RS-16-110, Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 06/06/2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 06/06/2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

ML16182A396
Person / Time
Site:	Quad Cities
Issue date:	06/30/2016
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-16-110
Download: ML16182A396 (18)

Text

ASUMMW Aww- Exelon Generation.

Order No. EA-13-109 RS-16-110 June 30, 2016 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:

Fourth Six-Month Status Report For Phases 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)

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 Phase 2 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 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. Exelon Generation Company, LLC Second 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 June 30, 2015 (RS-15-152)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2016 Page 2

8. Exelon Generation Company, LLC Phase 1 (Updated) and Phase 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 December 16, 2015 (RS-15-304)

9. NRC 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 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 11 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 (FLAP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an Overall Integrated Plan (OIP) by June 30, 2014 for Phase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order. The interim staff guidance (Reference 2) provides direction regarding the content of the OIP for Phase 1 and Phase 2. 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 response 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 OIP pursuant to Section IV, Condition D.1 of Reference 1. References 6 and 7 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Quad Cities Nuclear Power Station. Reference 8 provided the Quad Cities Nuclear Power Station, Units 1 and 2, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1.

The purpose of this letter is to provide the fourth six-month update report for Phases 1 and 2, pursuant to Section IV, Condition D.3 of Reference 1, that delineates progress made in implementing the requirements of Reference 1 for Quad Cities Nuclear Power Station, Units 1 and 2. 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 9.

It is noted that as a result of the recently announced early permanent plant shutdown date of June 1, 2018, EGC is evaluating the need for schedule relaxation and expects to submit a request for Order schedule relaxation after submittal of the notice of permanent cessation of operation for both units.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2016 Page 3 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 2016.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for Phases 1 and 2 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 III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, 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 Fourth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (14 pages)

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for Phases 1 and 2 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 (RCVS) 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.

Starting with this six month status report, updates of milestone accomplishments will be based on the combined Phase 1 and Phase 2 Overall Integrated Plan dated December 16, 2015.

Quad Cities Station developed an updated and combined Phase 1 and Phase 2 Overall Integrated Plan (Reference 7 in Section 8), documenting:

1. The installation of a RCVS 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.

2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve 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 combined Phase 1 and Phase 2 Overall Integrated Plan (Reference 7), 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 combined Phase 1 and Phase 2 Overall Integrated Plan (Reference 7), and are current as of May 15, 2016.

• Started On-line installation of Unit 1 Phase 1.

• Began conceptual design of Phase 2 for Unit 1 and Unit 2.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the combined Phase 1 and Phase 2 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.

Page 1 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 The revised milestone target completion dates do not impact the Order EA-13-109 implementation date.

Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Phase 1 and Phase 2 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates:

Update 1 Dec. 2014 Complete Update 2 Jun. 2015 Complete Update 3 Dec. 2015 Complete Complete with this Update 4 Jun 2016 submittal Update 5 Dec 2016 Not Started Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Unit 1 Modifications:

Complete Conceptual Design Jun 2014 Complete Complete Detailed Design and Issue Mar 2016 Complete Modification Package Begin Online Portion of the Installation Jan 2016 Complete Complete Online Installation Mar 2017 Started Begin Outage Portion of the Installation Mar 2017 Not Started Complete Outage Installation Apr 2017 Not Started Phase 1 Unit 1 Procedure Changes Active Operations Procedure Changes Apr 2017 Started Developed Site Specific Maintenance Procedure Apr 2017 Started Page 2 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Comments Target Milestone Completion Activity Status {Include date Date changes in this column)

Phase 1 and Phase 2 HCVS Milestone Table Developed Procedure Changes Active Apr 2017 Not Started Phase 1 Unit 1 Training:

Training Complete Apr 2017 Not Started Phase 1 Unit 1 Completion Phase 1 Unit 1 HCVS Implementation Apr 2017 Not Started Submit Phase 1 Unit 1 Completion Report Jun 2019 Not Started Phase 1 Unit 2 Modifications:

Complete Conceptual Design Jun 2014 Complete Complete Detailed Design and Issue Mar 2017 Started Modification Package Begin Online Portion of the Installation Nov 2016 Not Started Complete Online Installation Mar 2018 Not Started Begin Outage Portion of the Installation Mar 2018 Not Started Complete Outage Installation Apr 2018 Not Started Phase 1 Unit 2 Procedure Changes Active Operations Procedure Changes Apr 2018 Started Developed Site Specific Maintenance Procedure Apr 2018 Started Developed Procedure Changes Active Apr 2018 Not Started Phase 1 Unit 2 Training:

Training Complete Apr 2018 Not Started Phase 1 Unit 2 Completion Phase 1 Unit 2 HCVS Implementation Apr 2018 Not Started Submit Phase 1 Unit 2 Completion Report Jun 2018 Not Started Formerly May 2018 Page 3 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Phase 1 and Phase 2 HCVS Milestone Table Phase 2 Specific Milestones Phase 2 Unit 1 Modifications:

Begin Conceptual Design Apr 2016 Started Complete Conceptual Design Feb 2017 Not Started Begin Detailed Design Apr 2017 Not Started Common design Complete Detailed Design and Issue Jul 2017 Not Started with Unit 2.

Modification Package Formerly Mar 2018.

Common Begin Online Portion of the Installation Sep 2017 Not Started installation with Unit 2.

Common Complete Online Installation Mar 2018 Not Started installation with Unit 2.

Begin Outage Portion of the Installation NIA N/A No outage scope Complete Outage Installation N/A N/A No outage scope Phase 2 Unit 1 Procedure Changes Active Operations Procedure Changes Apr 2019 Not Started Developed Site Specific Maintenance Procedure Apr 2019 Not Started Developed Procedure Changes Active Apr 2019 Not Started Phase 2 Unit 1 Training:

Training Complete Apr 2019 Not Started Phase 2 Unit 1 Completion Phase 2 Unit 1 HCVS Implementation Apr 2019 Not Started Submit Phase 1 and Phase 2 Unit 1 Jun 2019 Not Started Completion Report Phase 2 Unit 2 Modifications:

Page 4 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Comments Target Milestone Completion Activity Status {include date Date changes in this column}

Phase 1 and Phase 2 HCVS Milestone Table Begin Conceptual Design Apr 2016 Started Complete Conceptual Design Feb 2017 Not Started Begin Detailed Design Apr 2017 Not Started Common design Complete Detailed Design and Issue Jul 2017 Not Started with Unit 1.

Modification Package Formerly Mar 2017.

Common Begin Online Portion of the Installation Sep 2017 Not Started installation with Unit 1.

Common Complete Online Installation Mar 2018 Not Started installation with Unit 1.

No outage Begin Outage Portion of the Installation N/A N/A installation No outage Complete Outage Installation N/A N/A installation Phase 2 Unit 2 Procedure Changes Active Operations Procedure Changes Apr 2018 Not Started Developed Site Specific Maintenance Procedure Apr 2018 Not Started Developed Procedure Changes Active Apr 2018 Not Started Phase 2 Unit 2 Training:

Training Complete Apr 2018 Not Started Phase 2 Unit 2 Completion Phase 2 Unit 2 HCVS Implementation Apr 2018 Not Started Submit Phase 1 and Phase 2 Unit 2 Jun 2018 Not Started Completion Report Page 5 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 4 Changes to Compliance Method Phase 1 Changes None.

Phase 2 Changes Quad Cities completed a dose assessment based on assumed Severe Accident conditions to determine the impacts on Emergency Response Organization actions during a Beyond Design Bases External Event (BDBEE). This assessment included determining the impacts on previously planned FLEX response actions and Phase 2 HCVS response actions to implement the Severe Accident Water Addition/Severe Accident Water Management (SAWA/SAWM) strategy. The assessment indicated high dose rates in some areas currently designated for use in the primary FLEX strategy. As a result, the Phase 2 design will require the use of available alternate FLEX deployment locations and changing the sequencing of FLEX actions in those locations in order to implement the SAWA/SAWM strategy.

The following table and narrative describe the changes to the conceptual Phase 2 design as previously described in the December 2015 OI P (Reference 7), and is subject to future changes as the design progresses.

The following changes (bolded) are made to Table 3.1 of the December 2015 Overall Integrated Plan (OIP) (Ref. 7):

Table 3.1 SAWA Manual Actions Primary Location/

Primary Action Notes Component

1. Establish RCVS capability

• MCR and ROS.

• Applicable to SAWA/SAWM in accordance with Part 2 of strategy.

this 01P.

2. Deploy diesel

• FLEX/SAWA pump

• Pump at Discharge Bay for FLEX/SAWA pump. west of Turbine all BDBEE except Local Building (TB). Intense Precipitation (LIP).

• Pump at storm drain west of Unit 1 Main Power Transformer for LIP.

3. Align flow path from FLEX

• Turbine Building

• RB connections made in

/ SAWA pump discharge to (ground level) valve first hour.

injection piping. manifold.

