Text

Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to Nrd Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe
	ML18120A165
Person / Time
Site:	Hope Creek
Issue date:	05/04/2018
From:	Rajender Auluck; Beyond-Design-Basis Engineering Branch
To:	Sena P; Public Service Enterprise Group
	Lee B, NRR/DLP, 415-2916
References
	Download: ML18120A165 (25)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 4, 2018 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC - N09 Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

HOPE CREEK GENERATING STATION - REPORT FOR THE AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS 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 NO. MF4458; EPID L-2014-JLD-0040)

Dear Mr. Sena:

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 Conditions," to all Boiling-Water Reactor licensees 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 25, 2014 (ADAMS Accession No. ML14177A508), PSEG Nuclear LLC (PSEG, the licensee) submitted its Phase 1 OIP for Hope Creek Generating Station (HCGS, Hope Creek). By letters dated December 19, 2014, June 18, 2015, December 28, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 29, 2016, December 22, 2016, June 27, 2017, and December 19, 2017 (ADAMS Accession Nos. ML14353A076, ML15173A026, ML15362A580, ML16181A210, ML16358A254, ML17178A300, and ML17354A772, respectively), the licensee submitted its 6-month updates to the OIP. The NRC 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 Hope Creek by letters dated February 12, 2015 (ADAMS Accession No. ML14332A154), and August 2, 2016 (ADAMS Accession No. ML16103A320), respectively. When developing the IS Es, 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 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.

P.Sena The NRC staff conducted teleconferences with the licensee on June 15, 2017, and April 19, 2018. 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 No. 50-354

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 EVALUATIONS OPEN ITEMS RELATED TO ORDER EA-13-109 MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354 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) licensees 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 (ac) power (ELAP). The order required all applicable licensees, by June 30, 2014, to submit to the Commission for review an overall integrated plan (OIP) that describes how compliance with the Phase 1 requirements described in Order EA-13-109 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 25, 2014 (ADAMS Accession No. ML14177A508}, PSEG Nuclear LLC (PSEG, the licensee) submitted its Phase 1 OIP for Hope Creek Generating Station (HCGS, Hope Creek). By letters dated December 19, 2014, June 18, 2015, December 28, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 29, 2016, December 22, 2016, June 27, 2017, and December 19, 2017 (ADAMS Accession Nos. ML14353A076, ML15173A026, ML15362A580, ML16181A210, ML16358A254, ML17178A300, and ML17354A772, respectively}, the licensee submitted its 6-month updates to the OIP, as required by the order.

The NRC 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 Hope Creek by letters dated February 12, 2015 (ADAMS Accession No. ML14332A154), and August 2, 2016 (ADAMS Accession No. ML16103A320}, respectively. When developing the IS Es, 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 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 NRC staff conducted teleconferences with the licensee on June 15, 2017, and April 19, 2018. The purpose of the audit teleconferences were to continue the audit review and provide the NRC 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, Revision 1 and related documents (e.g. White papers (ADAMS Accession Nos. ML14126A374, ML14358A040, ML15040A038 and ML15240A072, respectively) and frequently asked questions (FAQs), (ADAMS Accession No. ML15271A148))

that were developed and reviewed as part of overall guidance development. The NRC 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 Hope Creek. The open items are taken from the Phase 1 and Phase 2 ISEs issued on February 12, 2015, and August 2, 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 Hope Creek, 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 NRC staff will

evaluate the FIP, 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 Oraanization Team Lead/Sr. Project Manaqer Raiender Auluck NRR/DLP Project Manager Support/Technical Support - Containment / Ventilation Brian Lee NRR/DLP Technical Support - Containment/

Ventilation Bruce Heida NRR/DLP Technical Support - Electrical Kerbv Scales NRR/DLP Technical Support- Balance of Plant Garrv Armstronq NRR/DLP Technical Support - l&C Steve Wyman NRR/DLP Technical Support - Dose John Parillo NRR/DRA Attachment 1

Table 2 - Audit Documents Reviewed Calculation HC-MISC-005, "MAAP Analysis to Support FLEX Initial Strategy," Revision 7 Calculation GS-0026, "Hardened Containment Vent Capacity," Revision 1 Calculation GS-0027, "Disc Rupture Fluid Transient Analysis in Hardened Containment Vent Piping," Revision 1 Technical Evaluation 80115583 - Missile Evaluation (Hope Creek Conformance to HCVS-WP-04 Calculation H-1-FLX-MDC-4016, "Hope Creek Auxiliary Building Extended Loss of AC Power FLEX Response," Revision 3 Calculation PSEG104-CALC-007, "GOTHIC Modeling of Auxililary Building Extended Loss of AC Power FLEX Response for Hardened Vent," Revision 1 Calculation PSEG104-CAL-004, "Hope Creek Hardened Containment Vent System Dose Evaluation," Revision O Calculation PSEG104-CALC-002, "Backup Nitrogen Supply for Hardened Vent," Revision 0 Calculation PSEG104-CALC-005, "Hydrogen Concentration from HCVS into Reactor Building,"

