JAFP-17-0116, Seventh Six-Month Status Report for Phases 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable Of.

Seventh Six-Month Status Report for Phases 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable Of.

ML17349A029
Person / Time
Site:	FitzPatrick
Issue date:	12/15/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, JAFP-17-0116, RS-17-151
Download: ML17349A029 (25)

Text

Exelon Generation ,

JAFP-17-0116 RS-17-151 Order EA-13-109 December 15, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Seventh Six-Month Status Report For Phases 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

References:

1. NRC Order Number EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013

2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions", Revision 0, dated November 14, 2013

3. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions", Revision 0, dated April 2015

4. NEI 13-02, "Industry Guidance for Compliance With Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions", Revision 1, dated April 2015

5. James A. FitzPatrick Nuclear Power Plant Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (JAFP-14-0075)

6. James A. FitzPatrick Nuclear Power Plant Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015 (JAFP-15-0149)

7. NRC letter to James A. FitzPatrick Nuclear Power Plant- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated February 12, 2015

8. NRC letter to James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents}, dated December 16, 2016

U.S. Nuclear Regulatory Commission Seventh Six-Month Status Report for EA-13-109 December 15, 2017 Page 2 On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an Order (Reference 1) to James A. FitzPatrick Nuclear Power Plant (JAF). Reference 1 was immediately effective and directs JAF to take certain actions to ensure that JAF has a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an Overall Integrated Plan (OIP) by June 30, 2014 for Phase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order. The interim staff guidance (References 2 and 3) provide direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions identified in References 2 and 3. Reference 5 provided the JAF Phase 1 OIP pursuant to Section IV, Condition D.1 of Reference 1. Reference 6 provided the JAF Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1.

The purpose of this letter is to provide the seventh six-month update report for Phases 1 and 2, pursuant to Section IV, Condition D.3 of Reference 1 that delineates progress made in implementing the requirements of Reference 1 for JAF. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation open items contained in References 7 and 8.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 151h day of December 2017.

Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

U.S. Nuclear Regulatory Commission Seventh Six-Month Status Report for EA-13-109 December 15, 2017 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC NYSPSC NYSE RDA

RS-17-151 / JAFP-17-0116 Enclosure James A. FitzPatrick Nuclear Power Plant Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (21 pages)

RS-17-151 / JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1 Introduction JAF developed a Phase 1 Overall Integrated Plan (Reference 2) and a Phase 2 Overall Integrated Plan (Reference 3), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability in response to NRG Order Number EA-13-109 (Reference 1). This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan, Phase 2 Overall Integrated Plan, and the subsequent Six Month Status Reports, including any changes to the compliance method, schedule, or need for relief I relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Phase 1 Overall Integrated Plan (Reference 2) and Phase 2 Overall Integrated Plan (Reference 3),

and are current as of December 1, 2017. (See Section 3)

• Phase 2 Design Engineering On-site/Complete

• Submitted 7th Six-Month Status Report by letter RS-17-151 / JAFP-17-0116 3 Milestone Schedule Status The following provides an update to Part 5 of the Phase 1 Overall Integrated Plan (Reference 2) and Part 5 of the Phase 2 Overall Integrated Plan (Reference 3). It provides the status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

