Report Not Started See Section 5 of this enclosure.

Modifications Development &

Implementation:

Unit 1 Modification Development (All Feb 2014 Started April 2014 FLEX Phases)

Unit 1 Modification Implementation (All Apr 2015 Not Started FLEX Phases)

Unit 2 Modification Development (All Mar 2015 StaIted FLEX Phases)

Unit 2 Modification Implementation (All Apr 2016 Not Started FLEX Phases)

Procedures:

Create Site-Specific Procedures Apr 2015 Not Started Validate Procedures (NEI 12-06, Sect.

Apr 2015 Not Started 11.4.3)

Create Maintenance Procedures Apr 2015 Not Started Perform Staffing Analysis Nov 2014 Not Started Storage Plan and Construction Apr 2015 Started FLEX Equipment Acquisition Apr2015 Started Training Completion Apr 2015 Not Started Regional Response Center Operational Dec 2014 Started Unit 1 FLEX Implementation Apr 2015 Started See Section 5 of this enclosure.

Unit 2 FLEX Implementation Apr 2016 Started See Section 5 of this enclosure.

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Quad Cities Nuclear Power Station, Units I and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Target Revised Target Milestone Completion Activity Status Completion Date Date Full Site FLEX Implementation Apr 2016 Started See Section 5 of this enclosure.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5 Need for RelieflRelaxation and Basis for the RelieflRelaxation NRC Order EA-12-049 (Reference 2) requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging. or installing of equipment needed for the strategies. The Overall Integrated Plan (Reference I) provided the Quad Cities Station response to NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC order EA-12-050 (Reference 5) will also affect implementation of the Mitigation Strategies Order EA-12-049 actions. The Reference 1 enclosure describes the Quad Cities Station Mitigation Strategies that are based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System (HCVS) is required. Thus the Quad Cities Station NRC Order EA-12-049 response provided in Reference 1 was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Upon issuance of NRC Order EA-13-1 09 (Reference 3), the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050. As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for Quad Cities Station Units 1 and 2 will not be achieved until compliance to NRC Order EA-13-109 is achieved. Therefore, relaxation from the Mitigation Strategies (FLEX) full implementation date. as specified in NRC Order 12-049,Section IV.A.2 requirements is needed. The associated request for relaxation will be submitted separately.

In summary, the Quad Cites Overall Integrated Plan for Mitigation Strategies (Reference 1) will be met as planned and scheduled, except for areas impacted by NRC Order EA-13-109 on the Hardened Containment Vent System, which will be discussed in a separate request for relaxation.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference I) or the Draft Safety Evaluation (SE) (when available), and the status of each item.

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Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Section Overall Integrated Plan Open Item Status Reference Sequence of

1. The times to complete actions in the Events Timeline are Not Started Events (p. 4) based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures are developed, and the results will be provided in a future six-month update.

Sequence of

2. Issuance of BWROG document NEDC-33771P, "GEH Completed. Attached to Events (p.

Evaluation of FLEX Implementation Guidelines," on this 6-month update 4,5) 0113112013 did not allow sufficient time to perform the (Attachment 1) analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document prior to submittal of this Integrated Plan. This analysis is expected to be completed, documented on B, and provided to the NRC in the August 2013 six-month status update.

Sequence of

3. Additional work will be performed during detailed design Not Started Events (p. 6) development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

Sequence of

4. Initial calculations were used to determine the fuel pool Not Started Events (p. 7) timelines. Formal calculations will be performed to validate this information during development of the Spent Fuel Pool Cooling strategy detailed designs, and will be provided in a future six-month update.

Multiple

5. Procedures and programs will be developed to address Not Started Sections storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Quad Cities Programmatic 6. Quad Cities Nuclear Power Station will implement an Not Started controls (p. 8) administrative program for FLEX to establish responsibilities, and testing and maintenance requirements.

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Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Section Overall Integrated Plan Open Item Status Reference Multiple

7. Detailed designs based on the current conceptual designs Started Sections will be developed to determine the final plan and associated mitigating strategies. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for Quad Cities Nuclear Power Station during a scheduled six-month update. This update will include any changes to the initial designs as submitted in this Integrated Plan.

Maintain

8. Guidance will be provided to ensure that sufficient area is Started Core Cooling available for deployment and that haul paths remain Phase I accessible without interference from outage equipment (p.13) during refueling outages.

Maintain

9. Evaluation of the spent fuel pool area for steam and Not Started Spect Fuel condensation has not yet been performed. The results of this Pool evaluation and the vent path strategy, if needed, will be Coooling provided in a future six-month update.

Phase 1 (p.32)

Safety to. Habitability conditions will be evaluated and a strategy Started Function will be developed to maintain RCIC habitability Support (p.

42)

Safety

11. Habitability conditions will be evaluated and a strategy Not Started Function will be developed to maintain Main Control Room Support (p.

habitability.

42)

Safety

12. Battery Room Ventilation: Alternate ventilation will be Not Started Function provided to address Hydrogen generation and cold weather, Support (p.

as required.

43)

Safety

13. Fuel Oil Supply to Portable Equipment: A detailed fuel Not Started Function oil supply plan will be developed.

Support (p.

43)

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Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 Section Overall Integrated Plan Open Item Status Reference Attachment

14. Provide alternate cooling to the RCIC rooms. Procedure Not Started lA, Item 20 to be developed.

(p.59)

Section Draft Safety Evaluation Open Item Status Reference N/A N/A N/A 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Quad Cites Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013.

2.

NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.

3. 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.

4.