• Function of radiological

• FLEX Storz assessment (ISE-4, connections in Reactor Attachment 7).

Building (RB).

• TB connections made to

• Penetrations through FLEX timeline (more RB / TB wall. limiting than SAWA).

Page 6 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of RCVS Phases 1 and 2 June 30, 2016

4. Power SAWA / HCVS

• FLEX DG alternate

• FLEX primary deployment components with second deployment location at location in direct line-of-sight EA-12-049 (FLEX) the northwest corner of to the HCVS vent line.

generator. the Turbine Building.

• Extend cables 200' to make use of TB wall shielding.

5. Inject to Reactor Pressure

• Remote-manually open

• MOVs energized through Vessel (RPV) using FLEX I motor operated RHR FLEX diesel. MOVs are not SAWA pump. valves (MOVs). throttled for flow control.

• Flow control is by TB

• Initial SAWA flow rate is 400 valve manifold. gpm starting 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after event.

6. Monitor SAWA indications.

• Mechanical flow

• Pump flow.

meters on SAWA hose

• MOV valve position between distribution indication as per normal MCR manifold and TB wall. RHR indicators.

7. Use SAWM to maintain

• Suppression Pool

• Monitor DW pressure and availability of the WW vent indications in MCR. Suppression Pool level.

(Part 3. LA).

• Turbine Building

• Control SAWA flow at valve valve manifold. manifold.

• Vent line tap at top of Suppression Pool.

The Discharge Bay is already analyzed for use as a water source in response to a BDBEE IAW EA-12-049 (Reference 9). An Equipment Operator would be stationed with a Godwin HL130M diesel powered mobile pump at an existing concrete pad intended for that purpose near the Discharge Bay water level.

In the event of a LIP resulting in a Severe Accident, a Godwin HL130M will be deployed west of the Unit 1 Main Power Transformer. The LIP study (Reference 10) indicates the water is relatively stagnant in this area soon into the event response, with a depth of approximately 1 foot above grade. A grating to the Site storm drain system will be removed, and the suction hose will be dropped into the drain.

From the FLEX/SAWA pump (at either Discharge Bay or western storm drain), a 5" diameter hose will route to the line-of-site dose shadow of the Turbine and Reactor Buildings, through the Turbine Building, to a manifold near the centerline of the ground floor (595' elevation).

Several paths are available for routing this hose, so a partial collapse of the Turbine Building would not inhibit hose deployment. The length of the discharge hose is bounded by the existing FLEX hydraulic analysis (1350 feet, Reference 11), so there will be sufficient pressure and flow at the manifold to meet all water demands during the event.

From the manifold, 5" hoses will lead to three 6" pipes through wall penetrations between the Turbine Building and the Reactor Building. Each penetration will have a 6" gate valve in the Turbine Building to maintain Secondary Containment during normal operation.

In the Reactor Building, 5" fire hoses will connect the pipe penetrations to Storz connections installed under EA-12-049 to provide FLEX water supply to both Reactor Pressure Vessels (RPVs). The location of the wall penetrations at the ground level of the Reactor Building (595') centerline will be such that one 50-foot length of 5" hose will bridge each wall penetration to its respective RPV supply Storz connection.

Page 7 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Due to the timeline for Severe Accident progression and the rise of dose rates in the Reactor Building, the hose deployment in the Reactor Building will be performed in the first hour post-event. Hose deployment outside of the Reactor Building will conform to the FLEX response timeline, which is more limiting than the Severe Accident timeline.

Under this plan, the only difference between the water demand for a FLEX response and a SAWA response is flow rate. The FLEX hydraulic analysis used an input of 196 gpm to a single RPV, where SAWA requires 400 gpm to a single RPV starting at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> post-event and reducing to 80 gpm at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> post-event. Each Godwin HL130M pump is capable of flow in excess of 1000 gpm.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Quad Cities Station will comply with the Order implementation date and no relief/relaxation is required at this time. However, as a result of the recently announced early permanent plant shutdown date of June 1, 2018, EGC is evaluating the need for schedule relaxation and expects to submit a request for Order schedule relaxation after submittal of the notice of permanent cessation of operation for both units.

6 Open Items from Combined Phase 1 and Phase 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phase 1 and Phase 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Combined Phase 1 and Phase 2 OIP Open Status Items Phase 1 Open Items OI-1 Determine how Motive Power and/or HCVS Complete Per Quad Cities Station detailed design, Battery Power will be disabled during normal HCVS primary control panel will be provided with a operation. key lock switch to activate the system. Normally, system remains de-energized. This must be unlocked prior to performing any actuations of the DC powered components. With the panel being located in the MCR, unlocking and turning the switch can be performed in an FLAP with minimal operator action.