Revision O Calculation E-4.1 (Q), "HC Class 1 E 125 VDC Station Battery & Charger Sizing," Revision 18C Calculation E-4.6(Q), "Hope Creek 125 VDC Beyond Design Base Event Battery Sizing Calculation," Revision 1 Calculation E-15.16, "Hope Creek FLEX Electrical System Loading Analysis," Revision 0 Design Change Package (DCP) 80115583, "Hope Creek Hardened Torus Vent Modification,"

Revision 2 Calculation PSEG104-CALC-001, "Compressed Gas Purge System for Containment Hardened Vent," Revision 3 Calculation 1GSHV-11541, "Air Operated Valve (AOV) Capability Evaluation," Revision 3 Calculation 1GSHV-4964, "Air Operated Valve (AOV) Capability Evaluation," Revision 2 Design Change Package 80113942, "Hardened Containment Vent Electrical," Revision 3 Calculation H-1-FLX-MDC-4022, "FLEX Hydraulic Model," Revision 1 Calculation 2017-04167, "SAWA/SAWM GOTHIC Analyses," Revision 0 Calculation 2017-01221, "Hardened Containment Vent System Phase II Radiation Dose Assessment," Revision 0 BWROG-TP-008, "Severe Accident Water Addition Timing" BWROG-TP-011, "Severe Accident Water Management Supporting Evaluations" Attachment 2

Hope Creek Generating 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 Safety Evaluation (SE) provided in 6 month updates and on the status Requested Action ePortal Closed; Pending; Open (need additional information from licensee)

Phase 1 ISE 01 1 Complete. Anticipatory venting time The NRG staff reviewed the Closed constraints are included in the FLEX information provided in the 6-Finalize time constraints and strategy timeline which assumes torus month updates and on the [Staff evaluation to be their bases. Make available venting is initiated approximately four ePortal. included in SE Section for NRG staff audit the hours following an Extended Loss of AC 3.1.1.1]

finalized time constraints for Power (ELAP) event, based on torus The licensee finalized their time remote manual operations and water temperature of 200 degrees F. constraints, which includes their bases. MAAP [Modular Accident Analysis anticipatory venting (at approx .. 4 Program] analyses (HC-MISC-005, Rev. 8 hours) into the FLEX strategy is uploaded to the subfolder for this item timeline. The NRG staff in "ISE Item Closure/Phase 1") have been previously reviewed the HCVS revised to reflect the modified vent timeline as documented in design. NRG review of the OIP Section 3.3.1 of the Phase 2 ISE.

(Reference 5) timeline for HCVS is documented in Section 3.3.1 of the Phase No follow-up questions.

2 ISE (Reference 11 ).

Phase 1 ISE 01 2 Complete. Calculation GS-0026, The NRC staff reviewed the Closed "Hardened Containment Vent Capacity," information provided in the 6-Make available for NRC staff shows that the HCVS 12-inch vent can month updates and on the [Staff evaluation to be audit analyses demonstrating accommodate the required steam/energy ePortal. included in SE Section that HCVS has the capacity to equivalent of one percent of 3.1.2.1]

vent the steam/energy licensed/rated thermal power flow. GS- Calculation GS-0026 determined equivalent of one percent of 0026 uses 3917 MWt reactor power (1.02 the required flow for the steam licensed/rated thermal power x 3840 rated thermal power), vs 3902 equivalent of 1% of 3917 (unless a lower value is MWt per the license amendment request megawatt thermal (MWt (102% of justified), and that the for margin uncertainty recapture, current licensed reactor power of suppression pool and the ML17188A260. Calculation GS-0027, 3840 MWt) at 54.4 per square HCVS together are able to "Disc Rupture Fluid Transient Analysis in inch gauge (psig) is 147,108 lb/hr.

absorb and reject decay heat, Hardened Containment Vent Piping,"

such that following a reactor shows that the piping can accommodate Attachment 3

shutdown from full power the fluid dynamics of the steam/energy RELAP5 thermal-hydraulic containment pressure is equivalent of one percent of program was used to simulate restored and then maintained licensed/rated thermal power flow. Vendor two-phase flow in piping systems.

below the primary containment Technical Document (VTD) 432633, REFORC was used to determine design pressure and the "Suppression Pool Energy Capacity," flow generated forces in piping.

primary containment pressure used 3900 MWt (vs 3902 MWt in the Vent capacity with torus pressure limit. MUR LAR), and evaluated zero to three at 54.4 psig is 168,000 lb/hr.

hours from an ELAP based on Rev O of the OIP. VTD 432633 shows that the No follow-up questions.

suppression pool has sufficient capacity to absorb the energy released into the torus for the first three hours following an ELAP event, with approximately 60%

margin. MAAP analyses (HC-MISC-005, including cases run using 3902 MWt) support anticipatory venting at four hours based on torus water temperature of 200 degrees F and acceptable containment response thereafter.

