RS-14-306, First Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses W/ Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condition

First Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses W/ Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condition

ML14351A433
Person / Time
Site:	Quad Cities
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-14-306
Download: ML14351A433 (8)

Text

Exelon Generation Order No. EA-13-109 RS-14-306 December 17, 2014 U.S. Nuclear Regulatory Commission ATTN: 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 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-14-063)

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 EGG to require their BWRs with Mark I and Mark II 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 Quad Cities Nuclear Power 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:

Quad Cities Nuclear Power 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 Quad Cities Nuclear Power Station, Units 1 and 2 NRC Project Manager, NRR Quad Cities Nuclear Power 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 Quad Cities Nuclear Power 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 Quad Cities Nuclear Power 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 Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities Station) 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 Comments Activity Milestone Completion Status Date Phase 1 HCVS Milestone Table Submit Phase 1 Overall Integrated Plan June 2014 Complete Page 1 of 4

Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 17, 2014 Submit 6 Month Updates:

Complete Update 1 Phase 1 December 2014 with this submittal Update 2 Phase 1 June 2015 Not Started Update 3 [Simultaneous with Phase 2 OIP] December 2015 Not Started Update 4 Phases 1 and 2 June 2016 Not Started Update 5 Phases 1 and 2 December 2016 Not Started Update 6 Phases 1 and 2 June 2017 Not Started Update 7 Phases 1 and 2 December 2017 Not Started Modifications:

Hold preliminary/conceptual design meeting June 2014 Complete July 2014 Modifications Evaluation March 2016 Not Started Unit 1 Design Engineering Complete March 2016 Not Started Unit 1 Implementation Outage (Phase 1) April 2017 Not Started Unit 1 Implementation Outage (Phase 2) April 2019 Not Started Unit 1 Phase 1 Walk Through April 2017 Not Started Demonstration/Functional Test Unit 2 Design Engineering Complete March 2017 Not Started Unit 2 Implementation Outage (Phases 1 and 2) April 2018 Not Started Unit 2 Phases 1 and 2 Walk Through April 2018 Not Started Demonstration/Functional Test Procedure Changes Operations Procedure Changes Developed December 2016 Not Started Site Specific Maintenance Procedure Developed December 2016 Not Started Procedure Changes Active April 2017 Not Started Training:

Training Complete December 2016 Not Started Completion Unit 1 Phase 1 HCVS Implementation April 2017 Not Started Unit 1 Phase 1 Completion Report [60 days after June 2017 Not Started Unit 1 Phase 1 compliance]

Unit 2 HCVS Implementation (Phases 1 and 2) April 2018 Not Started Page 2 of 4

Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 17, 2014 Unit 2 Phases 1 and 2 Completion Report [60 June 2018 Not Started days after Unit 2 compliance]

Unit 1 Phase 2 HCVS Implementation April 2019 Not Started Unit 1 Phase 2 Completion Report [60 days after June 2019 Not Started Unit 1 Phase 2 compliance]

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 Quad Cities 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.

Overall Integrated Plan Phase 1 Open Item Status

1. Determine how Motive Power and/or HCVS Battery Complete Conceptual design Power will be disabled during normal operation (completed July 2014) determined the HCVS control panel will be provided with a key lock switch to activate the system. This must be unlocked prior to performing any actuations of the DC powered components.

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

3. Confirm diameter on new common HCVS Piping Not Started Design Dependent

4. Confirm suppression pool heat capacity Complete Vent not required for at least 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (Reference 7)

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

6. Develop a procedure for HCVS out-of-service Started requirements and compensatory measures.

7. Provide procedures for HCVS Operation. Not Started Design Dependent Page 3 of 4

Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of HCVS Phase 1 December 17, 2014

8. Confirm 125 VDC DC Station Battery Life Complete Battery life meets minimum FLEX strategy intent of 8- hours (Reference 6)

9. Supply Part 3 Drywell Boundary Condition Not Started Will be provided with Phase 2 01P (December 2015)

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.

8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. Quad Cities Nuclear Power Station, Units 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 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. NE! 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. Exelon Calculation QDC-8300-E-2100, Unit 1(2) 125 VDC Battery Coping Calculation for Beyond Design Basis FLEX Event, 09/26/2014.

7. QC-MISC-013, Revision 2, MAAP Analysis to Support FLEX Initial Strategy, 09/16/2014.

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