ML17272A733
| ML17272A733 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/05/2017 |
| From: | Rajender Auluck Division of Licensing Projects |
| To: | Berryman B Susquehanna |
| Auluck R, NRR/JLD, 415-1025 | |
| References | |
| CAC MF4364, CAC MF4365, EA-13-109 | |
| Download: ML17272A733 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 5, 2017 Mr. Brad Berryman Site Vice President Susquehanna Nuclear, LLC 769 Salem Boulevard NUCSB3 Berwick, PA 18603-0467
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1AND2- REPORT FOR THE AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATION OPEN ITEMS RELATED TO NRC ORDER EA-13-109 TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS (CAC NOS. MF4364 AND MF4365)
Dear Mr. Berryman:
On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), 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 Severe Accident Condition," to all Boiling Water Reactor licenses with Mark I and Mark II primary containments. The order requirements are provided in Attachment 2 to the order and are divided into two parts to allow for a phased approach to implementation. The order required licensees to submit for review overall integrated plans (OIPs) that describe how compliance with the requirements for both phases of Order EA-13-109 will be achieved.
By letter dated June 26, 2014 (ADAMS Accession Nos. ML14177A349, ML14177A364 and ML14177A731), Susquehanna Nuclear, LLC (the licensee) submitted its Phase 1 OIP for Susquehanna Steam Electric Station, Units 1 and 2 {Susquehanna). By letters dated December 23, 2014, June 23, 2015, December 23, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 29, 2016, December 19, 2016, and June 15, 2017 (ADAMS Accession Nos.
ML15040A155, ML15174A052, ML15362A528, ML16181A179, ML16355A294, and ML17166A472, respectively), the licensee submitted its 6-month updates to the OIP. The staff reviewed the information provided by the licensee and issued interim staff evaluations (ISEs) for Phase 1 and Phase 2 of Order EA-13-109 for Susquehanna by letters dated April 1, 2015 (ADAMS Accession No. ML15090A300), and August 25, 2016 (ADAMS Accession No. ML16231A509), respectively. When developing the ISEs, the staff identified open items where the staff needed additional information to determine whether the licensee's plans would adequately meet the requirements of Order EA-13-109.
The NRC staff is using the audit process described in the letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328),
to gain a better understanding of licensee activities as they come into compliance with the order.
As part of the audit process, the staff reviewed the licensee's closeout of the ISE open items.
B. Berryman The NRG staff conducted a teleconference with the licensee on September 14, 2017. The enclosed audit report provides a summary of that aspect of the audit.
If you have any questions, please contact me at 301-415-1025 or by e-mail at Rajender.Auluck@nrc.gov.
Sincerely, Rajender Auluck, Senior Project Manager Beyond-Design-Basis Engineering Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos.: 50-387 and 50-388
Enclosure:
Audit report cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATION OPEN ITEMS RELATED TO ORDER EA-13-109 MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS SUSQUEHANNA NUCLEAR. LLC SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1AND2 DOCKET NOS. 50-387 AND 50-388 BACKGROUND On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), 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 Severe Accident Condition," to all Boiling Water Reactor (BWR) licenses with Mark I and Mark II primary containments. The order requirements are divided into two parts to allow for a phased approach to implementation.
Phase 1 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a Hardened Containment Vent System (HCVS), using a vent path from the containment wetwell to remove decay heat, vent the containment atmosphere (including steam, hydrogen, carbon monoxide, non-condensable gases, aerosols, and fission products), and control containment pressure within acceptable limits. The HCVS shall be designed for those accident conditions (before and after core damage) for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of active containment heat removal capability or extended loss of alternating current power (ELAP). The order required all applicable licensees, by June 30, 2014, to submit to the Commission for review an overall integrated plan (01 P) that describes how compliance with the Phase 1 requirements described in Order EA-13-109 Attachment 2 will be achieved.
Phase 2 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a system that provides venting capability from the containment drywell under severe accident conditions, or, alternatively, to 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. The order required all applicable licensees, by December 31, 2015, to submit to the Commission for Enclosure
review an OIP that describes how compliance with the Phase 2 requirements described in Order EA-13-109 Attachment 2 will be achieved.
