RS-15-151, 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

ML15181A018
Person / Time
Site:	Peach Bottom
Issue date:	06/30/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-15-151, TAC MF4416, TAC MF4417
Download: ML15181A018 (11)

Text

Exelon Generation RS-15-151 June 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Order No. EA-13-109 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

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. 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-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

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 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-14-062)

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 19, 2014 (RS-14-305}

7. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - 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.

MF4416 and MF4417), dated February 12, 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 Peach Bottom Atomic Power Station, Units 2 and 3 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 Peach Bottom 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.

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 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 Page3 cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Peach Bottom Atomic Power Station, Units 2 and 3 NRC Project Manager, NRR - Peach Bottom Atomic Power Station, Units 2 and 3 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 (7 pages)

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 Peach Bottom Atomic Power Station, Units 2 and 3 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 3.

This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan (OIP),

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 June 2, 2015:

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 Activity Comments Milestone Completion Status Date Submit Overall Integrated Plan June 2014 Complete Submit 6 Month Uedates:

Update 1 December Complete 2014 Update 2 June 2015 Complete with this submittal Page 1 of7

PBAPS Second Six Month Status Report for the Implementation of HCVS Phase I June 30, 2015 Target Activity Comments Milestone Completion Status Date Update 3 [simultaneous with Phase 2 OIP]

December Not Started 2015 Update 4 June 2016 Not Started Update 5 December Not Started 2016 Update 6 June 2017 Not Started Update 7 December Not Started 2017 Update 8 June 2018 Not Started Submit Completion Report December Not Started 2018 Modifications:

Hold preliminary/conceptual design meeting April 2014 Complete U2 Design Engineering for Wetwell Vent Approved September Started 2015 U3 Design Engineering for Wetwell Vent Approved September Not Started 2016 Procedures:

U2 Wetwell Operations Procedure Changes September Not Started Developed 2016 U2 Wetwell Maintenance Procedure Changes September Not Started Developed 2016 U2 Wetwell Procedure Changes Active November Not Started 2016 U3 Wetwell Operations Procedure Changes September Not Started Developed 2017 U3 Wetwell Maintenance Procedure Changes September Not Started Developed 2017 U3 Wetwell Procedure Changes Active October Not Started 2017 Training:

U2 Wetwell Training Complete September Not Started 2016 Page 2 of 7

PBAPS Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Target Activity Comments Milestone Completion Status Date U3 Wetwell Training Complete September Not Started 2017 ComQletion:

U2 Wetwell Implementation Outage November Not Started 2016 U2 Wetwell Walk-Through Demonstration/ November Not Started Functional Test 2016 Submit U2 Wetwell Completion Report January Not Started 2017 U3 Wetwell Implementation Outage October Not Started 2017 U3 Wetwell Walk-Through Demonstration/ October Not Started Functional Test 2017 Submit U3 Wetwell Completion Report December Not Started 2017 4 Changes to Compliance Method In the Phase 1 Overall Integrated Plan (Reference 1 ), a secondary containment isolation valve (SCIV) was being considered as a replacement to the present rupture disc which prevents secondary containment leakage during design basis accidents. The decision was made to retain the rupture disc. The purge system that will be added for preventing hydrogen def lag ration and detonation also will be used to rupture the disc to allow anticipatory venting. There are no other changes to the compliance method outlined in Reference 1.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Peach Bottom Atomic Power Station, Units 2 and 3 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.

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PBAPS Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Overall Integrated Plan Phase 1 Open Item Status

1. Confirm that the Remote Operating Station SUPERSEDED BY NRC ISE OPEN (ROS) will be in an accessible area following a ITEM# 09.

Severe Accident (SA).

2. Provide procedures for HCVS Operation.

SUPERSEDED BY NRC ISE OPEN ITEM# 01.

3. Identify Site Specific Controlling Document for SUPERSEDED BY NRC ISE OPEN HCVS out of service and compensatory ITEM# 02.

measures.

4. Determine the design approach for combustible SUPERSEDED BY NRC ISE OPEN gas.

ITEM# 08.

Interim Staff Evaluation Open Item Status

01.

Make available for NRC staff audit Not Started guidelines and procedures for HCVS operation.

(Section 3.2.3.1)

02.

Make available for NRC staff audit the site Not Started specific controlling document for HCVS out of service and compensatory measures.

(Section 3.4.1)

03.

