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#REDIRECT [[RS-15-299, 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..]]
| number = ML15352A027
| issue date = 12/16/2015
| title = Dresden, Units 2 and 3 - 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 Con
| author name = Kaegi G T
| author affiliation = Exelon Generation Co, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000237, 05000249
| license number = DPR-019, DPR-025
| contact person =
| case reference number = EA-13-109, RS-15-299
| document type = Letter
| page count = 73
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:~Exelton GenerationOrder No. EA-13-109RS-1 5-299December 16, 2015U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Dresden Nuclear Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-19 and DPR-25NRC Docket Nos. 50-237 and 50-249
 
==Subject:==
Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013Commission Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-1 3-1 09)
 
==References:==
: 1. NRC Order Number EA-1 3-109, "Issuance of Order to Modify Licenses with Regard toReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions," dated June 6, 20132. NRC Interim Staff Guidance JLD-ISG-201 5-01, "Compliance with Phase 2 OrderEA-13-1 09, order Modifying Licenses with Regard to Reliable Hardened ContainmentVents Capable of Operation under Severe Accident Conditions", Revision 0, datedApril 20153. NEI 13-02, "Industry Guidance for Compliance With Order EA-1 3-1 09, BWR Mark I & IIReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions", Revision 1, dated April 20154. Exelon Generation Company, LLC's Answer to June 6, 2013, Commission OrderModifying Licenses with Regard to Reliable Hardened Containment Vents Capable ofOperation Under Severe Accident Conditions (Order Number EA-13-1 09), datedJune 26, 20135. Exelon Generation Company, LLC Phase 1 Overall Integrated Plan in Response to June6, 2013 Commission Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-13-109), dated June 30, 2014 (RS-14-058)6. Exelon Generation Company, LLC First Six-Month Status Report Phase 1 OverallIntegrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses withRegard to Reliable Hardened Containment Vents Capable of Operation Under SevereAccident Conditions (Order Number EA-13-109), dated December 17, 2014 (RS-14-302)7. Exelon Generation Company, LLC Second Six-Month Status Report Phase 1 OverallIntegrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses withRegard to Reliable Hardened Containment Vents Capable of Operation Under SevereAccident Conditions (Order Number EA-13-109), dated June 30, 2015 (RS-15-148)
U.S. Nuclear Regulatory CommissionIntegrated Plan Report to EA-13-109December 16, 2015Page 28. NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2and 3 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4462and MF4463), dated February 11, 2015On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order(Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediatelyeffective and directs EGC to require their BWRs with Mark I and Mark II containments to takecertain 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 withinacceptable limits following events that result in loss of active containment heat removal capabilitywhile maintaining the capability to operate under severe accident (SA) conditions resulting froman Extended Loss of AC Power (ELAP). Specific requirements are outlined in Attachment 2 ofReference 1.Reference 1 requires submission of an Overall Integrated Plan (QIP) by June 30, 2014 forPhase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order. The interimstaff guidance (Reference 2) provides direction regarding the content of the OIP for Phase 1 andPhase 2. Reference 2 endorses industry guidance document NEI 13-02, Revision 1(Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 providedthe EGC initial response regarding reliable hardened containment vents capable of operationunder severe accident conditions. Reference 5 provided the Dresden Nuclear Power Station,Units 2 and 3, Phase 10OIP. References 6 and 7 provided the first and second six-month statusreports pursuant to Section IV, Condition D.3 of Reference 1 for Dresden Station.The purpose of this letter is to provide both the third six-month update for Phase 1 of the Orderpursuant to Section IV, Condition D.3, of Reference 1, and the OIP for Phase 2 of the Orderpursuant to Section IV, Condition D.2 of Reference 1, for Dresden Nuclear Power Station, Units 2and 3. The third six-month update for Phase 1 of the Order is incorporated into the HCVSPhase 1 and Phase 2 overall integrated plan document which provides a complete updatedPhase I OIP, a list of the Phase 10OIP open items, and addresses the NRC Interim StaffEvaluation open items for Phase 1 contained in Reference 8. Future six-month status reports will.provide the updates for both Phase 1 and Phase 20OIP implementation in a single status report.Reference 3, Section 7.0. contains the specific reporting requirements for the Phase 1 andPhase 20OIP. The information in the Enclosure provides the Dresden Nuclear Power Station,Units 2 and 3 HCVS Phase 1 and Phase 20OIP pursuant to Reference 2. The enclosed Phase 1and Phase 20OIP is based on conceptual design information. Final design details and associatedprocedure guidance, as well as any revisions to the information contained in the Enclosure, willbe provided in the six-month Phase 1 and Phase 20OIP updates required by Section IV, ConditionD.3, of Reference 1.This letter contains no new regulatory commitments. If you have any questions regarding thisreport, please contact David P. Helker at 610-765-5525.
U.S. Nuclear Regulatory CommissionIntegrated Plan Report to EA-13-109December 16, 2015Page 3I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th dayof December 2015.Respectfully submitted,Glen T. KaegiDirector -Licensing & Regulatory AffairsExelon Generation Company, LLC
 
==Enclosure:==
Dresden Nuclear Power Station, Units 2 and 3, Overall Integrated Plan for Phase 1 andPhase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable ofOperation Under Severe Accident Conditionscc: Director, Office of Nuclear Reactor RegulationNRC Regional Administrator -Region IllNRC Senior Resident Inspector -Dresden Nuclear Power StationNRC Project Manager, NRR -Dresden Nuclear Power StationMr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRCMr. John P. Boska, NRR/JLD/JOMB, NRCIllinois Emergency Management Agency -Division of Nuclear Safety  Dresden Nuclear Power Station, Units 2 and 3Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable HardenedContainment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions(69 pages)
Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsTable of Contents:IntroductionPart 1: General Integrated Plan Elements and AssumptionsPart 2: Boundary Conditions for Wet Well VentPart 3: Boundary Conditions for EA-13-109, Option B.2Part 3.1 Boundary Conditions for SAWAPart 3.1A Boundary Conditions for SAWAISAWMPart 3.1B Boundary Conditions for SAWAISADVPart 4: Programmatic Controls, Training, Drills and MaintenancePart 5: Implementation Schedule MilestonesAttachment 1: HCVS/SAWA Portable Eq~uipmentAttachment 2A: Seqiuence of Events Timeline -HCVSAttachment 2.1.A: Sequence of Events Timeline -SAWA / SAWMAttachment 2.1.B: Sequence of Events Timeline -SADVAttachment 2.1.C: SAWA / SAWM Plant-Specific DatumAttachment 2.1.D: SAWM SAMG Approved LanguageAttachment 3: Conceptual SketchesAttachment 4: Failure Evaluation TableAttachment 5: ReferencesAttachment 6: Changes/Updates to this Overall Integrated Implementation PlanAttachment 7: List of Overall Integrated Plan Open ItemsPage 1 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsIntroductionIn 1989, the NRC issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," (Reference 2)to all licensees of Boiling Water Reactors (BWRs) with Mark I containments to encourage licensees tovoluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from thesuppression pooi to some point outside the secondary containment envelope (usually outside the reactorbuilding). Some licensees also installed a hardened vent branch line from the dryweUl.On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff perStaff Requirements Memorandum (SRM) for SECY-12-0 157 (Reference 26) to require licensees withMark I and Mark II containments to "upgrade or replace the reliable hardened vents required by OrderEA-12-050 with a containment venting system designed and installed to remain functional during severeaccident conditions.' In response, the NRC issued Order EA-13-109, Issuance of Order to ModifyLicenses with Regard to Reliable Hardened Containment Vents Capable of Operation Undter SevereAccidents, June 6, 2013 (Reference 4). The Order (EA-13-109) requires that licensees of BWR facilitieswith Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent toremove decay heat from the containment, and maintain control of containment pressure within acceptablelimits following events that result in the loss of active containment heat removal capability whilemaintaining the capability to operate under severe accident (SA) conditions resulting from an ExtendedLoss of AC Power (ELAP).The Order requirements are applied in a phased approach where:* "Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable,severe accident capable hardened vents to assist in preventing core damage and, if necessary, toprovide venting capability during severe accident conditions." (Completed "no later than staltup fromthe second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comesfirst.")*"Phase 2 involves providing additional protections for severe accident conditions through instailationof a reliable, severe accident capable drywell vent system or the development of a reliablecontainment venting strategy that makes it unlikely that a licensee would need to vent from thecontainment drywell during severe accident conditions." (Completed "no later than startup from thefirst refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.")The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim StaffGuidance (ISG) (JLD-ISG-2013-02) issued in November 2013 (Reference 6) and JLD-ISG-2015-01issued in April 2015 (Reference 31). The IS Gs endorse the compliance approach presented in NEI 13-02Revisions 0 and 1, Compliance with Order EA-13-109, Severe Accident Reliable Hardened ContainmentVents (Reference 9), with clarifications. Except in those cases in which a licensee proposes an acceptablealternative method for complying with Order EA-13-109, the NRC staff will use the methods described inthese ISGs to evaluate licensee compliance as presented in submittals required in Order EA-13-109.The Order also requires submittal of an overall integrated plan which will provide a description of howthe requirements of the Order will be achieved. This document provides the Overall Integrated Plan (OIP)for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRCJLD-ISG-2013-02 and JLD-ISG-2015-01. Six month progress reports will be provided consistent with therequirements of Order EA- 13-109.Page 2 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsThe submittals required are:* OIP for Phase 1 of EA-13.-109 was required to be submitted by Licensees to the NRC by June 30,2014. The NRC requires periodic (6-month) updates for the HCVS actions being taken. The firstupdate for Phase 1 was due December 2014, with the second due June 2015.* OIP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31,2015. It is expected the December 2015 six month update for Phase 1 will be combined with thePhase 20OP submittal by means of a combined Phase 1 and 20IO.*Thereafter, the 6-month updates will be for both the Phase 1 and Phase 2 actions until complete,consistent with the requirements of Order EA-13-109.Note: Per the Generic OIP, at the Licensee's option, the December 2015 six month update for Phase 1may be independent of the Phase 20OIP submittal, but will require separate six month updates forPhases 1 and 2 until each phase is in compliance. Exelon has not selected this option.The Dresden venting actions for the EA-13-109, Phase 1 severe accident capable venting scenario can besummarized by the following:*The Hardened Containment Vent System (HCVS) will be initiated via manual action from eitherthe Main Control Room (MCR) or from a Remote Operating Station (ROS) at the appropriatetime based on procedural guidance in response to plant conditions from observed or derivedsymptoms. The ROS capabilities are limited to the Order EA-13-109 Requirement 1.2.5.Specifically, in case the HCVS flow path valves or the Argon purge flow cannot be opened fromthe MCR, the ROS provides a back-up means of opening the valve(s) that does not requireelectrical power or control circuitry.*The vent will utilize Containment Parameters of Pressure and Suppression Pool Level from theMCR instrumentation to monitor effectiveness of the venting actions.*The vent operation will be monitored by HCVS valve position, temperature and effluent radiationlevels.*The HCVS motive force will be monitored and have the capacity to operate for 24 hours withinstalled equipment (EA-13-109, 1.2.6). Replenishment of the motive force will be by use ofportable equipment prior to the installed motive force being exhausted.*Venting actions will be capable of being maintained for a sustained period of up to 7 days (NEI13-02, 4.2.2.1.1).The Phase 2 actions can be summarized as follows:*Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the ReactorPressure Vessel (RPV). Although SAWA to the Drywell (DW) is an option, Exelon is planningSAWA injection to the RPV.*Utilization of Severe Accident Water Management (SAWM) to control injection and SuppressionPool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for theremoval of decay heat from containment.Page 3 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents*Ensure that the decay heat can be removed from the containment for seven (7) days using theHCVS or describe the alternate method(s) to remove decay heat from the containment from thetime the HCVS is no longer functional until alternate means of decay heat removal areestablished that make it unlikely the drywell vent will be required for DW pressure control.*The SAWA and SAWM actions will be manually activated and controlled from areas that areaccessible during severe accident conditions.*Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate andthe HCVS parameters listed above.Note: Although EA-13-109 Phase 2 allows selecting SAWA and a Severe Accident Capable DrywellVent (SADV) strategy, Exelon has selected SAWA and SAWM.Page 4 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and AssumptionsExtent to which the guidance, JLD-ISG-2013-02, JLD-ISG-2015-01, and NET 13-02 (Revision 1), are beingfollowed. Identify any deviations.Include a description of any alternatives to the guidance. A technical justifi cation and basis for the alternative needs tobe provided. This will likely require a pre-meeting with the NRC to review the alternative.Ref: JLD-ISG-2013-02, JLD-ISG-2015-01Compliance will be attained for Dresden with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-ISG-2015-01, and NEJ 13-02 for each phase as follows:* The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment andoperating guidance:* Severe Accident Wetwell Vent (SAWV) -Permanently installed vent from the Suppression Pool to the top ofthe Reactor Building.* Severe Accident Water Addition (SAWA) -A combination of permanently installed and portable equipmentto provide a means to add water to the RPV following a severe accident and monitor system and plantconditions.* Severe Accident Water Management (SAWM) strategies and guidance for controlling the water addition tothe RPV for the sustained operating period. (Reference attachment 2.1 .D)* Unit 3 Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June30, 2018, whichever comes first. Currently scheduled for 4Q20 16.* Unit 2 Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June30, 2018, whichever comes first. Currently scheduled for 4Q2017.* Unit 2 Phase 2 (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017,or June 30, 2019, whichever comes first. Currently scheduled for 4Q2017.* Unit 3 Phase 2: (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017,or June 30, 2019, whichever comes first. Currently scheduled for 4Q20 18.If deviations are identified at a later date, then the deviations will be communicated in a future 6-month updatefollowing identification.State Applicable Extreme External Hazard from NET 12-06, Section 4.0-9.0List resultant determination of screened in hazards from the EA-12-049 Compliance.Ref: NET 13-02 Section 5.2.3 and D.1.2The following extreme external hazards screen in for Dresden:* Seismic, external flooding, extreme cold, high wind, and extreme high temperature.The following extreme external hazards screen out for Dresden:* NAKey Site assumptions to implement NEI 13-02 Strategies. ....Page 5 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and AssumptionsProvide key assumptions associated with implementation of HCVS Phase 1 Strategies.Ref: NEI 13-02, Revision 1, Section 2 NEI 12-06 Revision 0Mark Ji/I Generic HCVS Related Assumptions:Applicable EA- 12-049 (Reference 3) assumptions:049-1. Assumed initial plant conditions are as identified in NEI 12-06, &sect;3.2.1.2, items 1 and 2 (Reference 8).049-2. Assumed initial conditions are as identified in NET 12-06, &sect;3.2.1.3, items 1, 2, 4, 5, 6 and 8 (Reference 8).049-3. Assumed reactor transient boundary conditions are as identified in NEI 12-06, &sect;3.2.1.4, items 1, 2, 3 and 4.049-4. No additional events or failures are assumed to occur immediately prior to or during the event, includingsecurity events, except for the failure of Reactor Core Isolation Cooling (RCIC) or High Pressure CoolantInjection (HPCI) (Reference NEI 12-06, &sect;3.2.1.3, item 9 [8]).049-5. At time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP isoccurring at any or all of the units.049-6. At time=l hour (time sensitive at a time greater than 1 hour) an ELAP is declared and actions begin asdefined in EA-12-049 compliance.049-7. DC power and distribution can be credited for the duration determined per the EA-12-049 (FLEX)methodology for station battery usage, (greater than approximately 6 hours with a calculatedlimiting value of approximately 6 hrs., EC Eval. 391973) (NEI 12-06, section 3.2.1.3 item 8).049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours.049-9. All activities associated with EA-12-049 (FLEX) that are not specific to implementation of the HCVS,including such items as debris removal, communication, notifications, Spent Fuel Pool (SFP) level andmakeup, security response, opening doors for cooling, and initiating conditions for the events, can becredited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity onSAWA)(HCVS-FAQ-1 1)Applicable EA-13-109 (Reference 4) generic assumptions:109-1. Site response activities associated with EA-13-109 actions are considered to have no access limitationsassociated with radiological conditions while Reactor Pressure Vessel (RPV) level is above 2/3 core height(core damage is not expected). This is further addressed in HCVS-FAQ-12.109-2. Portable equipment can supplement the installed equipment after 24 hours provided the portable equipmentcredited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supplyequipment that is credited to recharge air lines for HCVS components after 24 hours. The FLEX portableair supply used must be demonstrated to meet the "SA Capable" criteria that are defined in NEI 13-02Section 4.2.4.2 and Appendix D Section D.l.3 (Reference 9). This assumption does not apply to Phase 2SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hoursfrom the time of the loss of RPV injection. (Reference HCVS-FAQ-12).109-3. SFP Level is maintained with either on-site or off-site resources such that the SFP does not contribute to theanalyzed source term (Reference HCVS-FAQ-07 [18]).109-4. Existing containment components design and testing values are governed by existing plant containmentPage 6 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and Assumptionscriteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (Reference HCVS-FAQ-05 [16] and NET 13-02, &sect;6.2.2 [9]).109-5. Classical design basis evaluations and assumptions are not required when assessing the operation of theHCVS. The reason that this is not required is that the order postulates an unsuccessful mitigation of anevent such that an ELAP progresses to a severe accident with ex-vessel core debris that classical designbasis evaluations are intended to prevent (Reference NEI 13-02, &sect;2.3.1 [9]).109-6. HCVS manual actions require minimal operator steps and can be performed in the postulated thermalradiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation,valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality (ReferenceHCVS-FAQ-0l[12]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWAequipment needs to be connected and placed in service within 8 hours from the time of the loss of RPVinjection and will require more than minimal operator action.109-7. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to functionin an ELAP event that progresses to core melt ex-vessel (Reference HCVS-FAQ-02 [13] and White PaperHCVS-WP-01 [21]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWAequipment is not dedicated to HCVS but shared to support FLEX functions. This is further addressed inHCVS-FAQ-il1.109-8. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV waterlevel, temperatures, etc.) assumed for Order EA-13-109 Beyond Design Basis External Event (BDBEE) andSA HCVS operation (Reference FLEX MAAP Endorsement ML13190A201 [29]). Additional analysisusing RELAP5/MOD 3, GOTHIC, and MICROSHIELD, etc., are acceptable methods for evaluatingenvironmental conditions in other portions of the plant, provided that the specific version utilized isdocumented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 tosupport diywell temperature response to SAWA under severe accident conditions.109-9. NRC Published Accident evaluations (e.g., SOARCA, SECY-12-0157, NUREG 1465) as related to OrderEA-13-109 conditions are acceptable as references (Reference NEI 13-02, &sect;8 [9]).109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may becredited for use in Order EA-13-109 response.109-11. This Overall Integrated Plan is based on Emergency Operating Procedure (EOP) changes consistent withEmergency Procedures Guidelines/Severe Accident Guidelines (EPG/SAGs) Revision 3 as incorporated perthe site's EOP/Severe Accident Procedure (SAP) procedure change process. This assumption does notapply to Phase 2 SAWM because SAWM is not part of revision 3. (Refer to Attachment 2.1.D for SAWMSAMG changes approved by the BWROG Emergency Procedures Committee.)109-12. Under the postulated scenarios of Order EA-13-109, the Main Control Room is adequately protected fromexcessive radiation dose as per General Design Criterion (GDC) 19 in 10CFR50 Appendix A and no furtherevaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is asufficient distance away from the MCR or is shielded to minimize impact to the MCR dose. In addition,adequate protective clothing and protection are available if required to address contaminationissues (Reference HCVS-FAQ-0l [12] and HCVS-FAQ-09).109-13. The suppression pool/wetwell of a BWR Mark I/II containment is considered to be hounded by assuming asaturated environment for the duration of the event response because of the water/steam interactions.Page 7 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and Assumptions109-14. RPV depressurization is directedt by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1 &sect;1.1.3)109-15. The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure thecapability to protect containment exists for each unit. (HCVS-FAQ-01) This is further addressed in HCVS-FAQ-10.Plant Specific HCVS Related Assumptions/Characteristics:Dresden-i Provided Severe Accident (SA) conditions are not reached EA- 12-049 (FLEX) actions to restore powerare sufficient to ensure continuous operation of non-dedicated containment instrumentation identified inPart 2 (Key Venting Parameters) of this OIP. Modifications that allow a FLEX generator to rechargethe HCVS battery are assumed to have been installed such that a FLEX generator can be credited forHCVS operation beyond the initial 24-hour sustained operational period. If SA conditions are reached,these non-dedicated containment instruments will be monitored by use of hand held, testinstrumentation that rely on small batteries, and Dresden will provide a small portable generator tomaintain HCVS battery charge beyond the initial 24 hours.Dresden -2 In case of a severe flood warning, the Dresden units will be shutdown and cooldown (per procedureDOA 00 10-04) prior to the flooding causing an ELAP. The shutdown and cooldown prior to the ELAPwill significantly reduce the decay heat that would have to be removed by the Isolation CondenserSystem (ICS) or, in case of a failure of the ICS, by the HCVS. Dresden will evaluate what actions maybe necessary to ensure the WW venting path remains viable following a severe flood. Reactor buildingdewatering strategy is under development and will be updated in the next 6-month update (Ref. ISFOpen Item 2).Dresden -3 The Plant layout of buildings and structures are depicted in Sketches 2B and 2C. Note the Main ControlRoom is located at Control Building elevation 534'. The Control Building has substantial structuralwalls and features independent of the Reactor Building. The HCVS vent routing external to the ReactorBuilding is indicated on Sketch 2-C. The external piping is vertical with the exception of the point atwhich it exits the Reactor Building.Dresden -4 The HCVS external piping is all above 30-feet from ground level and it consists solely of large bore (10-inches nominal diameter piping and its piping supports (EC 400578). The external piping has less than300 square feet of cross section. The HCVS external piping meets the reasonable protectionrequirements of HCVS-WP-04. The external support structure used to support the HCVS piping isanalyzed to the Dresden design basis tornado missiles to preclude a failure of the tower due to tornadowinds and missiles.Page 8 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentProvide a sequence of events and identify any time or environmental constraint required forsuccess including the basis for the constraint.HCVS Actions that have a time constraint to be successful should be identified with a technical basis and ajustification provided that the tine can reasonably be met (for example, action to open vent valves).HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or HighDose areas) should be evaluated per guidance.Describe in detail in this section the technical basis for the constraints identified on the sequence of eventstimneline attachment.See attached sequence of events tirneline (Attachment 2A ).Ref: EA-13-109 Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02 Section 4.2.5, 4.2.6. 6.1.1The containment purge exhaust at each Dresden unit consists of a wetwell primary containment isolationvalve (PCIV), a DW PCIV, and a common downstream PCIV. The HCVS flow path will utilize portions ofthis system. The HCVS will connect between the two containment purge exhaust PCIVs. Consequently,the HCVS flow path will share the upstream PCIVs with the containment purge system, but it will have adownstream PCIV dedicated to the HCVS flow path. The new HCVS flow path will have a rupture discdownstream of the last PCIV on the HCVS line to serve as the secondary containment leakage barrier.Each unit will have piping that is totally separate from the other unit and with no interconnected systemsdownstream of the new downstream PCIV. The discharge from each unit is routed separately anddischarges above the unit's Reactor Building roof.The two Dresden units will have a dedicated motive power (Pressurized N2) for HCVS valves, ArgonPurge system, and DC power for HCVS components that, except for battery charging after 24 hours, doesnot rely on FLEX (EC 400578).Existing containment instruments (pressure and suppression pool level) are not considered HCVScomponents and power will be maintained through the actions for EA-12-049 for non-severe accidentconditions or using test equipment during severe accident conditions.The operation of the HCVS will be designed to minimize the reliance on operator actions in response tohazards listed in Part 1. Initial operator actions will be completed by trained plant personnel and willinclude the capability for remote-manual initiation from the HCVS control station. A list of the remotemanual actions performed by plant personnel to open the HCVS vent path can be found in the followingtable (Table 2-1). A HCVS ELAP Failure Evaluation table, which shows alternate actions that can beperformed, is included in Attachment 4.Table 2-1 HCVS Remote Manual ActionsPage 9 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentPrimary Action Primary Location!/ NotesComponent1. Energize the HCVS power supply MCRto the HCVS components2. Enable the N2 motive air for the ROS* ...... ---HCVS valves3. CeckshuttheDW PIV (3)- MCRPrecautionary steps; these valves are normally shut160 1-23, the downstream PCIV to and fail shut.the containment purge exhaust2(3)-1601-24, and downstreamPCIV to the SGTS 2(3)-1601-63opening the Argon Purge Line forthe specified amount of timeMCROnly required if venting is initiated at acontainment pressure below the rupture discset point (40 psid).5. Open WetelntPCnVe23)4601-60iverride.thcnanetioaon Alternate control via motive air manual valves atsignal by opening the the ROS.PCIV in the HVCSP~nPl6. Open the downstream PCIV 2(3)- Key locked hand Alternate control via motive air manual valves at1601-93 on the common HCVS switch located in the the ROS.line HVCS Panel7. Align FLEX Generator to As described in Prior to depletion of station battery. Required tomaintain power to Station Battery response to EA maintain power to containment instrumentation.049.. ........It P~LtN, LXJi not availalae (i.e., under SAconditions), DW pressure and suppression pool, level will be monitored using test equipment.8. Align generator to HCVS battery At ROS Prior to depletion of the HCVS battery supply,charger. actions will be required to recharge the battery.If FLEX DG is not available (i.e., under SAconditions), a small portable generator will be used9. Replace N2 motive power bottles Replacement Nitrogen Prior to depletion of the pneumatic sources, actionsor align portable compressor bottles and/or i.will be required to connect back-up sources at acompressor will be itime greater than 24 hours.located at the ROS.10. R~eplace-Ar-gon-puirge-gas- bottles .........t. RO~S ..............P... -irior-to diepletion of the-Argon purge supply-at a......time greater than 24 hours. Required only if SAconditions are reached.*ROS -Remote Operating Station......Page 10 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentAttachment 2A, Sequence of Events Timeline, was developed to identify required operator response timesand potential environmental constraints. This timeline is based upon the following three sequences:1. Sequence 1 is based upon the action response times developed for FLEX when utilizinganticipatory venting in a BDBEE without core damage. Containment venting is not required forDresden FLEX response since the Isolation Condenser System (ICS) removes all the decay heatfrom the reactor and the containment does not become pressurized enough to require venting.Dresden does not have a RCIC system but it has a steam driven High Pressure Coolant InjectionSystem (HPCI).2. Sequence 2 is based on SECY-12-0157 long-term station blackout (LTSBO) (or ELAP) with afailure of RCIC after a black start where failure occurs because of subjectively assuming overinjection. It is used for Dresden to represent a late failure of the ICS and HPCI. Late failure of theICS is due to the assumption that FLEX fails to provide make-up water to the ICS.3. Sequence 3 is based on NUREG-1935 (SOARCA) results for a prolonged SBO (or ELAP) withloss of RCIC case without black start. For Dresden, this represents that the ICS fails after its initialwater volume is expended (i.e., no FLEX make-up to the ICS), and the HPCI fails early at a pooltemperature of 140&deg;F [MAAP case 8].The following is a discussion of time constraints identified in Attachment 2A for the 3 timeline sequencesidentified above:* With case 1 (ICS operating), HCVS operation is not required since the only heat input intothe containment is from RCS leaks and ambient losses to the environment.*For case 3 (limiting case), in approximately 8 hours, initiate use of Hardened ContainmentVent System (HCVS) per site procedures to maintain containment parameters below thelower of Primary Containment Pressure Limit (PCPL) or contalnment design pressure.Reliable operation of HCVS will be met because HCVS meets the seismic requirements* identified in NEl 13-02, will be powered by DC power from a dedicated power source, andHCVS valves are supplied with motive force from portable nitrogen bottles. HCVS controlsand instrumentation and controls will be DC powered. HCVS valve motive force is frompressurized gas. Valves will be operable from the HCVS control panel in the MCR. DCpower and motive air will be available for 24 hours from permanent sources. Containmentpressure and WW indication will initially be powered from existing lE Station battery. If SAconditions are not reached, these containment indications will be maintained by FLEXgenerators. If SA conditions are reached, these indications will be monitored by hand heldinstruments powered from small batteries. Thus, initiation of the HCVS from the MCR orthe Remote Operating Station within approximately 8 hours is acceptable because the actionscan be performed any time after declaration of an ELAP until the venting is needed atapproximately 8 hours for BDBEE venting. This action can also be performed for SA HCVSoperation which occurs at a time further removed from an FLAP declaration as shown inAttachment 2.*Within 24 hours, the permanently installed nitrogen bottles at the ROS will be replaced, asrequired, to maintain sustained operation or alternatively a portable compressor will beconnect at the ROS. Typical of all activities required at 24 hours, this can be performed atPage 11 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventany time prior to 24 hours to ensure adequate capacity is maintained so this time constraint isnot limiting.