RS-15-149, Second Six-Month Status Report for 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..

Second Six-Month Status Report for 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..

ML15181A226
Person / Time
Site:	LaSalle
Issue date:	06/30/2015
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-049, RS-15-149
Download: ML15181A226 (10)

Text

Exelon Generation Order No. EA-13-109 RS-15-149 June 30, 2015 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 NRG Docket Nos. 50-373 and 50-374

Subject:

Second Six-Month Status Report For 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. NRG 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. NRG Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision O, dated April 2015

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

& II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April 2015

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)

6. Exelon Generation Company, LLC 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), dated December 17, 2014 (RS-14-303)

7. NRG letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4456 and MF4457), dated March 31, 2015

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2015 Page2 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 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 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 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 1 (Reference 3} with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial answer to the Order 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. Reference 6 provided the first six-month status report pursuant to Section IV, Condition D.3 of Reference 1 for LaSalle Station. The purpose of this letter is to provide the second 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. The enclosed report also addresses the NRC Interim Staff Evaluation open items contained in Reference 7.

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 30th day of June 2015.

Respectfully submitted, G~giT,/4¥ Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

LaSalle County Station, Units 1 and 2 Second 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 June 30, 2015 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region Ill NRC Senior Resident Inspector - LaSalle County Station, Units 1 and 2 NRC Project Manager, NRA- 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 Second 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 (6 pages)

Enclosure LaSalle County Station, Units 1 and 2 Second 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 enclosure 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 May 29, 2015.

• Held preliminary/conceptual design meeting

• First Six-Month Update

• Second 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 Activity Status Comments Completion 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:

Update 1 December 2014 Complete Complete with Update 2 June 2015 this submittal Page 1of6

LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Target Milestone Activity Status Comments Completion Date Phase 1 HCVS Milestone Table Simultaneous Update 3 December 2015 Not Started

- with 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:

Design U2 Phase 1 Design Engineering On- Engineering March 2016 Started site/Complete started in July 2014 Operations Procedure Changes Developed December 2016 Not Started Site Specific Maintenance Procedure Not Started December 2016 Developed 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 Not Started March 2017 Demonstration/Functional Test U 1 Phase 1 Design Engineering On- Not Started March 2017 site/Complete Submit U2 Phase 1 Completion Report May 2017 Not Started U1 Implementation Outage (Phase 1) February 2018 Not Started U1 Walk Through Not Started March 2018 Demonstration/Functional Test Submit U1 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).

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LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 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 Deleted (closed to ISE open item number 1 1 HCVS Battery Power will be disabled below) during normal operation.

Confirm that the Remote Operating Deleted (closed to ISE open item number 4 2 Station (ROS) will be in an accessible below) area following a Severe Accident (SA).

Determine wetwell line size to meet 1% Deleted (closed to ISE open item number 5 3

venting criteria. below)

Completed - See Reference 6 The MAAP analyses done for the LaSalle Confirm suppression pool heat station as part of the FLEX implementation 4

capacity. demonstrate that containment venting can be delayed for greater than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the start of the ELAP event.

Determine the approach for Deleted (closed to ISE open item number 9 5

combustible gases. below)

Provide procedures for HCVS Deleted (closed to ISE open item number 6

Operation. 13 below)

Number Interim Staff Evaluation Open Item Status 1 Make available for NRG audit a description of Not Started how HCVS de power and/or motive power will be disabled during normal operation to provide assurances against inadvertent operation, but to also minimize actions to enable HCVS operation during an ELAP.

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LaSalle County Station, Units I and 2 Second Six Month Status Report for the Implementation of HCVS Phase I June 30, 2015 2 Make available for NRC staff audit the final sizing Not Started evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

3 Make available for N RC staff audit Not Started documentation of the HCVS nitrogen pneumatic system design including sizing and location.

4 Make available for NRC staff audit an evaluation Not Started of temperature and radiological conditions to ensure that operating personnel can sat ely access and operate controls and support equipment.

5 Make available for NRC staff audit analyses Started demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

6 Make available for NRC staff audit the seismic Not Started and tornado missile final design criteria for the HCVS stack.

7 Make available for NRC staff audit the Not Started descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

8 Make available for NRC staff audit Not Started documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

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LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 9 Provide a description of the final design of the Not Started HCVS to address hydrogen detonation and deflagration.

10 Provide a description of the strategies for Not Started hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

11 Make available for NRC staff audit Not Started documentation of a seismic qualification evaluation of HCVS components.

12 Make available for NRC staff audit descriptions of Not Started all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

13 Make available for NRC staff audit the Not Started procedures for HCVS operation.

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. 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. 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 1, dated April 2015.

4. NRC Interim Staff Guidance JLD-ISG-2015-01, "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 April 2015.

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LaSalle County Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015

5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O," dated May 14, 2014 (ML14128A219).

6. LS-MISC-017, Revision 1, MAAP Analysis to Support Initial FLEX Strategy, dated February 13, 2013

7. LaSalle County Station's, First Six Month Status Report for the implementation of Hardened Containment Vent (Order EA-13-109), RS-14-303, dated December 17, 2014 (ML14351A450)

8. LaSalle County Station Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated March 31, 2015 (ML15084A180)

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