By letter dated June 26, 2014 (ADAMS Accession Nos. ML14177A349, ML14177A364 and ML14177A731 ), Susquehanna Nuclear, LLC (SNL, the licensee) submitted its Phase 1 OIP for Susquehanna Steam Electric Station, Units 1 and 2 (Susquehanna, SSES). By letters dated December 23, 2014, June 23, 2015, December 23, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 29, 2016, December 19, 2016, and June 15, 2017 (ADAMS Accession Nos. ML15040A155, ML15174A052, ML15362A528, ML16181A179, ML16355A294, and ML17166A472, respectively), the licensee submitted its 6-month updates to the OIP, as required by the order.
The staff reviewed the information provided by the licensee and issued interim staff evaluations (ISEs) for Phase 1 and Phase 2 for Susquehanna by letters dated April 1, 2015 (ADAMS Accession No. ML15090A300), and August 25, 2016 (ADAMS Accession No. ML16231A509),
respectively. When developing the ISEs, the staff identified open items where the staff needed additional information to determine whether the licensee's plans would adequately meet the requirements of Order EA-13-109.
The NRG staff is using the audit process in accordance with the letters dated May 27, 2014, (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328), to gain a better understanding of licensee activities as they come into compliance with the order. The staff reviews submitted information, licensee documents (via ePortals), and preliminary Overall Program Documents (OPDs)/OIPs, while identifying areas where additional information is needed. As part of this process, the staff reviewed the licensee closeout of the ISE open items.
AUDIT
SUMMARY
As part of the audit, the NRG staff conducted a teleconference with the licensee on September 14, 2017. The purpose of the audit teleconference was to continue the audit review and provide the NRG staff the opportunity to engage with the licensee regarding the closure of open items from the ISEs. As part of the preparation for these audit calls, the staff reviewed the information and/or references noted in the OIP updates to ensure that closure of ISE open items and the HCVS design are consistent with the guidance provided in Nuclear Energy Institute (NEI) 13-02, Rev. 1 and related documents (e.g. white papers (ADAMS Accession Nos. ML14126A374, ML14358A040, ML15040A038 and ML15240A072) and frequently asked questions (FAQs, ADAMS Accession No. ML15271A148)) that were developed and reviewed as part of overall guidance development. The NRG staff audit members are listed in Table 1. Table 2 is a list of documents reviewed by the staff. Table 3 provides the status of the ISE open item closeout for Susquehanna. The open items are taken from the Phase 1 and Phase 2 ISEs issued on April 1, 2015, and August 25, 2016, respectively.
FOLLOW UP ACTIVITY The staff continues to audit the licensee's information as it becomes available. The staff will issue further audit reports for Susquehanna, as appropriate.
Following the licensee's declarations of order compliance, the licensee will provide a final integrated plan (FIP) that describes how the order requirements are met. The NRG staff will
evaluate the FIPs, the resulting site-specific OPDs, as appropriate, and other licensee documents, prior to making a safety determination regarding order compliance.
CONCLUSION This audit report documents the staff's understanding of the licensee's closeout of the ISE open items, based on the documents discussed above. The staff notes that several of these documents are still preliminary, and all documents are subject to change in accordance with the licensee's design process. In summary, the staff has no further questions on how the licensee has addressed the ISE open items, based on the preliminary information. The status of the NRC staff's review of these open items may change if the licensee changes its plans as part of final implementation. Changes in the NRC staff review will be communicated in the ongoing audit process.
Attachments:
- 1. Table 1 NRC Staff Audit and Teleconference Participants
- 2. Table 2 - Audit Documents Reviewed
- 3. Table 3 - ISE Open Item Status Table
Table 1 - NRC Staff Audit and Teleconference Participants Title Team Member Organization Team Lead/Project Manager Rajender Auluck NRR/JLD Project Manager Support/Technical Suooort - Containment I Ventilation Brian Lee NRR/JLD Technical Support - Containment I Ventilation Bruce Heida NRR/JLD Technical Support - Electrical Kerby Scales NRR/JLD Technical Support - Balance of Plant Kevin Roche NRR/JLD Technical Support - l&C Steve Wyman NRR/JLD Technical Support - Dose John Parillo NRR/DRA Attachment 1
Table 2 - Audit Documents Reviewed DPA-02-Dl-2015-23844, "Evaluation for Deployment of FLEX Generators" EC-030-1007, Revision 22, "Control Structure Transient Temperature Response" EC-RADN-1180, Revision 0, "SSES HCVS Radiological Assessment" EC-002-1081, Revision 0, "Hardened Containment Vent System Battery Sizing" EC-073-1019, Revision 2, "HCVS Flow Capacity" DPA-11-2015-23844 describes the environmental conditions for the instrumentation listed in the HCVS Engineering Change Package.
