RS-17-068, Sixth 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.

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Sixth 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.
ML17181A034
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/30/2017
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-17-068, TAC MF4416, TAC MF4417
Download: ML17181A034 (19)
v • d • e


Text

Exelon Generation .,

Order No. EA-13-109 RS-17-068 June 30, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Sixth 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-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 14, 2013
3. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 Order EA-13-109, Order Modifying Licenses with Regar~ to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions", Revision O, dated April 2015
4. 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
5. 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
6. 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)
7. 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)
8. 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-15-151)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2017 Page 2

9. 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 15, 2015 (RS-15-303)
10. Exelon Generation Company, LLC 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), dated June 30, 2016 (RS-16-109)
11. Exelon Generation Company, LLC Fifth 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), dated December 15, 2016 (RS-16-235)
12. NRG 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

13. NRG 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 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos.

MF4416 and MF4417), dated August 2, 2016 On June 6, 2013, the Nuclear Regulatory Commission ("NRG" or "Commission") issued an Order (Reference 1) to Exelon Generation Company, LLC (EGG). Reference 1 was immediately effective and directs EGG 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 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 tor Phase 2 of the Order. The interim staff guidance (References 2 and 3) provide direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions identified in References 2 and 3. Reference 5 provided the EGG initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 provided the Peach Bottom Atomic Power Station, Units 2 and 3, Phase 1 OIP pursuant to Section IV, Condition D.1 of Reference 1.

References 7 and 8 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Peach Bottom Atomic Power Station. Reference 9 provided the Peach Bottom Atomic Power Station, Units 2 and 3, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1. References 10 and 11 provided the fourth and fifth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Peach Bottom Atomic Power Station.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2017 Page 3 The purpose of this letter is to provide the sixth 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 Peach Bottom Atomic Power Station, Units 2 and 3. 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 References 12 and 13.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David J. Distel at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 301h day of June 2017.

Respectfully submitted, James Bar1 ~k Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for Phases 1and2 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 - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection S. T. Gray, State of Maryland

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for Phases 1and2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (15 pages)

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Sixth 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 Peach Bottom Atomic Power Station (PBAPS) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. This is the sixth six-month status report updating milestone accomplishments based on the combined Phases 1 and 2 Overall Integrated Plan dated December 15, 2015.

PBAPS developed an updated and combined Phases 1 and 2 Overall Integrated Plan (Reference 6 in Section 8), documenting:

1 . 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.

2. An alternative venting strategy that makes it unlikely that a drywall 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 Fifth Six-Month Status Report for Phase 1 and Phase 2 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 combined Phases 1 and 2 Overall Integrated Plan (Reference 6), and are current as of June 1, 2017:

  • Sixth Six-Month Update (complete with this submittal)
  • Completed Unit 3 HCVS Phase 1 detailed design
  • Began Unit 3 HCVS Phase 1 installation 3 Milestone Schedule Status The following provides an update to Attachment 2 of the combined Phases 1 and 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.

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 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 [Simultaneous with Phase 2 Dec. 2015 Complete OIP]

Update 4 Jun. 2016 Complete Update 5 Dec. 2016 Complete Complete Update 6 Jun . 2017 with this submittal 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 2 Modifications Begin Conceptual Design Apr. 2014 Complete Complete Conceptual Design Jun. 201 5 Complete Begin Detailed Design Jun. 2015 Complete Complete Detailed Design and Issue Jun. 2016 Complete Modification Package Begin Online Portion of the Installation Jun. 2016 Complete Complete Online Installation Oct. 2016 Complete Begin Outage Portion of the Installation Oct. 2016 Complete Complete Outage Installation Nov. 2016 Complete Phase 1 Procedure Changes Active Operations Procedure Changes Nov. 2016 Complete Developed Page 2of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Site Specific Maintenance Procedure Nov. 2016 Complete Developed Procedure Changes Active Nov. 2016 Complete Phase 1 Training Training Complete Nov. 2016 Complete Phase 1 Completion Unit 2 Phase 1 HCVS Implementation Nov. 2016 Complete Phase 1 Unit 3 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Begin Detailed Design May 2016 Complete Complete Detailed Design and Issue Feb.2017 Complete Modification Package Begin Online Portion of the Installation Mar. 2017 Complete Complete Online Installation Oct. 2017 Started Begin Outage Portion of the Installation Oct. 2017 Not Started Complete Outage Installation Nov. 2017 Not Started Phase 1 Procedure Changes Active Operations Procedure Changes Nov.2017 Started Developed Site Specific Maintenance Procedure Nov. 2017 Started Developed Procedure Changes Active Nov. 2017 Started Phase 1 Training Training Complete Nov.2017 Started Phase 1 Completion Unit 3 Phase 1 HCVS Implementation Nov. 2017 Started Phase 2 Specific Milestones Page 3of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Phase 2 Unit 3 Modifications Begin Conceptual Design May 2016 Complete Complete Conceptual Design Nov. 2016 Complete Begin Detailed Design Dec. 2016 Complete Date Change:

Complete Detailed Design and Issue Jul. 2017 Started Previously Modification Package Feb.2017 Date Change:

Begin Online Portion of the Installation Sep.2017 Not Started Previously Mar. 2017 Complete Online Installation Oct. 2017 Not Started Begin Outage Portion of the Installation Oct. 2017 Not Started Complete Outage Installation Nov. 2017 Not Started Phase 2 Procedure Changes Active Operations Procedure Changes Nov. 2017 Started Developed Site Specific Maintenance Procedure Nov. 2017 Started Developed Procedure Changes Active Nov. 2017 Not Started Phase 2 Training Training Complete Nov.2017 Not Started Phase 2 Completion Unit 3 Phase 2 HCVS Implementation Nov.2017 Not Started Submit Full Compliance Report for Phase 1 Jan.2018 Not Started

& Phase 2 for Unit 3 Phase 2 Unit 2 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Page 4of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Date Change:

Begin Detailed Design Jun. 2017 Complete Previously Mar. 2017 Complete Detailed Design and Issue Sep. 2017 Not Started Modification Package Begin Online Portion of the Installation Feb. 2018 Not Started Complete Online Installation Oct. 2018 Not Started Begin Outage Portion of the Installation Oct. 2018 Not Started Complete Outage Installation Nov. 2018 Not Started Phase 2 Procedure Changes Active Operations Procedure Changes Nov. 2018 Not Started Developed Site Specific Maintenance Procedure Nov. 2018 Not Started Developed Procedure Changes Active Nov. 2018 Not Started Phase 2 Training Training Complete Nov. 2018 Not Started Phase 2 Completion Unit 2 Phase 2 HCVS Implementation Nov. 2018 Not Started Submit Full Compliance Report for Phase 1 Jan. 2019 Not Started

& Phase 2 for Unit 2 4 Changes to Compliance Method It was previously communicated in the combined Phases 1 and 2 Overall Integrated Plan (Reference 6) that Instruments PR/TR-4805 and PR/TR-5805 would be used to obtain containment pressure readings for Unit 2 and Unit 3, respectively, and that the instruments are Regulatory Guide (RG) 1.97 qualified. While the PR/TR-4805 and PR/TR-5805 instruments are RG 1.97 qualified, not all components that are either in the associated instrument loop or that may affect the loop are RG 1.97 qualified. These components include PT-4805, PT-5805, 2DC834 and 3DC834 and are evaluated for dose, thermal and humidity effects considering severe accident environmental conditions. The evaluation concluded that the PR/TR-4805 and PR/TR-5805 instrument loop will function during severe Page 5of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 accident conditions satisfactorily. Details of the evaluation are contained in EC 618957, Attachment 9A. EC 618957, Attachment 9A will be provided in the eportal when EC 618957 is issued.

Based on the above evaluation, PT-4805 and PT-5805 are qualified for the radiological, thermal and humidity conditions expected during a severe accident, and failure of 2DC834 and 3DC834 does not affect the PR/TR-4805 and PR!TR-5805 instrument loop. Therefore, it is acceptable to use recorders PR!TR-4805 and PR!TR-5805 for containment pressure indication during a severe accident.

The SAWA/SAWM PBAPS- Specific Datum was also previously communicated in Attachment 2.1.C of the combined Phases 1 and 2 Overall Integrated Plan (Reference 6) which contained erroneous values. The normal torus level was previously communicated as 15'-6"; however, the correct value is 14.7' (Reference 9). Additionally, the bottom of the vent pipe was previously communicated as 30'-3 W'; however, the correct value is 29.5' (Reference 9). The correction of these values changes the freeboard height and additional freeboard height values, previously communicated as 15'-6" to 21' and 9'-3 W', respectively, to 14.7' to 21' and 8.5', respectively. The correction of these values does not affect the successful performance of SAW A/SAWM (Reference 10).

