RS-14-303, First Six-Month Status Report Phase 1 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

First Six-Month Status Report Phase 1 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

ML14351A450
Person / Time
Site:	LaSalle
Issue date:	12/17/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-14-303
Download: ML14351A450 (8)

Text

ANP- Exelon Generation, Order No. EA-13-109 RS-14-303 December 17, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

First Six-Month Status Report Phase 1 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)

References:

1. 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

2. 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 14, 2013

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, BWR Mark I

& II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013

4. Exelon Generation Company, LLC's Answer 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, 2013

5. Exelon Generation Company, LLC Phase 1 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 (RS-14-059)

On June 6, 2013, 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 require their BWRs with Mark I and Mark ll containments to take certain actions to ensure that these facilities have a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 2 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 are outlined in of Reference 1.

Reference 1 required submission of an initial status report 20 days following issuance of the final interim staff guidance (Reference 2) and a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D by June 30, 2014. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the EGC initial status report regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 5 provided the LaSalle County Station, Units 1 and 2 Phase 1 Overall Integrated Plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Phase 1 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 for Phase 1 pursuant to Section IV, Condition D.3, 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.

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 17th day of December 2014.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

LaSalle County Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 17, 2014 Page 3 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 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 First Six-Month Status Report for Phase 1 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (4 pages)

Enclosure LaSalle County Station, Units 1 and 2 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" 1 Introduction LaSalle County Station, Units 1 and 2 (LSCS) developed an Overall Integrated Plan (Reference 1 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 The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of December 15, 2014.

• Held preliminary/conceptual design meeting

• First Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Part 5 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 milestone target completion dates do not impact the order implementation date.

Target Milestone Completion Activity Status Comments Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan June 2014 Complete Hold preliminary/conceptual design meeting June 2014 Complete Submit 6 Month Updates:

Complete with Update 1 December 2014 this submittal Page 1 of 4

LaSalle County Station, Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 30, 2014 Target Milestone Completion Activity Status Comments Date Phase 1 HCVS Milestone Table Update 2 June 2015 Not Started Simultaneous with Update 3 December 2015 Not Started Phase 2 OIP Update 4 June 2016 Not Started Update 5 December 2016 Not Started Update 6 June 2017 Not Started Update 7 December 2017 Not Started Modifications:

U2 Phase 1 Design Engineering Complete March 2016 Started July 2014 Operations Procedure Changes Developed December 2016 Not Started Site Specific Maintenance Procedure Developed December 2016 Not Started Training Complete December 2016 Not Started U2 Implementation Outage (Phase 1) February 2017 Not Started Procedure Changes Active March 2017 Not Started U2 Walk Through Demonstration/Functional Test March 2017 Not Started Ul Phase 1 Design Engineering Complete March 2017 Not Started Submit U2 Phase I Completion Report May 2017 Ul Implementation Outage (Phase 1) February 2018 Not Started Ul Walk Through Demonstration/Functional Test Not Started March 2018 Submit Ul Phase 1 Completion Report May 2018 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).

Page 2 of 4

LaSalle County Station. Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 30. 2014 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation LaSalle County Station expects to comply with the order implementation date: therefore, 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 the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Open Action Status Item Determine how Motive Power and/or 1 HCVS Battery Power will be disabled Not Started Design Dependent during normal operation.

Confirm that the Remote Operating Station 2 (ROS) will be in an accessible area Not Started Design Dependent following a Severe Accident (SA).

Determine wetwell line size to meet 1% Started RELAP analysis 3

venting criteria, started for line size verification 4 Confirm suppression pool heat capacity. Completed See Reference 6.

Determine the approach for combustible 5 Not Started Design Dependent gases.

6 Provide procedures for HCVS Operation. Not Started Design Dependent Interim Staff Evaluation Open Item Status No items at the present time.

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

Page 3 of 4

LaSalle County Station, Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 30, 2014 8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. LaSalle County Station, Units 1 and 2, Phase 1 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.

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. NET 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 14, 2013 (Accession No. ML13304B836).

5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).

6. LS-MISC-017, Revision 1, MAAP Analysis to Support Initial FLEX Strategy, 02/13/2013 Page 4 of 4