GS-0026, GS-0027 and VTD 432633 are in the subfolder for this item in "ISE Item Closure/Phase 1" - no changes from the June 2017 upload.

Phase 1 ISE 01 3 Complete. Design Change Package The NRC staff reviewed the Closed (DCP) 80115583, "Hardened information provided in the 6-Provide the seismic and Containment Vent Modification," month updates and on the [Staff evaluation to be tornado missile final design addresses the seismic design of the ePortal. included in SE Section criteria for the HCVS stack. HCVS stack and includes a Technical 3.2.2]

Evaluation of tornado missile protection Design Change Package (DCP) following NEI white paper HCVS-WP-04 80115583-0860, "Technical as endorsed by NRC letter to NEI dated Evaluation to Document Hope September 14, 2015 (ADAMS Accession Creek Conformance to HCVS-No. ML15240A072). WP-04," addresses all 4 assumptions. Procedure DCP 80115583 Rev 2 and Technical "HC.OP-AB.MISC-0001,"

Evaluation 80115583-0860 are in the provides guidance to re-establish subfolder for this item in "ISE Item vent path in the event the HCVS Closure/Phase 1" - no changes from the becomes damaged.

June 2017 upload.

No follow-up questions.

Phase 1 ISE 01 4 Complete. (Replaced reference to the OIP The NRC staff reviewed the Closed with the response text below, modified to information provided in the 6-Make available for NRC staff show the final POS [primary operating month updates and on the [Staff evaluation to be audit documentation that station] location at the Remote Shutdown ePortal. included in SE Section demonstrates adequate Panel): 3.1.1.1 J communication between the The communication methods are remote HCVS operation The HCVS POS is at the Remote the same as accepted in Order locations and HCVS decision Shutdown Panel in Room 3576 at EA-12-049.

makers during ELAP and elevation 137' in the Auxiliary Building and severe accident conditions. the ROS in the electrical chase is located No follow-up questions.

at 102 ft elevation of the Control/Diesel Building (also part of the Auxiliary Building). The POS is on the same elevation as the Main Control Room (MCR) and the ROS is two levels below the MCR. They are accessible from the MCR via pathways within the power block. Accessibility under postulated temperature and radiological conditions is addressed via ISE Open Item #5.

PSEG has implemented communications enhancements including radio upgrades to support diverse and flexible (FLEX) mitigating strategies for beyond-design-basis external events. These enhancements include the addition of a remote desk set in the MCR which is provided with FLEX-backed uninterruptible power supplies and direct connections to repeaters for reliable radio communication within the power block, including the MCR and the Operations Support Center. Communication between HCVS operators and decision makers would be maintained to support HCVS operation based on the proximity of the POS and ROS to the emerQency

response facilities, and radio communications capability.

Additional information regarding communications enhancements is provided in the subfolder for Phase 2 ISE

7. There is no e-portal folder for this Phase 1 item.

Phase 1 ISE 01 5 Complete. The GOTHIC model Vendor The NRC staff reviewed the Closed Technical Documents (VTDs) 432340 information provided in the 6-Perform dose evaluation for (001) (Auxiliary Building GOTHIC model) month updates and on the [Staff evaluation to be venting actions. Make and 432611 (001) (Room 5301 and TSC ePortal. included in SE Sections available for NRC staff audit areas GOTHIC model) as well as HCVS 3.1.1 .2 and 3.1 .1 .3]

an evaluation of temperature Dose Evaluation VTD 432634 (001 ), show Main control room (MCR) and radiological conditions to that the temperatures and radiation levels temperatures have been ensure that operating are acceptable for personnel addressed as part of the FLEX personnel can safely access ingress/egress. order and were found to and operate controls and acceptable by the NRC staff.

support equipment. The referenced VTDs are in the subfolder for this item in "ISE Item Closure/Phase Calculation PSEG104-CALC-007, 1." GOTHIC VTDs 432340 and 432611 "GOTHIC Modeling of Auxiliary have been revised for SAWA [Severe Building Extended Loss of AC Accident Water Addition] and the current Power FLEX Response for revisions are in this subfolder. There Hardened Vent," Revision 1 have been no changes to dose VTD shows that the remote operating 432634 since the June 2017 upload, but a station (ROS) (Room 5301) starts new dose VTD 432902 and summary at a little over 100°F ( 102°F) and report VTD 432889 were performed for remains relatively constant (cools SAWA and are in the subfolder for Phase slightly) for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

