RS-18-060, Eighth 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 ...

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Eighth 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 ...
ML18180A032
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 06/29/2018
From: David Helker
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-18-060
Download: ML18180A032 (14)
v • d • e


Text

Exelon Generation Order No. EA-13-109 RS-18-060 June 29, 2018 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277

Subject:

Eighth 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. NRG 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-14-062)
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 29, 2018 Page2

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) 1O. 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. 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 30, 2017 (RS-17-068)
13. Exelon Generation Company, LLC 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), dated December 15, 2017 (RS-17-155)
14. NRC 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

15. NRC 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

16. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Report for the Audit of Licensee Responses to Interim Staff Evaluation Open Items Related to NRC Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated November 30, 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.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 29, 2018 Page 3 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 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, 11, 12, and 13 provided the fourth, fifth, sixth, and seventh six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Peach Bottom Atomic Power Station.

The purpose of this letter is to provide the eighth 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, Unit 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 NRG Interim Staff Evaluation open items contained in References 14, 15, and 16.

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 29th day of June 2018.

Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Peach Bottom Atomic Power Station, Unit 2 Eighth 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 29, 2018 Page 4 cc: Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region I NRG Senior Resident Inspector - Peach Bottom Atomic Power Station NRG Project Manager, NRA - Peach Bottom Atomic Power Station Mr. Rajender Auluck, NRR/JLD!TSD/JCBB, NRG Mr. Brian E. Lee, NRR/JLD/JCBB, NRG Mr. Peter Bamford, NRR/JLD/JOMB, NRG 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, Unit 2 Eighth 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 (9 pages)

Enclosure Peach Bottom Atomic Power Station, Unit 2 Eighth 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 Eighth 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 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 Seventh 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, 2018:

  • Eighth Six-Month Update (complete with this submittal)
  • Started Phase 2 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, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 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 Update 6 Jun.2017 Complete Update 7 Dec.2017 Complete Complete Update 8 Jun.2018 with this submittal 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.2015 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 2of9

Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 Target Comments Activity Milestone Completion I Status II Date Phases 1 and 2 HCVS Miiestone 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 2 Unit 2 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Begin Detailed Design Jun. 2017 Complete Complete Detailed Design and Issue Sep.2017 Complete Modification Package Begin Online Portion of the Installation Feb.2018 Complete Complete Online Installation Oct. 2018 Started Status changed to Begin Outage Portion of the Installation N/A N/A N/A due to no outage work Status changed to Complete Outage Installation N/A N/A N/A due to no outage work Phase 2 Procedure Changes Active Operations Procedure Changes Nov.2018 Started Developed Site Specific Maintenance Procedure Nov.2018 Started Developed Procedure Changes Active Nov. 2018 Started Phase 2 Training Training Complete Nov.2018 Started Page 3of9

Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 Target Comments Activity Milestone 1

  • Completion Status Date Phases 1 and 2 HCVS Milestone Table Phase 2 Completion Unit 2 Phase 2 HCVS Implementation Nov. 2018 Started Submit Full Compliance Report for Phase 1 Jan.2019 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 the operation, testing and inspection requirements for the HCVS and Severe Accident Water Addition (SAWA) would follow the guidance provided in Section 6.2.4 of NEI 13-02, Rev. 1 (Reference 3). This guidance indicates that the HCVS and installed SAWA valves and the interfacing system boundary valves not used to maintain containment integrity during Modes 1, 2 and 3 be cycled once per every operating cycle and, after two consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle. This test is to verify functionality of the valves.

Per Exelon Performance Centered Maintenance (PCM) template, manual valves need to be cycled every 6 years if installed in severe environmental conditions or every 8 years if installed in mild environmental conditions for design basis Preventive Maintenance (PM) requirements. Per Exelon's engineering judgment, it is deemed that cycling the manual valves (and motor operated valves, check valves within the HCVS pneumatic supply line, and solenoid/air operated valves) within the frequency of the design basis requirements is sufficient for Beyond Design Basis External Events (BDBEE) systems/programs such as HCVS and SAWA. No new failure modes or degradation is expected for BDBEE systems/programs that is different from design basis. Following this approach, valves outside of the HCVS and SAWA modification scope, that are required to change position to establish HCVS venting or SAWA flow, do not need to be cycled prior to order compliance as long as they are cycled in accordance with the design basis PM requirements. Valves that currently have procedural/programmatic requirements to be cycled on a higher frequency will continue to meet those requirements.

All installed HCVS valves and existing valves that require manipulation for HCVS venting were cycled during implementation. All installed SAWA valves were cycled during implementation and all existing valves in the SAWA flow path that require manipulation have been previously stroked within the PCM template frequency from the date of SAWA implementation and will continue to meet the PCM template frequency. The ability to change state of all existing valves in the SAWA flow path that were not cycled during implementation was not impacted since these valves were outside of the modification boundary.