There are no other changes to the compliance method outlined in Reference 6.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation PBAPS expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Combined Phases 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phases 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) for Phase 1 and Phase 2 and the status of each item. Phase 1 open item responses were discussed with the NRC on May 18, 2017, and all items were adequately addressed and resolved. All additional information has been provided, and the Phase 1 open items are considered closed based on NRC review.

Combined Phases 1 and 2 OIP Open Item Status Phase 1 Open Items 01-1. Confirm that the Remote Operating Station (ROS) Deleted. Closed to ISE Open Item number 09.

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

01-2. Provide procedures for HCVS Operation Deleted. Closed to ISE Open Item number 01.

0 1-3. Identify site specific controlling document for Deleted. Closed to ISE Open Item number 02.

HCVS out of service and compensatory measures Page 6of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report tor the Implementation of HCVS Phases 1 and 2 June 30, 2017 Combined Phases 1 and 2 OIP Open Item Status 01-4. Determine the approach for combustible gases. Deleted. Closed to ISE Open Item number 08.

01 -5. Perform radiological evaluation for Phase 1 vent Complete line impact on ERO response actions.

Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 1 Interim Staff Evaluation Open Item Status ISE-1 . Make available for NRC staff audit guidelines Complete and procedures for HCVS operation. (Section 3.2.3.1)

Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-2. Make available for the NRC staff audit the site Complete specific controlling document for HCVS out of service and compensatory measures. (Section 3.4.1) Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-3. Make available for NRC staff audit a technical Complete justification for use of jumpers in the HCVS strategy.

(Section 3.1.3} Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-4. Make available for NRC staff audit analyses Complete demonstrating that the HCVS has the, capacity to vent the steam/energy equivalent of one percent of Completion support information is contained in the fifth six licensed/rated thermal power (unless a lower value is month update dated December 15, 2016 (Reference 8).

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. (Sections 3.2.2.1 and 3.2.2.2)

ISE-5. Make available for NRC staff audit descriptions Complete or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee Completion support information is contained in the fifth six justification for the HVAC release point being below and month update dated December 15, 2016 (Reference 8).

150 feet from the reactor building ventilation release point. (Section 3.2.2.3)

ISE-6. Make available for NRC staff audit details to Complete justify the deviation from tornado protection standards provided in NEI 13-02 or make available a description of Completion support information is contained in the fifth six how the HCVS will comply with the tornado protection month update dated December 15, 2016 (Reference 8).

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

ISE-7. Make available for NRC staff audit Complete documentation that demonstrates adequate communication between the remote HCVS operation Completion support information is contained in the fifth six locations and HCVS decision makers during ELAP and month update dated December 15, 2016 (Reference 8).

severe accident condition . (Section 3.2.2.5)

ISE-8. Provide a description of the final design of the Complete HCVS to address hydrogen detonation and deflagration.

(Section 3.2.2.6) Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-9. Make available for NRC staff audit an Complete evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and Completion support information is contained in the fifth six operate controls and support equipment. (Sections month update dated December 15, 2016 (Reference 8).

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)

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 1 Interim Staff Evaluation Open Item Status ISE-10. Make available for NRC staff audit descriptions Complete of all instrumentation and controls (existing and planned) necessary to implement this order including Completion support information is contained in the fifth six qualification methods. (Sections 3.2.2.9 and 3.2.2.10) month update dated December 15, 2016 (Reference 8).

ISE-11. Make available for NRC staff audit the final Complete sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading Completion support information is contained in the fifth six calculation. (Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, month update dated December 15, 2016 (Reference 8).

3.2.4.2, 3.2.5.1, 3.2.5.2, and 3.2.6)

ISE-12. Make available for NRC staff audit the Complete descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe Completion support information is contained in the fifth six accident for the components (valves, instrumentation, month update dated December 15, 2016 (Reference 8).

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)

ISE-13. Make available for NRC staff audit Complete documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, Completion support information is contained in the fifth six will open under the maximum expected differential month update dated December 15, 2016 (Reference 8).

pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

ISE-14. Provide a description of the strategies for Complete hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor Completion support information is contained in the fifth six building or other buildings. (Section 3.2.2.6 and 3.2.2.7) month update dated December 15, 2016 (Reference 8).

ISE-15. Make available for NRC audit documentation Complete confirming that HCVS will remain isolated from standby gas treatment system during ELAP and severe accident Completion support information is contained in the fifth six conditions. (Section 3.2.2.7) month update dated December 15, 2016 (Reference 8).