*Within 24 hours, the permanently installed Argon bottles at the ROS will be replaced, asrequired, to maintain sustained operation. Note that purging is only required if ventinghydrogen following severe accident conditions.*Within 24 hours, a generator will be installed and connected to recharge the dedicated HCVSpower supply to maintain sustalned operation. Under non-SA conditions this will be theFLEX generator. Under SA conditions this will be a small, portable generator.*Current Dresden station battery durations are calculated to last 6 hours. if SA conditions arenot reached, FLEX pre-staged DG will be in service 6 hours after an event (Reference FLEX0TP). Modifications will be implemented to facilitate the connections and operationalactions required to supply power within approximately 6 hours. Thus, under non-SAconditions, the FLEX DGs will be available to be placed in service at any point afterapproximately 6 hours as required to supply power to containment parameters (containmentpressure and WW level). A FLEX DG will be maintained and used in on-site FLEX storagebuildings. For the flood event, the DG will be transferred and staged via haul routes andstaging areas evaluated for impact from external hazards.Discussion of radiological, temperature. other environmental constraints identified in Attachment 2A*Actions to initiate HCVS operation are taken from the MCR or from the ROS in the TurbineBuilding. Both locations have significant shielding and/or physical separation fr'om radiologicalsources. Non-radiological habitability for the MCR is being addressed as part of the Dresden FLEXresponse. The ROS location in the Turbine Building has no heat sources.*Before the end of the initial 24-hour period, replenishment of the HCVS dedicated DC power, Argonpurge gas, and PCIV motive power (pressurized gas) will occur at the ROS. The selection of theROS location will take into account the SA temperature and radiation condition to ensure access tothe ROS is maintained. The design will allow replenishment with minimal actions.ISE Open Item -12: Confirm that the ROS will be in an area accessible following a SA.Provide Details on the Vent characteristics.Vent Size and Basis ('EA-13-!09 Section 1.2.1 /NE1 13-02 Section 4.1.1)What is the plants licensed power? Discuss any plans for possible increases in licensed power (e.g. MUR,EPU). What is the nominal diameter of the vent pipe in inches ? Is the basis determined by venting atcontainment design pressure, PCPL, or some other criteria (e.g. anticipatory venting) ?Vent Capacity (EA 1 09 Section 1.2.1/INEI 13-02 Section 4.1.1)Indicate any exceptions to the 1% decay heat removal criteria, including reasons for the exception.Provide the heat capacity of the suppression pool in terms of time versus pressurization capacity, assumingsuppression pool is the injection source.Page 12 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentVent Path and Discharg~e (EA-13-109 Section 1.1.4. 1.2.2 / NEI 13-02 Section 4.1.3, 4.1.5 and AppendixProvide a description of Vent path, release path, and impact of vent path on other vent element items.Power and Pneumatic Supply Sources (EA 1 09 Section 1.2.5 & 1.2.6 /NEI 13-02 Section 4.2.3. 2.5,4.2.2, 4.2.6. 6.1)Provide a discussion of electrical power requirements, including a description of dedicated 24 hour powersupply from permainently installed sources. Include a similar discussion as above for the valve motive forcerequirements. Indicate the area in the plant from where the installed/dedicated power and pneumaticsupply sources are coming.Indicate the areas where portable equipmnent will be staged after the 24 hour period, the dose fields in thearea, andt any shielding that would be necessary in that area.Location of Control Panels (EA 1 09 Section 1.1.1, 1.1.2, 1.1.3. 1.1.4, 1.2.4, 1.2.5 /NEI 13-02 Section4,1.3. 4.2.2. 4.2.3. 4.2.5, 4.2.6, 6.1.1. and Appendix FIG)Indicate the location of the panels, and the dose fields in the area during severe accidents and anyshielding that would be required in the area. This can be a qualitative assessment based on criteria in NEI13-02..Hydrog'en (EA-13.109 Section 1.2.10, &1.2.11, and 1.2.12/INEI 13-02 Section 2.3,2.4. 4.1.1. 4.1.6. 4.1.7,5.1, & Appendix H)State which approach or combination of approaches the plant will take to address the control of fiammablegases, clearly demarcating the segments of vent system to which an approach applies.Unintended Cross Flow of Vented Fluids (EA 1 09 Section 1.2.3, 1.2.12 / NEI 13-02 Section 4.1.2,4,1.4, 4.1.6 and Appendix H)Provide a description to eliminate/minimize unintended cross flow of vented fluids with emphasis oninterfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakagethrough interfacing valves or Appendix J type testing features?Prevention of lnadvertent Actuation (EA-13-109 Section 1.2.7/NEl 13-02 Section 4.2.1)The HCVS shall include means to prevent inadvertent actuation.Component Qualifications (EA-13-109 Section 2.1/INEI 13-02 Section 5.1)State qualification criteria based on use of a combination of safety related and augmented qualitydependent on the location, function andt interconnected system requiremnents._Monitoring of HCVS (Order Elements 1.1.4, 1.2.8, 1.2 .9/NEI 13-02 4.1.3, 4.2.2, 4.2.4, and AppendixFIG)qProvide a description of instruments used to monitor HCVS operation and effluent. Power for aninstrument will require the intrinsically safe equipment installed as part of the power sourcing.Comnonent reliable and rugv'ed oerformance (EA 1 09 Section 2.2 /NEI 13-02 Section 5.2. 5.3)HCVS components including instrumentation should be designed, as a minimum, to meet the seismic designrequirements of the plant.Page 13 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentComponents including instrumentation that are not required to be seismically designed by the design basisof the plant should be desi gned for reliable and rugged peiformance that is capable of ensuring HCVSfunctionality following a seismic event. (Reference JLD-ISG-2012-01 and JLD-ISG-2012-O3 for seismicdetails.)The components including instrumentation external to a seismic category I (or equivalent building orenclosure should be designed to meet the external hazards that screen in for the plant as defined inguidance NE1 12-06 as endorsed by JLD-ISG-12-O1 for Order EA-12-049.Use of instruments and supporting components with known operating principles that are supplied bymanufacturers with commercial quality assurance programs, such as 1S09001. The procurementspecifications shall include the seismic requirements and/or instrument design requirements, and specifythe need for commercial design standards and testing under seismic loadings consistent with design basisvalues at the instrument locations.Demonstration of the seismic reliability of the instrumentation through methods that predict performanceby analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis,or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard344-2004, "'IEEE Recommended Practice for Seismic Qualification of Class JE Equipment for NuclearPower Generating Stations,'" or a substantially similar industrial standtard could be used.Demonstration that the instrumentation is substantially similar in design to instrumentation that has beenpreviously tested to seismic loading levels in accordance with the plant design basis at the location wherethe instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should besimilar to that performed for the plant licensing basis.Page 14 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentVent Size and BasisThe HCVS flow path is designed for venting steanm/energy from the suppression pooi at a nominal capacityof 1% of the currently licensed power, 2957 MWt thermal power at pressure of 62 psig (UFSAR Table 1.2-1). This pressure is the lower of the containment design pressure and the PCPL value assuming nominaltorus water level. The nominal diameter is 18-inches through the shared upstream PCTV that is shared withthe containment purge exhaust and 10-inches for the downstream portion. The 10-inch diameter portionincludes the downstream PCIV and rupture disc. Refer to Sketch 2A, the P&TD. This line has been verifiedto meet the Order criteria for 1%.Vent CapacityThe 1% value at Dresden assumes that the suppression pooi pressure suppression capacity is sufficient toabsorb the decay heat generated during the first 3 hours. The vent would then be able to preventcontainment pressure from increasing above the containment design pressure. As part of the detaileddesign, the duration of suppression pool decay heat absorption capability was confirmed to exceed 3 hours(Reference 37, MAAP).Vent Path and DischargeThe Dresden station HCVS vent path will consist of a separate wetwell vent for each unit. The upstreamportion consists of 18-inch nominal diameter piping and the upstream PCIV that is shared with the toruscontainment purge exhaust path. The downstream portion consists of 10-inch nominal diameter piping andincludes the downstream PCIV and the rupture disc. The downstream PCTV and rupture disc are dedicatedto the HCVS function. The rupture disc is credited as the secondary containment isolation barrier. The 10-inch diameter vent line is initially routed vertically with the Reactor Building and then horizontally throughthe Reactor Building wall at elevation 591', which is approximately 74 feet above nominal plant groundelevation (EC 401069, DWG M-1 194A-1). This line is then routed vertically on the outside of the ReactorBuilding to a point above the top of the Reactor Building. There are no interconnected systemsdownstream of the second PCIVs and there is no sharing of any flow path between the two units.The HCVS discharge path is being routed to a point above any adjacent structure. This discharge point isjust above that unit's Reactor Building and will follow the guidance of FAQ- HCVS-04 (Reference 15) tothe extent reasonably possible such that the release point will vent away from emergency ventilation systemintake and exhaust openings, main control room location, location of HCVS portable equipment, accessroutes required following a ELAP and BDBEE, and emergency response facilities; however, these must beconsidered in conjunction with other design criteria (e.g., flow capacity) and pipe routing limitations, to thedegree practical. The external vertical piping for the two units will be run in close proximity to each otherto allow a common external support structure. The external piping meets the criteria for tornado missilereasonable protection (refer to Dresden Assumption 4).Power and Pneumatic Supply SourcesAll electrical power required for operation of HCVS components will be from a dedicated HVCS DCbattery source with permanently installed capacity for the first 24 hours and design provisions forrecharging to maintain sustained operation.Motive (pneumatic) power to the HCVS valves is provided by a dedicated bank of N2 gas bottles withpermanently installed capacity for the first 24 hours and design provisions for replacing bottles and/orPage 15 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventconnecting a portable compressor to maintain sustained operation. The initial stored motive air/gas willallow for a minimum of 8 vent cycles for the HCVS valves for the first 24-hours. The 8 vent cycles isdefined as initially opening all valves in the wetwell flow path, and then shutting and reopening one of thevalves in the flow paths.1. The HCVS flow path valves are air-operated valves (AOV). The existing, upstream PCIV is air-to-open and air-to-shut. The new downstream PCIV will be air-to-open and spring-to-shut. Openingthe valves from the HCVS control panel located in the MCR requires energizing a DC poweredsolenoid operated valve (SOV) and providing motive air/gas.2. An assessment of temperature and radiological conditions will be performed to ensure thatoperating personnel can safely access and operate controls at the Remote Operating Station basedon time constraints listed in Attachment 2.3. All permanently installed HCVS equipment, including any connections required to supplement theHCVS operation during an ELAP (i.e., DC power, Argon purge gas, and motive force [pressurizedN2/air]) will be located in areas reasonably protected from defined hazards listed in Part 1 of thisreport.47All valves required to open the flow path will be designed for remote manual operation followingan ELAP, such that the primary means of valve manipulation does not rely on use of a handwheel,reach-rod or similar means that requires close proximity to the valve (reference FAQ HCVS-03).The preferred method is opening from the MCR through the control switch that energizes theAOV's SOV. The back-up method for new valves is from the ROS by repositioning valves on thepneumatic supply; this allows opening and closing of a valve from the ROS without reliance onany electrical power or control circuit. Accessibility to the ROS will be verified during thedetailed design.5. Any supplemental connections will be pre-engineered to minimize man-power resources andaddress environmental concerns. Required portable equipment will be reasonably protected fromscreened in hazards listed in Part 1 of this OIP.6. Access to the locations described above will not require temporary ladders or scaffolding.Location of Control PanelsThe HCVS design allows initiating and then operating and monitoring the HCVS from the Main ControlRoom (MCR) and in addition, opening PCTVs and the Argon purge system from the ROS in case of a DCcircuit failure. The tentative location for the ROS is 561 foot elevation Turbine Building. The MCRlocation is protected from adverse natural phenomena and it is the normal control point for PlantEmergency Response actions. The ROS will be evaluated to ensure acceptable temperature and doseconsequences.HydroigenAs required by EA-13-109, Section 1.2.11, the HCVS design will include an Argon purge system that willbe connected just downstream of the second PCIV. It will be designed to prevent hydrogen detonationdownstream of the second PCIV. The Argon purge system will have a switch for the control valve in theMCR to allow opening the purge for the designated time, but it will also allow for local operation in theROS in case of a DC power or control circuit failure. The Argon purge will only be utilized followingsevere accident conditions when hydrogen is being vented. The installed capacity for the Argon purgePage 16 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventsystem will be sized for at least 8 purges within the first 24 hours of the ELAP. This number of vent cyclesis the same value used for sizing the PC1V motive air supply. The design will allow for Argon bottlereplacement for continued operation past 24 hours.The Argon purge system can also be used to breach the rupture disc if venting is required before reachingthe rupture disc setpoint. The MCR panel will include an indication of Argon pressure to the HCVS path toverify that the Argon purge system flow is occurring.Unintended Cross Flow of Vented FluidsRefer to Sketch 2A, the HCVS P&IID. The HCVS piping in each unit is totally independent of the otherunit's HCVS flow path. The upstream 18-inch nominal diameter portion isolates any interconnected, non-HCVS systems in that unit through normally shut, air-operated PCIVs that, if open, will automatically shut.The downstream dedicated 10-inch portion does not have any interconnected systems. This precludesunintended cross flow of vented fluids.Prevention of Inadvertent ActuationEOP/ERG operating procedures provide clear guidance that the HCVS is not to be used to defeatcontainment integrity during any design basis transients and accident. In addition, the HCVS will bedesigned to provide features to prevent inadvertent actuation due to a design error, equipment malfunction,or operator error such that any credited containment accident pressure (CAP) that would provide netpositive suction head to the emergency core cooling system (ECCS) pumps will be available (inclusive of adesign basis loss-of-coolant accident (DBLOCA)). However, the ECCS pumps will not have normal poweravailable because of the starting boundary conditions of an ELAP.Note that Dresden credits CAP for its DBLOCA. Preventing inadvertent operation is addressed. Thefeatures that prevent inadvertent actuation are two PCI Vs in series with a downstream rupture disc. Thedownstream PCIV is a normally shut, fail-shut AOV dedicated to the HCVS function. This valve is air toopen; spring to shut that requires energizing a SOV to allow the motive air to open the valve. This PCTV iscontrolled by its own key-locked switch. In addition, the DC power to its SOV and the motive air suppliedwill normally be disabled to prevent inadvertent operation.Component QualificationsThe HCVS components and components that interface with the HCVS are routed in seismically qualifiedstructures.HCVS components that are part of the containment pressure boundary will be safety-related. Thecontainment system limits the leakage or release of radioactive materials to the environment to preventoffsite exposures from exceeding the guidelines of 10 CFR 100. During normal or design basis operations,this means serving as a pressure boundary to prevent release of radioactive material. HCVS componentsdownstream of the containment pressure boundary (i.e., downstream of the downstream PCIV) will not besafety-related.The HCVS components (SOVs and instrumentation) will be powered from a normally de-energized,dedicated power supply that will not be safety-related but will be considered Augmented Quality.However, if any HCVS electrical or controls component interfaces with Class 1E power sources, it will heconsidered safety related up to and including appropriate isolation devices such as fuses or breakers, astheir failure could adversely impact containment isolation and/or a safety-related power source. Newlyinstalled piping and valves will be seismically analyzed to handle the forces associated with the Plant'sDesign Basis Seismic Requirements back to their isolation boundaries. Electrical and controls componentsPage 17 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventwill be seismically analyzed and will include the ability to handle harsh environmental conditions (althoughthey will not be considered part of the site Environmental Qualification (EQ) program).HCVS instrumentation performance (e.g., accuracy and precision) need not exceed that of similar plantinstalled equipment. Additionally, radiation monitoring instrumentation accuracy and range will besufficient to determine core conditions (i.e., no core damage thru severe core damage). The HCVSinstruments, including valve position indication, process instrumentation, radiation monitoring, and supportsystem monitoring, will be qualified by using one or more of the three methods described in the ISG, whichincludes:1. Purchase of instruments and supporting components with known operating principles frommanufacturers with commercial quality assurance programs (e.g., 1S09001) where the procurementspecifications include the applicable seismic requirements, design requirements, and applicabletesting.2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-20043. Demonstration that instrumentation is substantially similar to the design of instrumentationpreviously qualified.Instrument Qualification Method*HCVS Process Temperature 1509001 / IEEE 344-2004 / DemonstrationHCVS Process Radiation Monitor 1S09001 / IEEE 344-2004 / DemonstrationHCVS Valve Position Indication 1509001 I IEEE 344-2004 I DemonstrationHCVS Pneumatic Supply Pressure ISO09001 / IEEE 344-2004 / DemonstrationHCVS Electrical Power Supply Availability 1SO9001 / IEEE 344-2004 I DemonstrationHCVS Argon System Purge Pressure 1SO900 1/ IEEE 344-2004 I Demonstration* The specific qualification method used for each required HCVS instrument will be reported infuture 6-month status reports.[ISE OPEN ITEM-15: Complete evaluation for HCVS instrumentation qualification.]Monitoring of HCVSThe Dresden wetwell HCVS will be capable of being remote-manually operated during sustainedoperations from a control panel located in the main control room (MCR) and will meet the requirements ofOrder element 1.2.4. The MCR is a readily accessible location with no further evaluation required (GenericAssumption 109-12). Additionally, to meet the requirement of EA-13-109 Section 1.2.5, an accessibleRemote Operating Station (ROS) will also be incorporated into the HCVS design as described in NEI 13-02 section 4.2.2.1.2.1. The controls and indications at the ROS location will be accessible and functionalunder a range of plant conditions, including severe accident conditions with due consideration to sourceterm and dose impact on operator exposure, extended loss of AC power (ELAP), and inadequatecontainment cooling. An evaluation will be performed to determine accessibility to the ROS location,habitability, staffing sufficiency, and communication capability with Vent-use decision makers.Page 18 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentThe wetwell HCVS will include means to monitor the status of the vent system in the MCR and to monitorDC power, Argon pressure, and N2 pressure at the ROS. The proposed design for the HCVS includescontrol switches in the MCR with valve position indication. The HCVS controls will meet theenvironmental and seismic requirements of the Order for the plant severe accident with an ELAP. Theability to open/close these valves multiple times during the event's first 24 hours will be provided bydedicated motive air and DC power. Beyond the first 24 hours, the ability to maintain these valves open orclosed will be maintained by sustaining the motive air and DC power.The wetwell HCVS will include indications for vent pipe temperature and effluent radiation levels at theMCR. Other important information on the status of supporting systems, (i.e., DC power source status,Argon purge gas pressure and pneumatic supply pressure), will also be included in the design and locatedto support HCVS operation. Other instrumentation that supports HCVS function will be provided in theMCR. This includes existing containment pressure and suppression pool level indication. Thisinstrumentation is not required to validate HCVS function and is therefore not powered from the dedicatedHCVS batteries. However, these instruments are expected to be available since (a) under non-SAconditions the FLEX DG supplies the station battery charger for these instruments and will be installedprior to depletion of the station batteries and (b) under SA conditions, they will be monitored using hand-held test equipment.Component reliable and rugged performanceUnless otherwise required to be safety-related, Augmented Quality requirements will be applied to thecomponents installed in response to this Order.The HCVS downstream of the second containment isolation valve, including piping and supports, electricalpower supply, valve actuator pneumatic supply, and instrumentation (local and remote) components, willbe designed/analyzed to conform to the requirements consistent with the applicable design codes (e.g.,Non-safety, Seismic Category 1, B31.l) for the plant and to ensure functionality following a design basisearthquake.Additional modifications required to meet the Order will provide reliability at the postulated vent pipeconditions (temperature, pressure, and radiation levels). The instrumentation/powersupplies/cables/connections (components) will be qualified for temperature, pressure, radiation level, totalintegrated dose radiation appropriate for that location (e.g., near the effluent vent pipe or at the HCVS ROSlocation).Conduit design and/or cable trays will be installed to Seismic Class 1 criteria.Dresden complies with HCVS-WP-04 from reasonable protection of HCVS components located outside ofseismic Class 1 concrete structures.If the instruments are purchased as commercial-grade equipment, they will be qualified to operate undersevere accident environment as required by NRC Order EA-13-109 and the guidance of NEI 13-02. Theequipment will be qualified seismically (IEEE 344) and environmentally (IEEE 323). These qualificationswill be bounding conditions for Dresden per UFSAR 1.1.8 and 3.11.For the instruments required after a potential seismic event, the following methods will be used to verifyPage 19 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventthat the design and installation is reliable / rugged and thus capable of ensuring HCVS functionalityfollowing a seismic event. Applicable instruments are rated by the manufacturer (or otherwise tested) forseismic impact at levels commensurate with those of postulated severe accident event conditions in the areaof instrument component use using one or more of the following methods:* demonstration of seismic motion will be consistent with that of existing design basis loads at theinstalled location;* substantial history of operational reliability in environments with significant vibration with adesign envelope inclusive of the effects of seismic motion imparted to the instruments proposed atthe location;* adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7, 8,9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification ofClass JE Equipment for Nuclear Power Generating Stations, (Reference 28) or a substantiallysimilar industrial standard;* demonstration that proposed devices are substantially similar in design to models that have beenpreviously tested for seismic effects in excess of the plant design basis at the location where theinstrument is to be installed (g-levels and frequency ranges); or* seismic qualification using seismic motion consistent with that of existing design basis loading atthe installation location.Page 20 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingDetermine venting capability for BDBEE Venting, such as may be used in an ELAP scenario tomitigate core damage.Ref: EA-13-109 Section 1.1.4 /NEI 13-02 Section 2.2First 24 Hour Coping DetailProvide a general description of the venting actions for first 24 hours using installed equipment including stationmodifications that are proposed.Ref: EA-13-109 Section 1.2.6 I NEI 13-02 Section 2.5, 4.2.2The operation of the HCVS will be designed to minimize reliance on operator actions for response to an ELAPand severe accident events. Immediate operator actions will be completed by qualified plant personnel fromeither the MCR or the HCVS ROS using remote-manual actions. The operator actions required to open a ventpath are as described in Table 2-1.Remote-manual is defined in this report as a non-automatic power operation of a component and does not requirethe operator to be at or in close proximity to the component. No other operator actions are required to initiateventing under the guiding procedural protocol.The HCVS will be designed to allow initiation, control, and monitoring of venting from the MCR. This locationminimizes plant operators' exposure to adverse temperature and radiological conditions and is protected fromhazards assumed in Part 1 of this report.Permanently installed electrical power. and motive air/gas capability will be available to support operation andmonitoring of the HCVS for 24 hours.System control:i. Active: The PCI Vs will be operated in accordance with EOPs/SOPs to control containmentpressure. The HCVS will be designed for at least 8 vent cycles under ELAP conditions over thefirst 24 hours following an ELAP. Controlled venting will be permitted in the revised EPGs andassociated implementing EOPs.ii. Passive: Inadvertent actuation protection is provided by:A key locked switch for the dedicated downstream PCIV located in the Main Control Room andcontrolled by proceduresANDDisabling the HCVS DC power to the SOV and disabling the motive power (pressurized N2) forthe dedicated PCIV except when required by procedures to initiate containment ventingANDA rupture disc downstream of the PCIVs with a design pressure of 40 PSID.Page 21 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingGreater Than 24 Hour Coping DetailProvide a general description of the venting actions for greater than 24 hours using portable andinstalled equipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4 / NEI 13-02 Section 4.2.2Before the end of the 24 hours initial phase, available personnel will be able to connect supplemental air/gas forthe motive air system. Connections for supplementing electrical power and air/gas required for HCVS will belocated in accessible areas with reasonable protection per NEI 12-06 that minimize personnel exposure to adverseconditions for HCVS initiation and operation. Connections will be pre-engineered quick disconnects to minimizemanpower resources. Replenishment of the Argon supply is not required under non-SA conditions since purgingis not required.FLEX is credited to sustain power for a BDBEE ELAP to containment instruments used to monitor thecontainment (e.g., pressure and wetwell level) during non-Severe Accident (SA) conditions. Portable instrumentswill be used during SA conditions. The response to NRC EA-12-049 will demonstrate the capability for FLEXefforts to maintain the power source.These actions provide long term support for HCVS operation for the period beyond 24 hours to 7 days (sustainedoperation time period) because on-site and off-site personnel and resources will have access to the unit(s) toprovide needed action and supplies.Details:Provide a brief description of Procedures/IGuidelines:Confirm that procedure/guidance exists or will be developed to support implementation.Primary Containment Control Flowchart will be provided to direct operations in protection and control ofcontainment integrity, including use of the existing Hardened Containment Vent System.These flowcharts are being revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAPimplementation. HCVS-specific procedure guidance will be developed and implemented to support HCVSimplementation.ISE Open Item 18: -Provide procedures for HCVS Operation.Identify modifications:List modifications and describe how they support the HCVS Actions.EA- 12-049 Modifications* No additional EA-12-049 modifications are required to support HCVS.EA-13-109 Modifications* A modification will be required to install the new wetwell vent piping including the new downstreamPCIV and rupture disc. The rupture disc controls primary containment leakage during a design basisPage 22 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingLOCA. The new valve will include valve position indication and remote-manual control only. There isno sharing of any flow paths with the opposite unit.* A modification will be required to allow operation of the existing upstream wetwell PCIV. This includesthe capability to override a containment isolation signal. Reopening the valves following a BDBEE willbe remote-manual.* A modification will be required to install the dedicated batteries needed to supply power to HCVS for thefirst 24 hours including capability for recharging from a portable charger at or before 24 hours. Thebattery will be located at the ROS.* A modification will be required to install the dedicated motive power (Pressurized N2 gas) needed toopen the HCVS valves for the first 24 hours including capability for replacing N2 bottles or connection aportable compressor after 24 hours. The N2 bottles will be located at the ROS.*A modification will be required to install the dedicated Argon purge system. For non-SA conditions, theArgon purge system is not required to prevent hydrogen detonation in the piping. The Argon purgesystem, however, can be credited with breaching the rupture disc if venting is initifated at a containmentpressure below the rupture disc setpoint.* A modification will be required to add (a) HCVS flow path instrumentation consisting of temperature andeffluent radiation in the MCR and (b) Motive power and DC HCVS battery indication in the MCR andthe ROS.Key Venting Parameters:List instrumentation credited for this venting actions. Clearly indicate which of those already exist in the plantand what others will be newly installed (to comply with the vent order).Initiation, operation and monitoring of the HCVS venting will rely on the following key parameters andindicators. Indication for these parameters will be installed in the MCR or ROS to comply with EA-13-109:Key Parameter Component Identifier Indication LocationHCVS Effluent temperature TBD MCRHCVSEfflentRaditionTBDMCRHCVS valve position indication TBD MCRHCVS DC Power Voltage/Conditions TBD ROSHCVS Pneumatic supply pressure TBD ROSHCVS Purge System pressure TBD MCRIROSInitiation and cycling of the HCVS will be controlled based on several existing MCR key parameters andindicators which are qualified to the existing plant design: (Reference NEI 13-02 Section 4.2.2.1.9 [91):Key Parameter Component Identifier Indication LocationDrywell pressure 2(3)-1640-1 1A(B) MCR____ wetwell level 2(3)-1640-13A(B) MCRNotes: NonePage 23 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Severe Accident VentingDetermine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario tomitigate core damage.Ref: EA-13-109 Section 1.2.10 /NEI 13-02 Section 2.3First 24 Hour Coping DetailProvide a general description of the venting actions for first 24 hours using installed equipment including stationmodifications that are proposed.Ref: EA-13-109 Section 1.2.6 / NET 13-02 Section 2.5, 4.2.2Severe accident (SA) conditions assume that specific core cooling actions from the FLEX strategies identified inthe response to Order EA-12-049 were not successfully initiated. Core damage is assumed to start at 1.9 hours.(MAAP Case 8, Reference 37). This case assumes ICS is automatically initiated at the start of the ELAP butsecured at T=20 minutes (no credit for make-up to the ICS) and failure of the HPCJ when suppression pooitemperature reaches 140&deg;F. The operator actions required to open a vent path under SA conditions are the sameas previously listed in the BDBEE Venting Part 2 section of this report (Table 2-1). The operation of the HCVSunder SA conditions is the same as discussed under BDBEE (i.e., non-SA conditions) with the followingexceptions:*Access is not restricted prior to core damage. Thereafter, access to the reactor building will be restrictedas determined by the RPV water level and core damage conditions.