ML17256A240

Transmission Letter - Hardened Containment Venting System (HCVS) Phase 1 and 2 Final Integrated Plan Template (EA-13-109)

ML17256A240
Person / Time
Issue date:	09/28/2017
From:	John Marshall Japan Lessons-Learned Division
To:	Joseph E Pollock Nuclear Energy Institute
Auluck R, NRR/JLD, 415-1025
References
EA-13-109
Download: ML17256A240 (3)

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<,... *,,j,y 1? **** ... September 28, 2017 Mr. Joseph E. Pollock, Vice President Nuclear Operations Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004

Dear Mr. Pollock:

The U.S. Nuclear Regulatory Commission (NRG) staff has considered a request from the Nuclear Energy Institute (NEI), on behalf of the nuclear industry, to endorse the document dated September 12, 2017, entitled, "Hardened Containment Venting System (HCVS) Final Integrated Plan [FIP] Template (EA-13-109), Revision O," (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML17257A198}.

The purpose of the FIP template is to assist licensees that are subject to Order EA-13-109 (order), "Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions," (ADAMS Accession No. ML13130A067} in documenting how they meet the requirements of the order. The NRG staff has endorsed, with conditions and limitations, several industry guidance documents as acceptable methods for meeting the order requirements, including NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 1 (ADAMS Accession No. ML151138318), the related HCVS-FAQs [Frequently Asked Questions, ADAMS Accession No. ML15271A148] and HCVS white papers (ADAMS Accession Nos. ML14126A374, ML14358A040, ML15040A038 and ML15240A072, respectively). The FIP template does not convey or endorse methods of complying with Order EA-13-109 and does not alter the NRG staff's conditions or limitations imposed on previously endorsed guidance documents.

As required by the order, licensees submitted a Phase 1 Overall Integrated Plan (OIP) in June of 2014 and subsequently submitted a combined Phase 1 and 2 OIP in December of 2015.

These OIPs followed the guidance in NEI 13-02, Revisions O and 1, respectively. The NRG staff used the methods described in Japan Lessons-Learned Division (JLD) interim staff guidance (ISG) JLD-ISG-2013-02 and JLD-ISG-2015-01 (ADAMS Accession Nos.

ML133048836 and ML15104A118, respectively) to evaluate whether the licensees' plans support compliance with the order, if the plans were implemented as described in the OIPs.

The NRG staff provided Interim Staff Evaluations for the OIPs assessing the licensees' proposed compliance methods. In addition, licensees provided 6-month updates as required by the order, conveying updates to their plans.

When all units at a site comply with both phases of the order, licensees are expected to submit a FIP for staff review. The staff plans to issue a safety evaluation and conduct an inspection using Temporary Instruction (Tl} 2515/193, "Inspection of the Implementation of Order EA 109: Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," (ADAMS Accession No. ML17102A560) in order to evaluate the site's compliance with Order EA-13-109. The Fl P template is intended to

J. Pollock set the structure, content, and level of detail for the plant-specific information needed for the staff's review. During its development, the FIP template was discussed in a series of public meetings held on June 1, 2017, July 26, 2017, and August 17, 2017.

The NRC staff has reviewed the FIP template and finds it acceptable for preparation of the plant-specific Fl P for documenting compliance with Order EA-13-109. Licensees are strongly encouraged to follow the FIP template to facilitate a timely and efficient review by the NRC staff and to minimize the need for requests for additional information (RAls). While the NRC staff anticipates that following the FIP template will minimize the need for RAls and, in general, improve the efficiency of the review process, strict adherence to the template is not required.

Further, adherence to the template does not imply or indicate that the information submitted will be sufficient to support the NRC staff's review or assure that the FIP would be deemed adequate for fulfilling the requirements of Order EA-13-109 for any individual plant or site.

If you have any questions, please contact Dr. Rajender Auluck, of my staff, at (301) 415-1025, or via email to Rajender.Auluck@nrc.gov.

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C*~ne E. Marshall, Director j:pan Lessons-Learned Division Office of Nuclear Reactor Regulation

ML17256A240 OFFICE NRR/JLD/PM NRR/JLD/LA NRR/JLD/BC OGG* NRR/JLD/DD NRR/JLD/D NAME RAuluck Slent SBailey BHarris MS hams JMarshall DATE 09/13/2017 09/13/2017 09/21/2017 09/20/2017 09/25/2017 09/28/2017