ML16116A320

Limerick Generating Station, Units 1 and 2 -Staff Evaluation for Phase 2 of NRC Order EA-13-109

ML16116A320
Person / Time
Site:	Limerick
Issue date:	08/02/2016
From:	Quichocho J F Japan Lessons-Learned Division
To:	Bryan Hanson Exelon Nuclear
Raj Auluck 415-1025
References
CAC MF4418, CAC MF4419, EA-13-109
Download: ML16116A320 (24)

Text

Mr. Bryan C. Hanson UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 2, 2016 President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 -INTERIM STAFF EVALUATION RELATING TO OVERALL INTEGRATED PLAN IN RESPONSE TO PHASE 2 OF ORDER EA-13-109 (SEVERE ACCIDENT CAPABLE HARDENED VENTS) (CAC NOS. MF4418 AND MF4419)

Dear Mr. Hanson:

By letter dated June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Sever Accident Conditions" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13143A334). By letter dated December 15, 2015 (ADAMS Accession No. ML 15364A014), Exelon Generation Company, LLC (Exelon, the licensee), submitted its Third Six-Month Status Report of the Implementation of the Commission order with Regard to Requirements for Reliable Hardened Vents (EA-13-109). The letter also included the Overall Integrated Plan (OIP) for Limerick Generating Station, Units 1 and 2 (Limerick) in response to Phase 2 of Order EA-13-109. The focus of the Phase 2 Interim Staff Evaluation (ISE) is to document the NRC staff's review of the information provided for implementation of Phase 2 requirements of Order EA-13-109. The new information provided related to Phase 1 of the order and open items identified in the staff's ISE on Phase 1 will be addressed separately. Any changes to the compliance method will be reviewed as part of the ongoing audit process. The licensee's OIP for Limerick appears consistent with the guidance found in Nuclear Energy Institute (NEI) 13-02, Revision 1, endorsed, in part, by the NRC's Japan Lessons-Learned Project Directorate (JLD) Interim Staff Guidance (ISG) JLD-ISG-2015-01, as an acceptable means for implementing the requirements of Phase 2 of Order EA-13-109. This conclusion is based on satisfactory resolution of the open items detailed in the enclosed interim staff evaluation. This evaluation only addressed consistency with the guidance. Any plant modifications will need to be conducted in accordance with plant engineering change processes, the licensing basis, and the Commission's regulations.

B. Hanson If you have any questions, please contact Brian E. Lee, Project Manager, at 301-415-2916 or at Brian.Lee@nrc.gov. Docket Nos. 50-373 and 50-37 4

Enclosure:

Interim Staff Evaluation cc: Distribution via Listserv Sincerely, s1e F. Quichocho, Chief ontainment and Balance of Plant Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 INTERIM STAFF EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER EA-13-109 PHASE 2. MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS EXELON GENERATION COMPANY. LLC LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By letter dated June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC, the Commission) issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" [Reference 1]. The order requires licensees to implement its requirements in two phases. In Phase 1, licensees of boiling-water reactors (BWRs) with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the wetwell during severe accident conditions. In Phase 2, licensees of BWRs with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the drywell under severe accident conditions, or, alternatively, those licensees shall develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. As required by Order EA-13-109, Exelon Generation Company, LLC (Exelon, the licensee) submitted its Overall Integrated Plan (OIP) for Limerick Generating Station, Units 1 and 2 (Limerick) for Phase 1 on June 30, 2014 [Reference 2]. The NRC staff's evaluation of the licensee's OIP for implementation of Phase 1 requirements was provided in the interim staff evaluation (ISE) for Phase 1 on April 1, 2015 [Reference 3]. This ISE focuses on the staff's review of the information provided for implementation of the Phase 2 requirements of Order EA-13-109. Phase 2 of Order EA-13-109 requires that BWRs with Mark I and Mark II containments have either a vent path from the containment drywell or a strategy that makes it unlikely that venting would be needed from the drywell before alternate, reliable containment heat removal and pressure control is reestablished. The second phase is not required to be installed concurrently with the first phase. The second phase shall be implemented no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first. Enclosure By letter dated December 15, 2015 [Reference 4), Exelon provided its OIP for Limerick in compliance with Section IV, Condition D.2 of Order EA-13-109. The OIP describes the licensee's currently proposed modifications to systems, structures, and components, new and revised guidance, and strategies that it intends to implement in order to comply with the requirements of Phase 2 of Order EA-13-109. The OIP also includes the third 6-month update for Phase 1 of the order in accordance with Section IV, Condition D.3 of Order EA-13-109. As stated above, this ISE will focus on the staff's review of information provided in the OIP related to implementation of requirements for Phase 2 of the order. In specific areas where Phase 1 requirements are associated with the Phase 2 strategy, it is addressed in this ISE.