Detailed in December 2015 OIP (Reference 7).

0I-2 Confirm that the Remote Operating Station Closed to ISE Open Item number 4.

(ROS) will be in an accessible area following a Severe Accident (SA).

Page 8 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Combined Phase 1 and Phase 2 OIP Open Status Items 0I-3 Confirm diameter on new common HCVS Closed to ISE Open Item number 5.

Piping.

0I-4 Confirm suppression pool heat capacity. Complete - The MAAP analysis verified 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 12). 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 %.

0I-5 Determine the approach for combustible Closed to ISE Open Items 10 and 11.

gases.

0I-6 Develop a procedure for RCVS out-of-service Started. Will be incorporated into QCAP 1500-07, requirements and compensatory measures. Administrative Tracking Requirements for Unavailable FLEX Equipment.

0I-7 Provide procedures for RCVS Operation. Closed to ISE Open Item No. 14.

0I-8 Confirm 125 Volt DC Station Battery Life. Complete per Quad Cities Station calculation - QDC-8300-E-2100 (Reference 13) 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.

Phase 2 Open Items 01-9 Supply Part 3 Drywell Boundary Condition. Complete the Phase 2 Alternate option (SA WA/SAWM) was added to the December 2015 OIP (Reference 7).

OI-10 Determine deployment path for Discharge Not Started.

Bay booster pump with respect to HCVS dose.

Phase 1 Interim Staff Evaluation Open Items Status (Reference 18)

ISE-1 Make available for NRC staff audit the Complete - Supplied to NRC Audit team during onsite calculation (QDC-8300-E-2100) that confirms FLEX evaluation (Jan 2015). (Reference 13).

that Order EA-12-49 actions to restore power are sufficient to ensure continuous operation Page 9 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 3CL2O16 of non-dedicated containment ISE-2 Make available for NRC staff audit the final Complete - HCVS Battery design has been completed.

sizing evaluation for HCVS batteries/battery (References 14, 15 and 17) charger including incorporation into FLEX DG Started - Incorporation into FLEX DG loading loading calculation.

calculations is in progress.

ISE-3 Make available for NRC staff audit Started- HCVS Nitrogen system design in progress.

documentation o the HCVS nitrogen (References 14, 15 and 17) pneumatic system design including sizing and ISE-4 Make available for NRC staff audit an Complete- Temperature evaluation (Calculation 2014-evaluation of temperature and radiological 02948) was made available to NRC Audit team during conditions to ensure that operating onsite FLEX evaluation (Jan 2015)(Reference 21).

personnel can safely access and operate Complete - Phase I Radiological evaluation has been controls and support equipment.

completed. (Reference 16).

Started - Phase // Radiological evaluation has been initiated (Reference 6).

ISE-5 Make available for NRC staff audit Started. Refer to the response to ISE open item 6.

documentation of the licensee design effort to confirm the diameter on the new common HCVS piping.

ISE-6 Make available for NRC staff audit analyses Started. The required 1% vent capacity at the lower of demonstrating that HCVS has the capacity to PCPL or containment design pressure is being verified vent the steamlenergy equivalent of one using RELAP which models the line size and percent of licensed/rated thermal power routing. (Reference 19 prepared and in Site review)

(unless a lower value is justified), and that the suppression pool and the HCVS together are In addition, MAAP analyses (Reference 12) are able to absorb and reject decay heat, such credited to verify that (1) venting can be delayedfor thatfollowing a reactor shutdown from full at least three (3) hours and (2) anticipatory venting power containment pressure is restored and sufficiently limits the suppression pool heat up to then maintained below the primary maintain RC/CfunctionaL containment design pressure and primary containment pressure limit.

ISE-7 Make available for NRC staff audit the seismic Complete The HCVS stack seismic design meets the and tornado missile final design criteria for Station"s design basis earthquake design criteria.

the HCVS stack. (Reference 20)

Page 10 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 3CL2O16 The information provided in December 2015 OIP (Reference 7) demonstrates that the external piping meets the tornado missile protection criteria of HCVS-ISE-8 Make available for NRC staff audit the Started Component location design and local descriptions of local conditions (temperature, conditions impact are in progress. The HCVS primary radiation and humidity) anticipated during control panel will be located in the MCR (References ELAP and severe accidentfor the components 14, 15 and 17).

