PLA-7658, Seventh Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Operation Under Severe Accident..

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Seventh Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Operation Under Severe Accident..
ML17348A049
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 12/12/2017
From: Rausch T
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, PLA-7658
Download: ML17348A049 (17)
v • d • e


Text

Timothy S. Rausch Susquehanna Nuclear, LLC President and Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 TALEN ~

Tel. 570.542.3445 Fax 570.542.1504 . ENERGY Timothy. Rausch@talenenergy .com DEC. I 2 2017 U.S. Nuclear Regulatory Commission 10 CFR 2.202 ATTN: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION SEVENTH SIX-MONTH STATUS REPORT IN RESPONSE TO JUNE 6, 2013 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS Docket Nos. 50-387 (ORDER NUMBER EA-13-109) and 50-388 PLA-7658

References:

I. NRC Order Number EA-I3-I 09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013.

2. NRC Interim Staff Guidance JLD-ISG-20I3-02, "Compliance with Order EA-I3-I09, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 20I3 (Accession No. MLI3304B836 and JLD-ISG-20I5-0I, Revision 0, dated April 20I5 (Accession No. MLI5I04A118)).
3. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase I Overall Integrated Plan Template (EA-13-I09) Rev 0" (Accession No. ML14I28A2I9).
4. NEI I3-02, "Industry Guidance for Compliance with NRC Order EA-I3-I 09, "To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, "Revisions 0 and I.
5. PPL Letter (PLA-7I80), "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 -I3-I 09), " dated June 26, 20 I4.
6. PPL Letter (PLA-7269) T. S. Rausch (PPL Susquehanna, LLC) to US. NRC, "First Six-Month Status Report In Response to June 6, 20I3 Commission Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable Of Operation Under Severe Accident Conditions (Order Number EA-I3-I09), "dated December 23, 2014.
7. Susquehanna Letter (PLA-7345) T. S. Rausch (Susquehanna Nuclear, LLC) to US. NRC, "Second Six-Month Status Report In Response to June 6, 20I3 Commission Order Modifying Licenses With Regard To Reliable Hardened Containment Vents Capable Of Operation Under Severe Accident Conditions (Order Number EA-I3-I09), "dated June 23, 20I5.

Document Control Desk PLA-7658

8. NRC Endorsement of indusfly "Hardened Containment Venting System (HCVS) Phase 1 and 2 Overall Integrated Plan Template," Revision], dated September 22, 2015, and Frequently Asked Questions (FAQs) 10, 11, 12, and 13 (Accession No. ML15273A141).
9. Susquehanna Letter (PLA-7421), "Combined Phase 1 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 23, 2015.
10. Susquehanna Letter (PLA-7488) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S. NRC, "Fourth Six-Month Status Report 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 1 09), " dated June 29, 2016.
11. Susquehanna Letter (PLA-7550) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S. NRC, "Fifth Six-Month Status Report 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 19, 2016.
12. Susquehanna Letter (PLA-7612) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S. NRC, "Sixth Six-Month Status Report 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 15, 2017.

On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to PPL Susquehanna, LLC (PPL ). Reference 1 was immediately effective and directs Susquehanna to install a primary contairunent venting capability in accordance with the requirements outlined in Attachment 2 of Reference 1.

The Order (EA-13-109) requires that licensees ofBWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened containment vent system (HCVS). The HCVS must be able to remove decay heat from the containment and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability.

The HCVS must maintain the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP).

The Order requirements are applied in a phased approach where:

  • "Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened containment vents to assist in preventing core damage and, if necessary, to provide containment venting capability during severe accident conditions." (Completed "no later than startup from the second refueling outage that begins after June 30,2014, or June 30, 2018, whichever comes first.")
  • "Phase 2 involves providing additional protections for severe accident conditions through installation of a reliable, severe accident capable drywell vent system or the development of a reliable containment venting strategy that makes it unlikely

Document Control Desk PLA-7658 that a licensee would need to vent from the containment drywell during severe accident conditions." (Completed "no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.")

The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim Staff Guidance (JLD-ISG-2013-02 issued in November 2013 and JLD-ISG-2015-0 1 issued in April 20 15). The ISGs endorse the compliance approach presented in NEI 13-02 Revisions 0 and 1, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA-13-109, the NRC staffwill use the methods described in the ISGs to evaluate licensee compliance as presented in submittals required in Order EA-13-109.

The Order also requires submittal of an overall integrated plan which will provide a description of how the requirements of the Order will be achieved (Reference 8).

