RS-15-153, 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..

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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..
ML15181A017
Person / Time
Site: Nine Mile Point  Constellation icon.png
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-15-153, TAC MF4481
Download: ML15181A017 (15)
v • d • e


Text

Exelon Generation Order No. EA-13-109 RS-15-153 June 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and DPR-69 N RC Docket Nos. 50-220 and 50-41 O

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. Constellation Energy Nuclear Group, 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 21,2013
5. Exelon Generation Company, LLC Nine Mile Point Nuclear Station, Units 1 and 2, Overall Integrated Plan per Order EA-13-109 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 27, 2014
6. Exelon Generation Company, LLC December 2014 (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 16, 2014 (FLL-14-035)
7. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 1

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4481), dated March 26, 2015

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2015 Page 2

8. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 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 No. MF4482}, dated February 11, 2015 On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC), known previously as Constellation Energy Nuclear Group, LLC (Exelon, the licensee). 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 Nine Mile Point Nuclear Station, Units 1 and 2 Phase 1 Overall Integrated Plans.

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 Nine Mile Point 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 reports provide 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 reports also address the NRC Interim Staff Evaluation open items contained in References 7 and 8.

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 301h day of June 2015.

Respectfully submitted,

~fyfl,J, ~

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2015 Page 3

Enclosures:

1. Nine Mile Point Nuclear Station, Unit 1 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
2. Nine Mile Point Nuclear Station, Unit 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 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Nine Mile Point Nuclear Station, Units 1 and 2 NRC Project Manager, NRA - Nine Mile Point Nuclear Station, Units 1 and 2 Mr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC

Enclosure 1 Nine Mile Point Nuclear Station, Unit 1 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 (5 pages)

Enclosure 1 Nine Mile Point Unit 1 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 Nine Mile Point Unit 1 (NMP1) 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, 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 15, 2015.

  • 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.

Milestone Target Activity Comments Completion Status Date Hold preliminary/conceptual design meeting November Complete 2013 Submit Overall Integrated Implementation Plan June 2014 Complete Submit Six-Month Update December Complete 2014 Submit Six-Month Update June 2015 Complete with this submittal Submit Six-Month Update December Simultaneous 2015 with Phase 2 OIP Page 1 of5

Nine Mile Point Unit 1 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 Submit Six-Month Update June 2016 Submit Six-Month Update December 2016 Design Engineering Complete April 2016 Started Operations Procedure Changes Developed December 2016 Site Specific Maintenance Procedure December Developed 2016 Training Complete February 2017 NMP1 Implementation Outage April 2017 Procedure Changes Active April 2017 Walk Through Demonstration/Functional Test April 2017 Submit Completion Report June 2017 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 NMP1 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 Items Status

1. Perform final sizing evaluation for HCVS Deleted (closed to ISE open item batteries and battery charger and include in number 7 below)

FLEX DG loading calculation.

2. Perform final vent capacity calculation for the Deleted (closed to ISE open item Torus HCVS piping confirming 1% minimum number 2 below) capacity.
3. Perform final sizing evaluation for pneumatic Deleted (closed to ISE open item Nitrogen (N2) supply. number 8 below)

Page 2 of 5

Nine Mile Point Unit 1 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015

4. Perform confirmatory environmental condition Deleted (closed to ISE open item evaluation for the Turbine Building in the vicinity numbers 6 and 11 below) of the Remote Operating Station (ROS) and HCVS dedicated pneumatic supply and batteries.
5. State which approach or combination of Deleted (closed to ISE open item approaches the plant determines is necessary to number 3 below) address the control of combustible gases downstream of the HCVS control valve.
6. Complete evaluation for environmental/seismic Deleted (closed to ISE open item qua Iification of HCVS components. numbers 9 and 11 below)
7. Complete evaluation for environmental conditions Deleted (closed to ISE open item and confirm the travel path accessibility. number 6 below)

Interim Staff Evaluation Open Items Status

1. Make available for NRC staff audit the seismic and tornado missile final design criteria for the Not Started HCVS stack.
2. Make available for NRC staff audit analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one (1) 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 Started 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.
3. Provide a description of the final design of the HCVS to address hydrogen detonation and Started deflagration.
4. Make available for NRC staff audit documentation that demonstrates adequate communication between the remote HCVS Not Started operation locations and HCVS decision makers during ELAP and severe accident conditions.
5. Provide a description of the strategies for hydrogen control that minimizes the potential for Not Started hydrogen gas migration and ingress in the reactor building or other buildings.

Page 3 of 5

Nine Mile Point Unit 1 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015

6. Make available for NRC staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel can safely Started access and operate controls and support equipment.
7. Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger Started including incorporation into FLEX DG loading calculation.
8. Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic Started system design including sizing and location.
9. Make available for NRC staff audit documentation of a seismic qualification Not Started evaluation of HCVS components.

1o. Make available for NRC staff audit descriptions of all instrumentation and controls (existing and Started planned) necessary to implement this order including qualification methods.

