RS-17-152, Seventh 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 ...

From kanterella
(Redirected from RS-17-152)
Jump to navigation Jump to search
Seventh 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 ...
ML18239A032
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 12/15/2017
From: Gullott D
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-17-152
Download: ML18239A032 (25)
v • d • e


Text

Order No. EA-13-109 RS-17-152 December 15, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Seventh 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 Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, 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, LLCs 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-14-059)
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 17, 2014 (RS-14-303)
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-15-149)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 15, 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 16, 2015 (RS-15-300)
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-16-107)
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 14, 2016 (RS-16-233)
12. Exelon Generation Company, LLC 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), dated June 29, 2017 (RS-17-065)
13. NRC letter to Exelon Generation Company, LLC, LaSalle County 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. MF4456 and MF4457), dated March 31, 2015

14. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 -

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. MF4456 and MF4457), dated August 2, 2016 On June 6, 2013, the Nuclear Regulatory Commission (NRC or Commission) issued an Order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities have a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements are outlined in 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 (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 EGC initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 provided the LaSalle County Station, Units 1 and 2, 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 LaSalle County Station. Reference 9 provided the LaSalle County Station,

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 15, 2017 Page 3 Units 1 and 2, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1. References 1O, 11, and 12 provided the fourth, fifth, and sixth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for LaSalle County Station.

The purpose of this letter Is to provide the seventh 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 LaSalle County 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 References 13 and 14.

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 ot perjury that the foregoing is true and correct. Executed on the 1511i day of December 2017.

Respectfully submitted,

~~d:J Manager - Licensing Exelon Generation Company, LLC

Enclosure:

LaSalle County Station, Units 1 and 2 Seventh 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 Ill NAC Senior Resident Inspector - LaSalle County Station NRC Project Manager, NRA - LaSalle County Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 Seventh 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 (21 pages)

COMBINED PHASES 1 AND 2 SIX MONTH UPDATE Enclosure LaSalles Seventh 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 LaSalle 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 NRC Order EA-13-109 (Reference 2). Updates of milestone accomplishments are based on the combined Phases 1 and 2 Overall Integrated Plan (Reference 7), 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 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 latest status report, 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 June 1, 2017, and are current as of December 1, 2017:

  • Seventh Six-Month Update (complete with this submittal)
  • Phase 1 Unit 1 Complete Detailed Design and Issue Modification Package
  • Phase 2 Unit 1 Complete Detailed Design and Issue Modification Package
  • Phase 2 Unit 1 Complete Online Installation
  • Phase 2 Unit 2 Begin Detailed Design 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.

Page 1 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 The revised milestone target completion dates do not impact the order implementation date.

Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Submit Phase 1 Overall Jun 2014 Complete Integrated Plan Submit 6 Month Updates Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 and Phase 2 Dec 2015 Complete Overall Integrated Plan Update 4 Jun 2016 Complete Update 5 Dec 2016 Complete Update 6 Jun 2017 Complete Update 7 Dec 2017 Complete This submittal Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Unit 2 Modifications Begin Conceptual Jun 2014 Complete Design Complete Conceptual Jun 2014 Complete Design Begin Detailed Design Jun 2015 Complete Complete Detailed Design and Issue Nov 2016 Complete Modification Package Page 2 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Begin Online Jun 2016 Complete Installation Complete Online Feb 2017 Complete Installation Begin Outage Feb 2017 Complete Installation Complete Outage Installation and put Mar 2017 Complete system into service Phase 1 Unit 2 Procedure Changes Operations Procedures Dec 2016 Complete Developed Maintenance Dec 2016 Complete Procedures Developed Procedure Changes Mar 2017 Complete Active Phase 1 Unit 2 Training Training Complete Dec 2016 Complete Phase 1 Unit 2 Completion Unit 2 HCVS Phase 1 Mar 2017 Complete Implementation Phase 1 Unit 1 Modifications Begin Conceptual Jun 2014 Complete Design Complete Conceptual Jun 2014 Complete Design Begin Detailed Design Jun 2015 Complete Page 3 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Complete Detailed Design and Issue Mar 2017 Complete Aug 2017 Modification Package Begin Online May 2017 Complete Installation Complete Online Feb 2018 Started Dec 2017 Installation Begin Outage Feb 2018 Not Started Installation Complete Outage Installation and put Mar 2018 Not Started system into service Phase 1 Unit 1 Procedure Changes Operations Procedures Dec 2017 Started Developed Maintenance Dec 2017 Started Procedures Developed Procedure Changes Mar 2018 Not Started Active Phase 1 Unit 1 Training Training Complete Dec 2017 Started Phase 1 Completion Phase 1 Unit 1 Mar 2018 Not Started Implementation Phase 2 Specific Milestones Phase 2 Unit 1 Modifications Page 4 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Begin Conceptual Jun 2015 Complete Design Complete Conceptual Jun 2015 Complete Design Completed Mar 2017 Begin Detailed Design Jun 2016 Complete due to Phase 1 detailed design and installation Complete Detailed Design and Issue Mar 2017 Complete Aug 2017 Modification Package Begin Online May 2017 Complete Sep 2017 Installation Complete Online Feb 2018 Complete Nov 2017 Installation Begin Outage No outage work Feb 2018 Not Started Installation required Complete Outage No outage work Installation and put Mar 2018 Not Started required system into service Phase 2 Unit 1 Procedure Changes Operations Procedures Dec 2017 Started Developed Maintenance Dec 2017 Started Procedures Developed Procedure Changes Mar 2018 Started Dec 2017 Active Phase 2 Unit 1 Training Training Complete Dec 2017 Complete Oct 2017 Page 5 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Phase 2 Unit 1 Completion Phase 2 Unit 1 Mar 2018 Started Implementation Submit Unit 1 Phases 1 & 2 Full Compliance May 2018 Not Started Report Phase 2 Unit 2 Modifications Begin Conceptual Jun 2015 Complete Design Complete Conceptual Jun 2015 Complete Design Begin Detailed Design Jun 2017 Complete Sep 2017 Complete Detailed New Target: Apr 2018 Design and Issue Mar 2018 Not Started due to movement of the Modification Package start of detailed design New Target: Aug 2018 Begin Online May 2018 Not Started based on plant work Installation week schedule Complete Online Feb 2019 Not Started Installation Begin Outage No outage work Feb 2019 Not Started Installation required Complete Outage No outage work Installation and put Mar 2019 Not Started required system into service Phase 2 Unit 2 Procedure Changes Operations Procedures Dec 2018 Not Started Developed Page 6 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Maintenance Dec 2018 Not Started Procedures Developed Procedure Changes Mar 2019 Not Started Active Phase 2 Unit 2 Training Training Complete Dec 2018 Not Started Phase 2 Completion Phase 2 Unit 2 Mar 2019 Not Started Implementation Submit Unit 2 Phases 1 & 2 Full Compliance May 2019 Not Started Report 4 Changes to Compliance Method

1. Rather than as close as possible (Ref. 7, pg. 14), the PCIVs will be located as close as reasonably possible (Ref. 3, Sec. 4.1.2.1.2) to the penetration into primary containment. (Ref. 9, Dwg. M-959 Sht. 4; Ref. 12, Dwg. M-859 Sht. 4)
2. The motive gas supply to the PCIVs will be nitrogen, not argon. (Ref. 7, pg. 10 &

15; Ref. 9 & 12, Design Considerations Summary [DCS] 4.1.33)

3. Downstream of the outboard PCIV, the piping classification changes from Safety Related to Non-Safety Related and Seismically Supported (i.e., Augmented Quality) (including the rupture disc). This is similar to safety classification changes for the existing Containment Vent & Purge System where piping downstream of the outboard PCIV is Non-Safety Related and Seismically Supported and then penetrates through Secondary Containment. This includes the argon and nitrogen tubing. (Ref. 7, pg. 17; Ref. 9 & 12, DCS 4.1.4.2)
4. HCVS leak-off path isolation will be via pilot-operated 2-way valve located in the Reactor Building. The pneumatic pilot taps into the nitrogen supply to the upstream PCIV actuator, closing the leak-off pathway simultaneously with opening the upstream PCIV. Thus, it will not require separate manual action.