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 2 Interim Staff Evaluation Status Open Item ISE-1. Licensee to Complete demonstrate the SAWA equipment and controls, Equipment and Controls as well as ingress and egress paths for the Plant instrumentation for SAWM that is qualified to RG 1.97 or equivalent is considered expected severe qualified for the sustained operating period without further evaluation. The following plant accident conditions instruments are qualified to RG 1.97:

(temperature, humidity, radiation) remain PR!TR-4805 (Unit 2) operational throughout PR!TR-5805 (Unit 3) the sustained operating Ll-8123A (Unit 2) period. (Section 3.3.2.3) Ll-9123A (Unit3)

Not all components that are either in the PR!TR-4(5)805 instrument loops or that may affect the loops are RG 1.97 qualified. These components include PT-4805, PT-5805, 2DC834 and 3DC834, and are evaluated in EC 618957, Attachment 9A for the radiological, thermal and humidity conditions expected during a severe accident. These components are determined to be either acceptable or have no adverse effect on the PR!TR-4805 and PR!TR-5805 instrument loops if failure occurred.

Passive components that do not need to change state after initially establishing SAWA flow do not require evaluation beyond the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, at which time they are expected to be installed and ready for use to support SAWNSAWM.

The following additional equipment performing an active SAWNSAWM function is considered:

SAWNSAWM flow instrument.

SAWNSAWM pump (FLEX pump)

SAWNSAWM generator (FLEX generator)

Active valves in SAWA flow path Ingress and Egress A quantitative evaluation of expected dose rates has been performed per HCVS-WP-02 in Calculation PM-1207 and found the dose rates at deployment locations including ingress/egress paths are acceptable.

Calculation PM-1207 has been posted to the ePortal. Unit 3 EC 618957 will be posted to the ePortal upon aooroval of the EC.

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 2 Interim Staff Evaluation Status Open Item ISE-2. Licensee to Complete demonstrate that instrumentation and Equipment and Controls equipment being used forSAWA and Plant instrumentation for SAWM that is qualified to RG 1.97 or equivalent is considered supporting equipment is qualified for the sustained operating period without further evaluation. The following plant capable to perform for instruments are qualified to RG 1.97:

the sustained operating period under the PR!TR-4805 (Unit 2) expected temperature PR!TR-5805 (Unit 3) and radioloqical Ll-8123A (Unit 2) conditions. (Section Ll-9123A (Unit3) 3.3.2.3)

See response to Phase 2 ISE-1 for discussion on components that are associated with the PR!TR-4(5)805 instrument loops that are not RG 1.97 qualified.

Passive components that do not need to change state after initially establishing SAWA flow do not require evaluation beyond the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, at which time they are expected to be installed and ready for use to support SAWA/SAWM.

The following additional equipment performing an active SAWA/SAWM function is considered for temperature and radiation effects:

SAW A/SAWM flow instrument SAWA/SAWM pump (FLEX pump)

SAW A/SAWM generator (FLEX generator)

Active valves in SAWA flow path Temperature The location of SAWA equipment and controls are the same or similar as FLEX with the exceptions noted below. The areas/rooms of PBAPS that require operator actions or passage to implement the SAWA/SAWM strategy are evaluated. The evaluation concluded that the expected thermal conditions associated with a severe accident are considered to be acceptable to accomplish the required SAWA/SAWM actions for HCVS Phase 2. Details of the evaluation are contained in EC 618957, Attachment 99.

The SAW A/SAWM action time line is the same as the FLEX action time line with the exception of performing procedure FSG-043 "Defeating RCIC Interlocks" and FSG-032 "Establishing HPCl/RCIC/Sump Room Ventilation, Lighting and Water Removal". These procedures are not required to be performed as part of the SAW A/SAWM strategy since the actions performed in these procedures are to support RCIC/HPCI operation and RCIC and HPCI are assumed to fail for SAWA/SAWM. Technical Evaluation 2493544-28 established a temperature profile for areas of PBAPS during an ELAP that require operator actions or passage to implement the FLEX strategy. This evaluation considered loss of ventilation (until FLEX generators are deployed) combined with decay heat from the reactor and various subsystems and heat from plant equipment fed by station batteries such as relays, emergency lighting and other electrical components credited in the FLEX strategy. Active plant calculations involving loss of HVAC were evaluated to identify calculations where area temperatures would be bounding when compared to those temperatures anticipated during an ELAP. The following rooms were evaluated for FLEX in Technical Evaluation 2493544-28; however, they are not required to be accessed as part of the SAWA/SAWM strategy:

RCIC Pump Room and HPCI Pump Room Since RCIC and HPCI are assumed to fail immediately for SAWA/SAWM, there is no requirement to access the RCIC or HPCI pump rooms; however, operators will likely open the RCIC and HPCI oumo room doors oer procedure SE-11 and determine if the RCIC or Page 11of15

Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 2 Interim Staff Evaluation Status Open Item HPCI pumps can be started. The temperatures listed for these rooms in Technical Evaluation 2493544-28 would remain bounding for the relatively short time operators would spend determining if the RCIC or HPCI pumps can be started since the heat load from the RCIC or HPCI pump operation would not contribute to the overall heat load of the room.