2 ISE #3+4.

Calculation PSEG104-CAL-004, E-Plan Section 12 for Radiological "Hope Creek Hardened Exposure Control is also included and has Containment Vent System Dose not changed since the June Evaluation," Revision O was 2017 upload. performed to determine the integrated radiation dose due to HCVS operation. The NRC staff reviewed this calculation and determined that the licensee used conservative assumotions and

followed the guidance outlined in NEI 13-02 Rev.1 and HCVS-WP-02 Rev. 0. Based on the expected integrated whole body dose equivalent in the POS and ROS and the expected integrated whole body dose equivalent for expected actions during the sustained operating period, the NRC staff believes that the order requirements are met.

Temperature and radiological conditions should not inhibit operator actions needed to initiate and operate the HCVS during an ELAP with severe accident conditions.

No follow-up questions.

Phase 1 ISE 01 6 Complete. Parameters of drywell The NRC staff reviewed the Closed pressure, torus pressure, torus level, information provided in the 6-Make available for NRC staff torus water temperature, and reactor month updates and on the [Staff evaluation to be audit descriptions of all pressure on MCR instrumentation allow ePortal. included in SE Section instrumentation and controls monitoring effectiveness of torus venting 3.1.2.8]

(existing and planned) actions. For these parameters, HCGS The existing plant instuments necessary to implement this uses existing instrumentation and MCR required for HCVS (i.e. wetwell order including qualification displays qualified to Regulatory Guide level instruments and drywell methods. 1.97 and provided with Class 1E electrical pressure instruments) meet the power (Updated Final Safety Analysis requirements of Regulatory Guide Report, Table 7.5-1). (RG) 1.97.

HCVS operation is monitored by vent The licensee provided analyses valve position, vent flow, and effluent and/or supporting information of radiation levels. DCP 80113942, the HCVS instruments and "Hardened Containment Vent Electrical," controls (l&C), including a provided instrumentation and controls at description of each component the POS at the Remote Shutdown Panel and the qualification method. The in Room 3576 at elevation 137' in the staff's review indicates that the Auxiliary Buildinq, and at the ROS in the l&C components are consistent

Electrical Chase Area (Room 5301) on EL with the guidance in NEI 13-02 102'-0" of the Auxiliary Building. HCVS and its qualifications meet the flow rate is displayed via a recorder in the order requirements.

POS and flow indicator in the ROS. The HCVS instruments are qualified by using No follow-up questions.

one or more of the three methods described in JLD-ISG-2013-02 [Japan Lessons-Learned Directorate-Interim Staff Guidance] (Reference 8).

DCP 80113942 Rev. 3 is in the subfolder for this item in "ISE Item Closure/Phase 1." The second paragraph, above, is based on DCP Section 4.1.5 (p. 28/112).

Section 4.1 .36 (p. 62/112) has additional l&C requirements.

Phase 1 ISE 01 7 Complete. Details are provided in Section The NRC staff reviewed the Closed 4.3 of Reference 15 (5th six-month information provided in the 6-Make available for NRC staff update, ML16358A254). month updates and on the [Staff evaluation to be audit the final sizing evaluation ePortal. included in SE Section for HCVS batteries/battery The following documents are in the 3.1.2.6]

charger including incorporation subfolder for this item in "ISE Item The licensee stated that all into FLEX DG loading Closure/Phase 1": electrical power required for calculation. operation of HCVS components is

SAP Order Operation 80115232-0160 provided by the HCVS 125 volts (ISE07-Battery(80115232-0160).pdf) is direct current (VDC) battery and the Item response similar to the one battery charger.

provided in the 5th six-month update The battery sizing calculation E-

Procedure HC.OP-AB.ZZ-0135 Revision 4.6(Q), "Hope Creek 125 VDC 43, "Station Blackout/ Loss of Offsite Beyond Design Base Event Power/Diesel Generator Malfunction." Battery Sizing Calculation,"

Attachment 8 has the ELAP load shed Revision 1 confirmed that the 125 VDC battery has a minimum

Revisions to electrical calculations E-4.1 capacity capable of providing and E-4.6 resulting from Design Change power for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without Package 80113942 (HCVS Electrical) recharging, and therefore is adequate.

The licensee provided DCP 80113942, "Hardened Containment Vent Electrical,"

Revision 3, which discusses re-powering of the HCVS 125 VDC battery charger using the FLEX DG.

No follow-up questions.