2.0 REGULATORY EVALUATION

Following the events at the Fukushima Dai-ichi nuclear power plant on March 11, 2011, the NRC established a senior-level agency task force referred to as the Near-Term Task Force (NTTF). The NTTF was tasked with conducting a systematic and methodical review of the NRC regulations and processes and determining if the agency should make improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this review, the NTTF developed a set of recommendations, documented in SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan," dated July 12, 2011 [Reference 5). These recommendations were enhanced by the NRC staff following interactions with stakeholders. Documentation of the NRC staff's efforts is contained in the Commission's Staff Requirements Memorandum (SRM) for SECY-11-0124, "Recommended Actions to be Taken without Delay from the Near-Term Task Force Report," dated September 9, 2011 [Reference 6), and SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned," dated October 3, 2011 [Reference 7). As directed by the Commission's SRM for SECY-11-0093 [Reference 8), the NRC staff reviewed the NTTF recommendations within the context of the NRC's existing regulatory framework and considered the various regulatory vehicles available to the NRC to implement the recommendations. SECY-11-0124 and SECY-11-0137 established the NRC staff's prioritization of the recommendations based upon the potential safety enhancements. On February 17, 2012, the NRC staff provided SECY-12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami" [Reference 9), to the Commission, including the proposed order to implement the installation of a reliable hardened containment venting system (HCVS) for Mark I and Mark II containments. As directed by SRM-SECY-12-0025 [Reference* 10), the NRC staff issued Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents" [Reference 11 ), which required licensees to install a reliable HCVS for Mark I and Mark II containments. While developing the requirements for Order EA-12-050, the NRC acknowledged that questions remained about maintaining containment integrity and limiting the release of radioactive materials if the venting systems were used during severe accident conditions. The NRC staff presented options to address these issues for Commission consideration in SECY-12-0157, "Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments" [Reference 12). In the SRM for SECY-12-0157 [Reference 13), the Commission directed the staff to issue a modification to Order EA-12-050, requiring licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." The NRC staff held a series of public meetings following issuance of SRM SECY-12-0157 to engage stakeholders on revising the order. Accordingly, by letter dated June 6, 2013, the NRC issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions." Order EA-13-109, Attachment 2, requires that BWRs with Mark I and Mark II containments have a reliable, severe-accident capable HCVS. This requirement shall be implemented in two phases. In Phase 1, licensees of BWRs with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the wetwell during severe accident conditions. Severe accident conditions include the elevated temperatures, pressures, radiation levels, and combustible gas concentrations, such as hydrogen and carbon monoxide, associated with accidents involving extensive core damage, including accidents involving a breach of the reactor vessel by molten core debris. In Phase 2, licensees of BWRs with Mark I and Mark II containments shall design and install a venting system that provides venting capability from the drywell under severe accident conditions, or, alternatively, those licensees shall develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. On November 12, 2013, the Nuclear Energy Institute (NEI) issued NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 0 [Reference 14) to provide guidance to assist nuclear power reactor licensees with the identification of measures needed to comply with the requirements of Phase 1 of the HCVS order. On November 14, 2013, the NRC staff issued Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) JLDISG-2013-02, "Compliance with Order EA-13-109, 'Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Performing under Severe Accident Conditions"' [Reference 15), endorsing, in part, NEI 13-02, Revision 0, as an acceptable means of meeting the requirements of Phase 1 of Order EA-13-109, and published a notice of its availability in the Federal Register (FR) [November 25, 2013, 78 FR 70356). As required by the order, the licensee submitted its OIP for Limerick for Phase 1 on June 30, 2014. As stated above, the NRC staff issued its interim staff evaluation for implementation of Phase 1 requirements on April 1, 2015 [Reference 3). On April 23, 2015, the NEI issued NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 1 [Reference 16) to provide guidance to assist nuclear power reactor licensees with the identification of measures needed to comply with the requirements of Phase 2 of Order EA-13-109. On April 29, 2015, the NRC staff issued Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) 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 Performing under Severe Accident Conditions"' [Reference 17), endorsing, in part, NEI 13-02, Revision 1, as an acceptable means of meeting the requirements of Phase 2 of Order EA-13-109, and published a notice of its availability in the FR [May 7, 2015, 80 FR 26303). Licensees are free to propose alternate methods for complying with the requirements of Order EA-13-109.

By letter dated May, 27, 2014 [Reference 18), the NRC notified all BWR Mark I and Mark II licensees that the staff will be conducting audits of the implementation of Order EA-13-109. This letter described the audit process to be used by the staff in its review of the information contained in licensee's submittals in response to Phase 1 of Order EA-13-109. The staff is using a similar process for its review of the information submitted for implementation of Phase 2 requirements of the order.

3.0 TECHNICAL EVALUATION

Limerick is a dual unit General Electric BWR, each unit having an independent reactor building and a Mark II primary containment system. To implement the Phase 1 HCVS requirements of Order EA-13-109, the licensee plans to install a venting capability from the containment wetwell to provide a reliable, severe accident capable hardened vent to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. To implement the Phase 2 (alternate strategy) requirements, the licensee plans to provide (i) a capability for severe accident water addition (SAWA), which will include a combination of permanently installed and portable equipment to provide a means to add water to the reactor pressure vessel (RPV) following a severe accident and monitor system and plant conditions and (ii) a severe accident water management (SAWM) strategy and guidance for controlling the water addition to the RPV for the sustained operating period. The OIP describes evaluations of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. In addition, the OIP describes programmatic changes that include procedures, training, drills, and maintenance for SAWA and SAWM actions. 3.1 GENERAL INTEGRATED PLAN ELEMENTS AND ASSUMPTIONS 3.1.1 Evaluation of Extreme External Hazards Extreme external hazards for Limerick were evaluated in the Limerick 01 P in response to Order EA-12-049 (Mitigation Strategies) [Reference 21). In the Limerick ISE for Mitigation Strategies [Reference 20), the NRC staff documented an analysis of Limerick's extreme external hazards evaluation. The following extreme external hazards screened in: Seismic, Severe storms with high winds, Snow, Ice and Extreme Cold, and High Temperatures. The following extreme external hazards screened out: Sustained External Flooding. The NRC staff's review confirmed that the licensee's approach described in the Limerick 01 P in response to Order EA-12-049 (Mitigation Strategies), is consistent with the guidance found in NEI 12-06 [Reference 27), as endorsed by JLD-ISG-2012-01 [Reference 28), and that the requirements of Order EA-12-049 will be met for screening of the extreme external hazards if these requirements are implemented as described. 3.1.2 Assumptions In its OIP, the licensee stated that it has adopted a set of generic assumptions associated with Order EA-13-109 Phase 1 and Phase 2 actions. The NRC staff reviewed the information in the OIP and determined that the set of generic assumptions appear to establish a baseline for HCVS evaluation consistent with the guidance found in NEI 13-02, Revision 1, as endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable method to implement the requirements of Order EA-13-109. The NRC staff's review noted that there are four plant-specific assumptions added for implementation of Phase 1 requirements of the order in the OIP. The new plant-specific assumption are: Limerick-2 Limerick-3 Limerick-4 Limerick-5 Modifications that allow a FLEX generator to recharge the HCVS battery are assumed to have been installed such that a FLEX generator can be credited for HCVS operation beyond the initial 24-hour sustained operational period. The rupture disk will be manually breached from the MCR [main control room] if required for anticipatory venting during an ELAP [extended loss of all alternating current (ac) power]. The plant layout of buildings and structures are depicted in Sketch 3B. Note the Main Control Room is located in the Control Structure and has substantial structural walls and features independent of the Reactor Building. The HCVS vent routing is through the Reactor Building to the railroad bay hoistway. This vent is routed vertically in the hoistway and through the South Stack to above the Reactor Building Roof. The HCVS external piping is all above 30-feet from ground level, consists solely of large bore (14-inches nominal diameter) piping and its piping supports, and has less than 300 square feet of cross section. The HCVS external piping meets the reasonable protection requirements of HCVS-WP-04. The NRC staff reviewed the new plant-specific assumptions Limerick-2 through Limerick-4 and determined that the additional plant specific assumptions for Limerick do not appear to deviate from the guidance found in NEI 13-02, endorsed, in part, by JLD-ISG-2013-02 as an acceptable method to implement the requirements of Order EA-13-109. Assumption Limerick-5 assumes HCVS external piping 30-feet above grade meets the reasonable protection requirements of HCVS-WP-04 [Reference 29]. In HCVS-WP-04: "Missile Evaluation for HCVS Components 30 Feet Above Grade" defines "grade level" as the highest grade within 300 yards of the HCVS. Open Item: Licensee to demonstrate that the HCVS components meeting reasonable protection from tornado missiles is at least 30 feet above the highest grade within 300 yards. The NRC staff reviewed the new plant-specific assumptions and determined, pending addressing the open item that the additional plant specific assumptions for Limerick does not appear to deviate from the guidance found in NEI 13-02, endorsed, in part, by JLD-ISG-2013-02 as an acceptable method to implement the requirements of Order EA-13-109.