Reactor Building Sum12 Room and Core S12raJl Pum12 Room The reactor building sump room and core spray pump room are required to be accessed as part of the FLEX strategy per procedure FSG-032; however, these rooms are not required to be accessed as part of the SAW AJSAWM strategy since FSG-032 is not required to be performed as stated above.

South Isolation Valve Room (SIVRl Procedure FSG-044 aligns the backup instrument nitrogen bottles to the ADS valves as part of the FLEX and SAWAJSAWM strategy. This is achieved by bypassing the A and B backup instrument nitrogen solenoid valves via a local bypass line. The B backup instrument nitrogen solenoid valve is located in the SIVA and cannot be bypassed using the local bypass line since the Unit 3 SIVA is uninhabitable during a Severe Accident.

Therefore, the Engineering Change associated with SAW AJSAWM provides a new bypass line which is routed outside of the SIVA into the Control Rod Drive (CAD)

Equipment Area which is evaluated below.

The remaining areas identified in Technical Evaluation 2493544-28 are required to be accessed as part of the SAWAJSAWM strategy. The temperatures listed for the Stairwells, Reactor Building Closed Cooling Water (RBCCW) Rooms, CAD Equipment Areas, Corridors, and Operating Area are associated with a Loss of Coolant Accident (LOCA). As stated in Technical Evaluation 2493544-28, these area temperatures are greater than those anticipated in an ELAP. These LOCA temperatures are considered to be acceptable for application to SAW AJSAWM actions under a severe accident since these temperatures are conservative in nature under an ELAP, the SAWAJSAWM actions will be completed within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> into the event where containment heat up is restricted to core damage prior to vessel breach, and the drywell shield wall provides restrictive heat transfer which will mitigate the propagation of the higher drywall temperature. The temperatures listed for the Cable Spreading Room and Computer Room are from calculation PM-1034; these area temperatures are reasonable and would not be expected to have any notable increase due to location/proximity to primary containment. The Refuel Floor Area temperature is determined by calculation PM-1174, Rev. O and this temperature is also not expected to increase since the inputs and assumptions of the calculation remain the same. Per HCVS-FAQ-01, no evaluation is required for use of the MGR as the primary control station. Actions to open Reactor Building Railroad Doors and Refuel Floor Roof Hatch to establish natural circulation of the Secondary Containment atmosphere and establish MGR, Battery Room and Switchgear Room ventilation per FSG-030, FSG-031 and FSG-033 are maintained as part of the SAWAJSAWM strategy.

Technical Evaluation 2493544-28 established area/room temperatures during an ELAP for PBAPS and determined that these temperatures are acceptable to implement FLEX actions. Based on the determination that the temperatures listed in Technical Evaluation 2493544-28 can be applied to SAW AJSAWM actions and that these temperatures are acceptable to accomplish the required FLEX actions, the expected thermal conditions associated with SAWAJSAWM are considered to be acceptable to accomplish the required SAWAJSAWM actions for HCVS Phase 2.

Radiation For equipment locations within the Reactor Building, a quantitative evaluation of expected normal operation and containment shine (vent line shine) total integrated dose has been performed per HCVS-FAQ-12 (HCVS-WP-02) in Calculation PM-1207 and found the total integrated dose at deolovment locations is acceotable.

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 2 Interim Staff Evaluation Status Open Item For locations outside the Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA is being utilized, a quantitative evaluation of expected dose rates has been performed per HCVS-WP-02 in Calculation PM-1207 and found the dose rates at deployment locations are acceptable.

Calculation PM-1207 and Procedures FSG-030, FSG-031, FSG-032, FSG-033 and FSG-043 have been posted to the ePortal. The revised Procedure FSG-044 will be posted to the ePortal upon approval of the procedure revision. Unit 3 EC 618957 will be posted to the ePortal upon approval of the EC.

