ML18166A254
| ML18166A254 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/21/2018 |
| From: | Rajender Auluck Beyond-Design-Basis Engineering Branch |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Lee B, NRR/DLP, 415-2916 | |
| References | |
| CAC MF4464, EA-13-109, EPID L-2014-JLD-0049 | |
| Download: ML18166A254 (22) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 21, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - 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. MF4464; EPID L-2014-JLD-0049)
Dear Mr. Hanson:
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 30, 2014 (ADAMS Accession No. ML141816117), Exelon Generation Company, LLC (the licensee) submitted its Phase 1 OIP for James A. FitzPatrick Nuclear Power Plant (JAF, FitzPatrick). By letters dated December 19, 2014, June 30, 2015, December 29, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 22, 2016, June 29, 2017, and December 15, 2017 (ADAMS Accession Nos. ML14353A359, ML15181A261, ML15363A412, ML16182A377, ML16357A787, ML17180A951, and ML17349A029, 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
( IS Es) for Phase 1 and Phase 2 of Order EA-13-109 for FitzPatrick by letters dated February 12, 2015 (ADAMS Accession No. ML15007A090), and December 16, 2016 (ADAMS Accession No. ML163436030), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.
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 being performed for compliance with the order. As part of the audit process, the staff reviewed the licensee's closeout of the ISE open
B. Hanson items. The NRC staff conducted a teleconference with the licensee on June 7, 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. 50-333
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 EXELON GENERATION COMPANY, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 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 Conditions," 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 30, 2014 (ADAMS Accession No. ML14181B117), Exelon Generation Company, LLC ( the licensee) submitted its Phase 1 OIP for James A. FitzPatrick Nuclear Power Plant (JAF, FitzPatrick). By letters dated December 19, 2014, June 30, 2015, December 29, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 22, 2016, June 29, 2017, and December 15, 2017 (ADAMS Accession Nos. ML14353A359, ML15181A261, ML15363A412, ML16182A377, ML16357A787, ML17180A951, and ML17349A029, 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 FitzPatrick by letters dated February 12, 2015 (ADAMS Accession No. ML15007A090), and December 16, 2016 (ADAMS Accession No. ML163436030), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.
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 a teleconference with the licensee on June 7, 2018. The purpose of this audit teleconference was 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 IS Es. As part of the preparation for the audit call, 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, other 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 FitzPatrick. The open items are taken from the Phase 1 and Phase 2 ISEs issued on February 12, 2015, and December 16, 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 FitzPatrick, 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 Organization T earn Lead/Sr. Project Manaqer Rajender 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 Kerby Scales NRR/DLP Technical Suooort - Balance of Plant Garry Armstronq NRR/DLP Technical Suooort- l&C Steve Wyman NRR/DLP Technical Support- Dose John Parillo NRR/DRA Attachment 1
Table 2-Audit Documents Reviewed Calculation JAF-CALC-14-00015, "Hardened Containment Vent Capacity," Revision 0 Engineering Change (EC) 52721, "Phase 1 Hardened Containment Vent System (Parent EC),"
Revision 0 JAF-CALC-14-00017, "Hardened Containment Vent System: Process Piping Support Analysis,"
Revision 0 JAF-CALC-15-00008, "Hardened Containment Vent System: New Pipe Supports," Revision 0 JAF-CALC-15-00033, "Standby Gas Treatment Supports," Revision 0 JAF-CALC-14-00016, ""Hardened Containment Vent System: Process Piping Stress Analysis,"
Revision 0 Calculation JAF-CALC-15-00031, "FLEX Strategy - Portable Generator System Sizing,"