The NRC staff's review noted that there were no additional plant-specific assumptions added for implementation of Phase 2 requirements of the order in the OIP. 3.1.3 Compliance Timeline and Deviations In Part 1 of its OIP, the licensee stated that compliance will be attained with no known deviations to the guidelines included in JLD-ISG-2013-02, JLD-ISG-2015-01, and NEI 13-02 for each phase. Specifically, the OIP noted that the HCVS will be comprised of installed and portable equipment and operating guidance. For compliance with Phase 1 requirements of the order, the severe accident wetwell vent will be a permanently installed vent from the suppression pool to the top of the reactor building. For compliance with Phase 2 requirements of the order, strategies for the use of SAWA and SAWM will include a combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and guidance for controlling the water addition to the RPV for the sustained operating period. The OIP also notes that the current compliance schedule for Phase 2 is in the 1st Quarter of 2018 for Unit 1 and in the 1st Quarter of 2019 for Unit 2. The OIP also noted that if deviations are identified at a later date, then the deviations will be communicated in a future 6-month update following their identification. Limerick's implementation schedule complies with the requirements of the order, and neither Limerick nor the staff has identified any deviations. Therefore, the staff concludes that if the schedule is implemented as described, it appears Limerick will attain compliance with Phase 2 of Order EA-13-109 with no known deviations to the guidance found in NEI 13-02, endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable method to implement the requirements of Order EA-13-109. 3.2 BOUNDARY CONDITIONS FOR WETWELL VENT As documented in the ISE for implementation of Phase 1, dated April 1, 2015 [Reference 3], the NRC staff determined that the licensee's approach to Boundary Conditions for Wetwell Vent, if implemented as described in Section 3.2 and pending acceptable resolution of open items, appears to be consistent with the guidance found in NEI 13-02, endorsed in part by JLD-ISG-2013-02 as an acceptable means for implementing the requirements of Order EA-13-109. For the staff's complete analysis of the Boundary Conditions for Wetwell Vent, see the referenced ISE. Any new information included in the 6-month updates related to implementation of Phase 1 requirements of the order will be addressed separately. 3.3 BOUNDARY CONDITIONS FOR EA-13-109 Order EA-13-109, Attachment 2, Section B states that licensees with BWRs with Mark I and Mark II containments shall either: (1) design and install a HCVS, using a vent path from the containment drywell, that meets the requirements of Section B.1, or (2) develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell before alternate reliable containment heat removal and pressure control is established that meets the requirements in Section 8.2. In its OIP, the licensee confirmed that it will be using Option B.2 of EA-13-109 (SAWA and SAWM; or 545 degrees Fahrenheit (°F) severe accident drywell vent with SAWA). Therefore, the licensee used the OIP template found in NEI letter dated September 28, 2015 [Reference 23) and endorsed in NRC letter dated October 8, 2015 [Reference 26], as guidance to structure its OIP submittal. Both SAWM and severe accident drywell vent require the use of SAWA and may not be done independently. As a result, the HCVS actions under Part 2 of the licensee's OIP apply to Part 3 of the OIP, which includes the SAWA section and two subsections (SAWM and severe accident drywell vent, respectively). In Attachment 2.1.C of the licensee's OIP, additional plant-specific information is provided to support SAWA and SAWM actions. 3.3.1 Sequence of Events (SOE) Order EA-13-109, Sections 8.2.1, 8.2.2, and B.2.3 state that: 2.1 The strategy making it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions shall be part of the overall accident management plan for Mark I and Mark II containments. 2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions. 2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation. In accordance with the requirements of Order EA-13-109, the operation of the HCVS using SAWA will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1 of the OIP and in Section 3.1.1 above. These include: Seismic, Severe storms with high winds, Snow, Ice and Extreme Cold, and High Temperatures. The licensee noted in its OIP, that initial operator actions from the HCVS control station (MCR and/or Remote Operating Station (ROS). A list of the remote manual actions performed by plant personnel to open the HCVS vent path can be found in OIP table (Table 2-1). The licensee developed timelines (see attachments 2A, Sequence of Events Timeline -HCVS, and 2.1.A, Sequence of Events Timeline -SAWA/SAWM, of the OIP for SAWA and SAWM) to identify required operator response times and actions. The timelines are an expansion of Attachment 2A of the OIP and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as the SAWA flowrate is adjusted for Option 8.2 (SAWM) of Order EA-13-109. The licensee also indicated in the 01 P that the timelines are appropriate for both in-vessel and ex-vessel core damage conditions. A list of manual actions needed to be performed by the plant personnel are noted in Table 3.1 of the OIP. The licensee stated that all operator actions, either from the primary operating station (POS) or the ROS will be evaluated for expected radiological and temperature conditions using the guidance provided in NEI 13-02 and HCVS-FAQ [Frequently Asked Questions ]-12 [Reference 23]. Open Item: Licensee to confirm through analysis the temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. The NRC staff reviewed the three cases contained in the SOE timeline for use of the HCVS [Attachment 2A of the OIP] and compared them with the information contained in the guidance document NEI 13-02, Revision 1, and determined that the three cases appropriately bound the conditions for which the HCVS is required. The three cases are: (1) successful FLEX implementation with no failure of reactor core isolation cooling (RCIC); (2) late failure of RCIC leading to core damage; and (3) failure of RCIC to inject at the start of the event. The timelines accurately reflect the progression of events as described in the Limerick Mitigation Strategies OIP [Reference 21 ], SECY-12-0157 [Reference 12] and the State-of-the-Art Reactor Consequence Analyses (SOARCA) [Reference 22]. The NRC staff also reviewed the SOE timeline -SAWA/SAWM [Attachment 2.1.A of the OIP] and determined that the appropriate actions are identified for which the SAWA/SAWM is required and are consistent with the generic guidance provided in NEI 13-02, Revision 1. The NRC staff reviewed the licensee discussion on the SOEs identified in the OIP against the guidance in NEI 13-02 and confirmed that the identified items appear to be appropriately derived from the timelines developed in Attachment 2.1.A of the OIP, consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items. The timeline establishes when electrical power and Order EA-12-049 actions are needed to support the strategies for Order EA-13-109, Phase 1 and Phase 2; and when to initiate SAWA flow to the RPV. 3.3.2 Boundary Conditions for SAWA Order EA-13-109, Sections B.2.2, and B.2.3 state that: 2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions. 2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation. 3.3.2.1 SAWA Manual and Time Sensitive Actions Table 3.1 of the OIP provides a list of SAWA manual actions, which are time sensitive. These manual actions include establishing HCVS capability, making several electrical and mechanical connections in order to initiate water injection to the RPV, and monitoring SAWA indications. These time sensitive manual actions are expected to be performed within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> from the loss of injection systems due to a severe accident and to support the strategies and actions needed for Phase 1 and Phase 2 requirements of Order EA-13-109. These actions will also support the SAWA flow to the RPV in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The time sensitive actions to be completed within the reactor building will be evaluated per guidance in NEI 13-02 and HCVS-FAQ-12 [Reference 23). Time constraints for operator actions and their bases, including their validation will be completed per guidance in NEI 13-02 and HCVS-FAQ-13 [Reference 23). The flow path will be from the FLEX pump suction at the spray pond through the FLEX pump hoses to the residual heat removal service water (RHRSW) piping in the spray pond pump house. Once in the RHRSW system, underground piping is used to deliver water to the RHR system in the reactor building. This flow path requires opening two RHRSW to RHR motor operated valves (MOVs) and then opening and throttling (if required) through a RHR/low pressure coolant injection (LPCI) MOV. These valves will be energized from the FLEX diesel generator to allow remote-manual opening. The flow control method will be accomplished at the FLEX pump by adjusting the pump throttle or using a bypass valve when the flow requirement is below the pump capability. Drywell pressure and suppression pool level will be monitored and flow rate will be controlled by adjusting the FLEX pump speed and/or by throttling the RHR/LPCI MOV. Communication will be established between the MCR and the SAWA flow control location (at spray pond). The FLEX pump suction source is a significant distance from the discharge of the HCVS pipe with substantial structural shielding between the HCVS pipe and the pump deployment location. Pump refueling will also be accomplished from a dedicated diesel fuel tank located in the FLEX pump storage building as described in the EA-12-049 compliance documents. The NRC staff reviewed the SAWA Manual Actions (Table 3.1 of the OIP) and time sensitive SAWA actions and found that the components required for manual operation appear to be in areas that are readily accessible to plant operators, and do not require extensive operator actions to operate the SAWA system. Additionally, the manual actions minimize the time operators need to spend at the SAWA monitoring locations during system operation under severe accident conditions. The NRC staff reviewed the SAWA manual and time sensitive actions against the guidance in Section 6.1 and Attachment I of NEI 13-02, Revision 1 [Reference 16), and confirmed that these actions appear to consider minimizing the reliance on operator actions and be timely taken. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.2.2 SAWA Severe Accident Operation The SAWA operating requirements during a severe accident were developed using guidance provided in NEI 13-02, Section 4 and Appendix I. The guidance indicates that a maximum water addition flow of 500 gallons per minute (gpm) is sufficient for SAWA. The guidance also indicates that the time to establish water addition capability is expected to be less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Plant connection points and portable equipment satisfying the requirements of Order EA-12-049 may be credited by providing actions necessary to deploy and maintain equipment that can be performed under the thermal and radiological conditions that exist during a severe accident. The SAWA flow path should contain backflow prevention to minimize the possibility of