Page 7 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 From Table 2-1 of Reference 7 (pg. 10), Primary Action 2 is combined with opening the upstream PCIV and inserted between Primary Actions 4 and 5 in sequence, prior to breaching the rupture disc with argon. Primary Action 6 will be reduced to opening and closing the downstream PCIV to cycle the vent. (Ref. 9, Dwg. M-138 Sht. 3; Ref. 12, Dwg. M-92 Sht. 4)

5. Radiation shielding for the FLEX pump or generator deployment locations is not required; the dose rates at the FLEX pump deployment locations are low enough for personnel habitability without shielding, and the FLEX generators are relocated to take advantage of shielding provided by the Reactor Building itself.

(Ref. 7, pg. 28; procedure LOA-FSG-002 Rev. 6, Atts. B1, B2, & I; calculation L-004151 Rev. 0) 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation LaSalle 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) and the status of each item.

Page 8 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Combined Phases 1 and 2 OIP Status Open Items Phase 1 Open Items 7 Perform radiological Complete. LaSalle Calculation L-004151 evaluation for Phase 1 vent determines peak dose rates at FLEX and line impact on ERO actions. HCVS Phase 2 activity locations. Adjustments have been made to either the timing or location of actions to manage dose below 5 REM to any individual performing ERO actions in most cases, with a small number of actions potentially greater than 5 REM, but not exceeding 10 REM. The estimated dose is based on peak dose rates from LaSalle calculation L-004151, determined from a combination of all source term locations, and is a very conservative estimate. There is considerable margin to the maximum emergency response exposure guideline of 25 REM to any one individual performing ERO actions.

L-004151 Rev. 0 is available on ePortal.

Page 9 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Combined Phases 1 and 2 OIP Status Open Items Phase 2 Open Items 1 Evaluate feasibility of strategy Complete. LaSalle Calculation L-004151 due to radiological conditions. indicates that the affected Reactor Building (RB) will be uninhabitable 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the ELAP due to core damage. As a result, the hose connection point on elevation 710 will be relocated from the RB to the Diesel Corridor, and order of activities changed so that the hose connections on elevation 761 are made within the first hour after the ELAP. Should electrical load shedding in the RB occur prior to elevated radiation levels rendering the building uninhabitable, LOA-FSG-002 is adjusted so that SAWA/SAWM required loads remain switched on. Dose rates at the FLEX/SAWA pump location are low enough that additional shielding is not required. Refueling strategies and other exterior actions will be adjusted as necessary based on actual event conditions.

L-004151 Rev. 0 and LOA-FSG-002 Rev. 6 are available on ePortal.

Page 10 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Combined Phases 1 and 2 OIP Status Open Items 2 Verify required modifications Complete. The primary FLEX water strategy to support SAWA/SAWM. RB connection point is relocated into the Diesel Corridor, a safety related and missile protected structure outside of the RB, to support SAWA/SAWM when the radiation levels inside the RB render it uninhabitable due to fuel damage. The only other required modification is to construct the SAWA flow meter rig, which is mounted on a portable cart and stored in the Diesel Corridor. The flow meter is connected in-line with the FLEX water strategy hose downstream of a wye fitting where flow to the SFP splits off so the flow meter measures only RPV injection flow.

Ref. 13 is available on ePortal.

No. Phase 1 Interim Staff Status Evaluation Open Item 1 Make available for NRC staff Complete for Unit 2. The motive and purge gas audit documentation of a systems will be isolated by at least one locked-method to disable HCVS closed manual valve in each system during during normal operation to normal operation. Main Control Room (MCR) provide assurances against controls will be via key-locked switches with inadvertent operation that power normally de-energized. PCIVs are gas-also minimizes actions to to-open, spring/fail closed.

enable HCVS operation Ref. 9 & 12 (DCS 4.1.19, 4.1.33, 4.1.35, 4.1.36) following an ELAP.

and procedure LGA-VQ-202 provide direction for these actions and are available on ePortal.

In-progress for Unit 1 following the concept described for Unit 2, above.