Phase 1 ISE 01 8 Complete. DCP 80113941, "Hardened The NRC staff reviewed the Closed Containment Vent Mechanical," provided information provided in the 6-Make available for NRC staff a permanently installed nitrogen supply at month updates and on the [Staff evaluation to be audit documentation of the the ROS in the Electrical Chase Area ePortal. included in SE Section HCVS nitrogen pneumatic (Room 5301) on elevation 1 02'-0" of the 3.1.2.6]

system design including sizing Auxiliary Building. The ROS is protected DCP 80113941 and Vendor and location from all external hazards. VTD 432632, Technical Document (VTD)

"Backup Nitrogen Supply for Hardened 432632, describes the capability Vent," shows that the system possesses of the nitrogen system of enough volume for 8 cycles of the HCVS providing eight cycles for the valves. DCP 80113941 also installed the HCVS valves and bursting the capability to manually breach the HCVS rupture disk.

rupture disk from the ROS using a separate nitrogen source. The calculation shows that 8 bottles of AirGas 2HP can be DCP 80113941, VTD 432632 and used for 8 purge cycles at the drawing M-57-1 sheets 1 and 2 are in the minimum of 2,500 psig per cycle subfolder for this item in "ISE Item (the bottles are rated for 3500 Closure/Phase 1": Sheet 2 of the drawing psig). The amount of nitrogen shows details of the nitrogen system. needed for the bursting the rupture disc is 1600 psig. The AirGas 200 bottle is rated for 2265 psig. Therefore, the licensee confirmed that there will be more than enough nitrogen available to fulfill both functions.

No follow-up questions.

Phase 1 ISE 01 9 Complete. Functionality of HCVS The NRC staff reviewed the Closed components during ELAP and severe information provided in the 6-accident conditions is supported by the

Make available for NRC staff documents referenced in response to ISE month updates and on the [Staff evaluation to be audit the descriptions of local #5, combined with DCPs 80113941, ePortal. included in SE Section conditions (temperature, 80113942 and 80115583. 3.1.1.4]

radiation, and humidity) DCPs 80113941 and 80113942 anticipated during ELAP and A detailed response in SAP Order discuss the environmental severe accident for the Operation 80115232-0180 conditions during an accident at components (valves, "ISE09(80115232-0180).pdf" is in the the locations containing instrumentation, sensors, subfolder for this item in "ISE Item instrumentation and controls transmitters, indicators, Closure/Phase 1," with references (l&C) components. The staff's electronics, control devices, including current revisions of the DCPs. review indicated that the etc.) required for HCVS GOTHIC VTDs 432340 and 432611 have environmental qualification met venting including confirmation been revised for SAWA and the current the order requirements.

that the components are revisions are in this subfolder.

capable of performing their ISE09(80115232-0180).pdf and the other The primary control location is at functions during ELAP and references have not changed since the the POS at the Remote Shutdown severe accident conditions. June 2017 upload. Panel in Room 3576 at elevation 137' in the Auxiliary Building. The ROS is located in the Electrical Chase Area (Room 5301) on elevation 102' of the Auxiliary Building. The staff notes that some instrumentation was pre-existing from the HCGS Hardened Torus Vent (HTV} and the reviewed design documents appear to appropriately address the qualification of the existing/modified and new instrumentation.

The main control room was previously evaluated as part of Order EA-12-049.

No follow up questions.

Phase 1 ISE 01 10 Complete. The HCVS containment The NRC staff reviewed the Closed isolation valves (H1 GS- HV-11541 and information provided in the 6-Make available for NRC staff H1 GS-HV-4964) are shown to have a disc month updates and on the [Staff evaluation to be audit an evaluation verifying design differential pressure of 65 psig per ePortal. included in SE Section the existinq containment VTDs 315211 and 315212, respectively. 3.2.1]

isolation valves, relied upon for The Primary Containment Pressure Limit Documentation provided shows the HCVS, will open under the is 65 psig. the valves were purchased with maximum expected differential fail-closed design function.

pressure during BDBEE and The following files are in the subfolder for Maximum specified design severe accident wetwell this item in "ISE Item Closure/Phase 1": pressure is 65 psig. During the venting. audit, NRG staff requested

VTDs 315211 and 315212 information demonstrating the actuators can open the valves

HC.OP-EO.ZZ-0206-BASES, Rev. 1, under expected differential RPV Flooding Emergency Operating pressure and that the actuator Procedure Bases Document, supporting maintains operability under the PCPL value of 65 psig (p. 12/29) severe accident conditions for the duration of the coping mission

Valve data sheets from Specification H- time.

1-VAR-MGS-0010 (002) for Nuclear Butterfly Valves, Rev. 9 Licensee provided evaluations on the primary containment isolation These documents have not changed valves. The evaluation since the June 2017 upload. determined that the inboard primary isolation valve (PIV) actuator may not have sufficient torque to fully open the valve under maximum anticipated differential pressure. Procedures specify opening the inboard PIV first. As the downstream piping is pressurized equalizing the pressure across the inboard PIV.