JAF - Phase 1 and Phase 2 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Phase 1 Hold preliminary I conceptual design Jan 2014 Complete meeting Submit Overall Integrated Jun 2014 Complete Implementation Plan Submit 6 Month Status Report Dec 2014 Complete Submit 6 Month Status Report Jun 2015 Complete Design Engineering On-site/Complete Dec 2015 Complete Submit 6 Month Status Report Dec 2015 Complete Submit 6 Month Status Report Jun 2016 Complete Submit 6 Month Status Report Dec 2016 Complete Submit 6 Month Status Report Jun 2017 Complete Page 1 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Target Activity Milestone Completion Comments Status Date Complete with Submit 6 Month Status Report Dec 2017 this Submittal Operations Procedure Changes April 2018 Started Developed Site Specific Maintenance Procedure April 2018 Started Developed HCVS Implementation Complete May 2018 Started Procedure Changes Active Jun 2018 Not Started Walk Through Jun 2018 Not Started Demonstration/Functional Test Training Complete Jun 2018 Started HCVS Phase 1 Compliance Jun 2018 Not Started Submit Completion Report Nov 2018 Not Started Phase 2 Hold preliminary/conceptual design Oct 2015 Complete meeting Submit Overall Integrated Dec 2015 Complete Implementation Plan Submit 6 Month Status Report Jun 2016 Complete Submit 6 Month Status Report Dec 2016 Complete Submit 6 Month Status Report Jun 2017 Complete Design Engineering On-site/Complete Oct 2017 Complete Complete with Submit 6 Month Status Report Dec 2017 this submittal Operations Procedure Changes Jun 2018 Started Developed Site Specific Maintenance Procedure Jun 2018 Started Developed Training Complete Jun 2018 Started Submit 6 Month Status Report Jun 2018 Not Started Implementation Outage Sep 2018 Not Started Walk Through Sep 2018 Not Started Demonstration/Functional Test Procedure Changes Active Sep 2018 Not Started Page 2 of 21

RS-17-151 / JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Target Activity Milestone Completion Comments Status Date Submit Completion Report Nov 2018 Not Started 4 Changes to Compliance Method The JAF design changes to the HCVS will continue to meet the requirements of Order EA-13-109 (Reference 1). There are clarifications to the information presented in the JAF HCVS OIPs based on the final detailed design. The following clarifications are described based on the applicable sections in the Overall Integrated Plan.

Phase 1 There is no change to the compliance method that meets NEI 13-02 (Reference 4).

Phase 2 All updates below are a part of the Phase 2 Overall Integrated Plan (Reference 3), Part 3.1:

Boundary Conditions for SAWA:

Table 3.1-SAWA Manual Actions Step 2 - The existing LPCI 'B' train batteries will be used to open 27MOV-25B from the Main Control Room. Therefore, the Control Building is also considered a Primary Location for this action.

Step 3 - Load shedding is required in the Turbine and Administration Building as part of repowering plant components via the FLEX Diesel Generator (DG); therefore, the Turbine/Administration Building are also considered Primary Locations for this action.

Severe Accident Operation, Table 3. 1.B, Greater than 24 Hour Coping Detail; Attachment 1; Attachment 3 Sketch 1, 3 & 4 (AIB)

The SAWA injection pathway has been updated to use the RHR 'B' train rather than the RHR 'A' train as reflected in the Phase 2 OIP (Sketch 1 is updated below to reflect this change) . This update, resulting from the final detailed design, yields a strategy with less operator actions. A new common FLEX/SAWA cart mounted throttling valve and flow meter will be installed between valves 10RHR-460 and 76FPS-780. This throttling valve will be used to adjust flow rate, as needed. Resulting from this change, the credited ECCS check valve is 1OAOV-68B. The following valves require modulation:

• 10MOV-148B (Manual Open)

• 10MOV-149B (Manual Open)

• 1OMOV-25B (LPCI Batteries)

• 76FPS-807 (Manual Close)

• 76FPS-780 (Manual Open)

• 1ORHR-460 (Manual Open)

It is noted that 1OMOV-27B is normally open and 1ORHR-11 B no longer requires closing as it is a system dead leg.

Page 3 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Greater than 24 Hour Coping Detail (Instrumentation Table)

There are multiple instruments listed in support of the SAWA strategy. To clarify, the credited instruments for SAWA are:

• Drywell Pressure: 27Pl-115A2

• Torus Water Level: 23Ll-202A Additional instrumentation may be available and is considered defense-in-depth.