Susquehanna submitted a Combined Phase 1 and Phase 2 Overall Integrated Plan (OIP) for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRC JLD-ISG-2013-02 and JLD-ISG-2015-01 (Reference 9).

Reference 1 requires submission of status reports at six-month intervals following submittal of the Combined Phase 1 and Phase 2 Overall Integrated Plan. References 2 and 4 provide direction regarding the content of the status reports. The purpose of this letter is to provide the seventh six-month status report pursuant to Section IV, Condition D, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed Status Report provides an update of milestone accomplishments since submittal of the Combined Phase 1 and Phase 2 Overall Integrated Plan and the sixth six-month status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Jason Jennings, Manager- Nuclear Regulatory Affairs at (570) 542-3155.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Document Control Desk PLA-7658

Enclosure:

Susquehanna Nuclear, LLC's Seventh Six-Month Status Report in Response to the 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) cc: Director, Office of Nuclear Reactor Regulation NRC Region I Mr. Rajender Auluck, NRR/JLD/PSB, NRC Mr. Brian Lee, NRR/JLD/JOMB, NRC Ms. L. H. Micewski, NRC Sr. Resident Inspector Ms. T. E. Hood, NRC Project Manager Mr. W. D. Reckley, NRR/JLD/PSB, NRC Mr. M. Shields, PA DEP/BRP

Enclosure to PLA-7658 Seventh Six-Month Status Report In Response to the 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)

Enclosure to PLA-7658 Page 1 of 12 Susquehanna Nuclear, LLC's Seventh Six Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction Susquehanna Nuclear, LLC developed an Overall Integrated Plan (Reference 1, all references mentioned in this enclosure are in Section 8 of this enclosure), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2.

This six month status rep01i provides updates of milestone accomplishments based on the Combined Phase 1 and 2 Overall Integrated Plan dated December 23, 2015 (Reference 8) since submittal ofthe sixth six month status rep01i (Reference 14).

Susquehanna Nuclear, LLC developed an updated and Combined Phase 1 and 2 Overall Integrated Plan (Reference 8 in Section 8), documenting:

1. The installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2.
2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2.

This Enclosure provides an update of milestone accomplishments since submittal of the sixth six month status report (Reference 14), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. The information in this update is cunent as ofNovember 30, 2017.

2 Milestone Accomplishments The following milestone(s) have been completed since the submittal of the sixth six month status rep01i (Reference 14), and are current as ofNovember 30, 2017.

  • Unit 1 Phase 1 installation has made substantial progress.

3 Milestone Schedule Status The following provides an update to the Milestone Schedule presented in Pmi 5 of the Combined Phase 1 and 2 Overall Integrated Plan (Reference 8). It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Enclosure to PLA-7658 Page 2 of12 Comments Target

{Include date Milestone Completion Activity Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates:

Update 1 Dec. 2014 Complete Update 2 Jun.2015 Complete Simultaneous with Update 3 Dec. 2015 Complete Phase 2 OIP Update 4 Jun.2016 Complete Update 5 Dec. 2016 Complete Update 6 Jun.2017 Complete Dec. 2017 Complete with Update 7 this submittal Update 8 Jun.2018 Not Started Update 9 Dec. 2018 Not Stmied Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual design June 2014 Complete meeting Unit 2 Design Engineering Complete Apr. 2016 Complete Unit 2 Implementation Outage Mar. 2017 Complete Unit 2 Walk Through Apr. 2017 Complete Demonstration/Functional Test Unit 1 Design Engineering Complete Mar. 2017 Complete May2017 April2018 (Non-outage Unit 1 Implementation Outage Mar. 2018 Not Started installation scope complete)

Unit 1 Walk Through Apr. 2018 Not Started Demonstration/Functional Test Phase 1 Procedure Changes Active U2 Operations Procedure Changes Dec. 2016 Complete April2017 Developed U2 Maintenance Procedure Changes Dec. 2016 Complete April2017 Developed U2 Procedure Changes Active Apr. 2017 Complete U1 Operations Procedure Changes Dec. 2017 Started April2018 Developed U1 Maintenance Procedure Changes Dec. 2017 Started April2018 Developed

Enclosure to PLA-7658 Page 3 of 12 Comments Target

{Include date Milestone Completion Activity Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Changed from Mar.

