RS-17-156, 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.

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.

ML17345A778
Person / Time
Site:	Quad Cities
Issue date:	12/11/2017
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-17-156
Download: ML17345A778 (25)

Text

ExeLon Generation Order No. EA-13-109 December 11, 2017 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:

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, 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-14-063)

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-14-306)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 11, 2017 Page 2

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-15-152)

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-15-304)

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-16-110)

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 January 26, 2017 (RS-17-008)

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 27, 2017 (RS-17-069)

13. 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

14. 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 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos.

MF4460 and M174461), dated April 28, 2017 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 11, 2017 Page 3 operation under severe accident conditions. Reference 6 provided the Quad Cities Nuclear Power Station, Units 1 and 2, Phase 1 OI P 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 Quad Cities Nuclear Power Station. Reference 9 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. References 10, 11, and 12 provided the fourth, fifth, and sixth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Quad Cities Nuclear Power 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 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 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 of perjury that the foregoing is true and correct. Executed on the 15'" day of December 2017.

R ectfuIly, Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC

Enclosure:

Quad Cities Nuclear Power 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 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. Brian E. Lee, NRR/JLD/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 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)

Quad Cities 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 Quad Cities 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. Updates of milestone accomplishments will be based on the combined Phases 1 and 2 Overall Integrated Plan dated December 16, 2015.

Quad Cities developed an updated and combined Phases 1 and 2 Overall Integrated Plan (Reference 7 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 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 the Sixth Six-Month Update of the combined Phases 1 and 2 Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

In Reference 24, EGC requested an extension to comply with NRC Order EA-13-109 based on the earlier decision to permanently cease power operations at Quad Cities Nuclear Power Station, Units 1 and 2 by June 1, 2018, which caused engineering design and plant modification activities supporting Order implementation to be discontinued. As a result of the recent reversed cessation of operation decision, in Reference 25, EGC withdrew this request for extension to comply and provided a revised request for extension to comply with NRC Order EA-13-109 based on the continued operation of both units. EGC has now resumed work to complete full implementation of NRC Order EA-13-109 at Quad Cities Nuclear Power Station, Units 1 and 2 in accordance with this update to the Overall Integrated Plan, Section 3, Milestone Schedule, which is consistent with the requested extension letter (Reference 25), as approved by the NRC in Reference 33.

Page 1 of 21

2 Milestone Accomplishments The following milestone(s) have been completed since the Sixth Six-Month Update to the combined Phases 1 and 2 Overall Integrated Plan (Ref. 23), and are current as of December 1, 2017.

Completed detailed design on Unit 2 Phase 1 Completed detailed design on both Units Phase 2 Started construction on both Units Phase 2 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.

The revised milestone target completion dates do not impact the Order EA-13-109 implementation date.

Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

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 Update 4 Jun 2016 Complete Update 5 Jan 2017 Complete Update 6 Jun 2017 Complete I Complete with this Update 7 Dec 2017 submittal Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Page 2 of 21

Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Phase 1 Specific Milestones UNIT 1 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 Schedule relief granted Complete Online Installation Dec 2017 Complete under Ref. 33.

Outage specific portion of installation Begin Outage Portion of the Installation Mar 2017 Complete completed during Q1 R24.

Outage specific portion of installation Complete Outage Installation Apr 2017 Complete completed during 01 R24.

Schedule relief granted Installation Operational Acceptance June 2018 Not Started under Ref. 33.

Phase 1 Unit 1 Procedure Changes Operations Procedure Changes Schedule relief granted Dec 2017 Complete Developed under Ref. 33.

Schedule relief granted Site Specific Maintenance Procedure under Ref. 33.

Dec 2017 Complete Developed Schedule relief granted Procedure Changes Complete Dec 2017 Complete under Ref. 33.

Procedure Final Validation and f Implementation Schedule relief granted June 2018 Not Started under Ref. 33.

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Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Phase 1 Unit 1 Training:

Schedule relief granted Simulator Upgrade Completion Dec 2017 Started under Ref. 33.

Schedule relief granted Training Complete April 2018 Not Started under Ref. 33.

Phase 1 Unit 1 Completion Schedule relief granted Phase 1 Unit 1 HCVS Implementation June 2018 Not Started under Ref. 33.

UNIT 2 Phase 1 Unit 2 Modifications:

Complete Conceptual Design Jun 2014 Complete Complete Detailed Design and Issue Jul 2017 Complete Modification Package Begin Online Portion of the Installation Nov 2016 Complete Complete Online Installation Mar 2018 Started Begin Outage Portion of the Installation Mar 2018 Not Started Complete Outage Installation Apr 2018 Not Started Schedule relief granted Installation Operational Acceptance June 2018 Not Started under Ref. 33.