In addition, due to this strategy update, the following portable equipment (OIP Attachment

1) is revised/new for this update:

Severe List Portable BDBEE Performance Maintenance I PM Accident Equipment Venting Criteria Requirements Venting Per Response to EA-4" Hose (140')* x x - 12-049 361 gpm Per NEI 13-02 and Throttling Valve** x x minimum EA-12-049

• Revised

• • New 5 Need for Relief I Relaxation and Basis for the Relief I Relaxation On January 9, 2017, JAF received approval for an extension until June 30, 2018, to comply with requirements for implementation of Phase 1 (wetwell) vent at JAF (Reference 9). JAF expects to comply with the Phase 2 order implementation date and no relief/relaxation for Phase 2 is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 and Phase 2 Overall Integrated Plan, the Reference 7 Interim Staff Evaluation (ISE) for Phase 1 and Reference 8 ISE for Phase 2, and the status of each item.

Open Phase 1 Open Items from OIP Status Item None Page 4 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

1. Make available for NRG JAF is capable of (a) venting the equivalent of Complete staff audit analyses (1) percent of licensed/rated thermal power and demonstrating that HCVS (b) the Torus is capable of absorbing the decay has the capacity to _vent heat for the first three hours to maintain the the steam/energy integrity of primary containment.

equivalent of one (1) percent of licensed/rated Auditable analyses to justify the capability of thermal power (unless a the Torus, as described in this action, have lower value is justified), been issued as calculation JAF-CALC and that the suppression 00015 (part of the approved design change pool and the HCVS package EC 52721) and calculation JAF-together are able to CALC-15-00026 (part of the approved design absorb and reject decay change package EC 58158). For additional heat, such that following a discussion, see EC 52721 Topic Notes Section reactor shutdown from full 3.1.7 entitled "Hydraulic Requirements".

power containment References have been provided on the ePortal.

pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

2. Make available for NRG The Hardened Containment Vent System Complete staff audit the seismic and (HCVS) piping from the Torus to the discharge tornado missile final above the Reactor Building (RB) Roof is design criteria for the designed to be seismically rugged as HCVS stack. supported by calculations JAF-CALC 00017, JAF-CALC-15-00008, JAF-CALC 00033, and JAF-CALC-14-00016 (part of the approved design change package EC 52721 ).

Protection from tornado missiles is acceptable in accordance with evaluations based on the HCVS-WP-04 guidance. See EC 52721 Topic Notes Section 3.1.3 entitled "Structural Requirements". Specifically, see the associated subsection entitled Tornado Missiles".

References have been provided on the ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

3. Make available for NRC The HCVS Battery System will support a Complete staff audit the final sizing minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation. Refer to EC evaluation for HCVS 52721 Topic Notes, Section 3.1.4 entitled batteries/battery charger "Electrical Requirements." Specifically, refer to including incorporation the subsections entitled "Battery Selection and into FLEX DG loading Sizing," "Battery Charger Selection and Sizing,"

calculation. and the associated Engineering Change (EC) attachment, P2e Sequence No. 6.003.

The HCVS battery load has been incorporated into the FLEX Diesel Generator (DG) via approved EC 52736 (FLEX Strategy) and associated calculation JAF-CALC-15-00031 .

References have been provided on the ePortal.

4. Make available for NRC The HCVS pneumatic system design sizing will Complete staff audit documentation be capable of 12 cycles in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

of the HCVS nitrogen The sizing of the nitrogen motive force and pneumatic system design purge systems is provided in calculations JAF-including sizing and CALC-15-00013 and JAF-CALC-15-00038, location . respectively (part of the approved design change package EC 52721 ). For additional discussion, see EC 52721 Topic Notes Section 3.1 .6.3 entitled "Cross Flow & Hydrogen Detonation". Specifically, see the associated subsection entitled "HCVS Pipeline Protection".

References have been provided on the ePortal.

5. Provide a description of The JAF strategy for preventing hydrogen Complete the final design of the detonation and deflagration beyond the final HCVS to address isolation point (valve) is a nitrogen purge hydrogen detonation and system. Concurrent with closing the isolation deflagration. valve, the purge system will be initiated to purge the vented fluid from the HCVS pipeline.

For additional discussion, see EC 52721 Topic Notes Section 3.1.6.3 entitled "Cross Flow &

Hydrogen Detonation". Specifically, see the associated subsection entitled "HCVS Pipeline Protection".