(valves, instrumentation, sensors, Reactor Building temperatures are as noted in transmitters, indicators, electronics, control Calculation 2014-02948 (Reference 21).

devices, etc.) requiredfor HCVS venting including confirmation that the components Turbine Building temperatures at the ROS are as are capable of performing theirfunctions noted in Evaluation EC 402709 (Reference 22).

during ELAP and severe accident conditions.

Limiting radiation conditions for equipment as per Calculation QDC-0000-M-2199, HCVS 7-Day Dose Analysis (Reference 16).

ISE-9 Make available for NRC staff audit Started Communication as determined by FLEX documentation that demonstrates adequate response. Sound-powered phone jack near battery communication between the remote HCVS rack and bottle stations.

operation locations and HCVS decision makers during ELAP and severe accident ISE-10 Provide a description of the final design of the Complete as stated in the December 2015 01P, HCVS to address hydrogen detonation and Quad Cities will utilize Argon purge system to address deflagration. combustible gases in the HCVS piping. A summary of the design features is included in the December 2015 OIP (Reference 7).

ISE-11 Provide a description of the strategies for Complete - As described in the December 2015 OIP hydrogen control that minimizes the potential (Reference 7), the HCVS torus vent path in each Quad for hydrogen gas migration and ingress into Cities unit, starting at and including the downstream the Reactor Building or other buildings. PCIV, will be a dedicated HCVS flow path. There are no interconnected systems downstream of the downstream, dedicated HCVS PCIV. Interconnected systems are upstream of the downstream HCVS PCIV and are isolated by normally shut, fail shut PCIVs which, if open, would shut on an ELAP. There is no Page 11 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 shared HCVS piping between the two units.

The vent path will rely on Argon purge system to prevent the formation of a combustible gas mixture from forming within the line (References 14, 15 and 17).

ISE-12 Make available for NRC staff audit Started the Quad Cities Station seismic evaluation documentation of a determination of seismic will be based on the Quad Cities Station design basis qualification evaluation of the HCVS earthquake.

components.

ISE-13 Make available for NRC staff audit Started. Instrument design is in progress (References descriptions of all instrumentation and 14, 15 and 17).

controls (existing and planned) necessary to implement this order including qualification methods.

ISE-14 Make available for NRC staff audit the Started. Procedures are under development by procedures for HCVS operation. Operations.

Phase 2 Interim Staff Evaluation Open Items Status Phase 2 ISE has not been issued.

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

s References The following references support the updates to the combined Phase 1 and Phase 2 Overall Integrated Plan described in this enclosure.

1. Quad Cities 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)

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 Page 12 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016

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-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 2013 (ML13304B836)

5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109), Rev 0" (ML14128A219)

6. Calculation QDC-0000-M-2223, Revision 0, HCVS Phase 11 7-Day Dose Analysis

7. Quad Cities Combined Phase 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 December 16, 2015 (RS-15-304)

8. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of 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 (ML15104A118)

9. NRC Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

10. Exelon Calculation LIP-QDC-001, Rev. 4A, Quad Cities Local Intense Precipitation Evaluation 11.Exelon Calculation QDC-0000-M-2097, PIPE FLO Analysis of FLEX Strategy 12.Exelon Calculation QC-MISC-01 5, Rev. 0, MAAP Analysis to Support HCVS Design

13. Exelon Calculation QDC-8300-E-21 00, Unit 1(2) 125 VDC Battery Coping Calculation for Beyond Design Basis FLEX Event 14.EC 392256 - Unit 1 Hardened Containment Vent System (Non-Outage Portion) as Required by NRC Order EA-13-109 15.EC 392257 - Unit 1 Hardened Containment Vent System (Outage Portion) as Required by NRC Order EA-13-109 16.Exelon Calculation QDC-0000-M-2199, HCVS 7 Day Dose Analysis

17. EC 400666 Hardened Containment Vent System as Required by NRC Order EA 109 Unit 2 18.NRC Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase One of Order EA-13-109 (Severe Accident Capable Hardened Vents) JAC NOS.

MF4460 and MF4461) (ML15089A421), dated April 1, 2015 19.Exelon Calculation QDC-1600-M-2188, HCVS Vent Line Sizing Calculation, Rev. 0

20. Exelon Calculation QDC-0020-S-2192, HCVS Steel Tower Structural Calculation, Rev. 0 Page 13 of 14

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016

21. Exelon Calculation 2014-02948, Reactor Building Temperature Analysis Resulting from Extended Loss of AC Power

22. Exelon Evaluation EC 402709 Temperature in Proposed Location of Remote Operating Station Page 14 of 14