Page 11 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 2 Make available for NRC staff Complete. Calculation L-004114 performs the audit the final sizing sizing evaluation of the common HCVS evaluation for HCVS batteries and associated charger. The results batteries/battery charger show a margin of approximately 7% after 24 including incorporation into hours with all Unit 1 and Unit 2 HCVS loads FLEX DG loading calculation. drawing maximum current. The FLEX DG loading evaluations in ECs 396062 (DCS 4.1.35) and 396069 (DCS 4.1.35) show a margin on the more limited DG of 337 amps for future loads. The HCVS battery charger rated input current is 8 amps per Ref. 9 (DCS 4.1.35). Therefore, there is sufficient margin in either FLEX DG to power the HCVS battery charger.

L-004114 Rev. 0, the DCSs of ECs 396062 and 396069, and Ref. 9 & 12 are available on ePortal.

3 Make available for NRC staff Complete. Pneumatic system motive force audit documentation of the changed to nitrogen; see Section 4 of this HCVS argon pneumatic document, Ref. 9 & 12 (DCS 4.1.33), and system design including calculations L-004117 and L-004184.

sizing and location. L-004117 Rev. 0, L-004184 Rev. 0, and Ref. 9

& 12 are available on ePortal.

4 Make available for NRC staff Complete. The radiological evaluation in audit an evaluation of calculation L-004115 and temperature temperature and radiological evaluations in Ref. 9 & 12 (DCS 4.1.14) show conditions to ensure that no additional shielding or high temperature operating personnel can mitigation is required to safely access and safely access and operate operate controls and equipment.

controls and support L-004115 Rev. 2 and Ref. 9 & 12 are available equipment. on ePortal.

Page 12 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 5 Make available for NRC staff Complete. Calculations L-004097 and L-audit analyses demonstrating 004149 show that the HCVS has the capacity that HCVS has the capacity to vent the steam/energy equivalent of 1% of to vent the steam/energy rated thermal power while maintaining equivalent of one percent of containment pressure below containment licensed/rated thermal power design pressure and PCPL.

(unless a lower value is L-004097 Rev. 3 and L-004149 Rev. 0 are justified), and that the available on ePortal.

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.

6 Make available for NRC staff Complete. LaSalle design complies with the audit the seismic and tornado reasonable tornado protection criteria of missile final design criteria for Reference 6. The seismic and tornado missile the HCVS stack. protection design is described in Ref. 9 & 12 (DCS 4.1.38) and evaluated in calculation L-004092.

Ref. 9 & 12 and L-004092 Revs. 2 and 2A are available on ePortal.

Page 13 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 7 Make available for NRC staff Complete. Ref. 9 & 12 (DCS 4.1.14) include the audit the descriptions of local temperature and humidity evaluations and conditions (temperature, Calculation L-004115 evaluates the radiological radiation and humidity) conditions.

anticipated during ELAP and Ref. 9 & 12 and L-004115 Rev. 2 are available severe accident for the on ePortal.

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.

8 Make available for NRC staff Complete. FLEX communications strategies audit documentation that and equipment (as described in procedure demonstrates adequate LOA-FSG-010) will be utilized for HCVS. These communication between the methods are adequate for HCVS remote HCVS operation implementation.

locations and HCVS decision LOA-FSG-010 Rev. 3 is available on ePortal.

makers during ELAP and severe accident conditions.

9 Provide a description of the Complete. An argon purge system is provided final design of the HCVS to which is designed to purge the vent piping of a address hydrogen detonation detonable mixture of hydrogen and oxygen and deflagration. after each vent cycle. Installed capacity is provided for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after ELAP, and additional argon bottles are stored in a FLEX building to continue operation past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Calculations L-004137 Rev. 0 & L-004185 Rev.

0 and Ref. 9 & 12 (DCS 4.1.33) are available on ePortal.

Page 14 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 10 Provide a description of the Complete. LaSalles wetwell vent line has a strategies for hydrogen dedicated HCVS flowpath from the wetwell control that minimizes the penetration to the outside with no potential for hydrogen gas interconnected system. The discharge point migration and ingress into the meets the guidance of HCVS-FAQ-04 (Att. J of reactor building or other Reference 3).

buildings. See Ref. 9 (Dwg. M-138 Sht. 3) and Ref. 12 (Dwg. M-92 Sht. 4), available on ePortal.