Make available for NRC staff audit a Not Started technical justification for use of jumpers in the HCVS strategy. (Section 3.1.3)

04.

Make available for NRC staff audit Started - Existing Calculation PM-0546, analyses demonstrating that the HCVS has the Torus Hardened Vent-Flow Calculation, capacity to vent the steam/energy equivalent of demonstrates that the HCVS has the one percent of licensed/rated thermal power capacity to vent the steam/energy (unless a lower value is justified), and that the equivalent of one percent licensed/rated suppression pool and the HCVS together are able thermal power.

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. (Sections 3.2.2.1 and 3.2.2.2)

Page 4of7 The primary containment design pressure is 56 psig (UFSAR 5.2.3.1 ).

The primary containment pressure limit is 60 psig (UFSAR 5.2.3.6).

PM-0546 shows that the HCVS capacity exceeds one percent of licensed/rated thermal power at the lower of these values, and capacity exceeds one percent power at significantly lower pressure values, down to approximately 20 psig.

PBAPS Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015

05.

Make available for NRC staff audit descriptions or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee justification for the HV AC release point being below and 150 feet from the reactor building ventilation release point.

(Section 3.2.2.3)

Complete -

Reference drawing M-395:

The Reactor Building Exhaust System.

The Reactor Building Exhaust System Fans, including the Refuel Floor Exhaust Fans, Reactor Building Exhaust Fans, and Reactor Building Equipment Exhaust

Fans, have Fail-Close dampers in exhaust ducts to prevent uncontrolled or unmonitored release from the Reactor Building in the event of loss of power to the fan's solenoid valves.

Fail-Close dampers will eliminate pathway into the Reactor Building in the event of use of the HCVS in an ELAP.

06.

Make available for NRC staff audit details Started - Exelon is preparing an analysis to justify the deviation from tornado protection to demonstrate that the location of the standards provided in NEI 13-02 or make existing external piping already provides available a description of how the HCVS will reasonable protection from tornado comply with the tornado protection standards generated missiles.

provided in NEl-13-02. (Section 3.2.2.3)

07.

Make available for NRC staff audit Started - Engineering Change Request documentation that demonstrates adequate 15-00126 enhances plant internal communication between the remote HCVS communications capability in the event of operation locations and HCVS decision makers an ELAP.

during ELAP and severe accident conditions.

(Section 3.2.2.5)

08.

Provide a description of the final design of Started - HCVS preliminary design has the HCVS to address hydrogen detonation and selected Argon purging to prevent deflagration. (Section 3.2.2.6) hydrogen detonation and deflagration.

09.

Make available for NRC staff audit an Started evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

(Sections 3.2.1, 3.2.2.3, 3.2.2.4, 3.2.2.5, 3.2.2.10, 3.2.4.1, 3.2.4.2, 3.2.5.2, and 3.2.6)

10.

Make available for NRC staff audit Started descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

(Sections 3.2.2.9 and 3.2.2.1 O)

11.

Make available for NRC staff audit the final Not Started sizing evaluation for HCVS batteries/battery Page 5of7

PBAPS Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 charger including incorporation into FLEX DG loading calculation.

(Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 3.2.4.2, 3.2.5.1, 3.2.5.2, and 3.2.6)

12.

Make available for NRC staff audit the 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. (Sections 3.2.2.3, 3.2.2.5, 3.2.2.9, and 3.2.2.10)

13.

Make available for NRC staff audit Started -

Isolation valve analysis in documentation of an evaluation verifying the progress.

existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

14.

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

(Section 3.2.2.6 and 3.2.2.7)

15.

Make available for NRC audit Started -

Isolation valve analysis in documentation confirming that HCVS will remain progress.

isolated from standby gas treatment system during ELAP and severe accident conditions.

(Section 3.2.2.7) 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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PBAPS Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 8 References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure.

1. Peach Bottom Atomic Power Station, Units 2 and 3, 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. Peach Bottom Atomic Power Station, Units 2 and 3, 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 19, 2014.

3. 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.

4. 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 1, dated April 2015.

5. 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 (Accession No. ML15104A118).

6. NRC Endorsement of Industry Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev. 0, dated May 14, 2014 (Accession No. ML14128A219).

7. Peach Bottom Atomic Power Station Units 2 and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4416 and MF4417), dated February 12, 2015 (Accession No. ML15026A469).

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