RS-14-011, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events (Order No. EA-12-049)

Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events (Order No. EA-12-049)

ML14059A431
Person / Time
Site:	LaSalle
Issue date:	02/28/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-14-011
Download: ML14059A431 (11)

Text

1

' Exelo Generation Order No. EA-12-049 RS-14-011 February 28,2014 U.S. Nuclear Regulatory Commission ATrN

Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. I\IPF-11 and I\IPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Second 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)

References:

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

2. NRC Interim Staff Guidance ...ILD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis 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 Cornmission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis 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 Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2013 (RS-13-021)

6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order lVIodifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28,2013 (RS-13-121)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2014 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGG). 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 LaSalle County 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. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements o'f 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. t\I RC Order EA-13-1 09 issued by the NRC on June 6, 2013, rescinded the requirements of Order EA-12-050 and established revised schedule timelines 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-12-049. 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 February 2014.

Respectfully submitted, dd6 T7¥ Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28,2014 Page 3

Enclosure:

1. LaSalle County Station, Units 1 and 2 Second 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 - LaSalle County Station, Units 1 and 2 NRC Project Manager, NRR - LaSalle County Station, Units 1 and 2 Ms. Jessica A. Kratchman, I\JRR/JLD/PNlB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, I\JRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig, NRRlDSS/SCVB, NRC Mr. John Boska, NRR/DPR/MSD/MSPB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 Second 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 (7 pages)

Enclosure LaSalle County Station, Units 1 and 2 Second 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 LaSalle County Station, Units 1 and 2 developed an Overall Integrated Plan (Reference 1 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 last status report, 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 Site: LaSalle Target Revised Target Activity Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Contract with Regional Response Center Complete (RRC)

Submit 6 Month Updates:

Update 1 Aug 2013 Complete Complete with Update 2 Feb 2014 this submittal Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Page 1 of 7

LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Target Revised Target Activity Completion Activity Status Completion Date Date Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started See Section 5 of Submit Completion Report Sep 2017 Not Started this enclosure Modification Development &

Implementation:

Unit 1 Modification Development (All Jan 2015 Started FLEX Phases)

Unit 1 Modification Implementation (All Mar 2016 Not Stmted FLEX Phases)

Unit 2 Modification Development (All Jan 2014 Started Jul2014 FLEX Phases)

Unit 2 Modification Implementation (All Feb 2015 Not Started FLEX Phases)

Procedures:

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

Feb 2015 Not Started 11.4.3)

Create Maintenance Procedures Feb 2015 Not Started Perform Staffing Analysis Oct 2014 Not Started Storage Plan and Construction Feb 2015 Started FLEX Equipment Acquisition Feb 2015 Started Training Completion Feb 2015 Not Started Regional Response Center Operational Dec 2014 Started See Section 5 of Unit 1 FLEX Implementation Mar 2016 Started this enclosure See Section 5 of Unit 2 FLEX Implementation Feb 2015 Started this enclosure See Section 5 of Full Site FLEX Implementation Mar 2016 Started this enclosure Page 2 of7

LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX Febmary 28, 2014 4 Changes to Compliance Method Changes have been made to the compliance method with NEI 12-06 since the last update in August 2013 (Ref. 4). These changes continue to meet the requirements of NRC Order EA-12-049 (Ref. 2). of Reference 1 contained conceptual sketches of the water supply and electrical power supply strategies. Reference 4 described changes to both the electrical and water supply strategies. of this enclosure contains an additional change to the water supply strategy that supersedes the water supply strategy change described in Reference 4. Specifically, instead of installing new water piping in the to-be-installed hardened vent chase that will be routed up the outside of the Reactor Building, the decision has been made to utilize the existing Division 1 Fuel Pool Emergency Makeup (FC EMU) piping instead. As depicted on Attachment 1, a connection will be provided in the Division 1 FC EMU piping such that water can be provided to the spent fuel pool as well as the RPV and containment.