11 Make available for NRC staff Complete for Unit 2. See Calculations L-audit documentation of a 003953, L-004138 through L-004146, L-004161 seismic qualification through L-004166.

evaluation of HCVS All calculations are available on ePortal, except components. unapproved calculations as noted:

L-003953 Rev. 1B L-004138 Rev. 0 L-004139 Rev. 0 and 0A L-004140 Rev. 1 L-004141 Rev. 0 and 0A L-004142 Rev. 0 and 0A L-004143 Rev. 0 and 0A (0A not yet approved)

L-004144 Rev. 0 and 0A L-004145 Rev. 0 and 0A L-004146 Rev. 0 and 0A (0A not yet approved)

L-004161 Rev. 0 and 0A L-004162 Rev. 0 and 0A L-004163 Rev. 0 and 0A L-004164 Rev. 0 and 0A L-004165 Rev. 0 and 0A L-004166 Rev. 1 In-progress for Unit 1; design follows the same concept as Unit 2, but not all calculations are approved.

Page 15 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 12 Make available for NRC staff Complete for Unit 2; Unit 1 design follows the audit descriptions of all same concept as Unit 2, but not all calculations instrumentation and controls are approved.

(existing and planned) New instrumentation and controls are necessary to implement this described in Ref. 9 &12 (DCS 4.1.36), and order including qualification qualification methods are per calculations methods. shown in the table, below.

New Instruments Qualification Method Reference Calculations HCVS Temperature: IEEE 344-1975/1987 1(2)TE-PC310 L-004161 1(2)TT-PC311 L-004166 HCVS Radiation: IEEE 344-1975 1(2)RE-PC320 L-004139 1(2)RT-PC321 L-004166 HCVS PCIV Position IEEE 344-1975 Indication L-004140 HCVS Pneumatic IEEE 344-1975 Supply Pressure: L-004143 1(2)PI-PC450 HCVS Purge Supply IEEE 344-1975 Pressure: L-004143 1(2)PI-PC545 L-004141 1(2)PT-PC546 HCVS Electrical IEEE 344-1975 Supply Availability: L-004138 0DC51E HCVS Controls: IEEE 344-1975 0PM08J L-004146 manual valves L-004143 Existing instruments relied upon for initiation, operation, and monitoring of HCVS are qualified or evaluated to Regulatory Guide 1.97 and include the following: Drywell pressure (1(2)PI-CM029), Wetwell pressure (1(2)PI-CM056), Wetwell level (1(2)LI-CM192),

Wetwell water temperature (1(2)TI-CM037),

and Reactor pressure (1(2)C61-R011). (Ref. 9

& 12, DCS 4.1.14)

Page 16 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 All referenced documents are available on ePortal, except unapproved calculations as noted in Phase 1 ISE Open Item #11.

13 Make available for NRC staff Complete for Unit 2. Procedures LGA-VQ-202 audit the procedures for Rev 1 and LOP-PC-09 Rev 4 contain all HCVS operation. instructions for operation of the HCVS.

Above procedures are available on ePortal.

In-progress for Unit 1; design follows the same concept as Unit 2.

Phase 2 Interim Staff Status Evaluation Open Item 1 Licensee to confirm through Complete.

analysis the temperature and radiological conditions to Actions taken within the first hour (prior to start ensure that operating of core damage) from the start of the ELAP are personnel can safely access acceptable from an environmental and and operate controls and radiological perspective without further support equipment. (ISE evaluation.

Section 3.3.1) Actions performed within the MCR are acceptable for the entire period of Sustained Operation per HCVS-FAQ-06 Assumption 049-21.

For actions within the Reactor Building and between 1 and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, a quantitative evaluation of expected dose rates has been performed per HCVS-FAQ-12 and found the dose rates at deployment locations including ingress/egress paths are acceptable. See calculation L-004151. Note that no actions in the Reactor Building are planned for the unit in a severe accident after the first hour post-ELAP.

For ingress and egress paths 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 Page 17 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 performed per HCVS-WP-02 and found the dose rates at deployment locations including ingress/egress paths are acceptable. See L-004151.

Cautions will be added to procedures to provide guidance for high dose rate areas to minimize dose.

L-004151 Rev. 0 is available on ePortal.