Phase 1 Unit 2 Procedure Changes i Operations Procedure Changes Apr 2018 Complete Developed Site Specific Maintenance Procedure Apr 2018 Complete Developed Procedure Final Validation and Implementation Schedule relief granted June 2018 Not Started I under Ref. 33.

Phase 1 Unit 2 Training:

Simulator Upgrade Completion Dec 2017 N/A Unit 1 only.

Training Complete j Apr 2018 Not Started Page 4 of 21

Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Phase 1 Unit 2 Completion Schedule relief granted Phase 1 Unit 2 HCVS Implementation June 2018 Not Started under Ref. 33.

Phase 2 Specific Milestones UNIT 1 Phase 2 Unit 1 Modifications:

Begin Conceptual Design Apr 2016 Complete Common design with Complete Conceptual Design Feb 2017 Complete Unit 2.

i Common design with f Begin Detailed Design Apr 2017 Complete R Unit 2.

Common design with Complete Detailed Design and Issue Unit 2.

Jul 2017 Complete Modification Package Common install with Begin Online Portion of the Installation Sep 2017 Complete Unit 2.

Common install with Complete Online Installation Mar 2018 Started Unit 2.

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

Page 5 of 21

Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {include date Date changes in this column}

Training Complete Apr 2019 Not Started Phase 2 Unit 1 Completion Phase 2 Unit 1 HCVS Implementation Apr 2019 Not Started Submit Phases 1 and 2 Unit 1 Jun 2019 Not Started Completion Report (60-day letter)

UNIT 2 Phase 2 Unit 2 Modifications:

Begin Conceptual Design Apr 2016 Complete Common design with Complete Conceptual Design Feb 2017 Complete Unit 1.

Common design with Begin Detailed Design Apr 2017 Complete Unit 1.

Common design with Complete Detailed Design and Issue Jul 2017 Complete Unit 1. Formerly Mar Modification Package 2017, Common install with Begin Online Portion of the Installation Sep 2017 Complete Unit 1.

Common install with Complete Online Installation Mar 2018 Started Unit 1.

Begin Outage Portion of the Installation N/A N/A No outage install Complete Outage Installation N/A N/A No outage; install Schedule relief granted Installation Operational Acceptance June 2018 Not Started under Ref. 33.

Phase 2 Unit 2 Procedure Changes Active Operations Procedure Changes Apr 2018 Started Developed Site Specific Maintenance Procedure Apr 2018 Not Started Developed Procedure Changes Active Apr 2018 Not Started Page 6 of 21

Phase 1 and Phase 2 HCVS Milestone Table Comments Target Milestone Completion Activity Status {Include date Date changes in this column}

Procedure Final Validation and t Schedule relief granted June 2018 Not Started Implementation under Ref. 33.

Phase 2 Unit 2 Training:

Training Complete Apr 2018 Started Phase 2 Unit 2 Completion Schedule relief granted Phase 2 Unit 2 HCVS Implementation June 2018 Not Started under Ref. 33.

Submit Phases 1 and 2 Unit 2 Aug 2018 Not Started Completion Report (60-day letter) 4 Changes to Compliance Method Phase 1 Changes None Phase 2 Changes No changes needed since Fifth Six-Month Update (Ref. 31).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Quad Cities has received schedule relaxation from the NRC via letter dated March 21, 2017 (Ref. 33).

No additional need for relief/relaxation relative to Order EA-13-109 (Ref 2), other than as described above, has been identified at this time.

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6 Open Items from Comb ) ned Phase 1 and 2 Overall Mtegrated P an 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.

Combined Phase 1 and 2 01 Open Items Status Phase 1 Open Items OI-1 Determine how Motive Power and/or HCVS Complete Per QDC detailed design, HCVS primary Battery Power will be disabled during normal control panel will be provided with a key lock switch operation. 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 ELAP with minimal operator action. Detailed in December 2015 OIP (Ref. 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 Reference 16 has been provided in e-portal.

Severe Accident (SA).

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 /> (Ref. 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 %. Reference 12 has been provided in e-portal.

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

gases.

0I-6 Develop a procedure for HCVS 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 HCVS Operation. Closed to ISE Open Item No. 14.

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Combined Phase 1 and 2 OIP Open Items Status Confirm 125 Volt DC Station Battery Life. Complete per QDC calculation - QDC-8300-E-2100 (Ref. 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.