-10 -combustible gases, and the backflow of hot and radioactive fluids from exiting containment through the SAWA system. In its OIP, the licensee stated that its strategy for SAWA assumes loss of reactor injection at the onset of the event. The SAWA capability will be available within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and will use existing and portable equipment. The OIP also noted that the SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids, gases and potentially flammable conditions by inclusion of backflow prevention. The check valve is integral with the pump skid and will close and prevent leakage when the SAWA pump is secured. The RHR LPCI system injection mode has an installed emergency core cooling system (ECCS) check valve qualified for severe accident conditions to prevent reverse flow from the RPV. As part of SAWA operation, the OIP described the SAWA actions that will be required for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and coping details for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation. The OIP indicated that SAWA operation is the same for the full period of sustained operation. The SAWA system shall be capable of providing a RPV injection rate of 500 gpm within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a loss of all RPV injection following an ELAP/Severe Accident. The SAWA system shall meet the design characteristics of the HVCS with the exception of the dedicated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power source. Hydrogen mitigation is provided by the presence of a backflow prevention device in the SAWA flow path, as described above, which is consistent with the guidance found in Section 1.1.4.4 of NEI 13-02, Revision 1. The NRC staff reviewed the SAWA severe accident operation against the guidance in Section 4 and Appendix I to NEI 13-02, Revision 1 and determined that if operated as described in the Limerick OIP, this strategy appears to be able to maintain the temperature in the drywell less than 545 °F in an ELAP scenario. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.2.3 Equipment Locations/Controls/Instrumentation The licensee used the guidance provided in NEI 13-02, Section 1.1.6 in selecting the equipment locations, controls, and instrumentation. The ingress and egress paths will be evaluated for the expected severe accident conditions for the sustained operating period. Severe accident conditions include temperature, humidity, and radiation. The equipment will be evaluated to remain operational throughout the period of sustained operation. Personnel exposure and environmental conditions for operation of SAWA equipment has been evaluated and determined not to exceed the limits for emergency response organization dose and plant safety guidelines. In its OIP, the licensee stated that electrical equipment and instrumentation will be powered from the existing station batteries, and from ac distribution systems that are powered from the generators used in support of Order EA-12-049 requirements. Open Item: Licensee to evaluate the SAWA equipment and controls, as well as the ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period.