For subsequent HCVS operation, the inboard PIV will be kept open and the downstream valve cycled as required.

No follow-up questions.

Phase 1 ISE 01 11 Complete. The release point elevation The NRG staff reviewed the Closed and plume rise during venting (described information provided in the 6-Provide a description of the in References 12 and 13) will minimize month updates and on the [Staff evaluation to be strategies for hydrogen control migration and ingress of hydrogen into ePortal. included in SE Section that minimizes the potential for buildings. 3.1.2.12]

hydrogen gas migration and

ingress into the reactor Vendor Technical Document (VTD) The HCVS is connected to the building or other buildings. 432628 Volume 2, "Hydrogen Leakage Containment Pre-purge Cleanup from the CIVs of HCVS into the Enclosed System at valve HV4962 (24" CPCS Duct Return Line," shows that the diameter) and at valve HV4963 in-leakage of hydrogen into the vent is (2" diameter). Evaluation minimal in the time between venting PSEG104-CALC-005, Revision 0 operations. When the HCVS valves are indicates valve 1GS-HV-4962 has closed, the vent piping will be purged with a blank flange installed Argon gas using Emergency Operating downstream and therefore Procedure HC.OP-EO.ZZ-0318, leakage through the valve is "Containment Venting" (EOP-0318) if assumed to be O standard cubic hydrogen is expected. centiliters per minute (seem). The valves appear to be primary A detailed response in SAP Order containment isolation valves and Operation 80115232-0200 (ISE11- as such should be under an H2(80115232-0200).pdf) and references Appendix J leakage testing are provided in the subfolder for this item program. The Appendix J in "ISE Item Closure/Phase 1." leakage testing program provides assurance hydrogen is not likely The only document that has changed to leak into other since the June 2017 upload is EOP-318, systems/buildings.

for containment venting. The draft revision to EOP-318 with SAWA changes The NRC staff's review of the is included in the subfolder. proposed system indicates that the licensee's design appears to meet the requirement for minimizing the potential for hydrogen gas migration and ingress into the Reactor Building or other site buildings.

No follow-up questions.

Phase 1 ISE 01 12 Complete. Measures to prevent hydrogen The NRC staff reviewed the Closed deflagration/detonation have been information provided in the 6-Provide a description of the established by Emergency Operating month updates and on the [Staff evaluation to be final design of the HCVS to Procedure HC.OPEO. ZZ-0318, ePortal. included in SE Section address hydrogen detonation "Containment Venting" (EOP-0318) and 3.1.2.11]

and deflagration. the argon purge system installed DCP via The licensee's design is 80113941, "Hardened Containment Vent consistent with Option 5 of the System Mechanical." EOP-0318 has been

revised in order to require an argon purge NRC staff endorsed white paper of the HCVS prior to opening the HCVS-WP-03.

containment isolation valves in an accident scenario where hydrogen No follow-up questions.

generation is expected, and to keep the HCVS operating unless containment pressure approaches zero psig.

Vendor Technical Document (VTD) 432631 demonstrates that the volume of argon gas used to purge the HCVS is sufficient in order to prevent hydrogen detonation/deflagration by completely filling the HCV downstream of HV-11541.

The compressed gas purge system uses argon gas to fill the HCVS piping from valve HV-11541 (V-201) to the release point and prevent oxygen from entering the vent piping after a vent cycle.

A detailed response in SAP Order Operation 80115232-0210 (ISE12(80115232-21 O}.pdf) and references are provided in the subfolder for this item in "ISE Item Closure/Phase 1" Draft EOP-318, Containment Venting" with SAWA changes is included in the subfolder. HC.OP-DL.ZZ-0006-F1, HC-Auxiliary Building Log 6, has been revised since the June 2017 upload but the criteria for checking Argon bottle pressures have not chanqed.

Phase 1 ISE 01 13 Complete (References 12, 13, and 14). The NRC staff reviewed the Closed information provided in the 6-Finalize x/Q analysis (OIP #3). There is no e-portal folder for this item. month updates and on the [Staff evaluation to be Submit a relaxation request as References 12, 13, and 14 are docketed ePortal. included in SE Section stated in the Order for the correspondence in ADAMS. DCP 3.1.2.2]

deviation from Order EA 80115583 configured the release point The licensee finalized their x/Q 109 provision 1.2.2, "The consistent with the relaxation and is analysis and submitted a HCVS Section 3.2.2.3 shall included in the folder for Phase 2 ISE #1. relaxation request from Order EA-

discharge the effluent to a 13-109 provision 1.2.2 in letter release point above the main dated June 21, 2016 (ADAMS plant structures," which Accession No. ML16174A086), as includes a technical supplemented by letter dated justification for the deviation. September 7, 2016 (ADAMS Accession No. ML16251A309).