Reference 13 has been provided in e-portal.

Phase 2 Open Items 0I-9 Supply Part 3 Drywell Boundary Condition. Complete The Phase 2 Alternate option (SA WA/SAWM) was added to the December 2015 OIP (Ref. 7).

0I-10 Determine deployment path for Discharge Complete Booster pump will be staged at the some Bay booster pump with respect to HCVS dose. location as the FLEX/SAWA pump, which has been evaluated for dose effects under Reference 6 as i acceptable.

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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). (Ref. 13).

that Order EA-12-49 actions to restore power Calculation QDC-8300-E-2100 confirms that Order EA-are sufficient to ensure continuous operation 12-49 actions to restore power are sufficient to ensure of non-dedicated containment

continuous operation of non-dedicated containment instrumentation.

instrumentation.

Reference 13 has been provided in e-portal.

ISE-2 Make available for NRC staff audit the final Started - HCVS Battery design has been completed.

s sizing evaluation for HCVS batteries/battery (Refs. 14 and 17) charger including incorporation into FLEX DG Calculation QDC-1600-E-2200 evaluates the sizing of loading calculation.

the HCVS battery. (Ref. 28)

References have been provided in e-portal.

Incorporation into FLEX DG loading calculations is in progress.

ISE-3 Make available for NRC staff audit Started- Unit 1 nitrogen system installed. Calculation documentation of the HCVS nitrogen QDC-1600-M-2212 for sizing approved and applicable pneumatic system design including sizing and to both Units. Unit 2 system installation in progress.

location. (Refs. 14 and 17)

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)(Ref. 21).

personnel can safely access and operate phase 1 Radiological evaluation has been completed.

controls and support equipment.

(Ref. 16).

Phase 2 Radiological evaluation has been completed (Ref. 6).

Evaluations of temperature and radiological conditions ensure that operating personnel can safely access and operate controls and support equipment.

References have been provided in e-portal.

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

documentation that confirms the final design diameter of the HCVS piping.

ISE-6 Make available for NRC staff audit analyses Complete. Calculation QDC-1600-M-2188 for Unit 1 demonstrating that HCVS has the capacity to line sizing approved (Ref. 19). Calculation QDC-1600-vent the steam/energy equivalent of one M-2247 .for Unit 2 line sizing approved. (Ref. 30) percent of licensed/rated thermal power In addition, MAAP analyses (Ref. 12) are credited to (unless a lower value is justified), and that verify that (1) venting can be delayed for at least the suppression pool and the HCVS together three hours and (2) anticipatory venting sufficiently are able to absorb and reject decay heat, limits the suppression pool heat up to maintain RCIC such that following a reactor shutdown from

functional.

full power containment pressure is restored and then maintained below the primary MAAP also confirms the HCVS is of sufficient size to containment design pressure and primary prevent the Suppression Pool from reaching PCPL.

containment pressure limit.

References have been provided in e-portal.

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

criteria for the HCVS stack. 20)

Reference has been provided in e-portal.

The information provided in December 2015 OIP (Ref.

7) demonstrates that the external piping meets the tornado missile protection criteria of HCVS-WP-04.

ISE-8 Make available for NRC staff audit the Complete Component location design has been descriptions of local conditions (temperature, determined. The ROS, gas bottles, dedicated battery, radiation and humidity) anticipated during and most equipment are in the Turbine Building. The FLAP and severe accident for the components HCVS primary control panel is in the MCR (Refs. 14, 15 (valves, instrumentation, sensors, and 17).

transmitters, indicators, electronics, control Reactor Building temperatures are as noted in devices, etc.) required for HCVS venting calculation 2014-02948 (Ref. 21).

including confirmation that the components are capable of performing their functions Turbine Building temperatures at the ROS are as during ELAP and severe accident conditions. noted in evaluation EC 402709 (Ref. 22).

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

References have been provided in e-portal.

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j ISE-9 Make available for NRC staff audit Complete QCOP 0050-09 FLEX Response documentation that demonstrates adequate Instrumentation and Communication Equipment communication between the remote HCVS provides a detailed description of Communications operation locations and HCVS decision equipment dedicated to FLEX response utilized for makers during FLAP and severe accident Severe Accident Response. This equipment includes conditions. radios programed for talk around mode with additional batteries and Sound powered phones which can be used for communications between the Main Control Room and local control stations. QCOS 0050-04 FLEX Sound Powered Phone Surveillance is being revised to test two additional connection points that can be utilized for Severe Accident response and control of SA WA/SAWM flow and local operation of the HCVS valves.