U1 Procedure Changes Active Apr. 2018 Stmied 2018 per outage schedule Phase 1 Training:

U2 Training Complete Apr. 2017 Complete U1 Training Complete Apr. 2018 Stmied Phase 1 Completion Unit 2 HCVS Implementation Apr. 2017 Complete Unit 1 HCVS Implementation Apr. 2018 Started Full Site HCVS Implementation Apr. 2018 Stmied 60 days after Phase Submit Phase 1 Completion Report Jun. 2018 Not Stmied 1 compliance Phase 2 Specific Milestones Phase 2 Modifications:

Hold preliminary/conceptual design Oct. 2015 Complete meeting Unit 1 Design Engineering On-Dec. 2016 Complete site/Complete Unit 1 Implementation Outage Mar. 2018 Not Started Unit 1 Walk Through Apr. 2018 Not Started Demonstration/Functional Test Unit 2 Design Engineering On-Dec. 2017 Complete site/Complete Unit 2 Implementation Outage Mar. 2019 Not Statied Unit 2 Walk Through Apr. 2019 Not Stmied Demonstration/Functional Test Phase 2 Procedure Changes Active Unit 1 Operations Procedure Changes Apr. 2018 Started Developed Unit 1 Maintenance Procedure Apr. 2018 Started Changes Developed Unit 1 Procedure Changes Active Apr. 2018 Statied Unit 2 Operations Procedure Changes Apr. 2019 Started Developed Unit 2 Maintenance Procedure Apr. 2019 Stmied Changes Developed Unit 2 Procedure Changes Active Apr. 2019 Stmied Phase 2 Training:

U1 Training Complete Apr. 2018 Statied U2 Training Complete Apr. 2019 Stmied

Enclosure to PLA-7658 Page 4 of 12 Comments Target

{Include date Milestone Completion Activity Status changes in this Date column}

Phase 1 and 2 HCVS Milestone Table Training Complete Apr. 2019 Not Started Phase 2 Completion Unit 1 HCVS Implementation Apr. 2018 Statied Unit 2 HCVS Implementation Apr. 2019 Started Full Site HCVS Implementation Apr. 2019 Started 60 days after full site Submit Completion Repoti Jun.2019 Not Started compliance 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Combined Phase 1 and 2 Overall Integrated Plan (Reference 8).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Susquehanna Nuclear, LLC expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the Combined Phase 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (IS E) and the status of each item.

Combined Phase 1 and 2 OIP Open Item Status Phase 1 Open Items 1 Confirm suppression pool heat capacity. Complete 2 Deployment under severe accident conditions will be confitmed for the Complete deployment of the FLEX generators credited to re-energize battery chargers.

3 Deployment under severe accident conditions will be confirmed for Complete deployment of the supplemental gas bottles.

4 The gas supply will be sized to suppoti HCVS operation for a minimum Complete of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (a minimum of 8 valve cycles of valve operation is assumed, consistent with recommendations in HCVS-WP-02). This design assumption will require future validation in the design phase of this project.

Enclosure to PLA-7658 Page 5 of 12 Combined Phase 1 and 2 OIP Open Item Status 5 An assessment of temperature and radiological conditions will be Complete perfmmed to ensure that operating personnel can safely access and operate controls at the remote operating station, based on time constraints listed in Attachment 2 of the Overall Integrated Plan.

6 Evaluate viable options to address Hydrogen detonation concems in Complete HCVS piping to meet the requirements ofEA-13-109, Section 1.2.11 and incorporate in HCVS design. SSES will determine the method to be deployed once NRC review of HCVS-WP-03 is complete.

7 An evaluation will be perfmmed to confi1m the HCVS power supply Complete can suppmt HCVS operation for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Phase 2 Open Items 1 Revise EC-0 16-1043 to include simultaneous SAWA and FLEX case. Complete Ensure the SAWA flow instrument will operate in the conditions 2 Complete expected.

Enclosure to PLA-7658 Page 6 of 12 Phase 1 Interim Staff Evaluation Open Item Comment Status Status Summary 1 Make available for NRC staff audit an evaluation that Section 3 .1.2 Complete Susquehanna's HCVS electrical design confirms that all load stripping to support HCVS was changed from using the station operation can be accomplished within forty five batteries to using dedicated HCVS minutes of event initiation. batteries.

Therefore, this Open Item is no longer applicable 2 Make available for NRC staff audit the final sizing Section 3.2.1 Complete Susquehanna calculation EC-002-1 081, evaluation for HCVS batteries/battery charger Section 3.2.2.4 "Hardened Containment Vent System including incorporation into FLEX DG loading Section 3.2.3.1 Battery Sizing" documents that adequate calculation. Section 3.2.3.2 HCVS battery power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is Section 3.2.4.1 provided.

Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6 3 Make available for NRC staff audit documentation of Section 3.2.1 Complete Susquehanna calculation EC-073-1 018, the HCVS nitrogen pneumatic system design Section 3.2.2.4 "HCVS Compressed Air Bottle Sizing including sizing and location. Section 3 .2.3 .1 Calculation" documents that adequate Section 3.2.3.2 pneumatic capacity is provided for at least Section 3.2.4.1 8 valve cycles in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6

Enclosure to PLA-7658 Page 7 of 12 Phase 1 Interim Staff Evaluation Open Item Comment Status Status Summary 4 Make available for NRC staff audit an evaluation of Section 3 .2.1 Complete Susquehanna calculations EC-03 0-1007, temperature and radiological conditions to ensure that Section 3.2.2.3 "Transient Temperature Response ofthe operating personnel can safely access and operate Section 3.2.2.4 Control Structure with HV AC- Normal controls and support equipment. Section 3.2.2.5 and Accident Conditions" and EC-RADN-Section 3.2.2.10 1180, "SSES HCVS Radiological Section 3.2.4.1 Assessment" document that the potential Section 3.2.4.2 temperatures and radiological conditions Section 3.2.5.2 are acceptable.

Section 3.2.6 5 Make available for NRC staff audit analyses Section 3.2.2.1 Complete Susquehanna calculation EC-073-1019, demonstrating that HCVS has the capacity to vent the Section 3 .2.2.2 "Flow Capacity of Unit 1 and Unit 2 steam/energy equivalent of one percent of Hardened Containment Vent System licensed/rated thermal power (unless a lower value is Under ELAP Conditions" documents that justified), and that the suppression pool and the the HCVS designs provide adequate HCVS together are able to absorb and reject decay capacity to meet or exceed the order heat, such that following a reactor shutdown from full criteria at both Units 1 and 2.

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

6 Make available for NRC staff audit the seismic and Section 3 .2.2.3 Complete SSES HCVS seismic and tornado missile tornado missile final design criteria for the HCVS design is consistent with the NRC stack. endorsed white paper, HCVS-WP-04. As such, the HCVS seismic and tornado designs are acceptable.

Enclosure to PLA-7658 Page 8 of 12 Phase 1 Interim Staff Evaluation Open Item Comment Status Status Summary 7 Make available for NRC staff audit the descriptions Section 3.2.2.3 Complete The HCVS components are capable of oflocal conditions (temperature, radiation and Section 3.2.2.5 performing their functions during ELAP humidity) anticipated during ELAP and severe Section 3.2.2.9 and severe accident conditions.

accident for the components (valves, instrumentation, Section 3.2.2.10 I sensors, transmitters, indicators, electronic, control devices, and etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

8 Make available for NRC staff audit documentation Section 3.2.2.5 Complete The communication methods for remote that demonstrates adequate communication between Section 3.2.2.10 HCVS operations during an ELAP are the the remote HCVS operation locations and HCVS same as the accepted methods in decision makers during ELAP and severe accident Mitigation Strategies Order EA-12-049.

conditions.

9 Provide a description of the final design of the HCVS Section 3.2.2.6 Complete SSES HCVS design is consistent with to address hydrogen detonation and deflagration. option 5 of the NRC endorsed white paper, HCVS-WP-03, utilizing a check valve at the pipe discharge point.

10 Provide a description of the strategies for hydrogen Section 3.2.2.6 Complete The HCVS are separate from each other control that minimizes the potential for hydrogen gas and are independent from the existing migration and ingress into the reactor building or containment purge/vent systems.

other buildings.

11 Provide a justification for deviating from the Section 3.2.2.9 Complete SSES revised the version of the seismic instrumentation seismic qualification guidance qualification guidance to the NRC specified in NEI 13-02, endorsed, in part, by JLD- endorsed version, as documented in ISG-2013-02 as an acceptable means for previous SSES letter to the NRC, PLA-implementing applicable requirements of Order EA- 7421. This deviation no longer exists.13-109. -

Enclosure to PLA-7658 Page 9 of 12 Phase 1 Interim Staff Evaluation Open Item Comment Status Status Summary 12 Make available for NRC staff audit descriptions of all Section 3 .2.2.1 0 Complete Instrumentation is sufficient to monitor instrumentation and controls (existing and planned) and control HCVS operation. The necessary to implement this order including descriptions and qualification information qualification methods. meet industry standard.