-11 -In its OIP, the licensee provided information regarding how electrical equipment and instrumentation will be powered to monitor the required parameters during the sustained period of operation. The parameters to be monitored as noted in the OIP table include:

• Drywell Pressure

• Suppression Pool Level

• SAWA Flow The NRC staff reviewed the information provided regarding power sources for the electrical equipment and instrumentation to support the HCVS operation during the sustained operating period and finds it acceptable. The OIP also stated that equipment and instrumentation has been evaluated to perform its function for the sustained operating period under the expected radiological and temperature conditions. The OIP also stated, that SAWA components and connections external to protected buildings have been protected against the screened-in hazards of Order EA-12-049 for the station. Regarding component qualifications, the OIP stated that the SAWA permanently installed equipment shall meet the same qualifications as for the wetwell operation during severe accident conditions. Temporary and portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06. The NRC staff reviewed the equipment locations, controls, and instrumentation that are described for SAWA monitoring and control against the guidance in Appendix I to NEI 13-02, Revision 1 and, confirmed that it is consistent. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.2.4 SAWA Procedures/Guidelines In its OIP, the licensee stated that the procedures and guidelines for SAWA implementation will be developed per guidance provided in NEI 13-02, Sections 1.3 and 6.1.2. The NRC staff reviewed the Limerick OIP section which describes elements and action items in support of SAWA implementation. The staff agrees that the information provided will support completing the SAWA procedures and guidelines in support of SAWA implementation. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.3 Boundary Conditions for SAWNSAWM Order EA-13-109, Attachment 2, requirement A.1.2.1 requires the HCVS to have the capacity to vent the steam/energy equivalent of one percent of the licensed/rated thermal power and be able to restore and maintain containment pressure below the primary containment design pressure and the primary containment pressure limit. This was identified in the OIP for Phase 1. Order EA-13-109, Attachment 2, requirement B.2.2 requires that the licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions. Requirement A.1.2.1 provides assurance the HCVS has sufficient capacity to prevent containment failure as a

-12 -result of over pressurization. Maintaining the availability of the wetwell vent makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. NEI 13-02, Revision 1, as endorsed, in part, by NRC guidance JLD-ISG-2015-01, states that the preservation of the wetwell vent path, which is accomplished by managing the water addition flow rate to the extent that the wetwell vent line remains available until other means of severe accident coping are available, is termed Severe Accident Water Management (SAWM). NEI 13-02, Revision 1, also states that there are three approaches for demonstrating a successful SAWM strategy that constitute a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell before alternate reliable containment heat removal and pressure control is reestablished. Open Item: Licensee to demonstrate that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions. In its OIP, the licensee indicated that SAWM can be maintained > 7 days without the need for a drywell vent to maintain pressure below Primary Containment Pressure Limit, which meets the criteria for the first approach identified in the aforementioned guidance document. The NRC staff reviewed the boundary conditions for SAWA/SAWM against the guidance in Appendix C. 7 to NEI 13-02, Revision 1, and confirmed that under this approach, no detail concerning plant modifications or procedures is necessary in the licensee's OIP with respect to how alternate containment heat removal will be provided. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.3.1 Basis for SAWM Time Frame In NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, it states that SAWM will lead to an HCVS Stable State for the drywell and wetwell for at least 7 days from the start of the ELAP as shown in Figures C-2 through C-6 of the guidance document. Figures C-2 through C-6 of NEI 13-02, Revision 1, which are based on a representative BWR-4 with Mark I containment using Modular Accident Analysis Program [MAAP] 5.02, demonstrate that SAWA and SAWM in conjunction with the wetwell vent, can stabilize containment parameters and prevent containment failure even with a delay in water injection that results in core debris breaching the reactor vessel for the representative plant. In addition, the wetwell vent is effective in removing non-condensable gases from containment, including any hydrogen generated by the core oxidation and the core-concrete interaction. The licensee states in the OIP that Limerick is bounded by the evaluations performed in Boiling Water Reactor Owners Group TP-15-011 and representative of the reference plant in guidance document NEI 13-02 figures C-2 through C-6. The licensee did not provide a description of how Limerick is bounded by the reference plant analysis; therefore the staff has not completed its review. Open Item: Licensee shall demonstrate how the plant is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed.