*HCVS permanently installed power, Argon purge, and motive air/gas capability will be available tosupport operation and monitoring of the HCVS for 24 hours. Specifics are the same as for BDBEEVenting Part 2.*Containment instrumentation (DW pressure and suppression pool) will be monitored using testinstruments that are powered from self-contained batteries following depletion of the Station battery.A preliminary evaluation of travel pathways for dose and temperature concerns has been completed and travelpaths identified (ISE Open Item #12). A final evaluation of environmental conditions will be completed as partof detailed design for confirmation.[ISE OPEN ITEM-12: Confirm travel path accessibility.]System control:i. Active: Same as for BDBEE Venting Part 2.ii. Passive: Same as for BDBEE Venting Part 2Greater Than 24 Hour Coping DetailProvide a general description of the venting actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2Page 24 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Severe Accident VentingSpecifics are the same as for BDBEE Venting Part 2 except that (a) Argon purge gas replenishment is requiredafter 24 hours and (b) under SA conditions the FLEX DG will not be available and, consequently, the DWpressure and suppression pooi level indications will be monitored using hand held instruments. The HCVSsupport systems (including the Argon purge system) will be designed to allow replenishment under SAconditions. These actions provide long term support for HCVS operation for the period beyond 24 hours to 7 days(sustained operation time period) because on-site and off-site personnel and resources will have access to theunit(s) to provide needed action and supplies.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The operation of the HCVS will be governed the same for SA conditions as for BDBEE conditions. Existingguidance in the SAMGs directs the plant staff to consider changing radiological conditions in a severe accident.Identify modifications:List modifications and describe how they support the HCVS Actions.Modifications are the same as for BDBEE Venting Part 2 with the exception that a suitable location forconnecting test instruments for DW pressure and suppression pool water level will be required.Key Venting Parameters:List instrumentation credited for the HCVS Actions. Clearly indicate which of those already exist in theplant and what others will be newly installed (to comply with the vent order).Key venting parameters are the same as for BDBEE Venting Part 2.Notes: NonePage 25 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Support EquipmentFunctionsDetermine venting capability support functions needed.Ref: EA-13-109 Section 1.2.8, 1.2.9 /NEI 13-02 Section 2.5, 4.2.4, 6.1.2BDBEE VentingProvide a general description of the BDBEE Venting actions support functions. Identify methods andstrategy(ies) utilized to achieve venting results.Ref: EA-13-109 Section 1.2.9 / NET 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2All containment venting functions will be performed from the MCR or ROS.Venting to prevent containment overpressurization will be maintained by permanently installed equipment. TheHCVS dedicated DC power source, Argon purge gas, and dedicated motive force is adequate for the first 24hours, but it can be replenished to support sustained operation.Existing safety related station batteries will provide sufficient electrical power for MCR containmentinstrumentation for greater than approximately 6 hours (EC Eval 391973). Before station batteries are depleted,portable FLEX diesel generators, as detailed in the response to Order EA-12-049, will be credited to charge thestation batteries and maintain DC bus voltage after approximately 6 hours.Severe Accident VentingProvide a general description of the Severe Accident Venting actions support functions. Identify methods andstrategy(ies) utilized to achieve venting results.Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2The same support functions that are used in the BDBEE scenario would be used for severe accident venting withthe exception that the FLEX DG is not available. A suitable location for connecting test instruments for DWpressure and suppression pool water level will be required to monitor these parameters after approximately 6hours.The ROS (the location of the HCVS DC power source, Argon purge, and motive force) will be evaluated toconfirm accessibility under severe accident conditions.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The operation of the HCVS will be governed the same for SA conditions as for BDBEE conditions. Existingguidance in the SAMG directs the plant staff to consider changes in radiological conditions in a severe accident.Identify modifications."List modifications and describe how they support the HCVS Actions.The same as for BDBEE Venting Part 2 with the exception that a suitable location for connecting test instrumentsfor DW pressure and suppression pool water level will be required.Page 26 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Support EquipmentFunctionsKey Support Equipment Parameters:List instrumentation cred ited for the support equipment utilized in the venting operation. Clearlyindicate which of those already exist in the plant and what others will be newly installed (to comply withthe vent order).The same as for BDBEE Venting Part 2.Notes: NonePage 27 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Venting PortableEquipment DeploymentProvide a general description of the venting actions using portable equipment including modifications that areproposed to maintain and/or support safety functions.Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.2, D.1.3.1Deployment pathways developed for compliance with Order EA-12-049 are acceptable without further evaluationneeded except in areas around the Reactor Building or in the vicinity of the HCVS piping.Before the end of the initial 24-hour period, replenishment of the HCVS dedicated DC power, Argon purge gas,and motive power (pressurized gas) will occur at the ROS. The selection of the ROS location will take intoaccount the SA temperature and radiation condition to ensure access to the ROS is maintained. The design willallow replenishment with minimal actions.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The portable equipment that must be deployed for HCVS operation is limited to the FLEX DG that is credited formaintaining power to the containment instrumentation following Station battery depletion.Under non-SA conditions, operation of the FLEX DG is the same as for compliance with Order EA-12-049; thus,it is acceptable without further evaluation.Under SA conditions, radiological conditions will impede deployment of the FLEX DG. Consequently,procedures will be developed to install test instruments to monitor DW pressure and suppression pool water levelper Engineering Change (EC) process.Strategy Modifications Protection of connectionsPer compliance with Order EA- N/A Per compliance with Order EA- 12-04912-049 (FLEX) (FLEX)Notes: NonePage 28 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2GeneralLicensees that use Option B.] of EA 1 09 (SA Capable DW Vent without SA WA) must develop their own QIP.This template does not provide guidance for that option.Licensees using Option B.2 of EA-13-109 (SAWA and SAWM or 545&deg;F SADW Vent (SADV) with SAWA) may usethis templ ate for their OIP submittal. Both SA WM and SADV require the use of SA WA and may not be doneindependently. The HCVS actions uneter Part 2 apply to all of the following:This Part is divided into the following sections:3.1: Severe Accident Water Addition (SA WA)3.1.A: Severe Accident Water Management (SA WM)3.1.B: Severe Accident DW Vent (545 deg F)Provide a sequence of events and identify any time constraint required for success including the basis for thetime constraint.SA WA and SA WM or" SADV Actions supporting SA conditions that have a time constraint to be successful should beidentified with a technical basis and a justification provided that the time can reasonably be met (for example, awalkthrough of deployment). Actions already identified under the HCVS part of this template need not be repeatedhere.The time to establish the water addition capability into the RPV or DW should be less than 8 hours from the onsetof the loss of all injection sources.* Electrical generators satisfying the requirements of EA-12-049 may be credited for poweringcomponents and instrumentation needed to establish a flow path.* Time Sensitive Actions (TSAs) for the purpose of SAWA are those actions needed to transport, connectand start portable equipment needed to provide SA WA flow or provide power to SA WA components inthe flow path between the connection point and the RPV or drnywell. Actions needed to establish powerto SA WA instrumentation should also be included as TSAs.Ref: NET 13-02 Section 6.1.1.7.4.1,1.1.4, 1.1.5The operation of the HCVS using SAWA and SAWMvISADV will be designed to minimize the reliance on operatoractions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and willinclude the capability for remote-manual initiation from the MCR using control switches. In addition, HCVS valveoperation, as required by EA-13-109 Requirement 1.2.5, may occur at the ROS on the 561 foot elevation of theTurbine Building.Timelines (see attachments 2.1 .A for SAWAISAWM) were developed to identify required operator response timesand actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) orafter initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWM). The timelines donot assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damageconditions.Page 29 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Part 3.1: Boundary Conditions for SAWATable 3.1 -SAWA Manual Actions(Dresden non-flood scenario; flood scenario is less time limiting since there is greater than 24-hour floodwarning, equipment can be fully deployed before flood, and plant will be shutdown and in partial cooldownto Mode 4)Primary Action Primary Location!/Component Notes1. Establish HCVS capability in U MCR or ROS. U Applicable to SAWA/SAWMaccordance with Part 2 of this strategy.OIP.2. Connect SAWA pump discharge U Reactor building 517' elevation U Perform reactor buildingto injection piping. (ground level) hard pipe portions of deployment first.connection to Low PressureCoolant Injection (LPCI) Line.U Manually open motor operatedvalve (MOV) 2(3)-1501-22A(B).The second MOV 2(3)-1501-21A(B) is normally open).3. Connect SAWA pump to water U At Ultimate Heat Sink (UHS) U* Consist of a Diesel Drivensource, near intake structure, submersible pump dischargingto a diesel driven SAWABooster pump; with hoses.4. Install test equipment to allow U MCR U Required when Station batteriesmonitoring of DW pressure and are depleted.suppression pool water level.5. Inject to RPV using SAWA U Flow control is by a manual U Initial SAWA flow rate is 421pump (diesel). valve at the SAWA Booster gpm.pump.6. Monitor SAWA indications. U Flow indication at SAWA U Pump flow.Pumps' location(s).7. Use SAWM to maintain U TBD U Monitor DW pressure andavailability of the WW vent (Pail Suppression Pool level.3.1 .A). U Control SAWA flow at valvelocated on the diesel drivenpump to reduce flow to 85-~ gpm.-Discussion of timeline SAWA identified items HCVS operations are discussed under Phase 1 of EA-13-109 (Part 2 of this OIP).U Action being taken within the reactor building under EA-12-049 conditions after RPV level lowers to 2/3 coreheight must be evaluated for radiological conditions assuming permanent containment shielding remainsintact. (HC VS-FAQ- 12)Page 30 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2* 6 hours -Install test equipment for monitoring DW pressure and suppression pool water level. All otheractions required are assumed to be in-line with the FLEX timeline submitted in accordance with the EA-12-049 requirements.* Less than 8 hours -Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizingthe peak DW pressure during the initial cooling conditions provided by SAWA.Determine operating requirements for SA WA, such as may be used in an ELAP scenario to mitigate core damage.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 I NET 13-02 Section 1.1.6, 1.1.4.4It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systemsor presumed failure of injection systems in a timely manner. This does not preclude the use of the SAWA system tosupplement or replace the EA-12-049 injection systems if desired. SAWA will consist of both portable andinstalled equipment.The motive force equipment needed to support the SAWA strategy shall be available prior to T=8 hours from theloss of injection (assumed at T=0).The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids I gases andpotentially flammable conditions by inclusion of backflow prevention. The SAWA pump check valve is integralwith the pump skid and will close and prevent leakage when the SAWA pump is secured. LPCI injection mode hasinstalled ECCS check valve 2(3)-1501-25A(B) qualified for accident scenarios to prevent reverse flow from theRPV.Table 3.2 -SAWA Manual Actions TimelineTime Action NotesT<I hour U Connect SAWA hose in Reactor U No evaluation required forBuilding (Step 2 of Table 3.1). actions inside ReactorU Open MOV 2(3)-1501-22A(B). Building.U Core damage for Dresden isassumed to start at 1.9 hours.(MAAP Case 8).T-l-~7* hours U Complete actions started at T<l hour U Evaluate core gap and early in(Step 2 of Table 3.1). vessel release impact to reactor*The assumed times of T=1 hr to U Connect SAWA pump to water supply building access for SAWAT=8 hrs to establish the bounds of at intake structure (Step 3 of Table 3.1). actions. It is assumed thatapplicability of radiologicalevaluations bave been reduced to
* Install test equipment to monitor DW Reactor Building access isT=1 hr to T=7 hrs in order to Pressure and Suppression pool water limited due to the source termprovide sufficient margin to inform level (Step 4 of Table 3.1). at this time unless otherwiseoperator action feasibility U Establish flow of at least 421 gpm to the noted. (Refer to HCVS-FAQ-evaluations and will be further RPV using SAWA systems. Begin 12 for actions in T=l-8 hourinome yemrenyrspne injection (Step 5 of Table 3.1). timeframe.Page 31 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2dose assessment activities duringan actual event. This accounts forthe one hr gap between 7 and 8 hrsin this time line.T<8-1 2 hours U Monitor and Maintain SAWA flow at U SAWA flow must commence421 GPM for four hours Steps 5 & 6 of at T=8 hours but should beTable 3.1). done as soon as motive force isavailable.T_<12 hours U Proceed to SAWM actions per Part U SAWA flow may be reduced3.1.A (Step 7 of Table 3.]). to 85 GPM at four hours_____________________following SAWA initiation.* ~~Greater Than 24 Hour coping Detail *Provide a general description of the SA WA actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NEI 13-02 Section 4.2.2.4.1.3.1,1I.1.4SAWA Operation is the same for the full period of sustained operation. If SAWM is employed, flow rates will bedirected to preserve the availability of the HCVS wetwell vent (see 3.1 .A)." : ' ~~~DetailS: ...Details of Design Characteristics/Performance SpecificationsSA WA shall be capable of providing an RPV injection rate of 500 gpm within 8 hours of a loss of all RPV injectionfollowing an ELAP/Severe Accident. SA WA shall meet the design characteristics of the HCVS with the exception ofthe dedicated 24 hour power source. Hydrogen mitigation is provided by backflow prevention for SA WA.Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NEI 13-02 Section 1.1.4Equipment Locations/Controls/InstrumentationDresden has not performed a site specific evaluation to justify the use of a lower site unique initial SAWA flowrate. Consequently, Dresden will assume an initial flow rate of 421 gpm. This is based on the Industry genericvalue of 500 gpm multiplied by (Dresden rated power (2957 MWt)/Rated power for the generic plant (3514 MWt,NEI 13-02, 4.1.1.2.3). This initial flow rate will be established within 8 hours of the loss of all RPV injectionfollowing an ELAP/Severe Accident and will be maintained for four hours before reduction to the Wetwell ventpreservation flow rate.The locations of the SAWA equipment and controls, as well as ingress and egress paths will be evaluated for theexpected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period.Equipment will be evaluated to remain operational throughout the Sustained Operating period. Personnel exposureand temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERG doseand plant safety guidelines for temperature and humidity.The flow path will be suction at the intake structure for the plant Ultimate Heat Sink (UHS) through the submersiblepump and a downstream SAWA Booster pump. A valve manifold at the discharge of SAWA Booster pump willinclude valves with throttle capability and separate lines for Dresden Unit 2 RPV and Dresden Unit 3 RPV. Thisvalve manifold will also provide minimum flow and freeze protection for the pump. This pump and valve manifoldwill be in a suitable location to allow access under severe accident conditions.Page 32 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2From this valve manifold, hoses will be routed to the permanent SAWA connection point located in the ReactorBuilding 517' elevation. The connection at the Reactor Building location is on a LPCI line to the RPV. Thisconnection point includes one manual valve, which will be opened and kept open. In addition, it requires locallymanually opening motor operated valve (MOV) 2(3)-1501-22A(B) on the LPCI line. The second MOV (2(3)-1501-21A(B)) is normally open. The actions at the Reactor Building will be done within the first hour of the event priorto severe accident conditions occurring. Backflow in the LPCI line is prevented by an existing LPCI check valve2(3)- 1501 -25A(B).DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by use of the FLEX pumpcontrol valve at the valve manifold that also contains the SAWA flow indication. Communication will beestablished between the MCR and the SAWA flow control location.Containment instrumentation required for SAWA will be monitored through testing instruments powered frombatteries (e.g., 9 VDC).The Intake structure is a significant distance from the discharge of the HCVS pipe with substantial structuralshielding between the HCVS pipe and the pump deployment location. Pump refueling will also be accomplishedfrom the EDG fuel oil tanks as described in the EA-12-049 compliance documents. See mechanical and electricalsketches in attachments, plant layout sketches in the assumptions part and a list of actions elsewhere in this part.Evaluations of actions outside the Reactor Building for projected SA conditions (radiation ! temperature) indicatethat personnel can complete the initial and support activities without exceeding the ERG-allowable dose forequipment operation or site safety standards (reference HCVS-WP-02, Plant Specific Dose Analysis for the Ventingof Containment during SA Conditions). Evaluation of actions inside the Reactor Building for projected SAconditions (radiation/temperature) will be performed to determine that personnel can complete the initial andsupport activities without exceeding the ERG-allowable dose for equipment operation or site safety standards(reference HCVS-FAQ- 12).Electrical equipment and instrumentation will be powered from the power sources noted in the table below withportable generators to maintain battery capacities during the Sustained Operating period.Parameter Instrument Location Power Source / NotesDW Pressure* 2(3)-1640-11A(B) MCR Hand held testequipmentRG 1.97 qualifiedSuppression Pool Level* 2(3)-1640-13A(B) MCR Hand held testequipmentRG 1.97 qualifiedSAWA Flow* FLEX Pump Flow TBD Self-powered fromindicator internal batteryValve indications and NA NA All valves are locallycontrols manually operated* minimum required instruments.The instrumentation and equipment being used for SAWA and supporting equipment will be evaluated to performPage 33 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2for the Sustained Operating period under the expected radiological and temperature conditions.Equipment ProtectionSAWA installed components and connections external to protected buildings will be protected against the screened-in hazards of EA- 12-049 for the station. Portable equipment used for SAWA implementation will meet theprotection requirements for storage in accordance with the criteria in NEI 12-06, Revision 0.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 5.1.1, 5.4.6, 1.1.6Provide a brief description of Procedures I Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NEI 13-02 Section 1.3, 6.1.21. Connect SAWA pump discharge to LPCI piping.* Connect SAWA hose in Reactor Building (Step 2 of Table 3.1).* Open MOV 2(3)-150 1-22A(B).2. Connect SAWA pump to intake using FSG*.3. Power SAWAIHCVS components using FSG.4. Start SAWA pump to establish SAWA flow.5. Adjust SAWA flow at valve manifold and using SAWA flow indication to establish and maintain requiredflow.*Where an FSG (FLEX Support Guidelines) is referenced, it is yet to be determined if new guidance needs tobe developed or if it will be the same FSG reference with the same steps used for FLEX.Identify modifications:List modifications and describe how they support the SA WA Actions.Ref: EA-13-109 Attachment 2, Section B.2.2, / NET 13-02 Section 4.2.4.4, 7.2.1.8, Appendix IThe list of modifications, below, is limited to those required to upgrade EA-12-049 FLEX equipment to meet EA-13-109 Phase 2 SAWA requirements.Electrical Modifications -TBDMechanical Modifications -TBDInstrument Modifications -SAWA flow instrument (others TBD)Component Qualifications:State the qualification used for equipment supporting SA WARef: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 1.1.6Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this OIP.Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment asspecified in NEI 12-06 Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 designPage 34 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2conditions.Notes:NonePart 3.1 .A: Boundary Conditions for SAWAISAWM*
* Time periods for the maintaining SAWM actions such that the WW ventSA WM Actions supporting SA conditions that have a time constraint to be successful should be identified with atechnical basis and a justification provided that the time can reasonably be met (for example, a walkthrough ofdeployment). Actions already identified under the HCVS part of this template need not be repeated here.There are three time periods for the maintaining SA WM actions such that the W4W vent remains available to removedecay heat from the containment:* SAWM can be maintained for >7 days without the need for a dmywell vent to maintain pressure belowPCPL or containment design pressure, whichever is lower.o Under this approach, no detail concerning plant modifications or procedures is withrespect to how alternate containment heat removal will be provided.* SAWM can be maintained for at least 72 hours, but less than 7 days before DWpressure reaches PCPLor design pressure, whichever is lower.o Under this approach, a functional description is required of how alternate containment heatremoval might be established before DW pressure reaches PCPL or design pressure whichever islower~. Under this approach, physical plant mnodifications and detailed procedures are notnecessary, but written descriptions of possible app roaches for achieving alternate containment heatremoval and pressure control will be provided.* SAWM can be maintained for <72 hours SAWM strategy can be implemented but for less than 72hours before DW pressure reaches PCPL or design pressure whichever is lower.o Under this approach, a functional description is required of how alternate containment heatremo~val might be established before DW pressure reaches PC'PL or design pressure whichever islower. Under this approach, physical plant mnodifications and detailed procedures are required tobe implemented to insure achieving alternate containment heat removal and pressure control willbe provided for the sustained operating period.Ref: NEI 13-02 Appendix C.7SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.Basis for SAWM time frame... .. ."SAWM can be maintained >7 days:Dresden has not performed a site specific evaluation to justify the use of a lower site unique initial SAWA flowrate. Consequently, Dresden will assume an initial flow rate of 421 GPM. This is based on the Industry genericvalue of 500 gpm multiplied by (Dresden rated power/Rated power for the generic plant).This initial flow rate will be established within 8 hours of the loss of all RPV injection following an ELAP/SevereAccident and will be maintained for four hours before reduction to the Wetwell vent preservation flow rate of 85gpm.Page 35 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Instrumentation relied upon for SAWM operations is Drywell Pressure, Suppression Pool level and SAWA flow.Except for SAWA flow, SAWM instruments are initially powered by station batteries. After Station batterydepletion, these parameters will be monitored by portable test equipment using small batteries that will be availablefor the Sustained Operation period (7 days). The SAWA flow instrument will be self-powered from an internalpower supply capable of being replenished, if needed, through the Sustained Operation period. DW Temperaturemonitoring is not a requirement for compliance with Phase 2 of the order, but some knowledge of temperaturecharacteristics provides information for the operation staff to evaluate plant conditions under a severe accident andprovide confirmation to adjust SAWA flow rates (Ref. 9: C.7.l.4.2, C.8.3.1).Suppression Pool level indication is maintained throughout the Sustained Operation period, so the HCVS remainsin-service. The time to reach the level at which the WW vent must be secured is >7 days using SAWM flowrates(Ref. 9: C.6.3, C.7.1.4.3).Procedures will be developed that control the Suppression Pool level, while ensuring the DW pressure indicates thecore is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which SAWMflowrate should be adjusted (up or down) using suppression pool level and DW pressure as controlling parametersto remove the decay heat from the containment. (This is similar to the guidance currently provided in the .BWROGSAMGs.) (Ref. 9: C.7.1.4.3)Attachment 2.1 I.A shows the Sequence of Events Timeline for SAWA / SAWM. (Ref. 9: C.7. 1.4.4).Table 3 ,1,B -SAW M M anual Actions .* , ., ,Primary Action Primary Location!/Component Notes1. Lower SAWA injection rate to At the valve manifold on the e Control to maintaincontrol Suppression Pool Level SAWA Booster pump. containment and WWand decay heat removal. parameters to ensure WW ventremains functional.* 85 gpm minimum capability ismaintained for greater than 7days.2. Control SAWMV flowrate for Containment Instrument monitoring
* SAWM flowrate will becontainment control/decay heat in MCR. monitored using the followingremoval, instruments:SAWA flow at the valve manifold -SAWA Flowon the SAWA Booster pump. -Suppression Pool Level-Drywell Pressure* SAWM flowrate will becontrolled using the manualvalve at the valve manifold.3. Establish alternate decay heat Various locations. SAWM strategy can preserve theremoval. wetwell vent path for >7 days.4. Secure SAWA ! SAWM. At SAWA Pumps' location(s). When alternate decay heat removalis established.SAWM Time Sensitive Actions, Page 36 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Time Sensitive SAWM Actions:12 Hours -Initiate actions to maintain the Wetwell (WW) vent capability by lowering injection rate, whilemaintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the WWvent remains available.SAWiV Severe Accident OperationDetermine operating requirements for SA WM, such as may be used in an ELAP scenario to mitigate core damage.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix CIt is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plantinjection systems per direction by the plant SAMGs. Refer to Attachment 2.1 .D for SAWM SAMG languageadditions.First 24 Hour Coping DetailProvide a general description of the SA WM actions for first 24 hours using installed equipment including stationmodifications that are proposed.Given the initial conditions for EA-13-109:* BDBEE occurs with ELAP* Failure of all injection systems, including steam-powered injection systemsRef: EA-13-109 Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 I NEI 13-02 2.5, 4.2.2, Appendix C, SectionC.7SAWA will be established as described as stated above. SAWM will use the installed instrumentation to monitorand adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWMstrategy.Once the SAWA initial flow rate has been established for 4 hours, the flow will be reduced while monitoring DWpressure and Suppression Pool level. SAWM flowrate can be lowered to maintain containment parameters andpreserve the WW vent path. SAWM will be capable of injection for the period of Sustained Operation.= Greater Than 24 Hour Coping DetailProvide a general description of the SA WM actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 4.2.2, Appendix C,Section C.7SAWM can be maintained >7 days:The SAWM flow strategy will be the same as the first 24 hours until 'alternate reliable containment heat removaland pressure control' is reestablished. SAWM flow strategy uses the SAWA flow path. No additionalmodifications are being made for SAWM.t. Details:Page 37 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Details of Design Characteristics/Performance SpecificationsRef: EA-13-109 Attachment 2, Section B.2.2, B.2.3 I NEI 13-0)2 Section Appendix CSAWM shall be capable of monitoring the containment parameters (DW pressure and Suppression Pool Level) toprovide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control isestablished. SAWA will be capable of injection for the period of Sustained Operation.Equipment Locations/Controls/InstrumentationDescribe location for SA WM monitoring and control.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C, Section C.8, Appendix IThe SAWM control location is the same as the SAWA control location. Local indication of SAWM flow rate isprovided at the valve manifold by installed flow instrument qualified to operate under the expected environmentalconditions. The SAWA flow instrument is self-powered by an internal power supply. Communications will beestablished between the SAWM control location and the MCR.Injection flowrate is controlled by FLEX manual valve located on the valve manifold.Suppression Pool level and DW pressure will be read with hand-held test instruments. These indications are used tocontrol SAWM flowrate to the RPV.Key Parameters:List instrumentation credited for the SA WM Actions.Parameters used for SAWM are:* Drywell Pressure* Suppression Pool Level* SAWM FlowrateThe Drywe11 pressure and Suppression Pool level instruments (2(3)-1640-l1A(B) and 2(3)-1640-13A(B)) arequalified to RG 1.97 and are the same as listed in Part 2 of this OIP. The SAWM flow instrumentation will bequalified for the environmental conditions expected when needed.Notes:NonePage 38 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Part 3.1 .B: Boundary Conditions for SAWAISADVL ':" ", :/ .. " of WW Design Considerations" .. ""''This section is not applicable to Dresden since Dresden is not using the option of SADV.Table 3.1.C -SAD V Manual Actions-r " .... .. i. 'Timeline for SADVY_- '' "Severe Accident Venting -:First 24 Hour Coping Detail " "-* Greater Than 24 Hour Coping Detail -:* Details: :: .. " , 'Page 39 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Progralmmatic Controls. Training. Drills and MaintenanceIdentify how the programmatic controls will be met.Provide a description of the programmatic controls equipment protection, storage anddeployment and equipment quality addressing the impact of temperature and environment.Ref: EA-13-109 Section 3.1, 3.20 / NEI 13-02 Section 6.1.2, 6.1.3, 6.2Program Controls:The HCVS venting actions will include:*Site procedures and programs are being developed in accordance with NEI 13-02 to address useand storage of portable equipment relative to the Severe Accident defined in NRC Order EA-13-109 and the hazards applicable to the site per Part 1 of this OIP.*Routes for transporting portable equipment from storage location(s) to deployment areas will bedeveloped as the response details are identified and finalized. The identified paths and deploymentareas will be accessible when the HCVS is required to be functional including during SevereAccidents.Procedures:Procedures will be established for system operations when normal and backup power is available, andduring ELAP conditions.The HCVS and SAWA procedures will be developed and implemented following plant processes forinitiating or revising procedures and contain the following details:* appropriate conditions and criteria for use of the HCVS and SAWA* when and how to place the HCVS and SAWA in operation* location of system components* instrumentation available* normal and backup power supplies* directions for sustained operation (Reference 9), including the storage and location of portableequipment* location of the remote control HCVS operating station (panel)* training on operating the portable equipment* testing of portable equipmentDresden credits Containment Accident Pressure (CAP) for ECCS pump NPSH.Dresden will establish provisions for out-of-service requirements of the HCVS and compensatory measuresthat comply with the criteria from NEI 13-02 (Reference 9). The following provisions will be documentedin the HCVS Program Document:The provisions for out-of-service requirements for HCVS/SAWA are applicable in Modes 1, 2 and 3:* If for up to 90 consecutive days, the primary or alternate means of HCVS/SAWA operation are non-functional, no compensatory actions are necessary.* If for up to 30 days, the primary and alternate means of HCVS/SAWA operation are non-functional,Page 40 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and Maintenanceno compensatory actions are necessary.