Disposition of AR-2015-17244, "Evaluate BWR-OG-TP-005 Missile Strike on HCVS Piping" PLA-6927, "Susquehanna Communication Assessment" PLA-7034, "Susquehanna Updated Communication Assesment" EC-016-1043, Revision 3, "Flow Model of UHS Cooling Water Supply to Support Phase II and Ill FLEX Mitigating Strategy" (Revised for Simultaneous FLEX and SAWA)
EC-073-1018, Revision 0, "HCVS Compressed Air Bottle Sizing Calculation" BWROG-TP-008, "Severe Accident Water Addition Timing" BWROG-TP-011, "Severe Accident Water Management Supporting Evaluations" Procedure ES-273-007, Revision 0, "Venting Suppressin Chamber Through the HCVS" SNL Caclulation 13347-WP-08, Revision 0, "Time to Burst Rupture Disk" Attachment 2
Susquehanna Steam Electric Station Vent Order Interim Staff Evaluation Open Items:
Table 3 - ISE Open Item Status Table ISE Open Item Number Licensee Response - Information NRG Staff Close-out notes SE status provided in six-month updates and on the Closed; Pending; Open Requested Action ePortal (need additional information from licensee)
Phase 1 ISE 011 DPA-08-Dl-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff Not applicable since changed from station month updates and on the ePortal. [Staff evaluation to be audit an evaluation that batteries to dedicated HCVS batteries. included in safety evaluation confirms that all load This item in not applicable since (SE) Section 3.1.2.6]
stripping to support HCVS the licensee changed its strategy operation can be from using station batteries to accomplished within 45 dedicated HCVS batteries.
minutes of event initiation.
No follow-up questions.
Phase 1 ISE 01 2 DPA-07-Dl-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff Ref. EC-002-1081, Revision O in on the month updates and on the ePortal. [Staff evaluation to be audit the final sizing ePortal. included in SE Section evaluation for HCVS The NRC staff reviewed licensee 3.1.2.6]
batteries/battery charger calculation EC-002-1081, including incorporation into "Hardened Containment Vent FLEX DG loading System Battery Sizing," Revision calculation. 0, which verified the capability of HCVS battery for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation for HCVS functions.
No follow-up questions.
Phase 1 ISE 01 3 DPA-04-Dl-2015-23844. The NRG staff reviewed the Closed information provided in the six-Make available for NRC staff EC-073-1018, M-231 Sheet 1 IDCN 30, month updates and on the ePortal. [Staff evaluation to be audit documentation of the and AR-2015-23588 on the ePortal. included in SE Section HCVS nitrogen pneumatic Calculation EC-073-1018, Rev 0, 3.1.2.6]
"HCVS Compressed Air Bottle Attachment 3
system design including No longer using nitrogen. Gas supply Sizing Calculation," estimated the sizing and location. lasts at least 7 days. The OIP states 8 licensee would have sufficient cycles in 181 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. supply to operate the valves maintaining a minimum pressure of ES-273-997 has 30 psi control band for 2000 per square inch gauge (psig)
HCVS. in the compressed air supply bottles.
No follow-up questions.
Phase 1 ISE 01 4 OPA-05-01-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff Ref. EC-030-1007, Rev. 22 (pp. 694-719) month updates and on the ePortal. [Staff evaluation to be audit an evaluation of and EC-RADN-1180, Rev. 0. included in SE Sections temperature and radiological Calculation EC-030-1007, Rev. 22, 3.1 .1 .2 and 3.1 .1 .3]
conditions to ensure that "ROS Ventilation and Hydrogen operating personnel can Control," estimated the maximum safely access and operate ROS temperature to be less than controls and support 100°F (99.7°F).
equipment.
Temperatures do not exceed 110 degrees farenheit (F°), which is acceptable for long-term personnel habitability. Radiological conditions result in low operator dose.
No follow-up questions.