The NRC staff reviewed the relaxation request and was accepted in letter dated September 30, 2016 (ADAMS Accession No. ML16256A655).

No follow-up questions.

Phase 2 ISE 01 1 Complete. DCP 80115583, "Hope Creek The NRC staff reviewed the Closed Hardened Torus Vent Modification," information provided in the 6-Licensee shall provide the provides the final discharge location month updates and on the [Staff evaluation to be finalized design of HCVS design consistent with relaxation of the ePortal. included in SE Section' discharge location. release point height requirement (NRC 3.1.2.2]

Letter to PSEG, "Hope Creek Generating The NRC staff reviewed the Station- Request for Relaxation of the relaxation request and was Release Point Height Requirement of accepted in letter dated NRC Order EA-13-109, Order Modifying September 30, 2016 (ADAMS Licenses with Regard to Reliable Accession No. ML16256A655).

Hardened Containment Vents Capable of Operation under Severe Accident No follow-up questions.

Conditions (CAC No. MF4458)," dated September 30, 2016).

Page 3 of the NRC SER is consistent with the final design of the vent height in DCP 80115583 Revision 2, which is in the subfolder for this item in "ISE Item Closure/Phase 2" DCP 80115583 Affected Document (AD) MOS is also included, and shows the effect of the change on the system piping isometric drawing.

Phase 2 ISE 01 2 Complete. DCP 80118721, "HC Severe The NRC staff reviewed the Closed Accident Water Addition," provides the information provided in the 6-

Licensee shall provide the SAWA design to inject the required flow month updates and on the [Staff evaluation to be finalized design, which rate and to control flow under a flooded ePortal. included in SE Section demonstrates the capability to condition, as summarized in Section 4. 4.1.1.2]

inject the necessary SAWA Section 4 has been updated since the Calculation H-1-FLX-MDC-4022, flow rate and the ability to previous status report (Reference 16 "FLEX Hydraulic Model," Revision control that flow under a (ADAMS Accession No. ML17178A300)) 1, determined that the required flooded condition. to include additional details. SAWA flowrate was within the capacity of the portable FLEX Documents supporting the discussion in pumps.

Section 4 above are in the subfolder for this item in "ISE Item Closure/Phase 2." The NRG staff reviewed the flow Section 4 above is annotated with rates and pressures evaluated in comments to refer to sources of the hydraulic analyses and supporting information. DCP 80118721 is confirmed that the equipment is under revision and will be provided when capable of providing the needed available but the response in Section 4 flow rate. Based on the NRG above should not be affected by the staff's review of the FLEX changes. Supplements 1 and 2 to the pumping capabilities, as DCP (80118721 r0sup01 rO and described in the above hydraulic 80118721 r0sup02r1) are the electrical the analyses and in the OIP and mechanical sketches, respectively, for the subsequent 6-month updates, the SAWA design. licensee has demonstrated that its portable FLEX pumps should perform as intended to support SAWA flow.

Phase 2 ISE 01 3 Complete. Vendor Technical Document The NRG staff reviewed the Closed 432889, "Severe Accident Water Addition information provided in the 6-Licensee to confirm through Personnel and Equipment Environmental month updates and on the [Staff evaluation to be analysis the temperature and Qualification Report," summarizes the ePortal. included in SE Section radiological conditions to results of temperature and radiological 4.5.1.3]

ensure that operating analyses and their impact on personnel Calculation 2017-04167, personnel can safely access access to SAWA equipment. "SAW A/SAWM (Severe Accident and operate controls and Water Management) GOTHIC support equipment. VTD 432889 and its design inputs listed in Analyses," Revision O and Section 4 of the VTD are in the subfolder calculation 2017-01221, "ISE Item Closure/Phase 2/Ph2_1SE- "Hardened Containment Vent 3+4Temp+Dose." System Phase II Radiation Dose Assessment," Revision 0, demonstrates that the temperature and radiological

conditions should not inhibit operator actions needed to support SAWA/SAWM during an ELAP with severe accident conditions.

No follow-up questions.

Phase 2 ISE 01 4 Same response as for Phase 2 ISE # 3. The NRC staff reviewed the Closed information provided in the 6-Licensee to demonstrate how month updates and on the [Staff evaluation to be instrumentation and equipment ePortal. included in SE Sections being used for SAWA and 4.4.1 .3 and 4.5.1 .2]

supporting equipment is The drywall pressure and torus capable to perform for the level indications are RG 1.97 sustained operating period compliant and are acceptable as under the expected qualified.

temperature and radiological conditions. The NRC staff reviewed calculation 2017-01221, "Hardened Containment Vent System Phase 11 Radiation Dose Assessment," Revision O and determined that the licensee used conservative assumptions and followed the guidance outlined in NEI 13-02 Rev.1 and HCVS-WP-02 Rev.a. Based on the expected integrated whole body dose equivalent in the POS and ROS and the expected integrated whole body dose equivalent for expected actions during the sustained operating period, the NRC staff believes that the order requirements are met.