* If the out of service times exceed 30 or 90 days as described above, the following actions will beperformed through the site corrective action program:* Determine the cause(s) of the non-functionality,* Establish the actions to be taken and the schedule for restoring the system to functional statusand to prevent recurrence,* Initiate action to implement appropriate compensatory actions, and* Restore full HCVS functionality at the earliest opportunity not to exceed one full operatingcycle.Describe training planList training plans for affected organizations or describe the plan for training development.Ref: EA-13-109 Section 3.2 / NEI 13-02 Section 6.1.3Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receivenecessary training in the use of plant procedures for system operations when normal and backup power isavailable and during ELAP conditions. The training will be refreshed on a periodic basis and as anychanges occur to the HCVS/SAWAJSAWM actions, systems or strategies. Training content and frequencywill be established using the Systematic Approach to Training (SAT) process.Identify how the drills and exercise parameters will be met.Alignment with NE!113-06 andt 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking.The Licensee should demonstrate use in drills, tabletops, or exercises for HCVS operation as follows."* Hardened containment vent operation on normal power sources (no FLAP).*During FLEX demonstrations (as required by EA-12-049): Hardened containment vent operationon backup power and from. primary or alternate location during conditions of ELAP/loss of UHSwith no core danutge. System use is for containment heat removal AND containment pressurecontrol.*HCVS operation on backup power and from primar3, or alternate location during conditions ofFLAP/loss of UHS with core damage. System use is for containment heat renwval ANDcontainment pressure control with potential for combustible gases (Denonstration maty be inconjunction with SAG change).* Operation for sustained period with SAWA andt SAWM to provide decay heat removal andcontainment pressure control.Ref: EA-13-109 Section 3.1 / NET 13-02 Section 6.1.3Dresden will utilize the guidance provided in NEI 13-06 and 14-01 (References 10 and 11) for guidancerelated to drills, tabletops, or exercises for HCVS operation. In addition, Dresden will integrate theserequirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9.Page 41 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and MaintenanceDescribe maintenance plan:o The maintenance program should ensure that the HCVS/SAWA/SAWM equipment reliability is beingachieved in a manner similar to that required for FLEX equipment. Standard industr~y templates (e.g.,EPRI) and associated bases may be developed to define specific maintenance and testing.o Periodic testing and frequency should be determined based on equipment type and expecteduse (further details are provided in Part 6 of this document).o Testing should be done to verify design requirements and/or basis. The basis should bedocumented and deviations fr'om vendor recommendations and applicable standards shouldbe justifiled.o Preventive maintenance should be determined based on equipment type and expected use. Thebasis should be documented and deviations from vendor recommendations and applicablestandards should be justified.o Existing work control processes may be used to control maintenance and testing.* HCVS/SA WA permanent installed equipment should be maintained in a manner that is consistent withassuring that it performs its function when required.o HCVS/SAWA permanently installed equipment should be subject to maintenance and testingguidance provided to verify proper function.* HCVS/SAWA non-installed equipment should be stored and maintained in a manner that is consistentwith assuring that it does not degrade over long periods of storage and that it is accessible forperiodic maintenance andt testing.Ref: EA-13-109 Section 1.2.13 / NEL 13-02 Section 5.4, 6.2Dresden will utilize the standard EPRI industry PM process (similar to the Preventive Maintenance BasisDatabase) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SAWMcomponents. The control program will include maintenance guidance, testing procedures and frequenciesestablished based on type of equipment and considerations made within the EPRI guidelines.Dresden will implement the following operation, testing and inspection requirements for the HCVS andSAWA to ensure reliable operation of the system.Table 4-1: Testing and Inspection RequirementsDescription FrequencyCycle the HCVS and installed SAWA valves' Once per every2 operating cycleand the interfacing system valves not used tomaintain containment integrity during Mode 1,2 and 3. For HCVS valves, this test may beperformed concurrently with the control logictest described below.Cycle the HCVS and installed SAWA check Once per every other4 operating cyclevalves not used to maintain containmentintegrity during unit operations3.Perform visual inspections and a walk down of Once per every other4 operating cycleHCVS and installed SAWA components.Page 42 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and MaintenanceFunctionally test the HCVS radiation monitors.Once per operating cycleLeak test the HCVS. (1) Prior to first declaring the systemfunctional;(2) Once every three operating cyclesthereafter; and(3) After restoration of any breach ofsystem boundary within the buildingsValidate the HCVS operating procedures by Once per every other operating cycleconducting an open/close test of the HCVScontrol function from its control location andensuring that all HCVS vent path andinterfacing system valves5 move to their proper(intended) positions.SNtrequired for HCVS and SAWA check valves.2 Atrtwo consecutive successful performances, the test frequency may be reduced to a maximum of onceper every other operating cycle.3 o required if integrity of check function (open and closed) is demonstrated by other plant testingrequirements.4Atrtwo consecutive successful performances, the test frequency may be reduced by one operatingcycle to a maximum of once per every fourth operating cycle.5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (lossof power and/or air) do not require control function testing under this part. Performing existing plantdesign basis function testing or system operation that reposition the valve(s) to the HCVS requiredposition will meet this requirement without the need for additional testing.Notes:PCIVs are required for containment integrity during Modes 1-3 and thus are excluded from EA-13-109testing requirements. However, these PCI Vs are tested per by the Dresden design basis requirements toensure valve operability and leakage tightness. Refer to generic assumption 109-4.Page 43 of 69 Darese NucMlearPwrstatone Sceunis2enPart 5: Milestone ScheduleProvide a milestone schedule. This schedule should include:* Modifications timeline* Procedure guidance development completeo HCVS Actionso Maintenance* Storage plan (reasonable protection)* Staffing analysis completion* Long term use equipment acquisition timeline* Training completion for the TICVS ActionsThe dates specifically required by the order are obligated or" committed dates. Other dates are planned dates subjectto change. Updates will be provided in the periodic (six month) status reports.Ref: EA-13-109 Section D.1, D.3 / NET 13-02 Section 7.2.1The following milestone schedule is provided. The dates are planning dates subject to change as design andimplementation details are developed. Any changes to the following target dates will be reflected in the subsequent6-month status reports.Phase 1 Milestones:Milestone Target Activity Status CommentsCompletionDateHold preliminary/conceptual design meeting June 2014 CompleteSubmit Overall Integrated Implementation Plan Jun 2014 CompleteSubmit 6 Month Status Report Dec 2014 CompleteSubmit 6 Month Status Report Jun 2015 CompleteSubmit 6 Month Status Report Dec. 2015 Complete with Simultaneous withthis submittal Phase 2 OIPU3 Design Engineering Complete December Started2015U3 Implementation Outage October Not Started2016U3 Maintenance and Operation Procedure Changes November Not StartedDeveloped, Training Complete, & Walk-Through 2016Demonstration/Functional TestU2 Design Engineering Complete September Not Started2016U2 Implementation Outage October Not Started2017U2 Maintenance and Operation Procedure Changes November Not StartedDeveloped, Training Complete, & Walk-Through 2017Demonstration/Functional TestPage 44 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 5: Milestone ScheduleSubmit Completion Report May 2018Phase 2 Milestone Schedule: .. ..Phase 2 Milestone ScheduleMilestone Target Activity Status CommentsCompletionDateSubmit Overall Integrated Implementation Plan Dec 2015 Complete with Simultaneous withthis submittal Phase 1 Updated OWPHold preliminary/conceptual design meeting Jan 2016 Expect to beengineeringjustification notmodificationsSubmit 6 Month Status Report June 2016Submit 6 Month Status Report Dec 2016Submit 6 Month Status Report June 2017Submit 6 Month Status Report Dec 2017Submit 6 Month Status Report June 2018Submit 6 Month Status Report Dec 2018U2 Design Engineering Complete October 2016 Not Started Conceptual completedU2 Implementation Outage October 2017 Not Started Concurrent with Unit 2Phase 1U2 Maintenance and Operation Procedure Changes Developed, November Not Started SAMG Revision;Training Complete, & Walk-Trough Demonstration/Functional 2017 Concurrent with Unit 2Test Phase 1U3 Design Engineering Complete TBD Not StartedU3 Implementation Outage October 2018 Not StartedU3 Maintenance and Operation Procedure Changes Developed, November Not StartedTraining Complete, & Walk-Trough Demonstration/Functional 2018TestSubmit Completion Report May 2019Notes:NonePage 45 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 1: HCVS/SAWA/SADV Portable EquipmentBDBEE Severe Performance Maintenance /PM requirementsList portable equipment Venting Accident CriteriaVentingNitrogen Cylinders X X 2 cylinders Check periodically for pressure, replace orreplenish as needed (EC 400578,frequency specified by PM).Argon Cylinders NA X 14 cylinders Check periodically for pressure, replace orreplenish as needed.FLEX DG X X 800 KW 480V Per response to EA-12-049.FLEXISAWA Pump X X TBD Per vendor manual.Portable Air Compressor (optional) X X TBD Per vendor manual.Small Portable Generator X X TBD Per vendor manual.DW Pressure Indicator. Hand Held Test Eqpt. X X TBD Per vendor manualSuppression Pool Level Indicator, Hand Held X X TBD Per vendor manualTestEquipment ____________ _________ __________________Page 46 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2A: Seqiuence of Events Timeline -HCVSELAPt=OIS& ICS securedHPCI in due to shell sideservice inventorytr2.0m t= 20m ICS Rc~stnred hHPCI assumedlost (Flex OIP)No Injectiont=12 hrs. Begin monitoringHCVS support systems. Noreplenishment expected to berequired until 24 hours.utt=]Inlectitingtingt= 1{2 hrst= 24 hrs. Replenishmentof HCVS supportssystems required.18ion{SAWALost IlniectionLevel at 'TAFtz 23 hrs 24 hrs t= 3t=z 2't hrsSequence 1FLEX successful;Containment ventingnot required due toICSU/hrsContainment Ven(based on preventexceeding PCPL)t,Sequence 2SRCIC Late FailureRef: SECY-12-0 157t= 168 hrs Sequence 3*3 RCIC Early FailureRef: SOARCACoret~l r hrsSAWAIniectionLegendNot to ScaleAdequate core cooling maintained.... .......... Injection lostIncreased shine at wetwell-Post-RPV hreachPage 47 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .A: Sequence of Events Timeline -SAWA / SAWMSustained Operation periodT=168 hoursT=168 hoursSAWAMonitor containment parameters and conditions)Time ActionT=0 hours Start of FLAPT=8 hours Initiate SAWA flow at 421 gpm as soon as possible but no later than 8 hoursT=12 hours Throttle SAWA flow to 85 gpm 4 hours after initiation of SAWA flowT=168 hours End of Sustained OperationPage 48 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .B Sequence of Events Timeline -SADVNot applicable to DresdenPage 49 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .C: SAWA/SAWM Plant-Specific DatumSpill Over Pptrfl -2 503'Spillovertiejtt.t LEDrywell FloorEL Wetwetl Levelinstrumentrange (0-30')Wetwell14 9' MAX LCO (TSG-2)Total Torus Height 30fTorus Max [CO Level 14' -9" (897500 gal)Total Torus Voume -1919000 galFreeboard volume in torus ~1021500 galRate of level rise -0 3 ft/hr @ 421 gpmRate of level rise 0 0074 ft/hr @ 85 gpmTotal water added (421 gpm for 4 hours and85 gpm for 164 hours ~940000 galNote: The above calculation does not considermass loss rate by steam leaving the vernj,making the above estimates very conservativePage 50 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .D: SAWM SAMG Approved LanguageThe following general cautions, priorities and methods will be evaluated for plant specific applicability and incorporated as appropriate into the plant specificSAMGs using administrative procedures for EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefo~re addressa wide variety of possible plant conditions and capabilities while these changes are intended to accommodate those specific conditions assumed in Order EA-13-109. The changes will be made in a way that maintains the use of SAMGs in a s)ymptom based mode while at the same time addressing those conditions that mayexist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris.Actual Approved Language that will be incorporated into site SAMG*Cautions:SAddressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapidsteam generation.* Addressing the plant impact that raising suppression pool water level above the elevation of the suppression chamber vent opening elevation will flood thesuppression chamber vent path.Priorities:With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases asfollows:* Core debris in the primary containment is stabilized by water addition (SAWA).* Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting).* Water addition is managed to preserve the Mark I/II suppression chamber vent paths, thereby retaining the benefits of suppression pool scrubbing andminimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM).Methods:Identify systems and capabilities to add water to the RPV or drywell, with the Ib)llowing generic guidance:* Use controlled injection if possible.* Inject into the RPV if possible.Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.* Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.Page 51 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 3: Conceptual Sketches(Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies)Sketch 1A Electrical Layout of System (preliminary)Sketch 2A P&ID Layout of Wetweil VentSketch 2B Remote Operating StationSketch 2C HCVS Layout OverviewSketch 3A P&ID Layout of SAWASketch 3B SAWA Site LayoutPage 52 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 1A" Electrical Layout of System -HCYSpItV..),IA..3A.IA,IA)A.IPage 53 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2A: P&ID of Wetwell VentTO SI~OCFC0I-II2(3)-I1601-931601-13FCNCRupture DiscI!KEY16w-GoNCfin[~] )kA 14liii Iimliii N-m ~EW NE~-m DUTUatterv Power and Nitrogoenuoolv to Valves:601.-23501-60ew Block Valveew Control ValveSDRESDEN HCVS SCHEMATICPage 54 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2B: Remote Operating Station0o1rIjI_I-EC 40578REVI j057Rg1"O"I- ~' IIaPage 55 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2B contd..: Remote Operating StationROS for Unit 3-UA~m~E) Ir ~WO~KnPJ _"AR" ~ EL. -~me 5~ c*'r ~ir~j~~1/L1-)i1 -L*14.grL7~.%C ~-XrU~rrI TEA-~ IILU~ Wi4f~ ~ ________~i. ~?9 0 ~EC1~PUW r.~ItL.~IImm'7?0II (CI) I~K. I~~Q34-~*IM~ '7I~It~I 1i~~~f1&#xb6; ?4*4 ---u-~ '~ms ~1~r i~j~ ~4~'A ~? _ -~ ~___ _ :.6~L~ PLAN Eu. .~ JULUt-I _______ te UPage 56 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2C; HCVS Layout Overview -View I41 RELEASEATELEVG65'~OPO~ CRANIRAIL CL,~1I,~-~__________ MACH. AOO~ RQO~I MMJ.~L@~e. I'TO CAANt CA~IL. ~ai-*UNIT 2--- -~MlWd~ft ~Ift*L 'TAWC_______________ potA. ta, t~wIJ~IT2 ~ ~ L~-LL. S43~(C~dThQ4.~OD bAwlHY~S.AUIJC ~LMM(MT~AC~UM, M4.1@AtQP~1. A~9~7tF~VPIftOI1Ll~. ~~gTTOMOP NLAOL~b~1W~LL g~u'~ OAA.H FLOCA IL. 474~4__ FROM PA-BPage 57 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2C contd...: HCVS Layout Overview -View 2 showing ROSQtop ow ~YACe~&#xa3;L. S7~ 4~t1ff- af- I&R 30..IL ~ **I4 ~Th AUR. *Wgg?POU I RIM.cAR-6:4a RIACtORL1IWAUX ~?ACICIt5UILOrU-'S~R M0~&#xa3;L.It. !V.~,M-6~4~]II... &#xa3;94VS~~3IL.~3 1WY~a.m 4 M~WL4. TURRIME I ~4.LI TURBINE DECK 56V EL -.I,tI]jULWt~*JE1~J'u~ICON?Ashti's~IYATI'U".WAIlCut""'U2t.*R@0-ttt.~Irt'~IIL S1.TI~IIMtO.nA~ta.SQLUI'0W IAII~wAa~I'f ,4II5'SALIUI ]lIJSE.CI ION; B-BM1~'.---30WIPage 58 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 3A: P&ID Layout of SAWAToRPV1501-25 1501-26TORUSTo OtDivisiof LFLPCI HeatExchangerSAWABoosterPumptherion.1SAWA FlowIndicatorTo Other -...Unit SAWA TM .-...... Hose ".SAWA FlowIndicatorLiUHSLPCI PumpUHS SubmersiblePumpPage 59 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 3B: SAWA Site Layout,Page 60 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 4: Failure Evaluation Table (per NEI 13-06)Table 4A: Wetwell HCVS Failure Evaluation TableFunctional Failure Failure Cause Alternate Action Failure with AlternateMode Action Prevents____________Containment Venting?Fail to Vent (Open) Valves fail to open/close due to loss of normal None required -system SOVs utilize Noon Demand AC power/DC batteries, dedicated 24-hour power supply. ___________Valves fail to open/close due to depletion of Recharge system with provided portable Nodedicated power supply. generators.____________Valves fail to open/close due to complete loss Manually operate backup pneumatic NoOf power supplies, supply/vent lines at ROS. ___________Valves fail to open/close due to loss of normal No action needed. Valves are provided with Nopneumatic supply. dedicated motive force capable of 24-hour_____ ____ ____ ____ ____ ____ ____ ____ operation._ _ _ _ _ _ _ _ _ _ _ _Valves fail to open/close due to loss of Replace bottles as needed and/or recharge Noalternate pneumatic supply (long term). with portable air compressors.____________Valve fails to open/close due to SOV failure. Manually operate backup pneumatic Nosupply/vent lines at ROS.Fail to stop venting Not credible as there is not a common mode N/A No(Close) on demand failure that would prevent the closure of atleast 1 of the 2 valves needed for venting.Both valves designed to fail shut.____________________Spurious Opening Not credible as key-locked switch prevents N/A Nomispositioning of the downstream HCVSPCIV and, additionally, DC power for the_______________solenoid valve is normally de-energized. ____________________Spurious Closure Valves fail to remain open due to depletion of Recharge system with provided portable Nodedicated power supply, generators.Valves fail to remain open due to complete Manually operate backup pneumatic Noloss of power supplies, supply/vent lines at ROS.Valves fail to remain open due to loss of Replace bottles as needed and/or recharge Noalternate pneumatic supply (long term). with portable air compressors.Page 61 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 5: References1. Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regardto Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-13-109) RS-14-0582. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 19893. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 20124. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 20135. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis ExternalEvents, dated August 29, 20126. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents,dated November 14, 20137. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-IS G-2012-02: Compliance with Order EA- 12-050, Order Modifying Licenses with Regard to Reliable HardenedContainment Vents, ADAMS Accession No. ML12229A477, dated August 29, 20128. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August20129. NET 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 201510. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events,Revision 0, dated March 201411. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision0, dated March 201412. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations13. NEI HCVS-FAQ-02, HCVS Dedicated Equipment14. NEI HCVS-FAQ-03, HCVS Alternate Control Operating Mechanisms15. NEI HCVS-FAQ-04, HCVS Release Point16. NEI HCVS-FAQ-05, HCVS Control and 'Boundary Valves'17. NEI HCVS-FAQ-06, FLEX Assumptions/HCVS Generic Assumptions18. NEI HCVS-FAQ-07, Consideration of Release fr'om Spent Fuel Pool Anomalies19. NEI HCVS-FAQ-08, HCVS Instrument Qualifications20. NEl FHCVS-AQ-09, Use of Toolbox Actions for Personnel21. NEI White Paper HCVS-WP-01, HCVS Dedicated Power and Motive Force22. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach23. NEI White Paper HCVS-WP-03, Hydrogen/CO Control Measures24. Not Used25. NURFG/CR-71 10, Rev. 1, State-of-the-Art Reactor Consequence Analysis Project, Volume 1: Peach BottomIntegrated Analysis26. SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling WaterReactors with Mark I and Mark II Containments, 11/26/1227. Dresden UFSAR, Updated Safety Analysis Report.28. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1F Equipment forNuclear Power Generating Stations29. FLEX MAAP Endorsement ML13190A20130. Not Used31. JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regardto Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, datedApril 201532. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade,Revision 0, dated August 17, 201533. NEI HCVS-FAQ-10, Severe Accident Multiple Unit Response34. NEl HCVS-FAQ-1 1, Plant Response During a Severe Accident35. NEl HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial UsePage 62 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents36. NEI HCVS-FAQ-13, Severe Accident Venting Actions Validation37. MAAP Analysis to Support FLEX initial strategy, RM Document No. DR-MISC-043 Rev. 1Page 63 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 6: Changes/Updates to this Overall Integrated ImplementationPlanThis Overall Integrated Plan has been updated in formnat and content to encompass both, Phase 1 and Phase 2 of OrderEA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6-Month Status Reports.NonePage 64 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 7: List of Overall Integrated Plan Open ItemsThe following tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the statusof each item.Phase 1 Open Items from OIP StatusOpenItems1 Confirm that at least 6 hours battery coping time is available. Deleted. Closed to ISE Open Item number 1.2 Determine actions to enable wetwell (WW) venting following a flooding around the torus. Deleted. Closed to ISE Open Item number 2.3 Determine how Motive Power and/or HCVS Battery Power will be disabled during normal Deleted. Closed to ISE Open Item number 3.operation.4 Confirm that the Remote Operating Station (ROS) will be in an accessible area following a Deleted. Closed to ISE Open Item number 12.Severe Accident (SA).5 Confirm diameter on new common HCVS Piping. Deleted. Closed to ISE Open Item number 5.6 Confirm suppression pool heat capacity. Deleted. Closed to ISE Open Item number 6.7 Determine the approach for combustible gases. Deleted. Closed to ISE Open Item number 7.8 Provide procedures for HCVS Operation. Deleted. Closed to ISE Open Item number 18.9 Perform radiological evaluation for Phase ivent line impact on ERO response actions. Not StartedPage 65 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPhase 1 Interim Staff Evaluation (ISE) Open Items StatusOpenItems1Make available for NRC staff audit documentation confirming that Complete. EC 391973 Rev. 0 was completed to evaluate proposed battery loadat least 6 hours battery coping time is available, shed to support FLEX events. The evaluation addressed both 125V and 250Vbattery systems. The evaluation identified that with the load shed, the 125V and250V batteries will maintain acceptable capacity for a minimum of six (6)hours. This time supports the FLEX Strategy time line actions.2 Make available for NRC staff audit documentation that confirms the Started.ability to operate HCVS following flooding around the suppressionpool.3Make available for NRC staff audit documentation of a method to Started.disable HCVS during normal operation to provide assurancesagainst inadvertent operation that also minimizes actions to enableHCVS operation following an ELAP.4 Make available for NRC staff audit the seismic and tornado missile Started.________final design criteria for the HCVS stack.5 Make available for NRC staff audit documentation of the licensee Started. Refer to the response to ISE open item 6.design effort to confirm the diameter on the new common HCVSpiping.6Make available for NRC staff audit analyses demonstrating that Started. The required 1% vent capacity at the lower of PCPL or containmentHCVS has the capacity to vent the steam/energy equivalent of one design pressure is being verified using RELAP which models the line size andpercent of licensed/rated thermal power (unless a lower value is routing.justified), and that the suppression pool and the HCVS together are In addition, MAAP analyses are being credited to verify that venting can beable to absorb and reject decay heat, such that following a reactor delayed for at least three (3) hours, which supports assuming a maximum decayshutdown from full power containment pressure is restored and then heat rate of 1%.maintained below the primary containment design pressure and theprimary containment pressure limit.7Provide a description of the final design of the HCVS to address Started. Argon purge system design in progress.hydrogen detonation and deflagration.8Make available for NRC staff audit documentation of a Started.determination of seismic adequacy for the ROS location.Page 66 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents9 Make available for NRC staff audit documentation that demonstrates Not Started.adequate communication between the remote HCVS operationlocations and HCVS decision makers during ELAP and severeaccident conditions.10 Provide a description of the strategies for hydrogen control that Started. As described in the OIP, the HCVS torus vent path in each Dresdenminimizes the potential for hydrogen ga~s migration and ingress into unit, starting at and including the downstream PCIV, will be a dedicated HCVSthe reactor building or other buildings. flow path. There are no interconnected systems downstream of the downstream,dedicated HCVS PCIV. Interconnected systems are upstream of the downstreamHCVS PCIV and are isolated by normally shut, fail shut PCIVs which, if open,would shut on an ELAP. There is no shared HCVS piping between the twounits.The vent path will rely on an Argon purge system to prevent line failure due to____________________________________________hydrogen deflagration and detonation.11 Provide descriptions of design details that minimize unintended Started. Refer to the response to ISE item 10. This eliminates the possibility ofcross flow of vented fluids within a unit and between units on the cross flow of vented fluids within a unit and between the two units.site.12 Make available for NRC staff audit an evaluation of temperature and Started. Component location design in progress. The HCVS primary controlradiological conditions to ensure that operating personnel can safely panel will be located in the Main Control Room (MCR).access and operate controls and support equipment.13 Make available for NRC staff audit the final sizing evaluation for Started.HCVS batteries/battery charger including incorporation into FLEXDG loading calculation.14 Make available for NRC staff audit documentation of the HCVS Started. Nitrogen system design in progress.nitrogen pneumatic system design including sizing and location.15 Make available for NRC staff audit descriptions of all Started. Instrument design in progress.instrumentation and controls (existing and planned) necessary toimplement this order including qualification methods.Page 67 of 69 Dresden Nuclear Power Station Units 2 and 3________Overall Integrated Plan for Reliable Hardened Vents16 Make available for NRC staff audit the descriptions of local Started. Component location design in progress. The HCVS primary controlconditions (temperature, radiation and humidity) anticipated during panel will be located in the MCR.ELAP and severe accident for the components (valves,instrumentation, sensors, transmitters, indicators, electronics, controldevices, etc.) required for HCVS venting including confirmation thatthe components are capable of performing their functions duringELAP and severe accident conditions.17 Make available for NRC staff audit documentation of an evaluation Started. The existing containment isolation valves are being evaluated for theirverifying the existing containment isolation valves, relied upon for performance under wetwell venting conditions.the HCVS, will open under the maximum expected differentialpressure during BDBEE and severe accident wetwell venting.18 Make available for NRC staff audit procedures for HCVS operation. Not StartedPage 68 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPhase 2 Open Items from OIP CommentOpenItem1 Determine SAWA flow control. Not started2 Resolve location of the FLEX DG to mitigate radiological Not startedconsequences during severe accident conditions.3 Validate time-line for Reactor Building hose connections does not Not started________exceed 1 hour. __________________________________Page 69 of 69
~Exelton GenerationOrder No. EA-13-109RS-1 5-299December 16, 2015U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Dresden Nuclear Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-19 and DPR-25NRC Docket Nos. 50-237 and 50-249
 
==Subject:==
Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013Commission Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-1 3-1 09)
 
==References:==
: 1. NRC Order Number EA-1 3-109, "Issuance of Order to Modify Licenses with Regard toReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions," dated June 6, 20132. NRC Interim Staff Guidance JLD-ISG-201 5-01, "Compliance with Phase 2 OrderEA-13-1 09, order Modifying Licenses with Regard to Reliable Hardened ContainmentVents Capable of Operation under Severe Accident Conditions", Revision 0, datedApril 20153. NEI 13-02, "Industry Guidance for Compliance With Order EA-1 3-1 09, BWR Mark I & IIReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions", Revision 1, dated April 20154. Exelon Generation Company, LLC's Answer to June 6, 2013, Commission OrderModifying Licenses with Regard to Reliable Hardened Containment Vents Capable ofOperation Under Severe Accident Conditions (Order Number EA-13-1 09), datedJune 26, 20135. Exelon Generation Company, LLC Phase 1 Overall Integrated Plan in Response to June6, 2013 Commission Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-13-109), dated June 30, 2014 (RS-14-058)6. Exelon Generation Company, LLC First Six-Month Status Report Phase 1 OverallIntegrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses withRegard to Reliable Hardened Containment Vents Capable of Operation Under SevereAccident Conditions (Order Number EA-13-109), dated December 17, 2014 (RS-14-302)7. Exelon Generation Company, LLC Second Six-Month Status Report Phase 1 OverallIntegrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses withRegard to Reliable Hardened Containment Vents Capable of Operation Under SevereAccident Conditions (Order Number EA-13-109), dated June 30, 2015 (RS-15-148)
U.S. Nuclear Regulatory CommissionIntegrated Plan Report to EA-13-109December 16, 2015Page 28. NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2and 3 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4462and MF4463), dated February 11, 2015On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order(Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediatelyeffective and directs EGC to require their BWRs with Mark I and Mark II containments to takecertain 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 withinacceptable limits following events that result in loss of active containment heat removal capabilitywhile maintaining the capability to operate under severe accident (SA) conditions resulting froman Extended Loss of AC Power (ELAP). Specific requirements are outlined in Attachment 2 ofReference 1.Reference 1 requires submission of an Overall Integrated Plan (QIP) by June 30, 2014 forPhase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order. The interimstaff guidance (Reference 2) provides direction regarding the content of the OIP for Phase 1 andPhase 2. Reference 2 endorses industry guidance document NEI 13-02, Revision 1(Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 providedthe EGC initial response regarding reliable hardened containment vents capable of operationunder severe accident conditions. Reference 5 provided the Dresden Nuclear Power Station,Units 2 and 3, Phase 10OIP. References 6 and 7 provided the first and second six-month statusreports pursuant to Section IV, Condition D.3 of Reference 1 for Dresden Station.The purpose of this letter is to provide both the third six-month update for Phase 1 of the Orderpursuant to Section IV, Condition D.3, of Reference 1, and the OIP for Phase 2 of the Orderpursuant to Section IV, Condition D.2 of Reference 1, for Dresden Nuclear Power Station, Units 2and 3. The third six-month update for Phase 1 of the Order is incorporated into the HCVSPhase 1 and Phase 2 overall integrated plan document which provides a complete updatedPhase I OIP, a list of the Phase 10OIP open items, and addresses the NRC Interim StaffEvaluation open items for Phase 1 contained in Reference 8. Future six-month status reports will.provide the updates for both Phase 1 and Phase 20OIP implementation in a single status report.Reference 3, Section 7.0. contains the specific reporting requirements for the Phase 1 andPhase 20OIP. The information in the Enclosure provides the Dresden Nuclear Power Station,Units 2 and 3 HCVS Phase 1 and Phase 20OIP pursuant to Reference 2. The enclosed Phase 1and Phase 20OIP is based on conceptual design information. Final design details and associatedprocedure guidance, as well as any revisions to the information contained in the Enclosure, willbe provided in the six-month Phase 1 and Phase 20OIP updates required by Section IV, ConditionD.3, of Reference 1.This letter contains no new regulatory commitments. If you have any questions regarding thisreport, please contact David P. Helker at 610-765-5525.