Revision O Calculation JAF CALC-15-00013, "Hardened Containment Vent System: N2 Bottle and Venting Capacity," Revision O Calculation JAF CALC-15-00038, "Hardened Containment Vent System: Purge Bottle Sizing and PCV Setpoint," Revision O Calculation JAF CALC 17-00105, "Evaluation of JAF RHRSW Pump Rooms Minimum Temperature during the Extended Loss of AC Power (ELAP)," Revision 0 Engineering Report JAF-RPT-17-00029, "Hardened Containment Vent System Equipment Seismic Evaluations," Revision 0 Calculation JAF-CALC-14-00027, "Temperature Evaluation of Battery Room and DC Equipment Room During Extended Loss of Offsite Power (FLEX)," Revision 0 Calculation 14620.9011-US(N)-004, "Suppression Chamber (20") and Drywell (24") Vent and Purge Butterfly Valves Evaluation Based on RELAP5/MOD2 56 PSIG and 62 PSIG Results,"
Revision 0 Calculation JAF-CALC-15-00025, "Reactor Building Heat UP During Extended Loss of AC Power (ELAP)," Revsion O Calculation JAF-CALC-14-00029, "Hardened Containment Vent System: Dose Assessment,"
Revision 0 EC 620605 Attachment 6.003 - HCVS Phase 2 Torus Evaluation BWROG-TP-008, "Severe Accident Water Addition Timing" BWROG-TP-011, "Severe Accident Water Management Supporting Evaluations" Attachment 2
James A. FitzPatrick Nuclear Power Plant Vent Order Interim Staff Evaluation Open Items:
Table 3 - ISE Open Item Status Table ISE Open Item Number Licensee Response - Information NRC 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 JAF is capable of (a) venting the The NRC staff reviewed the Closed equivalent of ( 1) percent of licensed/rated information provided in the 6-Make available for NRC staff thermal power and (b) the Torus is month updates and on the [Staff evaluation to be audit analyses demonstrating capable of absorbing the decay heat for ePortal. included in SE Section that HCVS has the capacity to the first three hours to maintain the 3.1.2.1]
vent the steam/energy integrity of primary containment. Calculation JAF-CALC-14~00015, equivalent of one (1) percent "Hardened Containment Vent of licensed/rated thermal Auditable analyses to justify the capability Capacity," Revision O used a power (unless a lower value is of the Torus, as described in this action, rated thermal power of 2,536 MWt justified), and that the have been issued as calculation JAF- [megawatt thermal]. The flow rate suppression pool and the CALC-14-00015 (part of the approved equivalent of 1% reactor power HCVS together are able to design change package EC 52721) and thermal energy is 95,369 lbm/hr absorb and reject decay heat, calculation JAF-CALC-15-00026 (part of at 51.1 per square inch gauge such that following a reactor the approved design change package EC (psig). The primary containtment shutdown from full power 58158). For additional discussion, see pressure limit (PCPL) is 62 psig containment pressure is EC 52721 Topic Notes Section 3.1.7 which translates to a torus restored and then maintained entitled "Hydraulic Requirements". pressure of 51.1 psig with the below the primary containment torus water level at anticipated design pressure and the References have been provided on the maximum water level and primary containment. ePortal. downcomer submergence. The venting capacity based on a torus pressure of 51.1 psig is 95,472 lbm/hr steam.
No follow-up questions.
Phase 1 ISE 01 2 The Hardened Containment Vent System The NRC staff reviewed the Closed (HCVS) piping from the Torus to the information provided in the 6-Make available for NRC staff discharge above the Reactor Building month updates and on the [Staff evaluation to be audit the seismic and tornado (RB) Roof is designed to be seismically ePortal. included in SE Section ruqqed as supported by calculations JAF- 3.2.21 Attachment 3
missile final design criteria for CALC-14-00017, JAF-CALC-15-00008, Calculations JAF-CALC the HCVS stack. JAF-CALC-15-00033, and JAF-CALC 00017, JAF-CALC-15-00008, 00016 (part of the approved design JAF-CALC-15-00033, and JAF-change package EC 52721 ). CALC-14-00016 evaluates adequate seismic and wind Protection from tornado missiles is loading design on the HCVS.
acceptable in accordance with evaluations based on the HCVS-WP-04 The HCVS is routed inside the guidance. See EC 52721 Topic Notes reactor building (RB). It exits the Section 3.1. 3 entitled "Structural tornado protected portion of the Requirements". Specifically, see the RB at the refueling floor (elevation associated subsection entitled "Tornado 369'-6"). The RB above the Missiles". refueling floor has metal siding which does not provide tornado References have been provided on the protection. The refueling floor is ePortal. roughly 100 feet above grade.
The HCVS is protected from large tumbling missiles.
Engineering Change (EC) 52721 addresses how the assumptions in NRG-endorsed HCVS-WP-04 apply to JAF.
No follow-up questions.