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

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Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 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. Reference 1O provided the results of the audit of ISE Open Item closure information provided in References 8 and 9. All Phase 1 and 2 ISE Open Items are statused as closed in Reference 10.

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

{ROS) 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.

01-3. Identify site specific controlling document for Deleted. Closed to ISE Open Item number 02.

HCVS out of service and compensatory measures 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 Closed per References 8 and 10.

line impact on ERO response actions.

Phase 1 Interim Staff Evaluation Open Item Status ISE-1. Make available for NRC staff audit guidelines Closed per References 8 and 10.

and procedures for HCVS operation. {Section 3.2.3.1)

ISE-2. Make available for the NRC staff audit the site Closed per References 8 and 10.

specific controlling document for HCVS out of service and compensatory measures. (Section 3.4.1)

ISE-3. Make available for NRC staff audit a technical Closed per References 8 and 1O.

justification for use of jumpers in the HCVS strategy.

(Section 3.1.3)

ISE-4. Make available for NRC staff audit analyses Closed per References 8 and 10.

demonstrating that the HCVS has the, capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power {unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit. (Sections 3.2.2.1 and 3.2.2.2)

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Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 Phase 1 Interim Staff Evaluation Open Item Status ISE-5. Make available for NRC staff audit descriptions Closed per References 8 and 10.

or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee justification for the HVAC release point being below and 150 feet from the reactor building ventilation release point. (Section 3.2.2.3)

ISE-6. Make available for NRC staff audit details to Closed per References 8 and 10.

justify the deviation from tornado protection standards provided in NEI 13-02 or make available a description of how the HCVS will comply with the tornado protection standards provided in NEl-13-02. (Section 3.2.2.3)

ISE-7. Make available for NRC staff audit Closed per References 8 and 10.

documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident condition. (Section 3.2.2.5)

ISE-8. Provide a description of the final design of the Closed per References 8 and 10.

HCVS to address hydrogen detonation and deflagration.

(Section 3.2.2.6)

ISE-9. Make available for NRC staff audit an Closed per References 8 and 10.

evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. (Sections 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)

ISE-10. Make available for NRC staff audit descriptions Closed per References 8 and 10.

of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods. (Sections 3.2.2.9 and 3.2.2.10)

ISE-11. Make available for NRC staff audit the final Closed per References 8 and 10.

sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation. (Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 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 Closed per References 8 and 10.

descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions. (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 Closed per References 8 and 10.

documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

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Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 Phase 1 Interim Staff Evaluation Open Item Status ISE-14. Provide a description of the strategies for Closed per References 8 and 10.

hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings. (Section 3.2.2.6 and 3.2.2. 7)

ISE-15. Make available for NRC audit documentation Closed per References 8 and 10.

confirming that HCVS will remain isolated from standby gas treatment system during ELAP and severe accident conditions. (Section 3.2.2. 7)

Phase 2 Interim Staff Evaluation Open Status Item ISE-1. Licensee to demonstrate the SAWA equipment Closed per References 9 and 10.

and controls, as well as ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) remain operational throughout the sustained operating period. (Section 3.3.2.3)

ISE-2. Licensee to demonstrate that instrumentation Closed per References 9 and 10.

and equipment being used for SAWA and supporting equipment is capable to perform for the sustained operating period under the expected temperature and radioloqical conditions. (Section 3.3.2.3)

ISE-3 Licensee to demonstrate that containment Closed per References 9 and 10.

failure as a result of overpressure can be prevented without a drywall vent during severe accident conditions. (Section 3.3.3)

ISE-4 Licensee shall demonstrate whether a site Closed per References 9and10.

specific MAAP evaluation will be used to determine an initial SAWA flow rate. If the evaluations performed in BWROG TP-15-011 is considered, provide a description of how the plant is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed. (Section 3.3.3.1)

ISE-5 Licensee to demonstrate that there is Closed per References 9 and 10.

adequate communication between the MCA and the Intake Structure operator at the FLEX manual valve during severe accident conditions. (Section 3.3.3.4)

ISE-6 Licensee to demonstrate the SAWM flow Closed per References 9 and 10.

instrumentation qualification for the expected environmental conditions. (Section 3.3.3.4) 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation(s) identified at this time.

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Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018 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. ML13304B836).
5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O" (Accession No. ML14128A219).
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 Atomic Power Station, Units 2 and 3, Sixth 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 June 30, 2017 (RS-17-068).

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Peach Bottom Atomic Power Station, Unit 2 Eighth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 29, 2018

10. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRC Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated November 30, 2017.

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