No follow-up questions.

Phase 2 ISE 01 5 Complete. ISE #5 and ISE #6 are The NRC staff reviewed the Closed addressed in Technical Evaluation information provided in the 6-80115232-0380, which shows that the

Licensee to demonstrate that reference plant analyses are applicable to month updates and on the [Staff evaluation to be containment failure as a result Hope Creek and that the SAW A/SAWM ePortal. included in SE Section of overpressure can be strategy can prevent containment failure 4.2]

prevented without a drywell due to overpressure without the use of a The wetwell vent was designed vent during severe accident drywell vent. and installed to meet NEI 13-02 conditions. Revision 1 guidance and is sized TEVL 80115232-0380 and references to prevent containment (except for NEI 13-02 Rev 1) are in the overpressure under severe subfolder "ISE Item Closure/Phase accident conditions (see Phase 1 2/Ph2_1SE-5+6_Ref Plant_SAWA- ISE Open Item 2). Hope Creek SAWM." will follow the guidance (flow rate and timing) for SAW A/SAWM described in BWROG-TP-15-008, "Severe Accident Water Addition Timing", and BWROG-TP-15-011 "Severe Accident Water Management". The wetwell be opened prior to exceeding the PCPL value of 65 psig.

BWROG-TP-15-008 demonstrates adding water to the reactor vessel within 8-hours of the onset of the event will limit the peak containment drywell temperature significantly reducing the possibility of containment failure due to temperature.

Drywell pressure can be controlled by venting the suppression chamber through the suppression pool.

BWROG-TP-011 demonstrates that starting water addition at a high rate of flow and throttling after approximately 4-hours will not increase the suppression pool level to that which could block the suppression chamber HCVS.

No follow-up questions.

Phase 2 ISE 01 6 Same response as for Phase 2 ISE #5. The NRC staff reviewed the Closed information provided in the 6-Licensee shall demonstrate month updates and on the [Staff evaluation to be how the plant is bounded by ePortal. included in SE Section the reference plant analysis 4.2.1.1]

that shows the SAWM strategy The reference plant has a Torus is successful in making it freeboard of 525,000 gallons.

unlikely that a drywell vent is Hope Creek has a Torus needed. freeboard of 655,000 gallons.

Both the reference plant and Hope Creek assume SAWA flow of 500 gallons per minute (gpm) starting at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The reference plant reduces SAWA flow to 100 gpm at 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Hope Creek reduces SAWA flow to 100 gpm at 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months . BWROG TP-15-011, evaluation demonstrates that the Mark I (and Mark II) fleet is bounded by the reference plant analyses. This study addressed how suppression pool level control could be achieved in a manner that maintains long-term function of the wetwell vent, and determined if there would be adverse effects by controlling (limiting) flow rate. The study concludes that plants with Mark I containments, with injection into the RPV, can maintain containment cooling and preserve the wetwell vent without a plant specific analysis. The evaluation bounds the parameters at Hope Creek. Hope Creek plans to flow this strategy and is bounded bv

the conclusions of the BWROG evaluation.

No follow-up questions.

Phase 2 ISE 01 7 Complete. The SAWA design includes The NRC staff reviewed the Closed mechanical flow indicator (H1 BC-1 BCFI- information provided in the 6-Licensee to demonstrate that 0100) in the Control/Diesel area of the month updates and on the [Staff evaluation to be there is adequate Auxiliary Building at 102 ft. elevation, near ePortal. included in SE Section communication between the the manual flow control valve BC-V643, 4.1]

MCR and the operator at the which is used to control SAWA flowrate. The communication methods are FLEX pump during severe Communication between the operator the same as accepted in Order accident conditions. locally controlling SAWA flow and the EA-12-049.

MCR is via UHF radio or Plant Page, and is similar to communications capability No follow-up questions.

available during FLEX strategy implementation.

Details including FLEX communications enhancements are contained in SAP Order Operation 80115232-0340, which is in the subfolder "ISE Item Closure/Phase 2/Ph2_1SE-7_Communications." The subfolder also includes calculation 07.5 Revision 24, which is mentioned in the response as establishing Room 3197 as a mild environment (pp. 69, 106, and 145/190 for normal, abnormal, and design basis event conditions, respectively).

SAWA Design Change Package DCP 80118721 is under revision but the descriptions used in this response should not be affected.

ML18120A165 OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA NRR/DLP/PBEB/BC (A) NRR/DLP/PBEB/PM NAME RAuluck Slent TBrown RAuluck DATE 5/3/18 4/30/18 5/4/18 5/4/18 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 4, 2018 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC - N09 Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038