2 Licensee to evaluate the Complete.

ingress and egress paths for the expected severe accident The location of SAWA equipment and controls, conditions (temperature, including ingress and egress paths, will be the humidity, radiation) for the same or similar as FLEX and will be bounded sustained operating period. by the FLEX evaluations for temperature and (ISE Section 3.3.2.3) humidity.

See the response to Phase 2 ISE Open Item #1 for radiation.

3 Licensee to demonstrate that Complete.

containment failure as a result of overpressure can be The wetwell vent has been designed to meet prevented without a DW vent NEI 13-02 Rev 1 guidance, which will ensure during severe accident that it is adequately sized to prevent conditions. (ISE Section containment overpressure under severe 3.3.3) accident conditions.

The SAWM strategy will ensure that the wetwell vent remains functional for the period of sustained operation. LaSalle will follow the guidance (flow rate and timing) for SAWA/SAWM described in BWROG-TP 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.

Page 18 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 4 Licensee shall demonstrate Complete.

how the plant is bounded by the reference plant analysis Reference Plant LaSalle Torus freeboard Suppression chamber that shows the SAWM volume is 525,000 free volume is at least strategy is successful in gallons 1.23 million gallons making it unlikely that a DW SAWA flow is 500 SAWA flow is 500 vent is needed. (ISE Section GPM at 8 hr GPM at 8 hr followed 3.3.3.1) followed by 100 by 100 GPM from GPM from 12 hr to 12 hr to 168 hr 168 hr The above parameters for LaSalle compared to the reference plant that determines success of the SAWM strategy demonstrate that the reference plant values are bounding.

Therefore, the SAWM strategy implemented at LaSalle makes it unlikely that a DW vent is needed to prevent containment overpressure related failure.

Reference LaSalle UFSAR Table 6.2-1 for suppression chamber volume. Ref. 13 (DCS 4.1.19, 4.1.33 & Table 3) contains SAWA/SAWM flow rates. UFSAR Table 6.2-1 and Ref. 13 are available on ePortal.

5 Licensee to demonstrate that Complete.

there is adequate communication between the LaSalle utilizes handheld radios in the talk-MCR and the operator at the around mode to communicate between the FLEX pump during severe MCR and the operator at the FLEX pump. This accident conditions. (ISE communication method is the same as Section 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.

Page 19 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 6 Licensee to demonstrate the Complete.

SAWM flow instrumentation qualification for the expected For locations outside the Reactor Building environmental conditions. 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 (ISE Section 3.3.3.4) being utilized, a quantitative evaluation of expected dose rates has been performed per HCVS-WP-02 and found the dose rates at deployment locations including ingress/egress paths are acceptable (Ref. calculation L-004151, available on ePortal). The selected instrument is designed for the expected flow rate, temperature and pressure for SAWA over the period of sustained operation (Ref. 13, DCS 4.1.14). Ref. 13 is available on ePortal.

SAWA Flow Expected SAWA Instrument Parameter Range Qualification 3.30 - 1100 gpm 100 - 500 gpm

-4 to 140 °F 48 to 140 °F 0 to 285 psi 0 to 250 psi 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. LaSalles 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 (Accession No. ML14184A016).
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 (Accession No. ML13143A321).
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.

Page 20 of 21

LaSalle County Station, Units 1 and 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 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. ML13304B836).
5. NRC Endorsement of Industry Hardened Containment Venting System (HCVS)

Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0 (Accession No. ML14128A219).

6. Industry White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade, Revision 0, dated August 17, 2015.
7. LaSalles 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 (Accession No. ML15352A109).
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 (Accession No. ML15104A118).

9. Engineering Change EC 392353, U2 Hardened Containment Vent System (HCVS). Revision 5 approved 2/24/17.
10. NRC Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109, dated March 31, 2015.
11. NRC Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109, dated August 2, 2016.
12. Engineering Change EC 397691, U1 Hardened Containment Vent System (HCVS). Revision 1 approved 8/9/17.
13. Engineering Change EC 618667, U1 Hardened Containment Vent System (HCVS) Phase 2. Revision 0 approved 8/18/17.

Page 21 of 21

Retrieved from "https://kanterella.com/w/index.php?title=RS-17-152,_Seventh_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_...&oldid=2399584"