RS-15-152, 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..

ML15181A330
Person / Time
Site:	Quad Cities
Issue date:	06/30/2015
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-15-152, TAC MF4460, TAC MF4461
Download: ML15181A330 (11)

Text

Exelon Generation Order No. EA-13-109 RS-15-152 June 30, 2015 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 NRG Docket Nos. 50-254 and 50-265

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 0, 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-14-063)

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-14-306)

7. NRG letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power 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.

MF4460 and MF4461), dated April 1, 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 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. Reference 6 provided the first six-month status report pursuant to Section IV, Condition D.3 of Reference 1 for Quad Cities 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,

&;~~

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Quad Cities Nuclear Power 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 Page3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region 111 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 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 Quad Cities Nuclear Power 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 Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities Station) developed an Overall Integrated Plan (Reference 1), 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 First Six Month Update, 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 30, 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 (OIP) (Ref. 1). 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 1of7

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Submit 6 Month Updates:

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

Hold preliminary/conceptual design meeting June 2014 Complete July 2014 Modifications Evaluation March 2016 In Progress Unit 1 Design Engineering Complete March 2016 In Progress 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 (Phase 1 and April 2018 Not Started 2)

Unit 2 Phase 1 and 2 Walk Through April 2018 Not Started Demonstration/Functional Test Procedure Changes December Operations Procedure Changes Developed Not Started 2016 Site Specific Maintenance Procedure December Not Started Developed 2016 Procedure Changes Active April 2017 Not Started Training:

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Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 December Training Complete Not Started 2016 Completion Unit 1 Phase 1 HCVS Implementation April 2017 Not Started Unit 1 Phase 1 Completion Report [60 days June 2017 Not Started after Unit 1 Phase 1 compliance]

Unit 2 HCVS Implementation (Phase 1 and April 2018 Not Started 2}

Unit 2 Phase 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 June 2019 Not Started after Unit 1 Phase 2 compliance]

4 Changes to Compliance Method The following changes have been made to the compliance method for Phase 1 (the Phase 1 Overall Integrated Plan was provided under Reference 1):

• The Quad Cities HCVS Design has been changed to replace all previous references to a Secondary Containment Isolation Valve (SCIV) with a rupture disc rated for a pressure sufficient to withstand leakage through the downstream PCIV during a Design Basis Accident or LLRT.

• An Argon purge system has been determined to be the method of preventing hydrogen deflagration. The Argon purge system will be used to rupture the disc to allow anticipatory venting.

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 (identified by Exelon), 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 Complete - Conceptual design Battery Power will be disabled during normal (completed July 2014) determined Page 3of7

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 operation. the HCVS primary 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. Since the panel will be located in the MCR, unlocking and turning the switch can be performed in an ELAP with minimal operator action.

2. Confirm that the Remote Operating Station Superseded by ISE Open Item (ROS) will be in an area accessible following a No. 4.

Severe Accident (SA).

3. Confirm diameter on new common HCVS Piping. Superseded by ISE Open Item No. 5.

4. Confirm suppression pool heat capacity. Complete - The MAAP analysis verifies that the vent is 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). At 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the decay heat will be less than 1%.

5. Determine the approach for combustible gases. Superseded by ISE Open Item Nos. 1O and 11.

6. Develop a procedure for HCVS out-of-service Started.

requirements and compensatory measures.

7. Provide procedures for HCVS Operation. Superseded by ISE Open Item No.14.

8. Confirm 125 Volt DC Station Battery Life. Complete - QDC-8300-E-2100 (Reference 6) confirms that the 125 VDC Station Battery will continue to supply necessary power during the 8-hour duration prior to aligning the FLEX diesel generator. Also, refer to NRC ISE Open Item No. 1.

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

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Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Interim Staff Evaluation Open Item Status

1. Make available for NRC staff audit the calculation Complete - Supplied to NRC (QDC-8300-E-2100) that confirms that Order EA- Audit team during onsite FLEX 12-49 actions to restore power are sufficient to evaluation (Jan 2015). (Reference ensure continuous operation of non-dedicated 6).

containment instrumentation.