U.S. Nuclear Regulatory CommissionIntegrated Plan Report to EA-13-109December 16, 2015Page 3I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th dayof December 2015.Respectfully submitted,Glen T. KaegiDirector -Licensing & Regulatory AffairsExelon Generation Company, LLC
 
==Enclosure:==
Dresden Nuclear Power Station, Units 2 and 3, Overall Integrated Plan for Phase 1 andPhase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable ofOperation Under Severe Accident Conditionscc: Director, Office of Nuclear Reactor RegulationNRC Regional Administrator -Region IllNRC Senior Resident Inspector -Dresden Nuclear Power StationNRC Project Manager, NRR -Dresden Nuclear Power StationMr. Charles H. Norton, NRR/JLD/PPSD/JOMB, NRCMr. John P. Boska, NRR/JLD/JOMB, NRCIllinois Emergency Management Agency -Division of Nuclear Safety  Dresden Nuclear Power Station, Units 2 and 3Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable HardenedContainment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions(69 pages)
Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsTable of Contents:IntroductionPart 1: General Integrated Plan Elements and AssumptionsPart 2: Boundary Conditions for Wet Well VentPart 3: Boundary Conditions for EA-13-109, Option B.2Part 3.1 Boundary Conditions for SAWAPart 3.1A Boundary Conditions for SAWAISAWMPart 3.1B Boundary Conditions for SAWAISADVPart 4: Programmatic Controls, Training, Drills and MaintenancePart 5: Implementation Schedule MilestonesAttachment 1: HCVS/SAWA Portable Eq~uipmentAttachment 2A: Seqiuence of Events Timeline -HCVSAttachment 2.1.A: Sequence of Events Timeline -SAWA / SAWMAttachment 2.1.B: Sequence of Events Timeline -SADVAttachment 2.1.C: SAWA / SAWM Plant-Specific DatumAttachment 2.1.D: SAWM SAMG Approved LanguageAttachment 3: Conceptual SketchesAttachment 4: Failure Evaluation TableAttachment 5: ReferencesAttachment 6: Changes/Updates to this Overall Integrated Implementation PlanAttachment 7: List of Overall Integrated Plan Open ItemsPage 1 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsIntroductionIn 1989, the NRC issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," (Reference 2)to all licensees of Boiling Water Reactors (BWRs) with Mark I containments to encourage licensees tovoluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from thesuppression pooi to some point outside the secondary containment envelope (usually outside the reactorbuilding). Some licensees also installed a hardened vent branch line from the dryweUl.On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff perStaff Requirements Memorandum (SRM) for SECY-12-0 157 (Reference 26) to require licensees withMark I and Mark II containments to "upgrade or replace the reliable hardened vents required by OrderEA-12-050 with a containment venting system designed and installed to remain functional during severeaccident conditions.' In response, the NRC issued Order EA-13-109, Issuance of Order to ModifyLicenses with Regard to Reliable Hardened Containment Vents Capable of Operation Undter SevereAccidents, June 6, 2013 (Reference 4). The Order (EA-13-109) requires that licensees of BWR facilitieswith Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent toremove decay heat from the containment, and maintain control of containment pressure within acceptablelimits following events that result in the loss of active containment heat removal capability whilemaintaining the capability to operate under severe accident (SA) conditions resulting from an ExtendedLoss of AC Power (ELAP).The Order requirements are applied in a phased approach where:* "Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable,severe accident capable hardened vents to assist in preventing core damage and, if necessary, toprovide venting capability during severe accident conditions." (Completed "no later than staltup fromthe second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comesfirst.")*"Phase 2 involves providing additional protections for severe accident conditions through instailationof a reliable, severe accident capable drywell vent system or the development of a reliablecontainment venting strategy that makes it unlikely that a licensee would need to vent from thecontainment drywell during severe accident conditions." (Completed "no later than startup from thefirst refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.")The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim StaffGuidance (ISG) (JLD-ISG-2013-02) issued in November 2013 (Reference 6) and JLD-ISG-2015-01issued in April 2015 (Reference 31). The IS Gs endorse the compliance approach presented in NEI 13-02Revisions 0 and 1, Compliance with Order EA-13-109, Severe Accident Reliable Hardened ContainmentVents (Reference 9), with clarifications. Except in those cases in which a licensee proposes an acceptablealternative method for complying with Order EA-13-109, the NRC staff will use the methods described inthese ISGs to evaluate licensee compliance as presented in submittals required in Order EA-13-109.The Order also requires submittal of an overall integrated plan which will provide a description of howthe requirements of the Order will be achieved. This document provides the Overall Integrated Plan (OIP)for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRCJLD-ISG-2013-02 and JLD-ISG-2015-01. Six month progress reports will be provided consistent with therequirements of Order EA- 13-109.Page 2 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsThe submittals required are:* OIP for Phase 1 of EA-13.-109 was required to be submitted by Licensees to the NRC by June 30,2014. The NRC requires periodic (6-month) updates for the HCVS actions being taken. The firstupdate for Phase 1 was due December 2014, with the second due June 2015.* OIP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31,2015. It is expected the December 2015 six month update for Phase 1 will be combined with thePhase 20OP submittal by means of a combined Phase 1 and 20IO.*Thereafter, the 6-month updates will be for both the Phase 1 and Phase 2 actions until complete,consistent with the requirements of Order EA-13-109.Note: Per the Generic OIP, at the Licensee's option, the December 2015 six month update for Phase 1may be independent of the Phase 20OIP submittal, but will require separate six month updates forPhases 1 and 2 until each phase is in compliance. Exelon has not selected this option.The Dresden venting actions for the EA-13-109, Phase 1 severe accident capable venting scenario can besummarized by the following:*The Hardened Containment Vent System (HCVS) will be initiated via manual action from eitherthe Main Control Room (MCR) or from a Remote Operating Station (ROS) at the appropriatetime based on procedural guidance in response to plant conditions from observed or derivedsymptoms. The ROS capabilities are limited to the Order EA-13-109 Requirement 1.2.5.Specifically, in case the HCVS flow path valves or the Argon purge flow cannot be opened fromthe MCR, the ROS provides a back-up means of opening the valve(s) that does not requireelectrical power or control circuitry.*The vent will utilize Containment Parameters of Pressure and Suppression Pool Level from theMCR instrumentation to monitor effectiveness of the venting actions.*The vent operation will be monitored by HCVS valve position, temperature and effluent radiationlevels.*The HCVS motive force will be monitored and have the capacity to operate for 24 hours withinstalled equipment (EA-13-109, 1.2.6). Replenishment of the motive force will be by use ofportable equipment prior to the installed motive force being exhausted.*Venting actions will be capable of being maintained for a sustained period of up to 7 days (NEI13-02, 4.2.2.1.1).The Phase 2 actions can be summarized as follows:*Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the ReactorPressure Vessel (RPV). Although SAWA to the Drywell (DW) is an option, Exelon is planningSAWA injection to the RPV.*Utilization of Severe Accident Water Management (SAWM) to control injection and SuppressionPool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for theremoval of decay heat from containment.Page 3 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents*Ensure that the decay heat can be removed from the containment for seven (7) days using theHCVS or describe the alternate method(s) to remove decay heat from the containment from thetime the HCVS is no longer functional until alternate means of decay heat removal areestablished that make it unlikely the drywell vent will be required for DW pressure control.*The SAWA and SAWM actions will be manually activated and controlled from areas that areaccessible during severe accident conditions.*Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate andthe HCVS parameters listed above.Note: Although EA-13-109 Phase 2 allows selecting SAWA and a Severe Accident Capable DrywellVent (SADV) strategy, Exelon has selected SAWA and SAWM.Page 4 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and AssumptionsExtent to which the guidance, JLD-ISG-2013-02, JLD-ISG-2015-01, and NET 13-02 (Revision 1), are beingfollowed. Identify any deviations.Include a description of any alternatives to the guidance. A technical justifi cation and basis for the alternative needs tobe provided. This will likely require a pre-meeting with the NRC to review the alternative.Ref: JLD-ISG-2013-02, JLD-ISG-2015-01Compliance will be attained for Dresden with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-ISG-2015-01, and NEJ 13-02 for each phase as follows:* The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment andoperating guidance:* Severe Accident Wetwell Vent (SAWV) -Permanently installed vent from the Suppression Pool to the top ofthe Reactor Building.* Severe Accident Water Addition (SAWA) -A combination of permanently installed and portable equipmentto provide a means to add water to the RPV following a severe accident and monitor system and plantconditions.* Severe Accident Water Management (SAWM) strategies and guidance for controlling the water addition tothe RPV for the sustained operating period. (Reference attachment 2.1 .D)* Unit 3 Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June30, 2018, whichever comes first. Currently scheduled for 4Q20 16.* Unit 2 Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June30, 2018, whichever comes first. Currently scheduled for 4Q2017.* Unit 2 Phase 2 (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017,or June 30, 2019, whichever comes first. Currently scheduled for 4Q2017.* Unit 3 Phase 2: (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017,or June 30, 2019, whichever comes first. Currently scheduled for 4Q20 18.If deviations are identified at a later date, then the deviations will be communicated in a future 6-month updatefollowing identification.State Applicable Extreme External Hazard from NET 12-06, Section 4.0-9.0List resultant determination of screened in hazards from the EA-12-049 Compliance.Ref: NET 13-02 Section 5.2.3 and D.1.2The following extreme external hazards screen in for Dresden:* Seismic, external flooding, extreme cold, high wind, and extreme high temperature.The following extreme external hazards screen out for Dresden:* NAKey Site assumptions to implement NEI 13-02 Strategies. ....Page 5 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and AssumptionsProvide key assumptions associated with implementation of HCVS Phase 1 Strategies.Ref: NEI 13-02, Revision 1, Section 2 NEI 12-06 Revision 0Mark Ji/I Generic HCVS Related Assumptions:Applicable EA- 12-049 (Reference 3) assumptions:049-1. Assumed initial plant conditions are as identified in NEI 12-06, &sect;3.2.1.2, items 1 and 2 (Reference 8).049-2. Assumed initial conditions are as identified in NET 12-06, &sect;3.2.1.3, items 1, 2, 4, 5, 6 and 8 (Reference 8).049-3. Assumed reactor transient boundary conditions are as identified in NEI 12-06, &sect;3.2.1.4, items 1, 2, 3 and 4.049-4. No additional events or failures are assumed to occur immediately prior to or during the event, includingsecurity events, except for the failure of Reactor Core Isolation Cooling (RCIC) or High Pressure CoolantInjection (HPCI) (Reference NEI 12-06, &sect;3.2.1.3, item 9 [8]).049-5. At time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP isoccurring at any or all of the units.049-6. At time=l hour (time sensitive at a time greater than 1 hour) an ELAP is declared and actions begin asdefined in EA-12-049 compliance.049-7. DC power and distribution can be credited for the duration determined per the EA-12-049 (FLEX)methodology for station battery usage, (greater than approximately 6 hours with a calculatedlimiting value of approximately 6 hrs., EC Eval. 391973) (NEI 12-06, section 3.2.1.3 item 8).049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours.049-9. All activities associated with EA-12-049 (FLEX) that are not specific to implementation of the HCVS,including such items as debris removal, communication, notifications, Spent Fuel Pool (SFP) level andmakeup, security response, opening doors for cooling, and initiating conditions for the events, can becredited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity onSAWA)(HCVS-FAQ-1 1)Applicable EA-13-109 (Reference 4) generic assumptions:109-1. Site response activities associated with EA-13-109 actions are considered to have no access limitationsassociated with radiological conditions while Reactor Pressure Vessel (RPV) level is above 2/3 core height(core damage is not expected). This is further addressed in HCVS-FAQ-12.109-2. Portable equipment can supplement the installed equipment after 24 hours provided the portable equipmentcredited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supplyequipment that is credited to recharge air lines for HCVS components after 24 hours. The FLEX portableair supply used must be demonstrated to meet the "SA Capable" criteria that are defined in NEI 13-02Section 4.2.4.2 and Appendix D Section D.l.3 (Reference 9). This assumption does not apply to Phase 2SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hoursfrom the time of the loss of RPV injection. (Reference HCVS-FAQ-12).109-3. SFP Level is maintained with either on-site or off-site resources such that the SFP does not contribute to theanalyzed source term (Reference HCVS-FAQ-07 [18]).109-4. Existing containment components design and testing values are governed by existing plant containmentPage 6 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and Assumptionscriteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (Reference HCVS-FAQ-05 [16] and NET 13-02, &sect;6.2.2 [9]).109-5. Classical design basis evaluations and assumptions are not required when assessing the operation of theHCVS. The reason that this is not required is that the order postulates an unsuccessful mitigation of anevent such that an ELAP progresses to a severe accident with ex-vessel core debris that classical designbasis evaluations are intended to prevent (Reference NEI 13-02, &sect;2.3.1 [9]).109-6. HCVS manual actions require minimal operator steps and can be performed in the postulated thermalradiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation,valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality (ReferenceHCVS-FAQ-0l[12]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWAequipment needs to be connected and placed in service within 8 hours from the time of the loss of RPVinjection and will require more than minimal operator action.109-7. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to functionin an ELAP event that progresses to core melt ex-vessel (Reference HCVS-FAQ-02 [13] and White PaperHCVS-WP-01 [21]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWAequipment is not dedicated to HCVS but shared to support FLEX functions. This is further addressed inHCVS-FAQ-il1.109-8. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV waterlevel, temperatures, etc.) assumed for Order EA-13-109 Beyond Design Basis External Event (BDBEE) andSA HCVS operation (Reference FLEX MAAP Endorsement ML13190A201 [29]). Additional analysisusing RELAP5/MOD 3, GOTHIC, and MICROSHIELD, etc., are acceptable methods for evaluatingenvironmental conditions in other portions of the plant, provided that the specific version utilized isdocumented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 tosupport diywell temperature response to SAWA under severe accident conditions.109-9. NRC Published Accident evaluations (e.g., SOARCA, SECY-12-0157, NUREG 1465) as related to OrderEA-13-109 conditions are acceptable as references (Reference NEI 13-02, &sect;8 [9]).109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may becredited for use in Order EA-13-109 response.109-11. This Overall Integrated Plan is based on Emergency Operating Procedure (EOP) changes consistent withEmergency Procedures Guidelines/Severe Accident Guidelines (EPG/SAGs) Revision 3 as incorporated perthe site's EOP/Severe Accident Procedure (SAP) procedure change process. This assumption does notapply to Phase 2 SAWM because SAWM is not part of revision 3. (Refer to Attachment 2.1.D for SAWMSAMG changes approved by the BWROG Emergency Procedures Committee.)109-12. Under the postulated scenarios of Order EA-13-109, the Main Control Room is adequately protected fromexcessive radiation dose as per General Design Criterion (GDC) 19 in 10CFR50 Appendix A and no furtherevaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is asufficient distance away from the MCR or is shielded to minimize impact to the MCR dose. In addition,adequate protective clothing and protection are available if required to address contaminationissues (Reference HCVS-FAQ-0l [12] and HCVS-FAQ-09).109-13. The suppression pool/wetwell of a BWR Mark I/II containment is considered to be hounded by assuming asaturated environment for the duration of the event response because of the water/steam interactions.Page 7 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 1: General Integrated Plan Elements and Assumptions109-14. RPV depressurization is directedt by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1 &sect;1.1.3)109-15. The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure thecapability to protect containment exists for each unit. (HCVS-FAQ-01) This is further addressed in HCVS-FAQ-10.Plant Specific HCVS Related Assumptions/Characteristics:Dresden-i Provided Severe Accident (SA) conditions are not reached EA- 12-049 (FLEX) actions to restore powerare sufficient to ensure continuous operation of non-dedicated containment instrumentation identified inPart 2 (Key Venting Parameters) of this OIP. Modifications that allow a FLEX generator to rechargethe HCVS battery are assumed to have been installed such that a FLEX generator can be credited forHCVS operation beyond the initial 24-hour sustained operational period. If SA conditions are reached,these non-dedicated containment instruments will be monitored by use of hand held, testinstrumentation that rely on small batteries, and Dresden will provide a small portable generator tomaintain HCVS battery charge beyond the initial 24 hours.Dresden -2 In case of a severe flood warning, the Dresden units will be shutdown and cooldown (per procedureDOA 00 10-04) prior to the flooding causing an ELAP. The shutdown and cooldown prior to the ELAPwill significantly reduce the decay heat that would have to be removed by the Isolation CondenserSystem (ICS) or, in case of a failure of the ICS, by the HCVS. Dresden will evaluate what actions maybe necessary to ensure the WW venting path remains viable following a severe flood. Reactor buildingdewatering strategy is under development and will be updated in the next 6-month update (Ref. ISFOpen Item 2).Dresden -3 The Plant layout of buildings and structures are depicted in Sketches 2B and 2C. Note the Main ControlRoom is located at Control Building elevation 534'. The Control Building has substantial structuralwalls and features independent of the Reactor Building. The HCVS vent routing external to the ReactorBuilding is indicated on Sketch 2-C. The external piping is vertical with the exception of the point atwhich it exits the Reactor Building.Dresden -4 The HCVS external piping is all above 30-feet from ground level and it consists solely of large bore (10-inches nominal diameter piping and its piping supports (EC 400578). The external piping has less than300 square feet of cross section. The HCVS external piping meets the reasonable protectionrequirements of HCVS-WP-04. The external support structure used to support the HCVS piping isanalyzed to the Dresden design basis tornado missiles to preclude a failure of the tower due to tornadowinds and missiles.Page 8 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentProvide a sequence of events and identify any time or environmental constraint required forsuccess including the basis for the constraint.HCVS Actions that have a time constraint to be successful should be identified with a technical basis and ajustification provided that the tine can reasonably be met (for example, action to open vent valves).HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or HighDose areas) should be evaluated per guidance.Describe in detail in this section the technical basis for the constraints identified on the sequence of eventstimneline attachment.See attached sequence of events tirneline (Attachment 2A ).Ref: EA-13-109 Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02 Section 4.2.5, 4.2.6. 6.1.1The containment purge exhaust at each Dresden unit consists of a wetwell primary containment isolationvalve (PCIV), a DW PCIV, and a common downstream PCIV. The HCVS flow path will utilize portions ofthis system. The HCVS will connect between the two containment purge exhaust PCIVs. Consequently,the HCVS flow path will share the upstream PCIVs with the containment purge system, but it will have adownstream PCIV dedicated to the HCVS flow path. The new HCVS flow path will have a rupture discdownstream of the last PCIV on the HCVS line to serve as the secondary containment leakage barrier.Each unit will have piping that is totally separate from the other unit and with no interconnected systemsdownstream of the new downstream PCIV. The discharge from each unit is routed separately anddischarges above the unit's Reactor Building roof.The two Dresden units will have a dedicated motive power (Pressurized N2) for HCVS valves, ArgonPurge system, and DC power for HCVS components that, except for battery charging after 24 hours, doesnot rely on FLEX (EC 400578).Existing containment instruments (pressure and suppression pool level) are not considered HCVScomponents and power will be maintained through the actions for EA-12-049 for non-severe accidentconditions or using test equipment during severe accident conditions.The operation of the HCVS will be designed to minimize the reliance on operator actions in response tohazards listed in Part 1. Initial operator actions will be completed by trained plant personnel and willinclude the capability for remote-manual initiation from the HCVS control station. A list of the remotemanual actions performed by plant personnel to open the HCVS vent path can be found in the followingtable (Table 2-1). A HCVS ELAP Failure Evaluation table, which shows alternate actions that can beperformed, is included in Attachment 4.Table 2-1 HCVS Remote Manual ActionsPage 9 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentPrimary Action Primary Location!/ NotesComponent1. Energize the HCVS power supply MCRto the HCVS components2. Enable the N2 motive air for the ROS* ...... ---HCVS valves3. CeckshuttheDW PIV (3)- MCRPrecautionary steps; these valves are normally shut160 1-23, the downstream PCIV to and fail shut.the containment purge exhaust2(3)-1601-24, and downstreamPCIV to the SGTS 2(3)-1601-63opening the Argon Purge Line forthe specified amount of timeMCROnly required if venting is initiated at acontainment pressure below the rupture discset point (40 psid).5. Open WetelntPCnVe23)4601-60iverride.thcnanetioaon Alternate control via motive air manual valves atsignal by opening the the ROS.PCIV in the HVCSP~nPl6. Open the downstream PCIV 2(3)- Key locked hand Alternate control via motive air manual valves at1601-93 on the common HCVS switch located in the the ROS.line HVCS Panel7. Align FLEX Generator to As described in Prior to depletion of station battery. Required tomaintain power to Station Battery response to EA maintain power to containment instrumentation.049.. ........It P~LtN, LXJi not availalae (i.e., under SAconditions), DW pressure and suppression pool, level will be monitored using test equipment.8. Align generator to HCVS battery At ROS Prior to depletion of the HCVS battery supply,charger. actions will be required to recharge the battery.If FLEX DG is not available (i.e., under SAconditions), a small portable generator will be used9. Replace N2 motive power bottles Replacement Nitrogen Prior to depletion of the pneumatic sources, actionsor align portable compressor bottles and/or i.will be required to connect back-up sources at acompressor will be itime greater than 24 hours.located at the ROS.10. R~eplace-Ar-gon-puirge-gas- bottles .........t. RO~S ..............P... -irior-to diepletion of the-Argon purge supply-at a......time greater than 24 hours. Required only if SAconditions are reached.*ROS -Remote Operating Station......Page 10 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentAttachment 2A, Sequence of Events Timeline, was developed to identify required operator response timesand potential environmental constraints. This timeline is based upon the following three sequences:1. Sequence 1 is based upon the action response times developed for FLEX when utilizinganticipatory venting in a BDBEE without core damage. Containment venting is not required forDresden FLEX response since the Isolation Condenser System (ICS) removes all the decay heatfrom the reactor and the containment does not become pressurized enough to require venting.Dresden does not have a RCIC system but it has a steam driven High Pressure Coolant InjectionSystem (HPCI).2. Sequence 2 is based on SECY-12-0157 long-term station blackout (LTSBO) (or ELAP) with afailure of RCIC after a black start where failure occurs because of subjectively assuming overinjection. It is used for Dresden to represent a late failure of the ICS and HPCI. Late failure of theICS is due to the assumption that FLEX fails to provide make-up water to the ICS.3. Sequence 3 is based on NUREG-1935 (SOARCA) results for a prolonged SBO (or ELAP) withloss of RCIC case without black start. For Dresden, this represents that the ICS fails after its initialwater volume is expended (i.e., no FLEX make-up to the ICS), and the HPCI fails early at a pooltemperature of 140&deg;F [MAAP case 8].The following is a discussion of time constraints identified in Attachment 2A for the 3 timeline sequencesidentified above:* With case 1 (ICS operating), HCVS operation is not required since the only heat input intothe containment is from RCS leaks and ambient losses to the environment.*For case 3 (limiting case), in approximately 8 hours, initiate use of Hardened ContainmentVent System (HCVS) per site procedures to maintain containment parameters below thelower of Primary Containment Pressure Limit (PCPL) or contalnment design pressure.Reliable operation of HCVS will be met because HCVS meets the seismic requirements* identified in NEl 13-02, will be powered by DC power from a dedicated power source, andHCVS valves are supplied with motive force from portable nitrogen bottles. HCVS controlsand instrumentation and controls will be DC powered. HCVS valve motive force is frompressurized gas. Valves will be operable from the HCVS control panel in the MCR. DCpower and motive air will be available for 24 hours from permanent sources. Containmentpressure and WW indication will initially be powered from existing lE Station battery. If SAconditions are not reached, these containment indications will be maintained by FLEXgenerators. If SA conditions are reached, these indications will be monitored by hand heldinstruments powered from small batteries. Thus, initiation of the HCVS from the MCR orthe Remote Operating Station within approximately 8 hours is acceptable because the actionscan be performed any time after declaration of an ELAP until the venting is needed atapproximately 8 hours for BDBEE venting. This action can also be performed for SA HCVSoperation which occurs at a time further removed from an FLAP declaration as shown inAttachment 2.*Within 24 hours, the permanently installed nitrogen bottles at the ROS will be replaced, asrequired, to maintain sustained operation or alternatively a portable compressor will beconnect at the ROS. Typical of all activities required at 24 hours, this can be performed atPage 11 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventany time prior to 24 hours to ensure adequate capacity is maintained so this time constraint isnot limiting.*Within 24 hours, the permanently installed Argon bottles at the ROS will be replaced, asrequired, to maintain sustained operation. Note that purging is only required if ventinghydrogen following severe accident conditions.*Within 24 hours, a generator will be installed and connected to recharge the dedicated HCVSpower supply to maintain sustalned operation. Under non-SA conditions this will be theFLEX generator. Under SA conditions this will be a small, portable generator.*Current Dresden station battery durations are calculated to last 6 hours. if SA conditions arenot reached, FLEX pre-staged DG will be in service 6 hours after an event (Reference FLEX0TP). Modifications will be implemented to facilitate the connections and operationalactions required to supply power within approximately 6 hours. Thus, under non-SAconditions, the FLEX DGs will be available to be placed in service at any point afterapproximately 6 hours as required to supply power to containment parameters (containmentpressure and WW level). A FLEX DG will be maintained and used in on-site FLEX storagebuildings. For the flood event, the DG will be transferred and staged via haul routes andstaging areas evaluated for impact from external hazards.Discussion of radiological, temperature. other environmental constraints identified in Attachment 2A*Actions to initiate HCVS operation are taken from the MCR or from the ROS in the TurbineBuilding. Both locations have significant shielding and/or physical separation fr'om radiologicalsources. Non-radiological habitability for the MCR is being addressed as part of the Dresden FLEXresponse. The ROS location in the Turbine Building has no heat sources.*Before the end of the initial 24-hour period, replenishment of the HCVS dedicated DC power, Argonpurge gas, and PCIV motive power (pressurized gas) will occur at the ROS. The selection of theROS location will take into account the SA temperature and radiation condition to ensure access tothe ROS is maintained. The design will allow replenishment with minimal actions.ISE Open Item -12: Confirm that the ROS will be in an area accessible following a SA.Provide Details on the Vent characteristics.Vent Size and Basis ('EA-13-!09 Section 1.2.1 /NE1 13-02 Section 4.1.1)What is the plants licensed power? Discuss any plans for possible increases in licensed power (e.g. MUR,EPU). What is the nominal diameter of the vent pipe in inches ? Is the basis determined by venting atcontainment design pressure, PCPL, or some other criteria (e.g. anticipatory venting) ?Vent Capacity (EA 1 09 Section 1.2.1/INEI 13-02 Section 4.1.1)Indicate any exceptions to the 1% decay heat removal criteria, including reasons for the exception.Provide the heat capacity of the suppression pool in terms of time versus pressurization capacity, assumingsuppression pool is the injection source.Page 12 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentVent Path and Discharg~e (EA-13-109 Section 1.1.4. 