References have been provided on the ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

6. Provide a description of At JAF, the interfaces between the RB and the Complete the strategies for HCVS pipeline are limited to normally closed, hydrogen control that small bore drain and instrument valves minimizes the potential for minimizing the hydrogen gas migration and hydrogen gas migration ingress into the Reactor Building. In addition, and ingress into the migration to the Standby Gas Treatment reactor building or other System is minimized through the use of buildings. existing Class VI Motor Operated Valves (MOVs) that have been leak tested in accordance with NEI 13-02. For additional discussion, see EC 52721 Topic Notes Section 3.1.6.3 entitled "Cross Flow & Hydrogen Detonation". Specifically, see the associated subsection entitled "Interconnecting Systems".

References have been provided on the ePortal.

7. Make available for NRC The required instrumentation and controls Started staff audit descriptions of (existing and new) are identified as part of the all instrumentation and JAF OIP, Part 2. The qualification of the controls (existing and equipment has been described within the planned) necessary to approved design change package EC 52721 ;

implement this order however, additional documentation must be including qualification supplied by vendors before this item is methods. completed.

Upon completion, the evaluations will be posted to ePortal.

8. Make available for NRC The qualification of the equipment has been Started staff audit documentation described within the approved design change of a seismic qualification package EC 52721; however, additional evaluation of HCVS documentation must be supplied by vendors components. before this item is completed.

Upon completion, the evaluations will be posted to ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

9. Make available for NRG The approved design change package EC Started staff audit the descriptions 52721 describes the conditions and capability of local conditions of the equipment to function within the stated (temperature, radiation conditions. The qualification of the equipment and humidity) anticipated has been described within the approved design during ELAP and severe change package EC 52721; however, accident for the additional documentation must be supplied by components (valves, vendors before this item is completed.

instrumentation, sensors, Upon completion, the evaluations will be transmitters, indicators, posted to ePortal.

electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

10. Make available for NRG At JAF, the existing Primary Containment Complete staff audit documentation Isolation Valves (PCIVs) (27AOV-117 and -

of an evaluation verifying 118) that will be part of the EA-13-109 HCVS the existing containment flow path are currently a part of the Generic isolation valves, relied Letter (GL) 89-16 containment hardened pipe upon for the HCVS, will flow path. Calculation 14620.9011-US(N)-004 open under the maximum "Suppression Chamber (20") & Drywall (24")

expected differential Vent & Purge Butterfly Valves based on pressure during BDBEE RELAP 5/MOD2 56 psig and 62 psig Results" and severe accident concludes the valves can be opened against wetwell ventinq. the maximum expected differential pressure during an Order EA-13-109 event, the primary containment pressure limit of 62 psig.

References have been provided on the ePortal.

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RS-17-151 / JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 1 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

11. Make available for NRC JAF utilizes the site Ultra-High Frequency Complete staff audit documentation (UHF) security radio system (Ref. EC 53903) to that demonstrates communicate between the MCR and the adequate communication operator at the HCVS control location. This between the remote communication method is the same as HCVS operation locations accepted in Order EA-12-049. These items will and HCVS decision be powered and remain powered using the makers during ELAP and same methods as evaluated under EA-12-049 severe accident for the period of sustained operation.

conditions.

References have been provided on the ePortal.

12. Make available for NRC The approved design change package EC Complete staff audit an evaluation 52721, along with supporting calculations, has of temperature and identified the anticipated conditions during radiological conditions to ELAP and a Severe Accident and confirm the ensure that operating capability for operating personnel to safely personnel can safely access and operate controls and support access and operate equipment. For additional discussion, see EC controls and support 52721 Topic Notes Section 3.1.11.3 entitled equipment. "HCVS Manual Actions".

References have been provided on the ePortal.

Open Phase 2 Open Items from OIP Status Item

1. Complete.

See Calculation JAF-CALC-17-00104 titled "HCVS Phase 2 SAWA Complete hydraulic analysis of diesel fire pump for Hydraulic Analysis" issued SAWA I SAWM flowrates under the approved Engineering Change 620605.