Phase 1 ISE 01 5 OPA-09-01-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff Section 5.4 of EC-073-1019, Rev. 1 in the month updates and on the ePortal. [Staff evaluation to be audit analyses ePortal. included in SE Section demonstrating that HCVS In response to the staff's question 3.1.2.1]
has the capacity to vent the regarding HCVS capacity, the steam/energy equivalent of licensee provided Calculation one percent of OPA-09-01-2015-23844. This licensed/rated thermal power document indicated that Per (unless a lower value is section 5.3 of EC-073-1019, Rev.
justified), and that the 1, the vent flow required to remove suppression pool and the 1% of rated reactor power at HCVS together are able to
absorb and reject decay containment design pressure of 53 heat, such that following a psig is 41.2 lbm/sec.
reactor shutdown from full power containment pressure The Unit 2 vent capacity at 53 psig is restored and then was determined to be 48 lbm/sec maintained below the and the Unit 1 vent capacity at 53 primary containment design psig was determined to be 46.3 pressure and the primary lbm/sec. Both provide adequate containment pressure limit. capacity to meet or exceed the order criteria.
No follow-up questions.
Phase 1 ISE 01 6 DPA-1 O-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the six-Make available for NRC staff ES-273-007 has guidance to restore month updates and on the ePortal. [Staff evaluation to be audit the seismic and venting capability. Two other procedures included in SE Section 3.2.21 tornado missile final design have been revised for severe weather. DPA-10-01-2015-23844 addresses criteria for the HCVS stack. the HCVS seismic and tornado missile design. The licensee's design is consistent with the endorsed white paper and meets all of the tornado missile assumptions identified in HCVS-WP-04.
Calculation AR-2015-17244, "Evaluate BW ROG-TP-15-005, "Missile Strike on HCVS Piping".
AR 2015-28230 was issued to develop procedural guidance for compensatory actions if HCVS is damaged from wind generated missiles. Guidance placed in ES-273-007.
No fallow-up questions.
Phase 1 ISE 01 7 DPA-11-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff month updates.
audit the descriptions of
local conditions DPA-11-2015-23844 describes the [Staff evaluation to be (temperature, radiation and environmental conditions for the included in SE Section humidity) anticipated during instrumentation listed in this design 3.1.1.4]
ELAP and severe accident document. The NRC staff noted for the components (valves, that the document only referenced instrumentation, sensors, the new variables, but did not transmitters, indicators, mention the existing variables such electronics, control devices, as wetwell level. The staff found and etc.) required for HCVS that the response is satisfactory venting including because the existing variables are confirmation that the RG 1.97 variables that have components are capable of previously been reviewed and performing their functions determined to acceptable for the during ELAP and severe purposes of this vent order review.
accident conditions.
No follow-up questions.
Phase 1 ISE 01 8 DPA-12-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the six-Make available for NRC staff month updates and on the ePortal. [Staff evaluation to be audit documentation that included in SE Section demonstrates adequate The communication methods are 3.1.1.11 communication between the the same as accepted in Order remote HCVS operation EA-12-049.
locations and HCVS decision makers during No follow-up questions.
ELAP and severe accident conditions.
Phase 1 ISE 01 9 DPA-13-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Provide a description of the SSES Technical Specification S-7452 tor month updates and on the ePortal. [Staff evaluation to be final design of the HCVS to check valve is on the ePortal. included in SE Section address hydrogen The licensee's design is consistent 3.1.2.11]
detonation and deflagration. See DPA-06-Dl-2015-23844 response with option 5 of the endorsed white also. paper HCVS-WP-03.
No follow-up questions.
Phase 1 ISE 01 10 DPA-14-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Provide a description of the Totally separate systems. month updates and on the ePortal.
strategies for hydrogen
control that minimizes the The licensee's design for the Unit [Staff evaluation to be potential for hydrogen gas 1 and Unit 2 HCVS systems are included in SE Section migration and ingress into independent and do not share 3.1.2.12]
the reactor building or other components or connections with buildings. any existing containment purge/vent systems.
No follow-up questions.