1.2.2 / NEI 13-02 Section 4.1.3, 4.1.5 and AppendixProvide a description of Vent path, release path, and impact of vent path on other vent element items.Power and Pneumatic Supply Sources (EA 1 09 Section 1.2.5 & 1.2.6 /NEI 13-02 Section 4.2.3. 2.5,4.2.2, 4.2.6. 6.1)Provide a discussion of electrical power requirements, including a description of dedicated 24 hour powersupply from permainently installed sources. Include a similar discussion as above for the valve motive forcerequirements. Indicate the area in the plant from where the installed/dedicated power and pneumaticsupply sources are coming.Indicate the areas where portable equipmnent will be staged after the 24 hour period, the dose fields in thearea, andt any shielding that would be necessary in that area.Location of Control Panels (EA 1 09 Section 1.1.1, 1.1.2, 1.1.3. 1.1.4, 1.2.4, 1.2.5 /NEI 13-02 Section4,1.3. 4.2.2. 4.2.3. 4.2.5, 4.2.6, 6.1.1. and Appendix FIG)Indicate the location of the panels, and the dose fields in the area during severe accidents and anyshielding that would be required in the area. This can be a qualitative assessment based on criteria in NEI13-02..Hydrog'en (EA-13.109 Section 1.2.10, &1.2.11, and 1.2.12/INEI 13-02 Section 2.3,2.4. 4.1.1. 4.1.6. 4.1.7,5.1, & Appendix H)State which approach or combination of approaches the plant will take to address the control of fiammablegases, clearly demarcating the segments of vent system to which an approach applies.Unintended Cross Flow of Vented Fluids (EA 1 09 Section 1.2.3, 1.2.12 / NEI 13-02 Section 4.1.2,4,1.4, 4.1.6 and Appendix H)Provide a description to eliminate/minimize unintended cross flow of vented fluids with emphasis oninterfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakagethrough interfacing valves or Appendix J type testing features?Prevention of lnadvertent Actuation (EA-13-109 Section 1.2.7/NEl 13-02 Section 4.2.1)The HCVS shall include means to prevent inadvertent actuation.Component Qualifications (EA-13-109 Section 2.1/INEI 13-02 Section 5.1)State qualification criteria based on use of a combination of safety related and augmented qualitydependent on the location, function andt interconnected system requiremnents._Monitoring of HCVS (Order Elements 1.1.4, 1.2.8, 1.2 .9/NEI 13-02 4.1.3, 4.2.2, 4.2.4, and AppendixFIG)qProvide a description of instruments used to monitor HCVS operation and effluent. Power for aninstrument will require the intrinsically safe equipment installed as part of the power sourcing.Comnonent reliable and rugv'ed oerformance (EA 1 09 Section 2.2 /NEI 13-02 Section 5.2. 5.3)HCVS components including instrumentation should be designed, as a minimum, to meet the seismic designrequirements of the plant.Page 13 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentComponents including instrumentation that are not required to be seismically designed by the design basisof the plant should be desi gned for reliable and rugged peiformance that is capable of ensuring HCVSfunctionality following a seismic event. (Reference JLD-ISG-2012-01 and JLD-ISG-2012-O3 for seismicdetails.)The components including instrumentation external to a seismic category I (or equivalent building orenclosure should be designed to meet the external hazards that screen in for the plant as defined inguidance NE1 12-06 as endorsed by JLD-ISG-12-O1 for Order EA-12-049.Use of instruments and supporting components with known operating principles that are supplied bymanufacturers with commercial quality assurance programs, such as 1S09001. The procurementspecifications shall include the seismic requirements and/or instrument design requirements, and specifythe need for commercial design standards and testing under seismic loadings consistent with design basisvalues at the instrument locations.Demonstration of the seismic reliability of the instrumentation through methods that predict performanceby analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis,or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard344-2004, "'IEEE Recommended Practice for Seismic Qualification of Class JE Equipment for NuclearPower Generating Stations,'" or a substantially similar industrial standtard could be used.Demonstration that the instrumentation is substantially similar in design to instrumentation that has beenpreviously tested to seismic loading levels in accordance with the plant design basis at the location wherethe instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should besimilar to that performed for the plant licensing basis.Page 14 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentVent Size and BasisThe HCVS flow path is designed for venting steanm/energy from the suppression pooi at a nominal capacityof 1% of the currently licensed power, 2957 MWt thermal power at pressure of 62 psig (UFSAR Table 1.2-1). This pressure is the lower of the containment design pressure and the PCPL value assuming nominaltorus water level. The nominal diameter is 18-inches through the shared upstream PCTV that is shared withthe containment purge exhaust and 10-inches for the downstream portion. The 10-inch diameter portionincludes the downstream PCIV and rupture disc. Refer to Sketch 2A, the P&TD. This line has been verifiedto meet the Order criteria for 1%.Vent CapacityThe 1% value at Dresden assumes that the suppression pooi pressure suppression capacity is sufficient toabsorb the decay heat generated during the first 3 hours. The vent would then be able to preventcontainment pressure from increasing above the containment design pressure. As part of the detaileddesign, the duration of suppression pool decay heat absorption capability was confirmed to exceed 3 hours(Reference 37, MAAP).Vent Path and DischargeThe Dresden station HCVS vent path will consist of a separate wetwell vent for each unit. The upstreamportion consists of 18-inch nominal diameter piping and the upstream PCIV that is shared with the toruscontainment purge exhaust path. The downstream portion consists of 10-inch nominal diameter piping andincludes the downstream PCIV and the rupture disc. The downstream PCTV and rupture disc are dedicatedto the HCVS function. The rupture disc is credited as the secondary containment isolation barrier. The 10-inch diameter vent line is initially routed vertically with the Reactor Building and then horizontally throughthe Reactor Building wall at elevation 591', which is approximately 74 feet above nominal plant groundelevation (EC 401069, DWG M-1 194A-1). This line is then routed vertically on the outside of the ReactorBuilding to a point above the top of the Reactor Building. There are no interconnected systemsdownstream of the second PCIVs and there is no sharing of any flow path between the two units.The HCVS discharge path is being routed to a point above any adjacent structure. This discharge point isjust above that unit's Reactor Building and will follow the guidance of FAQ- HCVS-04 (Reference 15) tothe extent reasonably possible such that the release point will vent away from emergency ventilation systemintake and exhaust openings, main control room location, location of HCVS portable equipment, accessroutes required following a ELAP and BDBEE, and emergency response facilities; however, these must beconsidered in conjunction with other design criteria (e.g., flow capacity) and pipe routing limitations, to thedegree practical. The external vertical piping for the two units will be run in close proximity to each otherto allow a common external support structure. The external piping meets the criteria for tornado missilereasonable protection (refer to Dresden Assumption 4).Power and Pneumatic Supply SourcesAll electrical power required for operation of HCVS components will be from a dedicated HVCS DCbattery source with permanently installed capacity for the first 24 hours and design provisions forrecharging to maintain sustained operation.Motive (pneumatic) power to the HCVS valves is provided by a dedicated bank of N2 gas bottles withpermanently installed capacity for the first 24 hours and design provisions for replacing bottles and/orPage 15 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventconnecting a portable compressor to maintain sustained operation. The initial stored motive air/gas willallow for a minimum of 8 vent cycles for the HCVS valves for the first 24-hours. The 8 vent cycles isdefined as initially opening all valves in the wetwell flow path, and then shutting and reopening one of thevalves in the flow paths.1. The HCVS flow path valves are air-operated valves (AOV). The existing, upstream PCIV is air-to-open and air-to-shut. The new downstream PCIV will be air-to-open and spring-to-shut. Openingthe valves from the HCVS control panel located in the MCR requires energizing a DC poweredsolenoid operated valve (SOV) and providing motive air/gas.2. An assessment of temperature and radiological conditions will be performed to ensure thatoperating personnel can safely access and operate controls at the Remote Operating Station basedon time constraints listed in Attachment 2.3. All permanently installed HCVS equipment, including any connections required to supplement theHCVS operation during an ELAP (i.e., DC power, Argon purge gas, and motive force [pressurizedN2/air]) will be located in areas reasonably protected from defined hazards listed in Part 1 of thisreport.47All valves required to open the flow path will be designed for remote manual operation followingan ELAP, such that the primary means of valve manipulation does not rely on use of a handwheel,reach-rod or similar means that requires close proximity to the valve (reference FAQ HCVS-03).The preferred method is opening from the MCR through the control switch that energizes theAOV's SOV. The back-up method for new valves is from the ROS by repositioning valves on thepneumatic supply; this allows opening and closing of a valve from the ROS without reliance onany electrical power or control circuit. Accessibility to the ROS will be verified during thedetailed design.5. Any supplemental connections will be pre-engineered to minimize man-power resources andaddress environmental concerns. Required portable equipment will be reasonably protected fromscreened in hazards listed in Part 1 of this OIP.6. Access to the locations described above will not require temporary ladders or scaffolding.Location of Control PanelsThe HCVS design allows initiating and then operating and monitoring the HCVS from the Main ControlRoom (MCR) and in addition, opening PCTVs and the Argon purge system from the ROS in case of a DCcircuit failure. The tentative location for the ROS is 561 foot elevation Turbine Building. The MCRlocation is protected from adverse natural phenomena and it is the normal control point for PlantEmergency Response actions. The ROS will be evaluated to ensure acceptable temperature and doseconsequences.HydroigenAs required by EA-13-109, Section 1.2.11, the HCVS design will include an Argon purge system that willbe connected just downstream of the second PCIV. It will be designed to prevent hydrogen detonationdownstream of the second PCIV. The Argon purge system will have a switch for the control valve in theMCR to allow opening the purge for the designated time, but it will also allow for local operation in theROS in case of a DC power or control circuit failure. The Argon purge will only be utilized followingsevere accident conditions when hydrogen is being vented. The installed capacity for the Argon purgePage 16 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventsystem will be sized for at least 8 purges within the first 24 hours of the ELAP. This number of vent cyclesis the same value used for sizing the PC1V motive air supply. The design will allow for Argon bottlereplacement for continued operation past 24 hours.The Argon purge system can also be used to breach the rupture disc if venting is required before reachingthe rupture disc setpoint. The MCR panel will include an indication of Argon pressure to the HCVS path toverify that the Argon purge system flow is occurring.Unintended Cross Flow of Vented FluidsRefer to Sketch 2A, the HCVS P&IID. The HCVS piping in each unit is totally independent of the otherunit's HCVS flow path. The upstream 18-inch nominal diameter portion isolates any interconnected, non-HCVS systems in that unit through normally shut, air-operated PCIVs that, if open, will automatically shut.The downstream dedicated 10-inch portion does not have any interconnected systems. This precludesunintended cross flow of vented fluids.Prevention of Inadvertent ActuationEOP/ERG operating procedures provide clear guidance that the HCVS is not to be used to defeatcontainment integrity during any design basis transients and accident. In addition, the HCVS will bedesigned to provide features to prevent inadvertent actuation due to a design error, equipment malfunction,or operator error such that any credited containment accident pressure (CAP) that would provide netpositive suction head to the emergency core cooling system (ECCS) pumps will be available (inclusive of adesign basis loss-of-coolant accident (DBLOCA)). However, the ECCS pumps will not have normal poweravailable because of the starting boundary conditions of an ELAP.Note that Dresden credits CAP for its DBLOCA. Preventing inadvertent operation is addressed. Thefeatures that prevent inadvertent actuation are two PCI Vs in series with a downstream rupture disc. Thedownstream PCIV is a normally shut, fail-shut AOV dedicated to the HCVS function. This valve is air toopen; spring to shut that requires energizing a SOV to allow the motive air to open the valve. This PCTV iscontrolled by its own key-locked switch. In addition, the DC power to its SOV and the motive air suppliedwill normally be disabled to prevent inadvertent operation.Component QualificationsThe HCVS components and components that interface with the HCVS are routed in seismically qualifiedstructures.HCVS components that are part of the containment pressure boundary will be safety-related. Thecontainment system limits the leakage or release of radioactive materials to the environment to preventoffsite exposures from exceeding the guidelines of 10 CFR 100. During normal or design basis operations,this means serving as a pressure boundary to prevent release of radioactive material. HCVS componentsdownstream of the containment pressure boundary (i.e., downstream of the downstream PCIV) will not besafety-related.The HCVS components (SOVs and instrumentation) will be powered from a normally de-energized,dedicated power supply that will not be safety-related but will be considered Augmented Quality.However, if any HCVS electrical or controls component interfaces with Class 1E power sources, it will heconsidered safety related up to and including appropriate isolation devices such as fuses or breakers, astheir failure could adversely impact containment isolation and/or a safety-related power source. Newlyinstalled piping and valves will be seismically analyzed to handle the forces associated with the Plant'sDesign Basis Seismic Requirements back to their isolation boundaries. Electrical and controls componentsPage 17 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventwill be seismically analyzed and will include the ability to handle harsh environmental conditions (althoughthey will not be considered part of the site Environmental Qualification (EQ) program).HCVS instrumentation performance (e.g., accuracy and precision) need not exceed that of similar plantinstalled equipment. Additionally, radiation monitoring instrumentation accuracy and range will besufficient to determine core conditions (i.e., no core damage thru severe core damage). The HCVSinstruments, including valve position indication, process instrumentation, radiation monitoring, and supportsystem monitoring, will be qualified by using one or more of the three methods described in the ISG, whichincludes:1. Purchase of instruments and supporting components with known operating principles frommanufacturers with commercial quality assurance programs (e.g., 1S09001) where the procurementspecifications include the applicable seismic requirements, design requirements, and applicabletesting.2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-20043. Demonstration that instrumentation is substantially similar to the design of instrumentationpreviously qualified.Instrument Qualification Method*HCVS Process Temperature 1509001 / IEEE 344-2004 / DemonstrationHCVS Process Radiation Monitor 1S09001 / IEEE 344-2004 / DemonstrationHCVS Valve Position Indication 1509001 I IEEE 344-2004 I DemonstrationHCVS Pneumatic Supply Pressure ISO09001 / IEEE 344-2004 / DemonstrationHCVS Electrical Power Supply Availability 1SO9001 / IEEE 344-2004 I DemonstrationHCVS Argon System Purge Pressure 1SO900 1/ IEEE 344-2004 I Demonstration* The specific qualification method used for each required HCVS instrument will be reported infuture 6-month status reports.[ISE OPEN ITEM-15: Complete evaluation for HCVS instrumentation qualification.]Monitoring of HCVSThe Dresden wetwell HCVS will be capable of being remote-manually operated during sustainedoperations from a control panel located in the main control room (MCR) and will meet the requirements ofOrder element 1.2.4. The MCR is a readily accessible location with no further evaluation required (GenericAssumption 109-12). Additionally, to meet the requirement of EA-13-109 Section 1.2.5, an accessibleRemote Operating Station (ROS) will also be incorporated into the HCVS design as described in NEI 13-02 section 4.2.2.1.2.1. The controls and indications at the ROS location will be accessible and functionalunder a range of plant conditions, including severe accident conditions with due consideration to sourceterm and dose impact on operator exposure, extended loss of AC power (ELAP), and inadequatecontainment cooling. An evaluation will be performed to determine accessibility to the ROS location,habitability, staffing sufficiency, and communication capability with Vent-use decision makers.Page 18 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell VentThe wetwell HCVS will include means to monitor the status of the vent system in the MCR and to monitorDC power, Argon pressure, and N2 pressure at the ROS. The proposed design for the HCVS includescontrol switches in the MCR with valve position indication. The HCVS controls will meet theenvironmental and seismic requirements of the Order for the plant severe accident with an ELAP. Theability to open/close these valves multiple times during the event's first 24 hours will be provided bydedicated motive air and DC power. Beyond the first 24 hours, the ability to maintain these valves open orclosed will be maintained by sustaining the motive air and DC power.The wetwell HCVS will include indications for vent pipe temperature and effluent radiation levels at theMCR. Other important information on the status of supporting systems, (i.e., DC power source status,Argon purge gas pressure and pneumatic supply pressure), will also be included in the design and locatedto support HCVS operation. Other instrumentation that supports HCVS function will be provided in theMCR. This includes existing containment pressure and suppression pool level indication. Thisinstrumentation is not required to validate HCVS function and is therefore not powered from the dedicatedHCVS batteries. However, these instruments are expected to be available since (a) under non-SAconditions the FLEX DG supplies the station battery charger for these instruments and will be installedprior to depletion of the station batteries and (b) under SA conditions, they will be monitored using hand-held test equipment.Component reliable and rugged performanceUnless otherwise required to be safety-related, Augmented Quality requirements will be applied to thecomponents installed in response to this Order.The HCVS downstream of the second containment isolation valve, including piping and supports, electricalpower supply, valve actuator pneumatic supply, and instrumentation (local and remote) components, willbe designed/analyzed to conform to the requirements consistent with the applicable design codes (e.g.,Non-safety, Seismic Category 1, B31.l) for the plant and to ensure functionality following a design basisearthquake.Additional modifications required to meet the Order will provide reliability at the postulated vent pipeconditions (temperature, pressure, and radiation levels). The instrumentation/powersupplies/cables/connections (components) will be qualified for temperature, pressure, radiation level, totalintegrated dose radiation appropriate for that location (e.g., near the effluent vent pipe or at the HCVS ROSlocation).Conduit design and/or cable trays will be installed to Seismic Class 1 criteria.Dresden complies with HCVS-WP-04 from reasonable protection of HCVS components located outside ofseismic Class 1 concrete structures.If the instruments are purchased as commercial-grade equipment, they will be qualified to operate undersevere accident environment as required by NRC Order EA-13-109 and the guidance of NEI 13-02. Theequipment will be qualified seismically (IEEE 344) and environmentally (IEEE 323). These qualificationswill be bounding conditions for Dresden per UFSAR 1.1.8 and 3.11.For the instruments required after a potential seismic event, the following methods will be used to verifyPage 19 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for Wetwell Ventthat the design and installation is reliable / rugged and thus capable of ensuring HCVS functionalityfollowing a seismic event. Applicable instruments are rated by the manufacturer (or otherwise tested) forseismic impact at levels commensurate with those of postulated severe accident event conditions in the areaof instrument component use using one or more of the following methods:* demonstration of seismic motion will be consistent with that of existing design basis loads at theinstalled location;* substantial history of operational reliability in environments with significant vibration with adesign envelope inclusive of the effects of seismic motion imparted to the instruments proposed atthe location;* adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7, 8,9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification ofClass JE Equipment for Nuclear Power Generating Stations, (Reference 28) or a substantiallysimilar industrial standard;* demonstration that proposed devices are substantially similar in design to models that have beenpreviously tested for seismic effects in excess of the plant design basis at the location where theinstrument is to be installed (g-levels and frequency ranges); or* seismic qualification using seismic motion consistent with that of existing design basis loading atthe installation location.Page 20 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingDetermine venting capability for BDBEE Venting, such as may be used in an ELAP scenario tomitigate core damage.Ref: EA-13-109 Section 1.1.4 /NEI 13-02 Section 2.2First 24 Hour Coping DetailProvide a general description of the venting actions for first 24 hours using installed equipment including stationmodifications that are proposed.Ref: EA-13-109 Section 1.2.6 I NEI 13-02 Section 2.5, 4.2.2The operation of the HCVS will be designed to minimize reliance on operator actions for response to an ELAPand severe accident events. Immediate operator actions will be completed by qualified plant personnel fromeither the MCR or the HCVS ROS using remote-manual actions. The operator actions required to open a ventpath are as described in Table 2-1.Remote-manual is defined in this report as a non-automatic power operation of a component and does not requirethe operator to be at or in close proximity to the component. No other operator actions are required to initiateventing under the guiding procedural protocol.The HCVS will be designed to allow initiation, control, and monitoring of venting from the MCR. This locationminimizes plant operators' exposure to adverse temperature and radiological conditions and is protected fromhazards assumed in Part 1 of this report.Permanently installed electrical power. and motive air/gas capability will be available to support operation andmonitoring of the HCVS for 24 hours.System control:i. Active: The PCI Vs will be operated in accordance with EOPs/SOPs to control containmentpressure. The HCVS will be designed for at least 8 vent cycles under ELAP conditions over thefirst 24 hours following an ELAP. Controlled venting will be permitted in the revised EPGs andassociated implementing EOPs.ii. Passive: Inadvertent actuation protection is provided by:A key locked switch for the dedicated downstream PCIV located in the Main Control Room andcontrolled by proceduresANDDisabling the HCVS DC power to the SOV and disabling the motive power (pressurized N2) forthe dedicated PCIV except when required by procedures to initiate containment ventingANDA rupture disc downstream of the PCIVs with a design pressure of 40 PSID.Page 21 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingGreater Than 24 Hour Coping DetailProvide a general description of the venting actions for greater than 24 hours using portable andinstalled equipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4 / NEI 13-02 Section 4.2.2Before the end of the 24 hours initial phase, available personnel will be able to connect supplemental air/gas forthe motive air system. Connections for supplementing electrical power and air/gas required for HCVS will belocated in accessible areas with reasonable protection per NEI 12-06 that minimize personnel exposure to adverseconditions for HCVS initiation and operation. Connections will be pre-engineered quick disconnects to minimizemanpower resources. Replenishment of the Argon supply is not required under non-SA conditions since purgingis not required.FLEX is credited to sustain power for a BDBEE ELAP to containment instruments used to monitor thecontainment (e.g., pressure and wetwell level) during non-Severe Accident (SA) conditions. Portable instrumentswill be used during SA conditions. The response to NRC EA-12-049 will demonstrate the capability for FLEXefforts to maintain the power source.These actions provide long term support for HCVS operation for the period beyond 24 hours to 7 days (sustainedoperation time period) because on-site and off-site personnel and resources will have access to the unit(s) toprovide needed action and supplies.Details:Provide a brief description of Procedures/IGuidelines:Confirm that procedure/guidance exists or will be developed to support implementation.Primary Containment Control Flowchart will be provided to direct operations in protection and control ofcontainment integrity, including use of the existing Hardened Containment Vent System.These flowcharts are being revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAPimplementation. HCVS-specific procedure guidance will be developed and implemented to support HCVSimplementation.ISE Open Item 18: -Provide procedures for HCVS Operation.Identify modifications:List modifications and describe how they support the HCVS Actions.EA- 12-049 Modifications* No additional EA-12-049 modifications are required to support HCVS.EA-13-109 Modifications* A modification will be required to install the new wetwell vent piping including the new downstreamPCIV and rupture disc. The rupture disc controls primary containment leakage during a design basisPage 22 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -BDBEE VentingLOCA. The new valve will include valve position indication and remote-manual control only. There isno sharing of any flow paths with the opposite unit.* A modification will be required to allow operation of the existing upstream wetwell PCIV. This includesthe capability to override a containment isolation signal. Reopening the valves following a BDBEE willbe remote-manual.* A modification will be required to install the dedicated batteries needed to supply power to HCVS for thefirst 24 hours including capability for recharging from a portable charger at or before 24 hours. Thebattery will be located at the ROS.* A modification will be required to install the dedicated motive power (Pressurized N2 gas) needed toopen the HCVS valves for the first 24 hours including capability for replacing N2 bottles or connection aportable compressor after 24 hours. The N2 bottles will be located at the ROS.*A modification will be required to install the dedicated Argon purge system. For non-SA conditions, theArgon purge system is not required to prevent hydrogen detonation in the piping. The Argon purgesystem, however, can be credited with breaching the rupture disc if venting is initifated at a containmentpressure below the rupture disc setpoint.* A modification will be required to add (a) HCVS flow path instrumentation consisting of temperature andeffluent radiation in the MCR and (b) Motive power and DC HCVS battery indication in the MCR andthe ROS.Key Venting Parameters:List instrumentation credited for this venting actions. Clearly indicate which of those already exist in the plantand what others will be newly installed (to comply with the vent order).Initiation, operation and monitoring of the HCVS venting will rely on the following key parameters andindicators. Indication for these parameters will be installed in the MCR or ROS to comply with EA-13-109:Key Parameter Component Identifier Indication LocationHCVS Effluent temperature TBD MCRHCVSEfflentRaditionTBDMCRHCVS valve position indication TBD MCRHCVS DC Power Voltage/Conditions TBD ROSHCVS Pneumatic supply pressure TBD ROSHCVS Purge System pressure TBD MCRIROSInitiation and cycling of the HCVS will be controlled based on several existing MCR key parameters andindicators which are qualified to the existing plant design: (Reference NEI 13-02 Section 4.2.2.1.9 [91):Key Parameter Component Identifier Indication LocationDrywell pressure 2(3)-1640-1 1A(B) MCR____ wetwell level 2(3)-1640-13A(B) MCRNotes: NonePage 23 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Severe Accident VentingDetermine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario tomitigate core damage.Ref: EA-13-109 Section 1.2.10 /NEI 13-02 Section 2.3First 24 Hour Coping DetailProvide a general description of the venting actions for first 24 hours using installed equipment including stationmodifications that are proposed.Ref: EA-13-109 Section 1.2.6 / NET 13-02 Section 2.5, 4.2.2Severe accident (SA) conditions assume that specific core cooling actions from the FLEX strategies identified inthe response to Order EA-12-049 were not successfully initiated. Core damage is assumed to start at 1.9 hours.(MAAP Case 8, Reference 37). This case assumes ICS is automatically initiated at the start of the ELAP butsecured at T=20 minutes (no credit for make-up to the ICS) and failure of the HPCJ when suppression pooitemperature reaches 140&deg;F. The operator actions required to open a vent path under SA conditions are the sameas previously listed in the BDBEE Venting Part 2 section of this report (Table 2-1). The operation of the HCVSunder SA conditions is the same as discussed under BDBEE (i.e., non-SA conditions) with the followingexceptions:*Access is not restricted prior to core damage. Thereafter, access to the reactor building will be restrictedas determined by the RPV water level and core damage conditions.*HCVS permanently installed power, Argon purge, and motive air/gas capability will be available tosupport operation and monitoring of the HCVS for 24 hours. Specifics are the same as for BDBEEVenting Part 2.*Containment instrumentation (DW pressure and suppression pool) will be monitored using testinstruments that are powered from self-contained batteries following depletion of the Station battery.A preliminary evaluation of travel pathways for dose and temperature concerns has been completed and travelpaths identified (ISE Open Item #12). A final evaluation of environmental conditions will be completed as partof detailed design for confirmation.