The flow path to the RPV and containment is via a hose connection from the Division 1 FC EMU piping to the existing B.S.b connection points on 'A' or 'B' RHR. The drawing depicts the hose being connected to the 'A' RHR B.S.b connection point (which is completely independent of the primary water supply strategy use of 'B' RHR). The Division 1 FC EMU hose connection on the Refuel Floor can be used for either fill or spray capability.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation This section provides a summary of needed relief/relaxation only. The specific details will be submitted in a separate document.

NRC Order EA-12-049 requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies. Reference 1 provided the LaSalle County Station response to NRC Order EA-12-049. The cover letter to this enclosure identifies that delays in implementing the Hardened Containment Vent System as required by NRC Order EA-13-109 will also affect implementation of the Mitigation Strategies Order EA-12-049 actions.

The Reference 1 enclosure describes the LaSalle County 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 LaSalle County 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-12-0S0.

Upon issuance of NRC Order EA-13-109 on June 6,2013, the NRC revised the technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of NRC Order EA-12-0S0.

As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for LaSalle County Station Units 1 and 2 will not be achieved until compliance to NRC Order EA-13-109 is achieved. Compliance with NRC Order EA-13-109 wetwell vent requirements is required by startup from the U2 refuel outage in the Spring of 2017 and by startup from the U1 refuel outage in the Spring of 2018. Compliance with NRC Order EA-13-109 dryweU vent requirements is required by startup from the U2 refuel outage in the Spring of 2019 and by startup from the U1 refuel Page 3 of7

LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 outage in the Spring of 2018. Schedule relief/relaxation from the NRC Order 12-049 IV .A.2 requirements is required.

LaSalle County Station will be in compliance with the aspects of the Reference 1, Unit 1 and Unit 2, Mitigation Strategies that do not rely upon a Hardened Containment Vent System unless otherwise described.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table provides a summary of the open items documented in the Overall Integrated Plan and the Interim Staff Evaluation and the status of each item.

Section Reference Overall Integrated Plan Open Item Status Sequence of Events (p.5) The times to complete actions in the Not Stm1ed Events Timeline are based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures developed.

Sequence of Events (p.IO) Initial evaluations were used to Completed. Determined determine the fuel pool timelines. that the initial evaluations Formal calculations will be pelformed to that were pelformed are validate this information during sufficient.

development of the spent fuel pool cooling strategy detailed design.

Sequence of Events (p.IO) Analysis of deviations between Exelon's Completed.

engineering analyses and the analyses contained in BWROG Document NEDC-3377IP, "GEH Evaluation of FLEX Implementation Guidelines and documentation of results on Att. lB, "NSSS Significant Reference Analysis Deviation Table." Planned to be completed and submitted with August 2013 Six Month Update.

Strategy Deployment (p.ll) Transportation routes will be developed Started from the equi pment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation.

Page 4 of7

LaSalle County Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Section Reference OveraH Integrated Plan Open Item Status Identification of storage areas and creation of the administrative program are open items.

Programmatic Controls (p.12) An administrative program for FLEX to Started establish responsibilities, and testing &

maintenance requirements will be implemented.

Core Cooling Phase I (p.17) Additional work will be performed Started during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG I

analysis, throughout the event.

Fuel Pool Cooling Phase I (p.35) Complete an evaluation of the spent fuel Not Started pool area for steam and condensation.

Safety Functions Support Phase I Evaluate the habitability conditions for Started. LaSalle will be (p.44) the Main Control Room and develop a applying the "toolbox" strategy to maintain habitability. approach for habitability.

Safety Functions Support Phase I Evaluate the habitability conditions for Not Started (p.44) the Auxiliary Electric Equipment Room (AEER) and develop a strategy to maintain habitability.

Safety Functions Support Phase 2 Develop a procedure to prop open Not Started (p.48) battery room doors upon energizing the battery chargers to prevent a buildup of hydrogen in the battery rooms.

Section Referencelltem No. Interim Staff Evaluation Open and Status Confirmatory Items

{NOTE: LaSalle has not received the Interim Staff Evaluation as of the preparation date for this Update}

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 5 of 7

LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. LaSalle County Station's 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. LaSalle County Station's, First Six Month Status Report for the Implementation of FLEX, dated August 28, 2013.

9 Attachment

1. Revised Mechanical Drawing depicting new alternate water supply routing Page 6 of 7

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