References have been provided in e-portal.

ISE-10 Provide a description of the final design of Complete As stated in the December 2015 01P, the HCVS to address hydrogen detonation Quad Cities will utilize Argon purge system to address and deflagration. combustible gases in the HCVS piping. A summary of I the design features is included in the December 2015 01P (Ref. 7).

~ ISE-11 Provide a description of the strategies . for Complete - As described in the December 2015 OIP hydrogen control that minimizes the (Ref. 7), the HCVS torus vent path in each Quad Cities potential for hydrogen gas migration and unit, starting at and including the downstream PCIV, ingress into the Reactor Building or other will be a dedicated HCVS flow path. There are no buildings. 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 FLAP. There is no 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 (Refs. 14, 15 and 17).

References have been provided in e- portal ISE-12 ! Make available for NRC staff audit Started The Quad Cities seismic evaluation is based documentation of a determination of seismic on the Quad Cities SSE, which is sufficient by Exelon qualification evaluation of the HCVS Position Paper EXC-WP-15. A list of component components.

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evaluations is uploaded to ePortal. Due to the size of the evaluation, they are available upon request.

ISE-13 Make available for NRC staff audit Complete. Instrument design is complete with descriptions of all instrumentation and approval of modifications for construction. (Refs. 14, controls (existing and planned) necessary to 15 and 17).

implement this order including qualification References have been provided in e-portal.

methods.

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

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Phase 2 Interim Staff Evaluation Open Items Status (Reference 33)

E-1 Licensee to demonstrate that the hydraulic Complete. FLEX calculation QDC-0000-M-2097 (Ref.

analysis for the FLEX pump is capable to support 11) is revised with hydraulic parameters for addition the required 400 gpm SAWA flow rate. of SAWA scenarios.

References have been provided in e-portal.

ISE-2 Licensee to evaluate the SAWA equipment and Complete.

controls, as well as the ingress and egress paths for the expected severe accident conditions Equipment and Controls (temperature, humidity, radiation) for the Plant instrumentation for SAWM that is qualified to sustained operating period. k RG 1.97 or equivalent is considered qualified for the sustained operating period without further evaluation. The following plant instruments are qualified to RG 1.97:

DW Pressure Pi 1(2)-1640-11A/B Suppression Pool Level LI 1(2)-1640-10A/B 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:

SAWA/_SAWM flow instrument.

SAWA/SAWM pump SAWA/SAWM generator (the FLEX generator for the associated Unit)

Ingress and Egress 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 and found the dose rates at deployment locations including Page 14 of 21

ingress/egress paths are acceptable. (QDC-0000-M-2223, Ref. 6)

References have been provided in e-portal.

ISE-3 Licensee to demonstrate how instrumentation Complete.

and equipment being used for SAWA and supporting equipment is capable to perform for Equipment and Controls the sustained operating period under the Plant instrumentation for SAWA that is qualified to expected temperature and radiological RG 1.97 or equivalent is considered qualified for the conditions. sustained operating period without further evaluation. The following plant instruments are qualified to RG 1.97:

DW Pressure PI 1(2)-1640-11A/B Suppression Pool Level LI 1(2)-1640-10A/B 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:

SAWA/SAWM flow instrument.

SAWA/SAWM pump (maybe the FLEX pump)

SAWA/SAWM generator (may be the FLEX generator)

Temperature The location of the distribution manifold is one floor below the ROS, and has similar or better temperature conditions as at the ROS. The location of the SAWA pump is similar to the FLEX pump, i.e. outside, but on the West side of the Site vs. east side.

The location of SAWA equipment and controls are the same or similar as FLEX, and are bounded by the FLEX evaluations for temperature.

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Radiation For equipment 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 SA WA is being utilized, a quantitative evaluation of expected dose rates has been performed per HCVS-WP-02 and found the dose rates at deployment locations are acceptable. (QDC-0000-M-2223, Ref. 6)

References have been provided in e-portal.

ISE-4 Licensee to demonstrate that containment Complete. The Wetwell vent has been designed and failure as a result of overpressure can be installed to meet NEI 13 -02 Rev 1 guidance, which will prevented without a drywell vent during severe ensure that it is adequately sized to prevent accident conditions. containment overpressure under severe accident conditions.

The SAWM strategy will ensure that the Wetwell vent remains functional for the period of sustained operation. Quad Cities will follow the guidance (flow rate and timing) for SHWA/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 52 PSIG. Therefore, containment over pressurization is prevented without the need for a drywell vent.