[ISE OPEN ITEM-12: Confirm travel path accessibility.]System control:i. Active: Same as for BDBEE Venting Part 2.ii. Passive: Same as for BDBEE Venting Part 2Greater Than 24 Hour Coping DetailProvide a general description of the venting actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2Page 24 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Severe Accident VentingSpecifics are the same as for BDBEE Venting Part 2 except that (a) Argon purge gas replenishment is requiredafter 24 hours and (b) under SA conditions the FLEX DG will not be available and, consequently, the DWpressure and suppression pooi level indications will be monitored using hand held instruments. The HCVSsupport systems (including the Argon purge system) will be designed to allow replenishment under SAconditions. These actions provide long term support for HCVS operation for the period beyond 24 hours to 7 days(sustained operation time period) because on-site and off-site personnel and resources will have access to theunit(s) to provide needed action and supplies.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The operation of the HCVS will be governed the same for SA conditions as for BDBEE conditions. Existingguidance in the SAMGs directs the plant staff to consider changing radiological conditions in a severe accident.Identify modifications:List modifications and describe how they support the HCVS Actions.Modifications are the same as for BDBEE Venting Part 2 with the exception that a suitable location forconnecting test instruments for DW pressure and suppression pool water level will be required.Key Venting Parameters:List instrumentation credited for the HCVS Actions. Clearly indicate which of those already exist in theplant and what others will be newly installed (to comply with the vent order).Key venting parameters are the same as for BDBEE Venting Part 2.Notes: NonePage 25 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Support EquipmentFunctionsDetermine venting capability support functions needed.Ref: EA-13-109 Section 1.2.8, 1.2.9 /NEI 13-02 Section 2.5, 4.2.4, 6.1.2BDBEE VentingProvide a general description of the BDBEE Venting actions support functions. Identify methods andstrategy(ies) utilized to achieve venting results.Ref: EA-13-109 Section 1.2.9 / NET 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2All containment venting functions will be performed from the MCR or ROS.Venting to prevent containment overpressurization will be maintained by permanently installed equipment. TheHCVS dedicated DC power source, Argon purge gas, and dedicated motive force is adequate for the first 24hours, but it can be replenished to support sustained operation.Existing safety related station batteries will provide sufficient electrical power for MCR containmentinstrumentation for greater than approximately 6 hours (EC Eval 391973). Before station batteries are depleted,portable FLEX diesel generators, as detailed in the response to Order EA-12-049, will be credited to charge thestation batteries and maintain DC bus voltage after approximately 6 hours.Severe Accident VentingProvide a general description of the Severe Accident Venting actions support functions. Identify methods andstrategy(ies) utilized to achieve venting results.Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2The same support functions that are used in the BDBEE scenario would be used for severe accident venting withthe exception that the FLEX DG is not available. A suitable location for connecting test instruments for DWpressure and suppression pool water level will be required to monitor these parameters after approximately 6hours.The ROS (the location of the HCVS DC power source, Argon purge, and motive force) will be evaluated toconfirm accessibility under severe accident conditions.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The operation of the HCVS will be governed the same for SA conditions as for BDBEE conditions. Existingguidance in the SAMG directs the plant staff to consider changes in radiological conditions in a severe accident.Identify modifications."List modifications and describe how they support the HCVS Actions.The same as for BDBEE Venting Part 2 with the exception that a suitable location for connecting test instrumentsfor DW pressure and suppression pool water level will be required.Page 26 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Support EquipmentFunctionsKey Support Equipment Parameters:List instrumentation cred ited for the support equipment utilized in the venting operation. Clearlyindicate which of those already exist in the plant and what others will be newly installed (to comply withthe vent order).The same as for BDBEE Venting Part 2.Notes: NonePage 27 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 2: Boundary Conditions for WW Vent -Venting PortableEquipment DeploymentProvide a general description of the venting actions using portable equipment including modifications that areproposed to maintain and/or support safety functions.Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.2, D.1.3.1Deployment pathways developed for compliance with Order EA-12-049 are acceptable without further evaluationneeded except in areas around the Reactor Building or in the vicinity of the HCVS piping.Before the end of the initial 24-hour period, replenishment of the HCVS dedicated DC power, Argon purge gas,and motive power (pressurized gas) will occur at the ROS. The selection of the ROS location will take intoaccount the SA temperature and radiation condition to ensure access to the ROS is maintained. The design willallow replenishment with minimal actions.Details:Provide a brief description of Procedures / Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.The portable equipment that must be deployed for HCVS operation is limited to the FLEX DG that is credited formaintaining power to the containment instrumentation following Station battery depletion.Under non-SA conditions, operation of the FLEX DG is the same as for compliance with Order EA-12-049; thus,it is acceptable without further evaluation.Under SA conditions, radiological conditions will impede deployment of the FLEX DG. Consequently,procedures will be developed to install test instruments to monitor DW pressure and suppression pool water levelper Engineering Change (EC) process.Strategy Modifications Protection of connectionsPer compliance with Order EA- N/A Per compliance with Order EA- 12-04912-049 (FLEX) (FLEX)Notes: NonePage 28 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2GeneralLicensees that use Option B.] of EA 1 09 (SA Capable DW Vent without SA WA) must develop their own QIP.This template does not provide guidance for that option.Licensees using Option B.2 of EA-13-109 (SAWA and SAWM or 545&deg;F SADW Vent (SADV) with SAWA) may usethis templ ate for their OIP submittal. Both SA WM and SADV require the use of SA WA and may not be doneindependently. The HCVS actions uneter Part 2 apply to all of the following:This Part is divided into the following sections:3.1: Severe Accident Water Addition (SA WA)3.1.A: Severe Accident Water Management (SA WM)3.1.B: Severe Accident DW Vent (545 deg F)Provide a sequence of events and identify any time constraint required for success including the basis for thetime constraint.SA WA and SA WM or" SADV Actions supporting SA conditions that have a time constraint to be successful should beidentified with a technical basis and a justification provided that the time can reasonably be met (for example, awalkthrough of deployment). Actions already identified under the HCVS part of this template need not be repeatedhere.The time to establish the water addition capability into the RPV or DW should be less than 8 hours from the onsetof the loss of all injection sources.* Electrical generators satisfying the requirements of EA-12-049 may be credited for poweringcomponents and instrumentation needed to establish a flow path.* Time Sensitive Actions (TSAs) for the purpose of SAWA are those actions needed to transport, connectand start portable equipment needed to provide SA WA flow or provide power to SA WA components inthe flow path between the connection point and the RPV or drnywell. Actions needed to establish powerto SA WA instrumentation should also be included as TSAs.Ref: NET 13-02 Section 6.1.1.7.4.1,1.1.4, 1.1.5The operation of the HCVS using SAWA and SAWMvISADV will be designed to minimize the reliance on operatoractions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and willinclude the capability for remote-manual initiation from the MCR using control switches. In addition, HCVS valveoperation, as required by EA-13-109 Requirement 1.2.5, may occur at the ROS on the 561 foot elevation of theTurbine Building.Timelines (see attachments 2.1 .A for SAWAISAWM) were developed to identify required operator response timesand actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) orafter initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWM). The timelines donot assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damageconditions.Page 29 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Part 3.1: Boundary Conditions for SAWATable 3.1 -SAWA Manual Actions(Dresden non-flood scenario; flood scenario is less time limiting since there is greater than 24-hour floodwarning, equipment can be fully deployed before flood, and plant will be shutdown and in partial cooldownto Mode 4)Primary Action Primary Location!/Component Notes1. Establish HCVS capability in U MCR or ROS. U Applicable to SAWA/SAWMaccordance with Part 2 of this strategy.OIP.2. Connect SAWA pump discharge U Reactor building 517' elevation U Perform reactor buildingto injection piping. (ground level) hard pipe portions of deployment first.connection to Low PressureCoolant Injection (LPCI) Line.U Manually open motor operatedvalve (MOV) 2(3)-1501-22A(B).The second MOV 2(3)-1501-21A(B) is normally open).3. Connect SAWA pump to water U At Ultimate Heat Sink (UHS) U* Consist of a Diesel Drivensource, near intake structure, submersible pump dischargingto a diesel driven SAWABooster pump; with hoses.4. Install test equipment to allow U MCR U Required when Station batteriesmonitoring of DW pressure and are depleted.suppression pool water level.5. Inject to RPV using SAWA U Flow control is by a manual U Initial SAWA flow rate is 421pump (diesel). valve at the SAWA Booster gpm.pump.6. Monitor SAWA indications. U Flow indication at SAWA U Pump flow.Pumps' location(s).7. Use SAWM to maintain U TBD U Monitor DW pressure andavailability of the WW vent (Pail Suppression Pool level.3.1 .A). U Control SAWA flow at valvelocated on the diesel drivenpump to reduce flow to 85-~ gpm.-Discussion of timeline SAWA identified items HCVS operations are discussed under Phase 1 of EA-13-109 (Part 2 of this OIP).U Action being taken within the reactor building under EA-12-049 conditions after RPV level lowers to 2/3 coreheight must be evaluated for radiological conditions assuming permanent containment shielding remainsintact. (HC VS-FAQ- 12)Page 30 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2* 6 hours -Install test equipment for monitoring DW pressure and suppression pool water level. All otheractions required are assumed to be in-line with the FLEX timeline submitted in accordance with the EA-12-049 requirements.* Less than 8 hours -Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizingthe peak DW pressure during the initial cooling conditions provided by SAWA.Determine operating requirements for SA WA, such as may be used in an ELAP scenario to mitigate core damage.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 I NET 13-02 Section 1.1.6, 1.1.4.4It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systemsor presumed failure of injection systems in a timely manner. This does not preclude the use of the SAWA system tosupplement or replace the EA-12-049 injection systems if desired. SAWA will consist of both portable andinstalled equipment.The motive force equipment needed to support the SAWA strategy shall be available prior to T=8 hours from theloss of injection (assumed at T=0).The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids I gases andpotentially flammable conditions by inclusion of backflow prevention. The SAWA pump check valve is integralwith the pump skid and will close and prevent leakage when the SAWA pump is secured. LPCI injection mode hasinstalled ECCS check valve 2(3)-1501-25A(B) qualified for accident scenarios to prevent reverse flow from theRPV.Table 3.2 -SAWA Manual Actions TimelineTime Action NotesT<I hour U Connect SAWA hose in Reactor U No evaluation required forBuilding (Step 2 of Table 3.1). actions inside ReactorU Open MOV 2(3)-1501-22A(B). Building.U Core damage for Dresden isassumed to start at 1.9 hours.(MAAP Case 8).T-l-~7* hours U Complete actions started at T<l hour U Evaluate core gap and early in(Step 2 of Table 3.1). vessel release impact to reactor*The assumed times of T=1 hr to U Connect SAWA pump to water supply building access for SAWAT=8 hrs to establish the bounds of at intake structure (Step 3 of Table 3.1). actions. It is assumed thatapplicability of radiologicalevaluations bave been reduced to
* Install test equipment to monitor DW Reactor Building access isT=1 hr to T=7 hrs in order to Pressure and Suppression pool water limited due to the source termprovide sufficient margin to inform level (Step 4 of Table 3.1). at this time unless otherwiseoperator action feasibility U Establish flow of at least 421 gpm to the noted. (Refer to HCVS-FAQ-evaluations and will be further RPV using SAWA systems. Begin 12 for actions in T=l-8 hourinome yemrenyrspne injection (Step 5 of Table 3.1). timeframe.Page 31 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2dose assessment activities duringan actual event. This accounts forthe one hr gap between 7 and 8 hrsin this time line.T<8-1 2 hours U Monitor and Maintain SAWA flow at U SAWA flow must commence421 GPM for four hours Steps 5 & 6 of at T=8 hours but should beTable 3.1). done as soon as motive force isavailable.T_<12 hours U Proceed to SAWM actions per Part U SAWA flow may be reduced3.1.A (Step 7 of Table 3.]). to 85 GPM at four hours_____________________following SAWA initiation.* ~~Greater Than 24 Hour coping Detail *Provide a general description of the SA WA actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NEI 13-02 Section 4.2.2.4.1.3.1,1I.1.4SAWA Operation is the same for the full period of sustained operation. If SAWM is employed, flow rates will bedirected to preserve the availability of the HCVS wetwell vent (see 3.1 .A)." : ' ~~~DetailS: ...Details of Design Characteristics/Performance SpecificationsSA WA shall be capable of providing an RPV injection rate of 500 gpm within 8 hours of a loss of all RPV injectionfollowing an ELAP/Severe Accident. SA WA shall meet the design characteristics of the HCVS with the exception ofthe dedicated 24 hour power source. Hydrogen mitigation is provided by backflow prevention for SA WA.Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NEI 13-02 Section 1.1.4Equipment Locations/Controls/InstrumentationDresden has not performed a site specific evaluation to justify the use of a lower site unique initial SAWA flowrate. Consequently, Dresden will assume an initial flow rate of 421 gpm. This is based on the Industry genericvalue of 500 gpm multiplied by (Dresden rated power (2957 MWt)/Rated power for the generic plant (3514 MWt,NEI 13-02, 4.1.1.2.3). This initial flow rate will be established within 8 hours of the loss of all RPV injectionfollowing an ELAP/Severe Accident and will be maintained for four hours before reduction to the Wetwell ventpreservation flow rate.The locations of the SAWA equipment and controls, as well as ingress and egress paths will be evaluated for theexpected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period.Equipment will be evaluated to remain operational throughout the Sustained Operating period. Personnel exposureand temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERG doseand plant safety guidelines for temperature and humidity.The flow path will be suction at the intake structure for the plant Ultimate Heat Sink (UHS) through the submersiblepump and a downstream SAWA Booster pump. A valve manifold at the discharge of SAWA Booster pump willinclude valves with throttle capability and separate lines for Dresden Unit 2 RPV and Dresden Unit 3 RPV. Thisvalve manifold will also provide minimum flow and freeze protection for the pump. This pump and valve manifoldwill be in a suitable location to allow access under severe accident conditions.Page 32 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2From this valve manifold, hoses will be routed to the permanent SAWA connection point located in the ReactorBuilding 517' elevation. The connection at the Reactor Building location is on a LPCI line to the RPV. Thisconnection point includes one manual valve, which will be opened and kept open. In addition, it requires locallymanually opening motor operated valve (MOV) 2(3)-1501-22A(B) on the LPCI line. The second MOV (2(3)-1501-21A(B)) is normally open. The actions at the Reactor Building will be done within the first hour of the event priorto severe accident conditions occurring. Backflow in the LPCI line is prevented by an existing LPCI check valve2(3)- 1501 -25A(B).DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by use of the FLEX pumpcontrol valve at the valve manifold that also contains the SAWA flow indication. Communication will beestablished between the MCR and the SAWA flow control location.Containment instrumentation required for SAWA will be monitored through testing instruments powered frombatteries (e.g., 9 VDC).The Intake structure is a significant distance from the discharge of the HCVS pipe with substantial structuralshielding between the HCVS pipe and the pump deployment location. Pump refueling will also be accomplishedfrom the EDG fuel oil tanks as described in the EA-12-049 compliance documents. See mechanical and electricalsketches in attachments, plant layout sketches in the assumptions part and a list of actions elsewhere in this part.Evaluations of actions outside the Reactor Building for projected SA conditions (radiation ! temperature) indicatethat personnel can complete the initial and support activities without exceeding the ERG-allowable dose forequipment operation or site safety standards (reference HCVS-WP-02, Plant Specific Dose Analysis for the Ventingof Containment during SA Conditions). Evaluation of actions inside the Reactor Building for projected SAconditions (radiation/temperature) will be performed to determine that personnel can complete the initial andsupport activities without exceeding the ERG-allowable dose for equipment operation or site safety standards(reference HCVS-FAQ- 12).Electrical equipment and instrumentation will be powered from the power sources noted in the table below withportable generators to maintain battery capacities during the Sustained Operating period.Parameter Instrument Location Power Source / NotesDW Pressure* 2(3)-1640-11A(B) MCR Hand held testequipmentRG 1.97 qualifiedSuppression Pool Level* 2(3)-1640-13A(B) MCR Hand held testequipmentRG 1.97 qualifiedSAWA Flow* FLEX Pump Flow TBD Self-powered fromindicator internal batteryValve indications and NA NA All valves are locallycontrols manually operated* minimum required instruments.The instrumentation and equipment being used for SAWA and supporting equipment will be evaluated to performPage 33 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2for the Sustained Operating period under the expected radiological and temperature conditions.Equipment ProtectionSAWA installed components and connections external to protected buildings will be protected against the screened-in hazards of EA- 12-049 for the station. Portable equipment used for SAWA implementation will meet theprotection requirements for storage in accordance with the criteria in NEI 12-06, Revision 0.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 5.1.1, 5.4.6, 1.1.6Provide a brief description of Procedures I Guidelines:Confirm that procedure/guidance exists or will be developed to support implementation.Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NEI 13-02 Section 1.3, 6.1.21. Connect SAWA pump discharge to LPCI piping.* Connect SAWA hose in Reactor Building (Step 2 of Table 3.1).* Open MOV 2(3)-150 1-22A(B).2. Connect SAWA pump to intake using FSG*.3. Power SAWAIHCVS components using FSG.4. Start SAWA pump to establish SAWA flow.5. Adjust SAWA flow at valve manifold and using SAWA flow indication to establish and maintain requiredflow.*Where an FSG (FLEX Support Guidelines) is referenced, it is yet to be determined if new guidance needs tobe developed or if it will be the same FSG reference with the same steps used for FLEX.Identify modifications:List modifications and describe how they support the SA WA Actions.Ref: EA-13-109 Attachment 2, Section B.2.2, / NET 13-02 Section 4.2.4.4, 7.2.1.8, Appendix IThe list of modifications, below, is limited to those required to upgrade EA-12-049 FLEX equipment to meet EA-13-109 Phase 2 SAWA requirements.Electrical Modifications -TBDMechanical Modifications -TBDInstrument Modifications -SAWA flow instrument (others TBD)Component Qualifications:State the qualification used for equipment supporting SA WARef: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 1.1.6Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this OIP.Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment asspecified in NEI 12-06 Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 designPage 34 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2conditions.Notes:NonePart 3.1 .A: Boundary Conditions for SAWAISAWM*
* Time periods for the maintaining SAWM actions such that the WW ventSA WM Actions supporting SA conditions that have a time constraint to be successful should be identified with atechnical basis and a justification provided that the time can reasonably be met (for example, a walkthrough ofdeployment). Actions already identified under the HCVS part of this template need not be repeated here.There are three time periods for the maintaining SA WM actions such that the W4W vent remains available to removedecay heat from the containment:* SAWM can be maintained for >7 days without the need for a dmywell vent to maintain pressure belowPCPL or containment design pressure, whichever is lower.o Under this approach, no detail concerning plant modifications or procedures is withrespect to how alternate containment heat removal will be provided.* SAWM can be maintained for at least 72 hours, but less than 7 days before DWpressure reaches PCPLor design pressure, whichever is lower.o Under this approach, a functional description is required of how alternate containment heatremoval might be established before DW pressure reaches PCPL or design pressure whichever islower~. Under this approach, physical plant mnodifications and detailed procedures are notnecessary, but written descriptions of possible app roaches for achieving alternate containment heatremoval and pressure control will be provided.* SAWM can be maintained for <72 hours SAWM strategy can be implemented but for less than 72hours before DW pressure reaches PCPL or design pressure whichever is lower.o Under this approach, a functional description is required of how alternate containment heatremo~val might be established before DW pressure reaches PC'PL or design pressure whichever islower. Under this approach, physical plant mnodifications and detailed procedures are required tobe implemented to insure achieving alternate containment heat removal and pressure control willbe provided for the sustained operating period.Ref: NEI 13-02 Appendix C.7SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.Basis for SAWM time frame... .. ."SAWM can be maintained >7 days:Dresden has not performed a site specific evaluation to justify the use of a lower site unique initial SAWA flowrate. Consequently, Dresden will assume an initial flow rate of 421 GPM. This is based on the Industry genericvalue of 500 gpm multiplied by (Dresden rated power/Rated power for the generic plant).This initial flow rate will be established within 8 hours of the loss of all RPV injection following an ELAP/SevereAccident and will be maintained for four hours before reduction to the Wetwell vent preservation flow rate of 85gpm.Page 35 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Instrumentation relied upon for SAWM operations is Drywell Pressure, Suppression Pool level and SAWA flow.Except for SAWA flow, SAWM instruments are initially powered by station batteries. After Station batterydepletion, these parameters will be monitored by portable test equipment using small batteries that will be availablefor the Sustained Operation period (7 days). The SAWA flow instrument will be self-powered from an internalpower supply capable of being replenished, if needed, through the Sustained Operation period. DW Temperaturemonitoring is not a requirement for compliance with Phase 2 of the order, but some knowledge of temperaturecharacteristics provides information for the operation staff to evaluate plant conditions under a severe accident andprovide confirmation to adjust SAWA flow rates (Ref. 9: C.7.l.4.2, C.8.3.1).Suppression Pool level indication is maintained throughout the Sustained Operation period, so the HCVS remainsin-service. The time to reach the level at which the WW vent must be secured is >7 days using SAWM flowrates(Ref. 9: C.6.3, C.7.1.4.3).Procedures will be developed that control the Suppression Pool level, while ensuring the DW pressure indicates thecore is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which SAWMflowrate should be adjusted (up or down) using suppression pool level and DW pressure as controlling parametersto remove the decay heat from the containment. (This is similar to the guidance currently provided in the .BWROGSAMGs.) (Ref. 9: C.7.1.4.3)Attachment 2.1 I.A shows the Sequence of Events Timeline for SAWA / SAWM. (Ref. 9: C.7. 1.4.4).Table 3 ,1,B -SAW M M anual Actions .* , ., ,Primary Action Primary Location!/Component Notes1. Lower SAWA injection rate to At the valve manifold on the e Control to maintaincontrol Suppression Pool Level SAWA Booster pump. containment and WWand decay heat removal. parameters to ensure WW ventremains functional.* 85 gpm minimum capability ismaintained for greater than 7days.2. Control SAWMV flowrate for Containment Instrument monitoring
* SAWM flowrate will becontainment control/decay heat in MCR. monitored using the followingremoval, instruments:SAWA flow at the valve manifold -SAWA Flowon the SAWA Booster pump. -Suppression Pool Level-Drywell Pressure* SAWM flowrate will becontrolled using the manualvalve at the valve manifold.3. Establish alternate decay heat Various locations. SAWM strategy can preserve theremoval. wetwell vent path for >7 days.4. Secure SAWA ! SAWM. At SAWA Pumps' location(s). When alternate decay heat removalis established.SAWM Time Sensitive Actions, Page 36 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Time Sensitive SAWM Actions:12 Hours -Initiate actions to maintain the Wetwell (WW) vent capability by lowering injection rate, whilemaintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the WWvent remains available.SAWiV Severe Accident OperationDetermine operating requirements for SA WM, such as may be used in an ELAP scenario to mitigate core damage.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix CIt is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plantinjection systems per direction by the plant SAMGs. Refer to Attachment 2.1 .D for SAWM SAMG languageadditions.First 24 Hour Coping DetailProvide a general description of the SA WM actions for first 24 hours using installed equipment including stationmodifications that are proposed.Given the initial conditions for EA-13-109:* BDBEE occurs with ELAP* Failure of all injection systems, including steam-powered injection systemsRef: EA-13-109 Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 I NEI 13-02 2.5, 4.2.2, Appendix C, SectionC.7SAWA will be established as described as stated above. SAWM will use the installed instrumentation to monitorand adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWMstrategy.Once the SAWA initial flow rate has been established for 4 hours, the flow will be reduced while monitoring DWpressure and Suppression Pool level. SAWM flowrate can be lowered to maintain containment parameters andpreserve the WW vent path. SAWM will be capable of injection for the period of Sustained Operation.= Greater Than 24 Hour Coping DetailProvide a general description of the SA WM actions for greater than 24 hours using portable and installedequipment including station modifications that are proposed.Ref: EA-13-109 Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 4.2.2, Appendix C,Section C.7SAWM can be maintained >7 days:The SAWM flow strategy will be the same as the first 24 hours until 'alternate reliable containment heat removaland pressure control' is reestablished. SAWM flow strategy uses the SAWA flow path. No additionalmodifications are being made for SAWM.t. Details:Page 37 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Details of Design Characteristics/Performance SpecificationsRef: EA-13-109 Attachment 2, Section B.2.2, B.2.3 I NEI 13-0)2 Section Appendix CSAWM shall be capable of monitoring the containment parameters (DW pressure and Suppression Pool Level) toprovide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control isestablished. SAWA will be capable of injection for the period of Sustained Operation.Equipment Locations/Controls/InstrumentationDescribe location for SA WM monitoring and control.Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C, Section C.8, Appendix IThe SAWM control location is the same as the SAWA control location. Local indication of SAWM flow rate isprovided at the valve manifold by installed flow instrument qualified to operate under the expected environmentalconditions. The SAWA flow instrument is self-powered by an internal power supply. Communications will beestablished between the SAWM control location and the MCR.Injection flowrate is controlled by FLEX manual valve located on the valve manifold.Suppression Pool level and DW pressure will be read with hand-held test instruments. These indications are used tocontrol SAWM flowrate to the RPV.Key Parameters:List instrumentation credited for the SA WM Actions.Parameters used for SAWM are:* Drywell Pressure* Suppression Pool Level* SAWM FlowrateThe Drywe11 pressure and Suppression Pool level instruments (2(3)-1640-l1A(B) and 2(3)-1640-13A(B)) arequalified to RG 1.97 and are the same as listed in Part 2 of this OIP. The SAWM flow instrumentation will bequalified for the environmental conditions expected when needed.Notes:NonePage 38 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 3: Boundary Conditions for EA-13-109, Option 2Part 3.1 .B: Boundary Conditions for SAWAISADVL ':" ", :/ .. " of WW Design Considerations" .. ""''This section is not applicable to Dresden since Dresden is not using the option of SADV.Table 3.1.C -SAD V Manual Actions-r " .... .. i. 'Timeline for SADVY_- '' "Severe Accident Venting -:First 24 Hour Coping Detail " "-* Greater Than 24 Hour Coping Detail -:* Details: :: .. " , 'Page 39 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Progralmmatic Controls. Training. Drills and MaintenanceIdentify how the programmatic controls will be met.Provide a description of the programmatic controls equipment protection, storage anddeployment and equipment quality addressing the impact of temperature and environment.Ref: EA-13-109 Section 3.1, 3.20 / NEI 13-02 Section 6.1.2, 6.1.3, 6.2Program Controls:The HCVS venting actions will include:*Site procedures and programs are being developed in accordance with NEI 13-02 to address useand storage of portable equipment relative to the Severe Accident defined in NRC Order EA-13-109 and the hazards applicable to the site per Part 1 of this OIP.