References have been provided on the ePortal.

2. Complete.

See Calculation JAF-Identify and evaluate severe accident conditions for CALC-14-00029 titled Phase 2 manual actions. "Hardened Containment Vent System: Dose Assessment" and Page 9 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Attachment 10.07 (Manual Actions Table) issued under approved Engineering Change 620605.

References have been provided on the ePortal.

3. Complete.

The FLEX Engineering Change (EC 52736) has not See Engineering Change been completed; therefore, any reference to this 52736.

information is considered unverified. References have been provided on the ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

1. Licensee to evaluate the Tem12erature and Humidity Complete SAWA equipment and The location of SAWA equipment and controls, as well as the controls including ingress and egress paths ingress and egress paths that are the same or similar as FLEX and for the expected severe are bounded by the FLEX evaluations for accident conditions temperature and humidity (see EC 52736).

(temperature, humidity, radiation) for the sustained Ingress and Egress operating period.

Specific SAWA dose values are calculated in calculation JAF-CALC-14-00029 updated as part of EC 620605.

For locations inside the Reactor Building between 1 and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> when SAWA is being deployed, JAF has performed a quantitative evaluation of expected dose rates per HCVS-FAQ-12 and found the dose rates at deployment locations including ingress/egress paths are acceptable For locations outside the Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA is being utilized, JAF has performed a quantitative evaluation of expected dose rates per HCVS-WP-02 and found the dose rates at deployment locations including ingress/egress paths are acceptable.

Attachment 10.07 ("Manual Actions Table")

to EC 620605 provides a list of SAWA manual actions along with the expected environmental conditions and associated operational limitations.

References have been provided on the ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

2. Licensee to demonstrate Egui12ment and Controls Complete how instrumentation and Plant instrumentation for SAWA that is equipment being used for qualified to RG 1.97 or equivalent is SAWA and supporting considered qualified for the sustained equipment is capable to operating period without further evaluation.

perform for the sustained The following plant instruments are operating period under the qualified to RG 1.97:

expected temperature and radiological conditions.

• Drywell Pressure: 27Pl-115A2

• Torus Water Level: 23Ll-202A Passive components that do not need to change state after initially establishing SAWA flow do not require evaluations.

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

• SAWA/SAWM flow instrument

• SAWA/SAWM pump (FLEX pump)

• SAW A/SAWM generator (FLEX generator)

• Active valves in SAWA flow path Temperature The location of SAWA equipment and controls that are the same or similar as FLEX will be bounded by the FLEX evaluations for temperature and humidity. A supplementary calculation (JAF-CALC 00105) was completed as part of the SAWA Engineering Change (EC 620605) to evaluate the temperature conditions local to flow meter during extreme cold conditions.

See Phase 2 ISE OIP Item 5 for more information.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items (continued)

Radiation Specific SAWA dose values are calculated in calculation JAF-CALC-14-00029 updated as part of EC 620605.

For additional discussion, see EC 620605 Topic Notes Section 3.1.8 entitled "Instrumentation and Controls Characteristics" and 3.1.9 "Mechanical Requirements". Attachment 10.07 ("Manual Actions Table") to EC 620605 provides a list of SAWA expected environmental conditions.

References have been provided on the ePortal.

3. Licensee to demonstrate The wetwell vent has been designed and Complete that containment failure as will be installed to meet NEI 13-02 Rev 1 a result of overpressure guidance, which will ensure that it is can be prevented without a adequately sized to prevent containment drywell vent during severe overpressure under severe accident accident conditions. conditions (Ref. JAF-CALC-14-00015).

The SAWM strategy will ensure that the wetwell vent remains functional for the period of sustained operation. JAF will follow the guidance (flow rate and timing) for SAWA/SAWM described in BWROG-TP-15-008 and BWROG-TP-15-011.

References have been provided on the ePortal.

Page 13 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items The wetwell vent will be opened prior to exceeding the PCPL value of 62 PSIG.

Therefore, containment over pressurization is prevented without the need for a drywell vent.