Phase 2 Interim Staff Evaluation Open Item " Comment Status Status Summary

1. Licensee to evaluate the SAWA equipment and Section 3.3 .2.3 Complete Susquehanna calculation EC-030-1 007, controls, as well as ingress and egress paths for the "Transient Temperature Response of expected severe accident conditions (temperature, Control Structure with HV AC- Normal &

humidity, radiation) to ensure that operating personnel Accident Conditions" documents that the can safely access and operate controls and support SAWA equipment and controls, as well as equipment for the sustained operating period. ingress and egress path conditions are acceptable. See also Phase 1 ISE OI-4.

2. Licensee to demonstrate that SAWA components and Section 3.3.2.3 Complete The SSES SAWA uses the same connections external to protected buildings have been components and connections as used for protected against the screened-in hazards of Order FLEX. These were previously evaluated EA-12-049 for the station. and determined to be adequately protected, as documented in SSES letter to the NRC, PLA-7421.
3. Licensee to demonstrate that containment failure as a Section 3.3.3 Complete The containments will be protected from result of overpressure can be prevented without a overpressure failure as documented in EC-drywell vent during severe accident conditions. 073-1019, "Flow Capacity ofUnit 1 and Unit 2 Hardened Containment Vent System Under ELAP Conditions." HCVS will be open, per procedure, prior to exceeding the containment pressure limit.

See also Phase 1 ISE OI-5.

Enclosure to PLA-7658 Page 10 of 12 Phase 2 Interim Staff Evaluation Open Item Comment Status Status Summary

4. Licensee shall demonstrate how the plant is bounded Section 3.3 .3 .1 Complete The reference plant analysis bounds by the reference plant analysis that shows the SAWM Susquehanna (Suppression Pool volume strategy is successful in making it unlikely that a and the time dependent SAWA flow drywell vent is needed. rates).
5. Licensee to demonstrate that there is adequate Section 3.3.3.4 Complete The communication methods are the same communication between the MCR and the operator at as the accepted methods in Mitigation the FLEX pump during severe accident conditions. Strategies Order EA-12-049.

Enclosure to PLA-7658 Page 11 of 12 7 Interim Staff Evaluation Impacts There are no potential impacts from or to the Interim StaffEvaluation(s) identified at this time.

The NRC issued an Audit Repmi for the Interim Staff Evaluation (ISE) of Susquehanna's EA-13-109 order compliance status on October 5, 2017 (Reference 15). The NRC did not identify any new Open Items and has cunently described the status of all existing Phase 1 and Phase 2 ISE Open Items as "Closed" .

8 References The following references suppmi the updates to the Combined Phase 1 and 2 Overall Integrated Plan described in this Enclosure.

1. PLA-7180, Susquehanna, LLC's 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 109)," dated June 26, 2014.
2. NRC Order Number EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions,"

dated June 6, 2013.

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April2015.
4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).
5. NRC Endorsement of industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).
6. PPL Letter (PLA-7269) T. S. Rausch (PPL Susquehanna, LLC) to U.S. NRC, "First Six-Month Status Repmi 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 23, 2014.

7. Susquehanna Letter (PLA-7345) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S.

NRC, "Second Six-Month Status Repmi 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 23, 2015.

Enclosure to PLA-7658 Page 12 of 12

8. Susquehanna Letter (PLA-7421), Susquehanna, LLC's Combined Phase 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 23,2015. (Also the Third Six-Month Update.)
9. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated April 2015 (Accession No. ML15104A118).
10. NRC Endorsement of industry "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 (Accession No. ML15273A141).
11. Susquehanna Letter (PLA-7488) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S.

NRC, "Fourth Six-Month Status Report 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 29, 2016.

12. NRC Letter toSSES (Jon Franke), Interim Staff Evaluation for Phase 2 with 5 Open Items, August 25, 2016, ML16231A509.
13. Susquehanna Letter (PLA-7550) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S.

NRC, "Fifth Six-Month Status Report 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 19, 2016.

14. Susquehanna Letter (PLA-7612) T. S. Rausch (Susquehanna Nuclear, LLC) to U.S.

NRC, "Sixth Six-Month Status Report 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 15, 2017.

15. NRC letter to Susquehanna (Brad Benyman), "Susquehanna Steam Electric Station, Units 1 and 2- 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), dated October 5, 2017 (ML17272A733).
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