*Routes for transporting portable equipment from storage location(s) to deployment areas will bedeveloped as the response details are identified and finalized. The identified paths and deploymentareas will be accessible when the HCVS is required to be functional including during SevereAccidents.Procedures:Procedures will be established for system operations when normal and backup power is available, andduring ELAP conditions.The HCVS and SAWA procedures will be developed and implemented following plant processes forinitiating or revising procedures and contain the following details:* appropriate conditions and criteria for use of the HCVS and SAWA* when and how to place the HCVS and SAWA in operation* location of system components* instrumentation available* normal and backup power supplies* directions for sustained operation (Reference 9), including the storage and location of portableequipment* location of the remote control HCVS operating station (panel)* training on operating the portable equipment* testing of portable equipmentDresden credits Containment Accident Pressure (CAP) for ECCS pump NPSH.Dresden will establish provisions for out-of-service requirements of the HCVS and compensatory measuresthat comply with the criteria from NEI 13-02 (Reference 9). The following provisions will be documentedin the HCVS Program Document:The provisions for out-of-service requirements for HCVS/SAWA are applicable in Modes 1, 2 and 3:* If for up to 90 consecutive days, the primary or alternate means of HCVS/SAWA operation are non-functional, no compensatory actions are necessary.* If for up to 30 days, the primary and alternate means of HCVS/SAWA operation are non-functional,Page 40 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and Maintenanceno compensatory actions are necessary.* If the out of service times exceed 30 or 90 days as described above, the following actions will beperformed through the site corrective action program:* Determine the cause(s) of the non-functionality,* Establish the actions to be taken and the schedule for restoring the system to functional statusand to prevent recurrence,* Initiate action to implement appropriate compensatory actions, and* Restore full HCVS functionality at the earliest opportunity not to exceed one full operatingcycle.Describe training planList training plans for affected organizations or describe the plan for training development.Ref: EA-13-109 Section 3.2 / NEI 13-02 Section 6.1.3Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receivenecessary training in the use of plant procedures for system operations when normal and backup power isavailable and during ELAP conditions. The training will be refreshed on a periodic basis and as anychanges occur to the HCVS/SAWAJSAWM actions, systems or strategies. Training content and frequencywill be established using the Systematic Approach to Training (SAT) process.Identify how the drills and exercise parameters will be met.Alignment with NE!113-06 andt 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking.The Licensee should demonstrate use in drills, tabletops, or exercises for HCVS operation as follows."* Hardened containment vent operation on normal power sources (no FLAP).*During FLEX demonstrations (as required by EA-12-049): Hardened containment vent operationon backup power and from. primary or alternate location during conditions of ELAP/loss of UHSwith no core danutge. System use is for containment heat removal AND containment pressurecontrol.*HCVS operation on backup power and from primar3, or alternate location during conditions ofFLAP/loss of UHS with core damage. System use is for containment heat renwval ANDcontainment pressure control with potential for combustible gases (Denonstration maty be inconjunction with SAG change).* Operation for sustained period with SAWA andt SAWM to provide decay heat removal andcontainment pressure control.Ref: EA-13-109 Section 3.1 / NET 13-02 Section 6.1.3Dresden will utilize the guidance provided in NEI 13-06 and 14-01 (References 10 and 11) for guidancerelated to drills, tabletops, or exercises for HCVS operation. In addition, Dresden will integrate theserequirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9.Page 41 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and MaintenanceDescribe maintenance plan:o The maintenance program should ensure that the HCVS/SAWA/SAWM equipment reliability is beingachieved in a manner similar to that required for FLEX equipment. Standard industr~y templates (e.g.,EPRI) and associated bases may be developed to define specific maintenance and testing.o Periodic testing and frequency should be determined based on equipment type and expecteduse (further details are provided in Part 6 of this document).o Testing should be done to verify design requirements and/or basis. The basis should bedocumented and deviations fr'om vendor recommendations and applicable standards shouldbe justifiled.o Preventive maintenance should be determined based on equipment type and expected use. Thebasis should be documented and deviations from vendor recommendations and applicablestandards should be justified.o Existing work control processes may be used to control maintenance and testing.* HCVS/SA WA permanent installed equipment should be maintained in a manner that is consistent withassuring that it performs its function when required.o HCVS/SAWA permanently installed equipment should be subject to maintenance and testingguidance provided to verify proper function.* HCVS/SAWA non-installed equipment should be stored and maintained in a manner that is consistentwith assuring that it does not degrade over long periods of storage and that it is accessible forperiodic maintenance andt testing.Ref: EA-13-109 Section 1.2.13 / NEL 13-02 Section 5.4, 6.2Dresden will utilize the standard EPRI industry PM process (similar to the Preventive Maintenance BasisDatabase) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SAWMcomponents. The control program will include maintenance guidance, testing procedures and frequenciesestablished based on type of equipment and considerations made within the EPRI guidelines.Dresden will implement the following operation, testing and inspection requirements for the HCVS andSAWA to ensure reliable operation of the system.Table 4-1: Testing and Inspection RequirementsDescription FrequencyCycle the HCVS and installed SAWA valves' Once per every2 operating cycleand the interfacing system valves not used tomaintain containment integrity during Mode 1,2 and 3. For HCVS valves, this test may beperformed concurrently with the control logictest described below.Cycle the HCVS and installed SAWA check Once per every other4 operating cyclevalves not used to maintain containmentintegrity during unit operations3.Perform visual inspections and a walk down of Once per every other4 operating cycleHCVS and installed SAWA components.Page 42 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 4: Programmatic Controls. Training. Drills and MaintenanceFunctionally test the HCVS radiation monitors.Once per operating cycleLeak test the HCVS. (1) Prior to first declaring the systemfunctional;(2) Once every three operating cyclesthereafter; and(3) After restoration of any breach ofsystem boundary within the buildingsValidate the HCVS operating procedures by Once per every other operating cycleconducting an open/close test of the HCVScontrol function from its control location andensuring that all HCVS vent path andinterfacing system valves5 move to their proper(intended) positions.SNtrequired for HCVS and SAWA check valves.2 Atrtwo consecutive successful performances, the test frequency may be reduced to a maximum of onceper every other operating cycle.3 o required if integrity of check function (open and closed) is demonstrated by other plant testingrequirements.4Atrtwo consecutive successful performances, the test frequency may be reduced by one operatingcycle to a maximum of once per every fourth operating cycle.5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (lossof power and/or air) do not require control function testing under this part. Performing existing plantdesign basis function testing or system operation that reposition the valve(s) to the HCVS requiredposition will meet this requirement without the need for additional testing.Notes:PCIVs are required for containment integrity during Modes 1-3 and thus are excluded from EA-13-109testing requirements. However, these PCI Vs are tested per by the Dresden design basis requirements toensure valve operability and leakage tightness. Refer to generic assumption 109-4.Page 43 of 69 Darese NucMlearPwrstatone Sceunis2enPart 5: Milestone ScheduleProvide a milestone schedule. This schedule should include:* Modifications timeline* Procedure guidance development completeo HCVS Actionso Maintenance* Storage plan (reasonable protection)* Staffing analysis completion* Long term use equipment acquisition timeline* Training completion for the TICVS ActionsThe dates specifically required by the order are obligated or" committed dates. Other dates are planned dates subjectto change. Updates will be provided in the periodic (six month) status reports.Ref: EA-13-109 Section D.1, D.3 / NET 13-02 Section 7.2.1The following milestone schedule is provided. The dates are planning dates subject to change as design andimplementation details are developed. Any changes to the following target dates will be reflected in the subsequent6-month status reports.Phase 1 Milestones:Milestone Target Activity Status CommentsCompletionDateHold preliminary/conceptual design meeting June 2014 CompleteSubmit Overall Integrated Implementation Plan Jun 2014 CompleteSubmit 6 Month Status Report Dec 2014 CompleteSubmit 6 Month Status Report Jun 2015 CompleteSubmit 6 Month Status Report Dec. 2015 Complete with Simultaneous withthis submittal Phase 2 OIPU3 Design Engineering Complete December Started2015U3 Implementation Outage October Not Started2016U3 Maintenance and Operation Procedure Changes November Not StartedDeveloped, Training Complete, & Walk-Through 2016Demonstration/Functional TestU2 Design Engineering Complete September Not Started2016U2 Implementation Outage October Not Started2017U2 Maintenance and Operation Procedure Changes November Not StartedDeveloped, Training Complete, & Walk-Through 2017Demonstration/Functional TestPage 44 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPart 5: Milestone ScheduleSubmit Completion Report May 2018Phase 2 Milestone Schedule: .. ..Phase 2 Milestone ScheduleMilestone Target Activity Status CommentsCompletionDateSubmit Overall Integrated Implementation Plan Dec 2015 Complete with Simultaneous withthis submittal Phase 1 Updated OWPHold preliminary/conceptual design meeting Jan 2016 Expect to beengineeringjustification notmodificationsSubmit 6 Month Status Report June 2016Submit 6 Month Status Report Dec 2016Submit 6 Month Status Report June 2017Submit 6 Month Status Report Dec 2017Submit 6 Month Status Report June 2018Submit 6 Month Status Report Dec 2018U2 Design Engineering Complete October 2016 Not Started Conceptual completedU2 Implementation Outage October 2017 Not Started Concurrent with Unit 2Phase 1U2 Maintenance and Operation Procedure Changes Developed, November Not Started SAMG Revision;Training Complete, & Walk-Trough Demonstration/Functional 2017 Concurrent with Unit 2Test Phase 1U3 Design Engineering Complete TBD Not StartedU3 Implementation Outage October 2018 Not StartedU3 Maintenance and Operation Procedure Changes Developed, November Not StartedTraining Complete, & Walk-Trough Demonstration/Functional 2018TestSubmit Completion Report May 2019Notes:NonePage 45 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 1: HCVS/SAWA/SADV Portable EquipmentBDBEE Severe Performance Maintenance /PM requirementsList portable equipment Venting Accident CriteriaVentingNitrogen Cylinders X X 2 cylinders Check periodically for pressure, replace orreplenish as needed (EC 400578,frequency specified by PM).Argon Cylinders NA X 14 cylinders Check periodically for pressure, replace orreplenish as needed.FLEX DG X X 800 KW 480V Per response to EA-12-049.FLEXISAWA Pump X X TBD Per vendor manual.Portable Air Compressor (optional) X X TBD Per vendor manual.Small Portable Generator X X TBD Per vendor manual.DW Pressure Indicator. Hand Held Test Eqpt. X X TBD Per vendor manualSuppression Pool Level Indicator, Hand Held X X TBD Per vendor manualTestEquipment ____________ _________ __________________Page 46 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2A: Seqiuence of Events Timeline -HCVSELAPt=OIS& ICS securedHPCI in due to shell sideservice inventorytr2.0m t= 20m ICS Rc~stnred hHPCI assumedlost (Flex OIP)No Injectiont=12 hrs. Begin monitoringHCVS support systems. Noreplenishment expected to berequired until 24 hours.utt=]Inlectitingtingt= 1{2 hrst= 24 hrs. Replenishmentof HCVS supportssystems required.18ion{SAWALost IlniectionLevel at 'TAFtz 23 hrs 24 hrs t= 3t=z 2't hrsSequence 1FLEX successful;Containment ventingnot required due toICSU/hrsContainment Ven(based on preventexceeding PCPL)t,Sequence 2SRCIC Late FailureRef: SECY-12-0 157t= 168 hrs Sequence 3*3 RCIC Early FailureRef: SOARCACoret~l r hrsSAWAIniectionLegendNot to ScaleAdequate core cooling maintained.... .......... Injection lostIncreased shine at wetwell-Post-RPV hreachPage 47 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .A: Sequence of Events Timeline -SAWA / SAWMSustained Operation periodT=168 hoursT=168 hoursSAWAMonitor containment parameters and conditions)Time ActionT=0 hours Start of FLAPT=8 hours Initiate SAWA flow at 421 gpm as soon as possible but no later than 8 hoursT=12 hours Throttle SAWA flow to 85 gpm 4 hours after initiation of SAWA flowT=168 hours End of Sustained OperationPage 48 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .B Sequence of Events Timeline -SADVNot applicable to DresdenPage 49 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .C: SAWA/SAWM Plant-Specific DatumSpill Over Pptrfl -2 503'Spillovertiejtt.t LEDrywell FloorEL Wetwetl Levelinstrumentrange (0-30')Wetwell14 9' MAX LCO (TSG-2)Total Torus Height 30fTorus Max [CO Level 14' -9" (897500 gal)Total Torus Voume -1919000 galFreeboard volume in torus ~1021500 galRate of level rise -0 3 ft/hr @ 421 gpmRate of level rise 0 0074 ft/hr @ 85 gpmTotal water added (421 gpm for 4 hours and85 gpm for 164 hours ~940000 galNote: The above calculation does not considermass loss rate by steam leaving the vernj,making the above estimates very conservativePage 50 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 2.1 .D: SAWM SAMG Approved LanguageThe following general cautions, priorities and methods will be evaluated for plant specific applicability and incorporated as appropriate into the plant specificSAMGs using administrative procedures for EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefo~re addressa wide variety of possible plant conditions and capabilities while these changes are intended to accommodate those specific conditions assumed in Order EA-13-109. The changes will be made in a way that maintains the use of SAMGs in a s)ymptom based mode while at the same time addressing those conditions that mayexist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris.Actual Approved Language that will be incorporated into site SAMG*Cautions:SAddressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapidsteam generation.* Addressing the plant impact that raising suppression pool water level above the elevation of the suppression chamber vent opening elevation will flood thesuppression chamber vent path.Priorities:With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases asfollows:* Core debris in the primary containment is stabilized by water addition (SAWA).* Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting).* Water addition is managed to preserve the Mark I/II suppression chamber vent paths, thereby retaining the benefits of suppression pool scrubbing andminimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM).Methods:Identify systems and capabilities to add water to the RPV or drywell, with the Ib)llowing generic guidance:* Use controlled injection if possible.* Inject into the RPV if possible.Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.* Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.Page 51 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 3: Conceptual Sketches(Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies)Sketch 1A Electrical Layout of System (preliminary)Sketch 2A P&ID Layout of Wetweil VentSketch 2B Remote Operating StationSketch 2C HCVS Layout OverviewSketch 3A P&ID Layout of SAWASketch 3B SAWA Site LayoutPage 52 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 1A" Electrical Layout of System -HCYSpItV..),IA..3A.IA,IA)A.IPage 53 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2A: P&ID of Wetwell VentTO SI~OCFC0I-II2(3)-I1601-931601-13FCNCRupture DiscI!KEY16w-GoNCfin[~] )kA 14liii Iimliii N-m ~EW NE~-m DUTUatterv Power and Nitrogoenuoolv to Valves:601.-23501-60ew Block Valveew Control ValveSDRESDEN HCVS SCHEMATICPage 54 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2B: Remote Operating Station0o1rIjI_I-EC 40578REVI j057Rg1"O"I- ~' IIaPage 55 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2B contd..: Remote Operating StationROS for Unit 3-UA~m~E) Ir ~WO~KnPJ _"AR" ~ EL. -~me 5~ c*'r ~ir~j~~1/L1-)i1 -L*14.grL7~.%C ~-XrU~rrI TEA-~ IILU~ Wi4f~ ~ ________~i. ~?9 0 ~EC1~PUW r.~ItL.~IImm'7?0II (CI) I~K. I~~Q34-~*IM~ '7I~It~I 1i~~~f1&#xb6; ?4*4 ---u-~ '~ms ~1~r i~j~ ~4~'A ~? _ -~ ~___ _ :.6~L~ PLAN Eu. .~ JULUt-I _______ te UPage 56 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2C; HCVS Layout Overview -View I41 RELEASEATELEVG65'~OPO~ CRANIRAIL CL,~1I,~-~__________ MACH. AOO~ RQO~I MMJ.~L@~e. I'TO CAANt CA~IL. ~ai-*UNIT 2--- -~MlWd~ft ~Ift*L 'TAWC_______________ potA. ta, t~wIJ~IT2 ~ ~ L~-LL. S43~(C~dThQ4.~OD bAwlHY~S.AUIJC ~LMM(MT~AC~UM, M4.1@AtQP~1. A~9~7tF~VPIftOI1Ll~. ~~gTTOMOP NLAOL~b~1W~LL g~u'~ OAA.H FLOCA IL. 474~4__ FROM PA-BPage 57 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 2C contd...: HCVS Layout Overview -View 2 showing ROSQtop ow ~YACe~&#xa3;L. S7~ 4~t1ff- af- I&R 30..IL ~ **I4 ~Th AUR. *Wgg?POU I RIM.cAR-6:4a RIACtORL1IWAUX ~?ACICIt5UILOrU-'S~R M0~&#xa3;L.It. !V.~,M-6~4~]II... &#xa3;94VS~~3IL.~3 1WY~a.m 4 M~WL4. TURRIME I ~4.LI TURBINE DECK 56V EL -.I,tI]jULWt~*JE1~J'u~ICON?Ashti's~IYATI'U".WAIlCut""'U2t.*R@0-ttt.~Irt'~IIL S1.TI~IIMtO.nA~ta.SQLUI'0W IAII~wAa~I'f ,4II5'SALIUI ]lIJSE.CI ION; B-BM1~'.---30WIPage 58 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 3A: P&ID Layout of SAWAToRPV1501-25 1501-26TORUSTo OtDivisiof LFLPCI HeatExchangerSAWABoosterPumptherion.1SAWA FlowIndicatorTo Other -...Unit SAWA TM .-...... Hose ".SAWA FlowIndicatorLiUHSLPCI PumpUHS SubmersiblePumpPage 59 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsSketch 3B: SAWA Site Layout,Page 60 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 4: Failure Evaluation Table (per NEI 13-06)Table 4A: Wetwell HCVS Failure Evaluation TableFunctional Failure Failure Cause Alternate Action Failure with AlternateMode Action Prevents____________Containment Venting?Fail to Vent (Open) Valves fail to open/close due to loss of normal None required -system SOVs utilize Noon Demand AC power/DC batteries, dedicated 24-hour power supply. ___________Valves fail to open/close due to depletion of Recharge system with provided portable Nodedicated power supply. generators.____________Valves fail to open/close due to complete loss Manually operate backup pneumatic NoOf power supplies, supply/vent lines at ROS. ___________Valves fail to open/close due to loss of normal No action needed. Valves are provided with Nopneumatic supply. dedicated motive force capable of 24-hour_____ ____ ____ ____ ____ ____ ____ ____ operation._ _ _ _ _ _ _ _ _ _ _ _Valves fail to open/close due to loss of Replace bottles as needed and/or recharge Noalternate pneumatic supply (long term). with portable air compressors.____________Valve fails to open/close due to SOV failure. Manually operate backup pneumatic Nosupply/vent lines at ROS.Fail to stop venting Not credible as there is not a common mode N/A No(Close) on demand failure that would prevent the closure of atleast 1 of the 2 valves needed for venting.Both valves designed to fail shut.____________________Spurious Opening Not credible as key-locked switch prevents N/A Nomispositioning of the downstream HCVSPCIV and, additionally, DC power for the_______________solenoid valve is normally de-energized. ____________________Spurious Closure Valves fail to remain open due to depletion of Recharge system with provided portable Nodedicated power supply, generators.Valves fail to remain open due to complete Manually operate backup pneumatic Noloss of power supplies, supply/vent lines at ROS.Valves fail to remain open due to loss of Replace bottles as needed and/or recharge Noalternate pneumatic supply (long term). with portable air compressors.Page 61 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 5: References1. Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regardto Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (OrderNumber EA-13-109) RS-14-0582. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 19893. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 20124. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 20135. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis ExternalEvents, dated August 29, 20126. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents,dated November 14, 20137. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-IS G-2012-02: Compliance with Order EA- 12-050, Order Modifying Licenses with Regard to Reliable HardenedContainment Vents, ADAMS Accession No. ML12229A477, dated August 29, 20128. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August20129. NET 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 201510. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events,Revision 0, dated March 201411. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision0, dated March 201412. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations13. NEI HCVS-FAQ-02, HCVS Dedicated Equipment14. NEI HCVS-FAQ-03, HCVS Alternate Control Operating Mechanisms15. NEI HCVS-FAQ-04, HCVS Release Point16. NEI HCVS-FAQ-05, HCVS Control and 'Boundary Valves'17. NEI HCVS-FAQ-06, FLEX Assumptions/HCVS Generic Assumptions18. NEI HCVS-FAQ-07, Consideration of Release fr'om Spent Fuel Pool Anomalies19. NEI HCVS-FAQ-08, HCVS Instrument Qualifications20. NEl FHCVS-AQ-09, Use of Toolbox Actions for Personnel21. NEI White Paper HCVS-WP-01, HCVS Dedicated Power and Motive Force22. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach23. NEI White Paper HCVS-WP-03, Hydrogen/CO Control Measures24. Not Used25. NURFG/CR-71 10, Rev. 1, State-of-the-Art Reactor Consequence Analysis Project, Volume 1: Peach BottomIntegrated Analysis26. SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling WaterReactors with Mark I and Mark II Containments, 11/26/1227. Dresden UFSAR, Updated Safety Analysis Report.28. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1F Equipment forNuclear Power Generating Stations29. FLEX MAAP Endorsement ML13190A20130. Not Used31. JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regardto Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, datedApril 201532. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade,Revision 0, dated August 17, 201533. NEI HCVS-FAQ-10, Severe Accident Multiple Unit Response34. NEl HCVS-FAQ-1 1, Plant Response During a Severe Accident35. NEl HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial UsePage 62 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents36. NEI HCVS-FAQ-13, Severe Accident Venting Actions Validation37. MAAP Analysis to Support FLEX initial strategy, RM Document No. DR-MISC-043 Rev. 1Page 63 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 6: Changes/Updates to this Overall Integrated ImplementationPlanThis Overall Integrated Plan has been updated in formnat and content to encompass both, Phase 1 and Phase 2 of OrderEA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6-Month Status Reports.NonePage 64 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsAttachment 7: List of Overall Integrated Plan Open ItemsThe following tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the statusof each item.Phase 1 Open Items from OIP StatusOpenItems1 Confirm that at least 6 hours battery coping time is available. Deleted. Closed to ISE Open Item number 1.2 Determine actions to enable wetwell (WW) venting following a flooding around the torus. Deleted. Closed to ISE Open Item number 2.3 Determine how Motive Power and/or HCVS Battery Power will be disabled during normal Deleted. Closed to ISE Open Item number 3.operation.4 Confirm that the Remote Operating Station (ROS) will be in an accessible area following a Deleted. Closed to ISE Open Item number 12.Severe Accident (SA).5 Confirm diameter on new common HCVS Piping. Deleted. Closed to ISE Open Item number 5.6 Confirm suppression pool heat capacity. Deleted. Closed to ISE Open Item number 6.7 Determine the approach for combustible gases. Deleted. Closed to ISE Open Item number 7.8 Provide procedures for HCVS Operation. Deleted. Closed to ISE Open Item number 18.9 Perform radiological evaluation for Phase ivent line impact on ERO response actions. Not StartedPage 65 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPhase 1 Interim Staff Evaluation (ISE) Open Items StatusOpenItems1Make available for NRC staff audit documentation confirming that Complete. EC 391973 Rev. 0 was completed to evaluate proposed battery loadat least 6 hours battery coping time is available, shed to support FLEX events. The evaluation addressed both 125V and 250Vbattery systems. The evaluation identified that with the load shed, the 125V and250V batteries will maintain acceptable capacity for a minimum of six (6)hours. This time supports the FLEX Strategy time line actions.2 Make available for NRC staff audit documentation that confirms the Started.ability to operate HCVS following flooding around the suppressionpool.3Make available for NRC staff audit documentation of a method to Started.disable HCVS during normal operation to provide assurancesagainst inadvertent operation that also minimizes actions to enableHCVS operation following an ELAP.4 Make available for NRC staff audit the seismic and tornado missile Started.________final design criteria for the HCVS stack.5 Make available for NRC staff audit documentation of the licensee Started. Refer to the response to ISE open item 6.design effort to confirm the diameter on the new common HCVSpiping.6Make available for NRC staff audit analyses demonstrating that Started. The required 1% vent capacity at the lower of PCPL or containmentHCVS has the capacity to vent the steam/energy equivalent of one design pressure is being verified using RELAP which models the line size andpercent of licensed/rated thermal power (unless a lower value is routing.justified), and that the suppression pool and the HCVS together are In addition, MAAP analyses are being credited to verify that venting can beable to absorb and reject decay heat, such that following a reactor delayed for at least three (3) hours, which supports assuming a maximum decayshutdown from full power containment pressure is restored and then heat rate of 1%.maintained below the primary containment design pressure and theprimary containment pressure limit.7Provide a description of the final design of the HCVS to address Started. Argon purge system design in progress.hydrogen detonation and deflagration.8Make available for NRC staff audit documentation of a Started.determination of seismic adequacy for the ROS location.Page 66 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened Vents9 Make available for NRC staff audit documentation that demonstrates Not Started.adequate communication between the remote HCVS operationlocations and HCVS decision makers during ELAP and severeaccident conditions.10 Provide a description of the strategies for hydrogen control that Started. As described in the OIP, the HCVS torus vent path in each Dresdenminimizes the potential for hydrogen ga~s migration and ingress into unit, starting at and including the downstream PCIV, will be a dedicated HCVSthe reactor building or other buildings. flow path. There are no interconnected systems downstream of the downstream,dedicated HCVS PCIV. Interconnected systems are upstream of the downstreamHCVS PCIV and are isolated by normally shut, fail shut PCIVs which, if open,would shut on an ELAP. There is no shared HCVS piping between the twounits.The vent path will rely on an Argon purge system to prevent line failure due to____________________________________________hydrogen deflagration and detonation.11 Provide descriptions of design details that minimize unintended Started. Refer to the response to ISE item 10. This eliminates the possibility ofcross flow of vented fluids within a unit and between units on the cross flow of vented fluids within a unit and between the two units.site.12 Make available for NRC staff audit an evaluation of temperature and Started. Component location design in progress. The HCVS primary controlradiological conditions to ensure that operating personnel can safely panel will be located in the Main Control Room (MCR).access and operate controls and support equipment.13 Make available for NRC staff audit the final sizing evaluation for Started.HCVS batteries/battery charger including incorporation into FLEXDG loading calculation.14 Make available for NRC staff audit documentation of the HCVS Started. Nitrogen system design in progress.nitrogen pneumatic system design including sizing and location.15 Make available for NRC staff audit descriptions of all Started. Instrument design in progress.instrumentation and controls (existing and planned) necessary toimplement this order including qualification methods.Page 67 of 69 Dresden Nuclear Power Station Units 2 and 3________Overall Integrated Plan for Reliable Hardened Vents16 Make available for NRC staff audit the descriptions of local Started. Component location design in progress. The HCVS primary controlconditions (temperature, radiation and humidity) anticipated during panel will be located in the MCR.ELAP and severe accident for the components (valves,instrumentation, sensors, transmitters, indicators, electronics, controldevices, etc.) required for HCVS venting including confirmation thatthe components are capable of performing their functions duringELAP and severe accident conditions.17 Make available for NRC staff audit documentation of an evaluation Started. The existing containment isolation valves are being evaluated for theirverifying the existing containment isolation valves, relied upon for performance under wetwell venting conditions.the HCVS, will open under the maximum expected differentialpressure during BDBEE and severe accident wetwell venting.18 Make available for NRC staff audit procedures for HCVS operation. Not StartedPage 68 of 69 Dresden Nuclear Power Station Units 2 and 3Overall Integrated Plan for Reliable Hardened VentsPhase 2 Open Items from OIP CommentOpenItem1 Determine SAWA flow control. Not started2 Resolve location of the FLEX DG to mitigate radiological Not startedconsequences during severe accident conditions.3 Validate time-line for Reactor Building hose connections does not Not started________exceed 1 hour. __________________________________Page 69 of 69}}

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