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ISE-5 Licensee shall demonstrate how the plant is Complete.

bounded by the reference plant analysis that Reference Plant _ Quad Cities _

shows the SAWM strategy is successful in Torus freeboard volume Torus freeboard volume is making it unlikely that a drywell vent is needed. is 525,0001 gallons 619,1902 gallons SAWA flow is 500 GPM at SAWA flow is 400 GPM at 8 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed by 100 hours followed by 80 GPM GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> 168 hours The above parameters for Quad Cities compared to the reference plant that determine success of the SAWM strategy demonstrate that the reference plant values are bounding. SAWA flow rates are based on RCIC

,design flow as allowed by NEI 13-02, Rev. 1, Section 4.1.1.2.2. Therefore, the SAWM strategy implemented at Quad Cities makes it unlikely that a DW vent is needed to prevent containment overpressure related failure.

ISE-6 Licensee to demonstrate that there is adequate Complete. Quad Cities utilizes handheld radios to communication between the MCR and the communicate between the MCR, the operator at the SAWA/SAWM control location during severe FLEX pump, and the operator at the SAWA flow accident conditions. control location. This communication method is the some as 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.

' 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.

2 Quad Cities' freeboard volume is based on Torus water level from 14' to 22.5' in a torus with 30' minor diameter and 109' major diameter.

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ISE-7 Licensee to demonstrate the SAWM flow Complete. For locations outside the Reactor Building instrumentation qualification for the expected 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 environmental conditions. 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. The selected instrument is designed for the expected flow rate, temperature, and pressure for SAWA over the period of sustained operation.

SAWA Flow Expected SAWA Instrument Parameter Range

_Qualification 2.21 to 736 GPM 80 to 400 GPM

-4 to 140 °F 32 to 120 "F 0 to 285 PSI 0 to 120 PSI 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation(s) identified at this time.

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The following references support the updates to the combined Phases 1 and 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 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.

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 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. ML1330413836).

5. NRC Endorsement of industry "Hardened Containment Venting System (RCVS)

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

6. Calculation QDC-0000-M-2223, Revision 0, HCVS Phase II 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 (Accession No. ML15104A118).

9. 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-015, Rev. 0, MAAP Analysis to Support HCVS Design.

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13.Exelon Calculation QDC-8300-E-2100, 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, Rev. 001.

15.EC 392257 - Unit 1 Hardened Containment Vent System (Outage Portion) as Required by NRC Order EA-13-109, Rev. 000.

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-13-109 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.

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.

23. Quad Cities Units 1 and 2, 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 109), dated June 30, 2016 (RS-16-110).

24. Exelon Generation Company, LLC Request for Extension to Comply with NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" and NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated November 16, 2016 (RS-16-210).

25. Exelon Generation Company, LLC Request for Extension to Comply with NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" and NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated January 12, 2017 (RS-17-006).

26. Exelon Generation Company, LLC Letter to USNRC, Certification of Permanent Cessation of Power Operations at Quad Cities Nuclear Power Station, Units 1 and 2, dated June 20, 2016.

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27. Exelon Generation Company, LLC Letter to USNRC, Withdrawal of Certification of Permanent Cessation of Power Operations for Quad Cities Nuclear Power Station, Units 1 and 2 and Previously Submitted Licensing Actions in Support of Decommissioning, dated December 14, 2016 (RS-16-253).

28. Exelon Calculation QDC-1600-E-2200, 125 VDC Battery Sizing Calculation for Hardened Containment Vent System for 24-Hour Duty Cycle, Rev. 0.

29. Exelon Calculation QDC-1600-M-2212, RCVS Nitrogen Bottle Sizing and Pressure Regulator Set Point Determination, Rev. 0.

30. Exelon Calculation QDC-1600-M-2247, Unit 2 HCVS Vent Line Sizing Calculation, Rev. 0.

31. Quad Cities Units 1 and 2, 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 109), dated January 26, 2016 (RS-17-008).

32. Quad Cities Nuclear Power 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) (CAC Nos. MF4460 and MF 4461),

dated April 28, 2017 (Accession No. ML17109A077).

33. Quad Cities Nuclear Power Station, Units 1 and 2 Relaxation of Schedule Requirements for Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" and Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (CAC Nos. MF1048, MF1049, M174460, and MF 4461), dated March 21, 2017 (Accession No. ML17025A248).

34. Quad Cities Units 1 and 2, 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 109), dated June 27, 2017 (RS-17-069).

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