Phase 1 ISE 01 11 DPA-15-Dl-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Provide a justification for Changed version in 01 P to comply with month updates and on the ePortal. (Staff evaluation to be deviating from the ISG. included in SE Section instrumentation seismic The NRG confirmed the OIP 3.1.1.4]
qualification guidance change that now complies with the specified in NEI 13-02, ISG. Further, the staff reviewed endorsed, in part, by JLD- licensee document DPA-15-2015-ISG-2013 as an acceptable 23844 and confirmed that the means for implementing methodology is acceptable and applicable requirements of that the licensee used a review Order EA-13-109. level ground motion that is beyond-design-basis.
No follow-up questions.
Phase 1 ISE 0112 DPA-16-01-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Make available for NRG staff month updates and on the ePortal. (Staff evaluation to be audit descriptions of all included in SE Section instrumentation and controls Instrumentation appears sufficient 3.1.2.8]
(existing and planned) to monitor and control HCVS necessary to implement this operation. Qualification standards order including qualification are industry-accepted for this type methods. of application.
No follow-up questions.
Phase 2 ISE 011 OPA-59-01-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Licensee to evaluate the DPA-02-01-2015-23844. month updates and on the ePortal.
severed accident water
addition (SAWA) equipment AR-2016-02782 (ES-273-007 note to Control Room was evaluated [Staff evaluation to be and controls, as well as warn people). under Order EA-12-049. Cale EC- included in SE Section ingress and egress paths for 030-1007, Rev. 22 was reviewed 4.1.1.4]
the expected severe OPA-05-01-2015-23844. in Phase 1 ISE 01-4.
accident conditions (temperature, humidity, EC-30-1007, Rev. 22 (pp. 694-719) and No follow-up questions.
radiation) to ensure that EC-RAON-1180, Rev. 0.
operating personnel can safely access and operate OPA-57-01-2015-23844. Instrument is ok.
controls and support equipment for the sustained operatinq period.
Phase 2 ISE 01 2 OPA-60-01-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Licensee to demonstrate SAWA uses the same components and month updates and on the ePortal. [Staff evaluation to be that SAWA components and connection points as FLEX. included in SE Section connections external to Per OPA-60-01-2015-23844 the 4.1.1.4]
protected buildings have components and collection points been protected against the were evaluated under Order EA-screened-in hazards of 12-049. No changes made for Order EA-12-049 for the HCVS.
station.
No follow-up questions.
Phase 2 ISE 01 3 OPA-61-01-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Licensee to demonstrate month updates and on the ePortal. [Staff evaluation to be that containment failure as a included in SE Sections 4.1 result of overpressure can Calculation EC-073-1019 and 4.2]
be prevented without a evaluating vent capacity was drywell vent during severe reviewed in Phase 1 ISE-01-5.
accident conditions. Section HCVS will be opened per 3.3.3 procedure prior to exceeding Primary Containment Pressure Limit value of 65 psig.
No follow-up questions.
Phase 2 ISE 01 4 OPA-62-01-2015-23844. The NRG staff reviewed the Closed information provided in the 6-Licensee shall demonstrate month updates and on the ePortal.
how the plant is bounded by
the reference plant analysis Staff reviewed the parameters [Staff evaluation to be that shows the Severe from the reference plant to those of included in SE Section Accident Water Susquehanna. The staff concurs 4.2.1.1]
Management strategy is that it is unlikely the suppression successful in making it chamber HCVS could become unlikely that a drywell vent is blocked. Therefore, it is unlikely a needed. Section 3.3.3.1 drywell vent would be required to maintain containment integrity.
No follow-up questions.
Phase 2 ISE 01 5 DPA-63-Dl-2015-23844. The NRC staff reviewed the Closed information provided in the 6-Licensee to demonstrate DPA-12-Dl-2015-23844 + PA and Sat month updates and on the ePortal. [Staff evaluation to be that there is adequate phones. included in SE Section 4.1]
communication between the The communication methods are Main Control Room and the Communications Assessment. the same as accepted in Order Intake Structure operator at EA-12-049.
the FLEX manual valve during severe accident No follow-up questions.
conditions. Section 3.3.3.4
ML17272A733 "via e-mail OFFICE NRR/DLP/PBEB/PM NRR/JLD/LA NRR/DLP/PBEB/BC NRR/DLP/PBEB/PM NAME RAuluck SLent TBrown RAuluck DATE 10/ 2 /2017 09/ 29 /2017 10/ 4 /2017 10/ 5 /2017