Proprietary NEDC-33771 P, GEH Evaluation of FLEX Implementation Guidelines, Revision I, January 2013.

5. NRC Order EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012.

9 Attachments I.

Quad Cities Station FLEX Integrated Plan Analyses Reconciliation to NEDC-33771P, Rev. I Page 6 of9

Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 ATTACHMENT 1 Quad Cities Station FLEX Integrated Plan Analyses Reconciliation to NEDC-33771P, Rev 1 (Reference 4)

NOTE: NEDC-33771P, Rev 1, Appendices Band D (BWR/4 Mark I with RCIC (No Venting, Suction From Suppression Pool, and Venting Starting at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, Suction From CST)) are most similar to the Quad Cities Station FLEX Plan strategy for maintaining Containment Integrity. Notable differences between the input parameters used in the Quad Cities Station FLEX analyses and the NEDC-33771P, Rev 1, analyses are noted below in the Gap and Discussion column.

NEDC-Quad Cities 33771P Design Item Parameter of Interest Value (Page Analyses Applied Value Gap and Discussion Reference)*

Value Input Parameter Values 1

Core Thermal Power 17 2957 MWT N/A 2

Reactor Dome Pressure 17 1020 psia N/A 3

Initial RPV Water Level above 17 533 inches N/A vessel zero 4

Primay system Leakage 17 38GPM N/A MAAP model configured with Recirc pump leakage 16 gpm/pump 5

RPV Depressurization Time 17 60 minutes N/A 6

RPV Depressurization Rate 17 80°F/hr N/A 7

RPV Maintained Pressure 17 200-250 psig N/A I

8 Initial Containment Airspace 17 82.5-150 of N/A I

Temperature 9

Initial Containment Pressure 17 0-1.2 psig N/A 10 Suppression Pool Level 17 14.05 ft N/A 11 Initial Suppression Pool 17 92.5°F N/A Temp 12 DW Free Volume 17 158,236 ft3 N/A

• Actual values are contained in the Proprietary NEDC-33771P, Rev 1 (Reference 4)

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Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28, 2013 ATIACHMENT 1 Quad Cities Station FLEX Integrated Plan Analyses Reconciliation to NEDC-3377IP, Rev 1 (Reference 4)

NOTE: NEDC-33771P, Rev 1, Appendices Band D (BWR/4 Mark I with RCIC (No Venting, Suction From Suppression Pool, and Venting Starting at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, Suction From CST)) are most similar to the Quad Cities Station FLEX Plan strategy for maintaining Containment Integrity. Notable differences between the input parameters used in the Quad Cities Station FLEX analyses and the NEDC-33771P, Rev 1, analyses are noted below in the Gap and Discussion column.

NEDC-Quad Cities Item Parameter of Interest 33771P Analyses Applied Design Gap and Discussion Value (Page Value Reference)*

Value 13 Start of Venting 17 3.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> N/A MAAP Containment Venting starting when pressure reaches 25 psia 14 Venting Flow Coefficient 17 K= 1.8 N/A 15 Venting Pipe Size 17 12" N/A Resultant Parameter Values Maximum Suppression Pool 34 329"F at 21.3 hrs 281"F Temperature (No venting)

Maximum WetWell 34 341"F at 21.3 hrs 281"F The Plant (MAAP) analysis performed Temperature (No venting) assumed containment failure at 120 psig.

Maximum Wetwell Pressure 34 120 psia at 21.3 hrs 56psig Therefore, the maximum containment (No venting) temperature values and pressure values are Maximum Drywell based on differing end points in both Temperature (No Venting) 34 328"F at 21.3 hrs 281"F analyses.

Maximum Drywell Pressure 34 120 psia at 21.3 hrs 56psig (No venting)

-~-

--~

• Actual values are contained in the Proprietary NEDC-33771P, Rev 1 (Reference 4)

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Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of FLEX August 28,2013 ATIACHMENT 1 Quad Cities Station FLEX Integrated Plan Analyses Reconciliation to NEDC-33771P, Rev 1 (Reference 4)

NOTE: NEDC-33771P, Rev 1, Appendices Band D (BWR/4 Mark I with RCiC (No Venting, Suction From Suppression Pool, and Venting Starting at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, Suction From CST)) are most similar to the Quad Cities Station FLEX Plan strategy for maintaining Containment Integrity. Notable differences between the input parameters used in the Quad Cities Station FLEX analyses and the NEDC-33771P, Rev 1, analyses are noted below in the Gap and Discussion column.

NEDC-Quad Cities Item Parameter of Interest 33771P Analyses Applied Design Gap and Discussion Value (Page Value Reference)*

Value Maximum Suppression Pool Temperature (Venting, CST 36 225°F at ~13 hrs 281°F Suction)

The differences identified between the SHEX and MAAP analyses are due to the time in Maximum WetWell which containment venting was initiated.

Temperature (Venting, CST 36 242°F at > 24 hrs 281°F Analyses of the containment pressures and Suction) temperature prior to initiation of the venting Maximum Wetwell Pressure 36 23.6 psia at 3.4 hrs 56psig action are approximately equal. The time for (Venting, CST Suction) containment venting initiation in the MAAP Maximum Drywell analysis is based on pressure reaching 25 psia.

Temperature (Venting, CST 36 26rF at > 24 hrs 281°F The SHEX venting was initiated at a longer Suction) duration and higher containment pressure than MAAP (refer to NEDC-33771P, page 36).

Maximum Drywell Pressure (Venting, CST Suction) 36 25 psia at 3.4 hrs 56psig

• Actual values are contained in the Proprietary NEDC-33771P, Rev 1 (Reference 4)

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