-13 -Instrumentation that will be utilized to implement the SAWM strategy includes drywell pressure, suppression pool level and SAWA flow. Except for SAWA flow, SAWM instruments are initially powered by station batteries and then by the FLEX (EA-12-049) generator, which is placed service prior to core breach. The diesel generator will provide power throughout the sustained operation period (7 days). SAWA flow is self-powered from the diesel pump internal battery. The OIP states that suppression pool level indication will be maintained throughout the sustained operation period, so the HCVS remains in-service. The time to reach the level at which the wetwell vent must be secured is > 7 days using SAWM flowrates. Procedures will be developed that control the suppression pool level in the indicating range. The instruments to monitor pressure in the drywell will also be maintained to assist in determining how effectively the core is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which the SAWM flowrate should be adjusted (up or down) using suppression pool level and drywell pressure as controlling parameters to remove the decay heat from the containment. The NRC staff reviewed the basis for the SAWM time frame against the guidance in Appendix C to NEI 13-02, Revision 1 and, confirmed that they are consistent. This appears to be in accordance with NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.3.2 SAWM Manual and Time Sensitive Actions Table 3.1.B of the OIP provides a list of SAWM manual actions. The time sensitive SAWM actions include: (1) initiate actions to maintain the wetwell vent capability by lowering injection rate, while maintaining the cooling of the core debris; and (2) monitor SAWM critical parameters while ensuring the severe accident wetwell vent remains available. The NRC staff reviewed the SAWM Manual Actions (Table 3.1.B of the OIP) and time sensitive SAWM actions, and found that the components required for manual operation appear to be in areas that are readily accessible to plant operators, and do not require extensive actions to facilitate the SAWM strategy. Additionally, the manual actions appear to minimize the time operators need to spend at the SAWM monitoring locations during system operation under severe accident conditions. The NRC staff reviewed the SAWA manual and time sensitive actions against the guidance in Section 6.1 and Attachment C of NEI 13-02, Revision 1 [Reference 16], and confirmed that these actions appear to consider minimizing the reliance on operator actions. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.3.3 SAWM Severe Accident Operation Order EA-13-109 Attachment 2, Sections B.2.2 and B.2.3 state that: 2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

-14 -2.3 Implementation of the strategy shall include licensees preparing the necessary procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing the needed instrumentation. The licensee anticipates that SAWM will only be used in severe accident events based on presumed failure of plant injection systems, as directed by the plant Severe Accident Mitigation Guidelines (SAMGs). Attachment 2.1.D of the OIP provides language for SAWM that will be incorporated into the site SAMGs. The SAWA capability will be established as described above in Section 3.2.2. The SAWM strategy will use the installed instrumentation to monitor and adjust the flow from the SAWA equipment to control the pump discharge to deliver flowrates applicable to the SAWM strategy. Once the SAWA initial flow rate has been established for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the flow will be controlled while monitoring drywell pressure and suppression pool level. The SAWM flowrate will be controlled to maintain containment parameters and preserve the wetwell vent path. The SAWA equipment is expected to be capable of injection for the period of sustained operation. The SAWNSAWM flow strategy will be the employed until alternate reliable containment heat removal and pressure control are reestablished (which is not expected to exceed 7 days). The SAWM flow strategy uses the SAWA flow path and no additional modifications are being made forSAWM. The instrumentation necessary to employ the SAWM strategy shall be capable of monitoring the containment parameters of drywell pressure and suppression pool level to provide information to operators to assist them in determining how SAWA injection rates should be controlled, until alternate containment decay heat/pressure control is established. The SAWA equipment is expected to be capable of injection for the period of sustained operation (7 days). The NRC staff reviewed the SAWM severe accident operation, specifically the expected SAWA flow rates from initiation of SAWA, the expected suppression pool water level response, the suppression pool freeboard, and the minimum permitted flow rate for containment protection. It was determined that under this water management strategy, sufficient water will be supplied to reduce thermal challenges to the containment so that the containment capability remains intact, and in addition, water flow rate can be optimized, when appropriate, in order to avoid compromising the wetwell vent path. The NRC staff reviewed the SAWM severe accident operation against the guidance in Appendix C to NEI 13-02, Revision 1 and determined that if operated as described, this strategy may be used in an ELAP scenario to mitigate core damage. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.3.3.4 Equipment Locations/Controls/Instrumentation The SAWM control location is the same as the SAWA control location. The OIP indicates the SAWA flowrate is provided at the FLEX pump by an installed flow instrument qualified to operate under the expected environmental conditions. The SAWA flowrate is controlled by throttling FLEX pump flow or throttling a RHR/LPCI MOV. Suppression pool level and drywall

-15 -pressure are read in the control room using indicators powered by the FLEX diesel generator installed under EA-12-049. These indications are used to control SAWM flowrate to the RPV. Open Item: Licensee to demonstrate that there is adequate communication between the MCR and the operator at the FLEX pump during severe accident conditions. The OIP also noted that the key parameters used for SAWM implementation are:

• Drywell Pressure

• Suppression Pool Level

• SAWA Flowrate The Drywell pressure and suppression pool level instruments are qualified to Regulatory Guide 1.97 requirements and are the same instruments used for the wetwell vent. The SAWA flow instrumentation needs to be qualified for the expected environmental conditions. Open Item: Licensee to demonstrate the SAWM flow instrumentation qualification for the expected environmental conditions. The NRC staff reviewed the equipment locations, controls, and instrumentation that are described for SAWM monitoring and control of the SAWA system and, determined that they appear to be reasonable. This appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01, pending satisfactory resolution of open items, as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.4 PROGRAMMATIC CONTROLS, TRAINING, DRILLS AND MAINTENANCE 3.4.1 Programmatic Controls Order EA-13-109, Sections 3.1 and 3.2 state that: 3.1 The licensee shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power. 3.2 The licensee shall train appropriate personnel in the use of the HCVS. The training curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power. In Part 4 of its OIP, the licensee states that a site-specific program and procedures are being developed following the guidance provided in NEI 13-02, Sections 5, 6.1.2, and 6.1.3. These will address the use and storage of portable equipment including routes for transportation from the storage locations to deployment areas. In addition, procedures will be established for system operations when normal and backup power is available, and during ELAP conditions. The OIP also states that provisions will be established for out-of-service requirements of the HCVS and the compensatory measures. The OIP provided specific time frames for service requirements for the HCVS/SAWA functionality.

-16 -In its OIP, the licensee provides an overview of how programmatic controls and procedures will be developed for implementation of SAWA and SAWM strategy. The OIP also provides a list of key areas where either new procedures will be developed or existing procedures will be revised. The NRC staff reviewed the overall procedures and programs development process including the list of key components to be included and noted that, it appears to be consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2013-02 and JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. The NRC staff determined that procedure development appears to be in accordance with existing industry protocols. The provisions for out-of-service requirements appear to reflect consideration of the probability of an ELAP requiring severe accident venting and the consequences of a failure to vent under such conditions. 3.4.2 Training Order EA-13-109, Section 3.2 states that: 3.2 The licensee shall train appropriate personnel in the use of the HCVS. The training curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power. In Part 4 of its OIP, the licensee stated that all personnel expected to perform direct execution of the HCVS/SAWNSAWM actions will receive necessary training. The training plan will be developed per the guidance provided in NEI 13-02, Section 6.1.3 and will be refreshed on a periodic basis as changes occur to the HCVS/SAWNSAWM actions, systems or strategies. In addition, training content and frequency will follow the systems approach to training process. The Limerick OIP describes HCVS training requirements that, which the NRC staff reviewed and confirmed are consistent with the guidance found in Section 6.1.3 of NEI 13-02, Revision 1 [Reference 16]. The systematic approach to the training process has been accepted by the NRC as appropriate for developing training for nuclear plant personnel. The training plan appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.4.3 Drills Order EA-13-109, Section 3.1, states that: 3.1 The licensee shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power. In Part 4 of its OIP, the licensee states that drills and exercise parameters will be developed and aligned with the guidance provided in NEI 13-06, "Enhancements to Emergency to Response Capabilities for Beyond Design Basis Accidents and Events" [Reference 24] and NEI 14-01, "Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents"

-17 -[Reference 25]. In addition, drills, tabletops, or exercises will be developed to use of HCVS/SAWNSAWM system. The Limerick OIP describes an approach to drills, which the NRC staff reviewed and confirmed is consistent with the guidance found in Section 6.1.3 of NEI 13-02, Revision 1 [Reference 16]. This approach appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 3.4.4 Maintenance Order EA-13-109, Section 1.2.13 states that: 1.2.13 The HCVS shall include features and provisions for the operation, testing, inspection and maintenance adequate to ensure that reliable function and capability are maintained. For Phase 2 compliance requirements, Table 4-1 was revised to include testing and inspection requirements for SAWA components. The NRC staff reviewed Table 4-1 and found that it is consistent with Section 6.2.4 of NEI 13-02, Revision 1. Implementation of these testing and inspection requirements for HCVS and SAWA will ensure reliable operation of the systems. In Part 4 of its OIP, the licensee states that the maintenance program will be developed following the guidance provided in NEI 13-02, Sections 5.4, and 6.2 and will utilize the standard Electric Power Research Institute industry preventive maintenance process for the maintenance calibration and testing for the HCVS/SAWNSAWM components. The Limerick OIP describes an approach to maintenance, which the NRC staff reviewed and confirmed is consistent with the guidance found in Sections 5.4 and 6.2 of NEI 13-02, Revision 1 [Reference 16]. The maintenance plan as described appears to be in accordance with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing applicable requirements of Order EA-13-109. 4.0 OPEN ITEMS This section contains a summary of the open items identified to date as part of the staff's evaluation. Open items, whether NRC or licensee identified, are topics for which there is insufficient information to fully resolve the issue, for which the NRC staff requires clarification to ensure the issue is on a path to resolution, or for which the actions to resolve the issue are not yet complete. The intent behind designating an issue as an open item is to highlight items that the staff intends to review further. The NRC staff has reviewed the licensee OIP for consistency with NRC policy and technical accuracy. NRC and licensee identified open items have been identified in Section 3.0 and are listed in the table below. Furthermore, these open items have been communicated to the licensee during the May 4th, 2016 teleconference between NRC staff and the licensee.

-18 -L. t f 0 "t IS 0 1pen 1 ems Open Item Action ISE Section 1. Licensee to demonstrate that the HCVS components meeting Section 3.1.2 reasonable protection from tornado missiles is at least 30 feet above the highest grade within 300 yards. 2. Licensee to confirm through analysis the temperature and Section 3.3.1 radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. 3. Licensee to evaluate the SAWA equipment and controls, as Section 3.3.2.3 well as the ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operatinQ period. 4. Licensee to demonstrate that containment failure as a result of Section 3.3.3 overpressure can be prevented without a drywell vent during severe accident conditions. 5. Licensee shall demonstrate how the plant is bounded by the Section 3.3.3.1 reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed. 6. Licensee to demonstrate that there is adequate Section 3.3.3.4 communication between the MCR and the operator at the FLEX pump during severe accident conditions. 7. Licensee to demonstrate the SAWM flow instrumentation Section 3.3.3.4 qualification for the expected environmental conditions. 5.0 SUMMARY As required by Order EA-13-109, the licensee has provided an OIP for implementation of Phase 2 requirements of the order. The OIP describes how containment venting strategies will be developed and used to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits during a severe accident and loss of active heat removal capability. These strategies include use of SAWA equipment to inject water into the RPV and use of a SAWM strategy to control water injection and suppression pool level to ensure the HCVS wetwell vent will remain functional for removal of decay heat from containment during the prescribed period of Sustained Operation. The NRC staff finds that the licensee's OIP for Phase 2 of Order EA-13-109 describes: plan elements and assumptions; boundary conditions; provisions for programmatic controls, training, drills and maintenance; and an implementation schedule that, subject to acceptable closure of the above open items, appear consistent with the guidance found in NEI 13-02, Revision 1, endorsed, in part, by JLD-ISG-2015-01 as an acceptable means for implementing Phase 2 requirements of Order EA-13-109.