11. Make available for NRC staff audit the description of local conditions (temperature, radiation, and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, Started 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.

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

Page 4 of 5

Nine Mile Point Unit 1 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. Letter from M. G. Korsnick to Document Control Desk (NRC), Overall Integrated Plan per Order EA-13-109 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 27, 2014(ML141848340)
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(ML13143A321)
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, Rev. 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, Rev. 0, dated April 2015
5. Letter from M. G. Korsnick to Document Control Desk (NRC), December 2014 Six-Month Status Report in Response to Order EA-13-109 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated December 16, 2014
6. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 1 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4481), dated March 26, 2015 Page 5 of 5

Enclosure 2 Nine Mile Point Nuclear Station, Unit 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 (5 pages)

Enclosure 2 Nine Mile Point Unit 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 Nine Mile Point Unit 2 (NMP2) 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, 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 15, 2015.

  • 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.

Milestone Target Activity Comments Completion Status Date Hold preliminary/conceptual design meeting November Complete 2013 Submit Overall Integrated Implementation Plan June 2014 Complete Submit Six-Month Update December Complete 2014 Design Engineering Complete June 2015 Started August 2015 Outage-related engineering is complete.

Submit Six-Month Update June 2015 Complete Page 1 of5

Nine Mile Point Unit 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 with this submittal Operations Procedure Changes Developed December 2015 Site Specific Maintenance Procedure December Developed 2015 Submit Six-Month Update December Simultaneous 2015 with Phase 2 OIP Training Complete February 2016 NMP2 Implementation Outage April 2016 Procedure Changes Active April 2016 Walk Through Demonstration/Functional Test A13Fil aG~e May 2016 (Outage End)

Submit Completion Report June 2016 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 NMP2 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. Perform final sizing evaluation for HCVS Deleted (closed to ISE open item batteries and battery charger and include in number 8 below)

FLEX DG loading calculation.

2. Perform final vent capacity calculation for the Deleted (closed to ISE open item Torus HCVS piping confirming 1% minimum number 3 below) capacity.

Page 2 of 5

Nine Mile Point Unit 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015

3. Perform final sizing evaluation for pneumatic Deleted (closed to ISE open item Nitrogen (N2) supply. number 9 below)
4. Perform seismic evaluation of Reactor Building Deleted (closed to ISE open item Track Bay. number 2 below)
5. State which approach or combination of Deleted (closed to ISE open item approaches the plant determines is necessary to number 4 below) address the control of combustible gases downstream of the HCVS control valve.
6. Complete evaluation for environmental/seismic Deleted (closed to ISE open item qualification of HCVS components. numbers 10 and 12 below)
7. Complete evaluation for environmental conditions Deleted (closed to ISE open item and confirm the travel path accessibility. number 7 below)
8. Perform final environmental evaluation of the Deleted (closed to ISE open item Remote Operating Station (ROS) location. number 7 below)

Interim Staff Evaluation Open Item Status

1. Make available for NRC staff audit the seismic Started and tornado missile final design criteria for the HCVS stack.
2. Make available for NRC staff review Started documentation of a determination of seismic adequacy for the ROS location in the Reactor Building Track Bay.
3. Make available for NRC staff audit analyses Started demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one (1) 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.
4. Provide a description of the final design of the Started HCVS to address hydrogen detonation and deflagration.
5. Make available for NRC staff audit Started documentation that demonstrates adequate communication between the remote HCVS Page 3 of 5

Nine Mile Point Unit 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 operation locations and HCVS decision makers during ELAP and severe accident conditions.

6. Provide a description of the strategies for Started hydrogen control that minimizes the potential for hydrogen gas migration and ingress in the reactor building or other buildings.
7. Make available for NRC staff audit an evaluation Started of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.
8. Make available for NRC staff audit the final sizing Started evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.
9. Make available for NRC staff audit Started documentation of the HCVS nitrogen pneumatic system design including sizing and location.
10. Make available for NRC staff audit Started documentation of a seismic qualification evaluation of HCVS components.
11. Make available for NRC staff audit descriptions of Started all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.
12. Make available for NRC staff audit the Started description 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.
13. Make available for NRC staff audit Started documentation of an evaluation verifying the existing containment isolation valves relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

Page 4 of 5

Nine Mile Point Unit 2 Second Six Month Status Report for the Implementation of HCVS Phase 1 June 30, 2015 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. Letter from M. G. Korsnick to Document Control Desk (NRC), Overall Integrated Plan per Order EA-13-109 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 27, 2014(ML141848340)
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(ML13143A321)
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, Rev. 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, Rev. 0, dated April 2015
5. Letter from M. G . Korsnick to Document Control Desk (NRC), December 2014 Six-Month Status Report in Response to Order EA-13-109 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated December 16, 2014
6. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 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 No. MF4482), dated February 11, 2015 Page 5 of 5

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