2. Make available for NRC staff audit the final sizing Started - HCVS Battery design in evaluation for HCVS batteries/battery charger progress. (References 8 and 9) including incorporation into FLEX DG loading calculation.

3. Make available for NRC staff audit Started - HCVS Nitrogen system documentation of the HCVS nitrogen pneumatic design in progress. (References 8 system design including sizing and location. and 9)

4. Make available for the NRC staff audit an Started - Temperature evaluation evaluation of temperature and radiological (Calculation 2014-02948) was conditions to ensure that operating personnel can made available to NRC Audit team safely access and operate controls and support during onsite FLEX evaluation equipment. (Jan 2015). Radiological evaluation in progress.

(References 8 and 9)

5. Make available for NRC staff review Started - Ref er to the response to documentation that confirms the final design ISE Open Item No. 6.

diameter of the HCVS piping.

6. Make available for NRC staff audit analyses Started - The required 1% vent demonstrating that HCVS has the capacity to capacity at the lower of PCPL or vent the steam/energy equivalent to one percent containment design pressure will be verified using RELAP which of licensed/rated thermal power (unless a lower models the line size and routing.

value is justified) and that the suppression pool In addition, MAAP analyses will be and HCVS together are able to absorb and reject credited to verify that ( 1) venting decay heat, such that following a reactor can be delayed for at least three shutdown from full power containment pressure hours and (2) anticipatory venting is restored and then maintained below the sufficiently limits the suppression primary containment design pressure and the pool heat up to maintain RCIC primary containment pressure limit. functional. (References 8 and 9)

7. Make available for NRC staff audit the seismic Started - The HCVS stack seismic and tornado missile final design criteria for the design criteria is the Station's HCVS stack. design basis earthquake.

The HCVS line will exit the Reactor Building more than 30 feet above any highest ground elevation located within 'V2 mile.

The tornado missile criterion for Page 5of7

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 above 30 feet is under evaluation.

(References 8 and 9)

8. Make available for NRG staff audit the Started - Component location descriptions of local conditions (temperature, design and local condition impacts radiation and humidity) anticipated during ELAP are in progress. The HCVS and severe accident for the components (valves, primary control panel will be instrumentation, sensors, transmitters, indicators, located in the MGR. (References 8 electronics, control devices, and etc.) required for and 9}

HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

9. Make available for NRG 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.

10. Provide a description of the final design of the Started - Argon purge system HCVS to address hydrogen detonation and design in progress. (References 8 deflagration. and 9) 11 . Provide a description of the strategies for Started - As described in the 01 P hydrogen control that minimizes the potential for (Ref. 1), the HCVS torus vent path hydrogen gas migration and ingress into the in each Quad Cities unit starting Reactor Building or other buildings. with, and including, the downstream PCIV will be a dedicated HCVS flow path. There are no interconnected systems downstream of the dedicated HCVS PCIV. Interconnected systems are upstream of the HCVS PCIV and are isolated by normally shut, fail shut (air-to-open, spring-to-shut) PCIVs which, if open, would shut on an ELAP. There is no shared HCVS piping between the two units.

The vent path will rely on an Argon purge system to prevent line failure due to potential hydrogen deflagration and detonation. (References 8 and 9)

12. Make available for NRG staff audit Not Started.

documentation of a seismic qualification Page 6of7

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 evaluation of HCVS components.

13. Make available for NRC staff audit descriptions of Started - Instrument design in all instrumentation and controls (existing and progress. (References 8 and 9) planned) necessary to implement this order including qualification methods.

14. 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. 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. 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 (Accession No. ML15104A118).

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 (Accession No. ML14128A219).

6. Exelon Calculation QDC-8300-E-2100, Unit 1(2) 125 VDC Battery Coping Calculation for Beyond Design Basis FLEX Event, dated September 26, 2014.

7. QC-MISC-013, Revision 3, MAAP Analysis to Support FLEX Initial Strategy.

8. EC 392256 - Unit 1 Hardened Containment Vent System (Non-Outage Portion) as Required by NRC Order EA-13-109.

9. EC 392257 - Unit 1 Hardened Containment Vent System (Outage Portion) as Required by NRC Order EA-13-109.

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