ISE-3 Licensee to Complete demonstrate that containment failure as a The wetwell vent has been designed and installed to meet NEI 13-02, Rev. 1 guidance result of overpressure which will ensure that it is adequately sized to prevent containment overpressure under can be prevented severe accident conditions.

without a drywell vent during severe accident The SAWM strategy will ensure that the wetwell vent remains functional for the period of conditions. (Section sustained operation. PBAPS will follow the guidance (flow rate and timing) for 3.3.3) SAWA/SAWM described in BWROG-TP-15-008 and BWROG-TP-15-011 . These documents have been posted to the ePortal for NRC staff review. The wetwell vent will be opened prior to exceeding the PCPL value of 60 psig. Therefore, containment over pressurization is prevented without the need for a drywell vent.

ISE-4 Licensee shall Complete demonstrate whether a site specific MAAP Peach Bottom will implement the initial SAWA flow rate of 500 GPM used in the reference evaluation will be used plant evaluation. A site specific MAAP evaluation fo r determining an appropriate site to determine an initial specific initial SAWA flow rate is not required.

SAWA flow rate. If the evaluations performed Using Figure 2.1.C from the combined Phases 1 and 2 OIP, compare the reference plant in BWROG TP-15-011 parameters to the plant specific parameters.

is considered, provide a description of how the Reference Plant Peach Bottom plant is bounded by the Torus freeboard volume is 525,000' Torus freeboard volume is 525,000' reference plant analysis gallons aallons that shows the SAWM SAWA flow is 500 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> SAWA flow is 500 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> strategy is successful in followed by 100 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to followed by 100 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to making it unlikely that a 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> drywell vent is needed. The above parameters for Peach Bottom compared to the reference plant that (Section 3.3.3.1) determine success of the SAWM strategy demonstrate that the reference plant values are bounding. Therefore, the SAWM strategy implemented at Peach Bottom makes it unlikelv that a OW vent is needed to prevent containment overpressure related failure.

ISE-5 Licensee to Complete demonstrate that there is adequate The SAWA/SAWM pump (FLEX pump) and SAWA manual valve location is adjacent to communication between the 3 Startup Switchgear Building north of the Unit 3 Reactor Building. This location is the MGR and the Intake shown in EC 618957, Attachment 12. Unit 3 EC 618957 will be posted to the ePortal upon Structure operator at approval of the EC.

the FLEX manual valve during severe accident PBAPS utilizes radio communications to communicate between the MCR and the conditions. (Section operator at the SAWA flow control location. This communication method is the same as 3.3.3.4) accepted in Order EA-12-049. These items will be powered and remain powered using the same methods as evaluated under EA-12-049 for the period of sustained operation, which may be longer than identified for EA-12-049.

1 Peach Bottom available freeboard volume in gallons is estimated from nominal water level of 14.7 feet to 21 feet. 21 feet is the upper range of the wide range torus level instrument and the assumed loss of wetwell vent function. The Peach Bottom torus is 31 feet in diameter.

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017 Phase 2 Interim Staff Evaluation Status Open Item ISE-6 Licensee to Complete demonstrate the SAWM flow instrumentation For locations outside the Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA is qualification for the being utilized, a quantitative evaluation of expected dose rates has been performed per expected environmental HCVS-WP-02 in Calculation PM-1207 and found the dose rates at deployment locations conditions. (Section are acceptable. The selected instrument is designed for the expected flow rate, 3.3.3.4) temperature and pressure for SAWA over the period of sustained operation.

SAWA Flow Instrument Expected SAWA Parameter Qualification Range 3.3 to 1100 GPM 100 to 500 GPM

-4 to 140 °F 10 to 95 °F 740 PSI 300 PSI The SAWA flow instrument qualifications are contained in EC 618957, Attachment 4. Unit 3 EC 618957 will be posted to the ePortal upon approval of the EC.

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

8 References The following references support the updates to the combined Phases 1 and 2 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. 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-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 (Accession No. ML133048836).
5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. ML14128A219).

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Peach Bottom Atomic Power Station, Units 2 and 3 Sixth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2017

6. Peach Bottom Atomic Power Station, Units 2 and 3, Combined 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)," dated December 15, 2015.
7. 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 (Accession No. ML15104A118).
8. Peach Bottom Atomic Power Station, Units 2 and 3, Fifth Six-Month Status Report for Phase 1 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 15, 2016 (RS-16-235).

9. Peach Bottom TSG 1.3, Rev. 3, "Peach Bottom RPV and Containment Flooding Diagram".
10. PB-MISC-023, Rev. 1, MAAP Analysis to Support HCVS Design, dated December 2, 2016.

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