-19 -6.0 REFERENCES 1. Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," June 6, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13143A321). 2. Letter from Exelon, Limerick Generating Station, Units 1 and 2 to NRC, "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 (ADAMS Accession No. ML 14181A418). 3. Letter from NRC to Exelon, "Limerick Generating Station, Units 1 and 2 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Phase One Of Order Ea-13-109 (Severe Accident Capable Hardened Vents)," dated April 1, 2015 (ADAMS Accession No. ML 15082A433). 4. Letter from Exelon to NRC, "Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)" dated December 15, 2015 (ADAMS Accession No. ML 15364A014). 5. SECY-11-0093, "Near-Term Report and Recommendations for Agency Actions Following the Events in Japan", (ADAMS Accession No. ML 111861807). 6. SRM-SECY-11-0124, "Recommended Actions to be taken Without Delay from the NearTerm Task Force Report", (ADAMS Accession No. ML 112911571). 7. SRM-SECY-11-0137, "Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned", (ADAMS Accession No. ML 113490055). 8. SRM-SECY-11-0093, "Staff Requirements -SECY-11-0093-Near-Term Report and Recommendations for Agency Actions following the Events in Japan," August 19, 2011 (ADAMS Accession No. ML 112310021). 9. SECY-12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," February 17, 2012 (ADAMS Accession No. ML 12039A103). 10. SRM-SECY-12-0025, "Staff Requirements -SECY-12-0025 -Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," March 9, 2012 (ADAMS Accession No. ML 120690347). 11. Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 9, 2012 (ADAMS Accession No. ML 12054A694).

-20 -12. SECY-12-0157, "Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments", November 26, 2012 (ADAMS Accession No. ML 12325A704). 13. SRM-SECY-12-0157, "Staff Requirements -SECY-12-0157, "Consideration Of Additional Requirements For Containment Venting Systems For Boiling Water Reactors With Mark I And Mark II Containments", March 19, 2013 (ADAMS Accession No. ML 13078A017). 14. NEI 13-02, 'Industry Guidance for Compliance with Order EA-13-109 (NEI 13-02 Rev.O), "BWR Mark I and II, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions. "November 12, 2013 (ADAMS Accession No. ML 13316A853). 15. Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents," November 14, 2013 (ADAMS Accession No. ML 13304B836). 16. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 1, April 23, 2015 (ADAMS Accession No. ML 15113B318). 17. Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Phase 2 of Order EA-13-109, Severe Accident Reliable Hardened Containment Vents," April 29, 2015 (ADAMS Accession No. ML 15104A118). 18. Nuclear Regulatory Commission Audits Of Licensee Responses To Phase 1 of Order EA-13-109 to Modify Licenses With Regard To Reliable Hardened Containment Vents Capable Of Operation Under Severe Accident Conditions (ADAMS Accession No. ML 14126A545). 19. Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", March 12, 2012 (ADAMS Accession No. ML 12054A735). 20. Limerick Generating Station, Units 1 and 2 -Interim Staff Evaluation related to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (ADAMS Accession No. ML 15082A433). 21. Letter from Exelon to NRC, Limerick Generating Station, Units 1 and 2 -Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (ADAMS Accession No. ML 13060A 127). 22. NUREG-1935, State-of-the-Art Reactor Consequence Analyses (SOARCA) Report (ADAMS Accession No. ML 12332A058).

-21 -23. Letter from NEI to NRC, "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision 1, dated September 22, 2015, and Frequently Asked Questions (FAQs) 10, 11, 12, and 13 (ADAMS Accession No. ML 15273A141). 24. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014. 25. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014. 26. Letter from NRC to NEI endorsing, "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision 1, dated October 8, 2015, and FAQs 10, 11, 12, 13 (ADAMS Accession No. is ML 15271A148). 27. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012. 28. Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events," dated August 29, 2012. 29. HCVS-WP-04, "Tornado Missile Evaluation for HCVS Components 30 Feet Above Grade," Revision 0, dated August 17, 2015, Principal Contributors: Date: August 2, 2016 Bruce Heida Brian Lee Brett Titus Rajender Auluck B. Hanson If you have any questions, please contact Brian E. Lee, Project Manager, at 301-415-2916 or at Brian.Lee@nrc.gov. Docket Nos. 50-352 and 50-353

Enclosure:

Interim Staff Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC JOMB R/F RidsNrrDorllpl 1-2Resource RidsNrrPMlimerickResource RidsNrrLASlentResource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No.: ML16116A320 OFFICE NRR/JlD/JCBB/PM NRR/JlD/JlD/LA NAME Blee Slent DATE 04/20/2016 04/25/2016 Sincerely, IRA/ Jessie F. Quichocho, Chief Containment and Balance of Plant Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation RidsOGCMailCenter RidsRgn1 MailCenter Resource JHughey, NRR RAuluck, NRR Blee, NRR NRR/JlD/JOMB/PM OGC JHughey BHarris 05/06/2016 06/6/2016 *via email NRR/JlD/JCBB/C JQuichocho 08/2/2016 OFFICIAL RECORD COPY