JAF is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed as demonstrated by the following table. The values in this table are formalized in Attachment 6.004 to EC 620605.

Reference Plant James A. FitzPatrick Torus freeboard volume is 525,000 2 Torus freeboard volume is determined to be gallons 813,012 gallons SAWA flow is 500 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> SAWA flow is 361 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed followed by 100 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by 73 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> The above parameters for JAF compared to the reference plant that determine success of the SAWM strategy demonstrate that the reference plant values are bounding. Therefore, the SAWM strategy implemented at JAF makes it unlikely that a OW vent is needed to prevent containment overpressure related failure.

2 Peach Bottom available freeboard volume in gallons is estimated from nominal water level of 14. 7 feet to 21 feet. 21 feet is the upper range of the wide range torus level instrument and the assumed loss of wetwell vent function. The Peach Bottom torus is 31 feet in diameter.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

4. Licensee to demonstrate JAF utilizes the site Ultra-High Frequency Complete that there is adequate (UHF) security radio system (Ref. EC communication between 53903) to communicate between the MCA the primary HCVS and the operator at the SAWA/SAWM flow operating station and the control location. This communication operator at the FLEX method is the same as accepted in Order supply hose splitter valve EA-12-049. These items will be powered during severe accident and remain powered using the same conditions. methods as evaluated under EA-12-049 for the period of sustained operation.

References have been provided on the ePortal.

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RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Interim Staff Open Evaluation (ISE) Open Description Status Item Items

5. Licensee to demonstrate JAF utilizes a four inch size Seametrics Complete the SAWA/SAWM flow AG2000 flowmeter. The flow meter is instrumentation deployed in the RHRSW 'B' I 'D' room which qualification for the is part of the plant circulating water Screen expected environmental House building. This room is located a substantial distance from the Hardened conditions.

Containment Vent System (HCVS) vent line and is well shielded from the expected HCVS vent line dose.

For locations outside the Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA is being utilized, JAF performed a quantitative evaluation of equipment and deployment locations and confirmed they are protected by buildings with substantial shielding to minimize dose rates. Specific SAWA dose values are calculated in calculation JAF-CALC-14-00029 updated as part of EC 620605. Attachment 10.07 ("Manual Actions Table") to EC 620605 provides a list of SAWA expected environmental conditions.

The selected instrument is designed for the expected flow rate, temperature and pressure for SAWA over the period of sustained operation. The instrument qualification for pressure, temperature and flow provided in the table below is from the product technical data.

References have been provided on the ePortal.

SAWA Flow Instrument SAWA Parameter Range Qualification 12-1,000 GPM 73-361 GPM 1O - 130°F Operating 11 - 110°F Operating I Storage 158°F Storage 0 - 150 PSI Working Pressure 0- 148 psig Page 16 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 7 Interim Staff Evaluation Impacts There are no potential impacts to the Phases 1 or 2 Interim Staff Evaluations (References 7 and 8) identified at this time.

8 References The following references support the updates to the Phases 1 & 2 Overall Integrated Plan described in this attachment.

1. NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions dated June 6, 2013(ML13143A321)

2. Letter JAFP-14-0075, James A. FitzPatrick Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (ML141818117)

3. Letter JAFP-15-0149, James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015(ML15365A593}

4. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109: 8WR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, dated April 2015 (ML151138318)

5. NRC Interim Staff Guidance, JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013 (ML133048836)

6. NRC Interim Staff Guidance, JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated April 2015 (ML15104A118)

7. NRC letter to James A. FitzPatrick Nuclear Power Plant- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated February 12, 2015 (ML15007A090)

8. NRC Letter to James A. FitzPatrick Nuclear Power Plant- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated December 16, 2016 (ML163438030)

9. NRC Letter to James A. FitzPatrick Nuclear Power Plant - Relaxation of the Schedule Requirements for Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated January 9, 2017(ML16336A754)

Page 17 of 21

RS-17-151 I JAFP-17-0116 Enclosure Seventh Six-Month Status Report for Phases 1and2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Phase 2 Overall Integrated Plan: Sketch 1

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