Phase 1 ISE 01 3 The HCVS Battery System will support a The NRC staff reviewed the Closed minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation. Refer information provided in the 6-Make available for NRC staff to EC 52721 Topic Notes, Section 3.1.4 month updates and on the [Staff evaluation to be audit the final sizing evaluation entitled "Electrical Requirements." ePortal. included in SE Section for HCVS batteries/battery Specifically, refer to the subsections 3.1.2.6]
charger including incorporation entitled "Battery Selection and Sizing," The licensee stated that all into FLEX DG loading "Battery Charger Selection and Sizing," electrical power required for calculation. and the associated Engineering Change operation of HCVS components is (EC) attachment, P2e Sequence No. provided by the 24 voe [volt 6.003. direct current] battery/battery charger.
The HCVS battery load has been incorporated into the FLEX Diesel The battery sizing requirements Generator (DG) via approved EC 52736 (in EC 52721) confirmed that the HCVS batteries have a minimum
(FLEX Strategy) and associated capacity capable of providing calculation JAF-CALC-15-00031. power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without recharging, and therefore is References have been provided on the adequate.
ePortal.
The licensee provided EC 52736 and JAF-CALC-15-00031, which discusses re-powering of the HCVS battery charger using a FLEX DG.
No follow-up questions.
Phase 1 ISE 01 4 The HCVS pneumatic system design The NRC staff reviewed the Closed sizing will be capable of 12 cycles in the information provided in the 6-Make available for NRC staff first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The sizing of the nitrogen month updates and on the [Staff evaluation to be audit documentation of the motive force and purge systems is ePortal. included in SE Section HCVS nitrogen pneumatic provided in calculations JAF CALC 3.1.2.6]
system design including sizing 00013 and JAF-CALC-15-00038, Calculations JAF-CALC and location. respectively (part of the approved design 00013, "Hardened Containment change package EC 52721 ). For Vent System: N2 Bottle and additional discussion, see EC 52721 Venting Capacity," Revision O and Topic Notes Section 3.1 .6.3 entitled JAF-CALC-15-00038, "Hardened "Cross Flow & Hydrogen Detonation". Containment Vent System: Purge Specifically, see the associated Bottle Sizing and PCV Setpoint,"
subsection entitled "HCVS Pipeline Revision 0, evaluates nitrogen Protection". requirements for 12 purging cycles. The licensee provided the References have been provided on the assumptions and formulas to ePortal. identify the pressure and purge time for the nitrogen bottles to be used throughout the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensee concluded that 5 nitrogen bottles rated at 2640 psig each is needed to complete 12 purging cycles. The minimum bottle pressure needed to change out the nitrogen bottles was determined by the licensee to be at 2230 psig.
No follow-up questions.
Phase 1 ISE 01 5 The JAF strategy for preventing hydrogen The NRC staff reviewed the Closed detonation and deflagration beyond the information provided in the 6-Provide a description of the final isolation point (valve) is a nitrogen month updates and on the [Staff evaluation to be final design of the HCVS to purge system. Concurrent with closing ePortal. included in SE Section address hydrogen detonation the isolation valve, the purge system will 3.1.2.11]
and deflagration. be initiated to purge the vented fluid from EC 52721 describes that the the HCVS pipeline. For additional HCVS design will include a discussion, see EC 52721 Topic Notes nitrogen purge system to support Section 3.1 .6.3 entitled "Cross Flow & the HCVS in preventing hydrogen Hydrogen Detonation". Specifically, see detonation. The licensee the associated subsection entitled "HCVS provided the areas where Pipeline Protection". hydrogen migration is possible, and how the purge system will be References have been provided on the used in those areas.
ePortal.
The licensee's design is consistent with Option 3 of the NRG-endorsed white paper HCVS-WP-03.
No follow-up questions.
Phase 1 ISE 01 6 At JAF, the interfaces between the RB The NRC staff reviewed the Closed and the HCVS pipeline are limited to information provided in the 6-Provide a description of the normally closed, small bore drain and month updates and on the [Staff evaluation to be strategies for hydrogen control instrument valves minimizing the ePortal. included in SE Section that minimizes the potential for hydrogen gas migration and ingress into 3.1.2.12]
hydrogen gas migration and the Reactor Building. In addition, The HCVS wetwell pipe provides ingress into the reactor migration to the Standby Gas Treatment minimal interface with the RB, building or other buildings. System (SGTS} is minimized through the which is limited to normally use of existing Class VI Motor Operated closed, small bore drain and Valves (MOVs) that have been leak instrument valves. In addition, tested in accordance with NEI 13-02. For migration to the SGTS is additional discussion, see EC 52721 minimized through the use of Topic Notes Section 3.1.6.3 entitled existing Class VI MOVs that have "Cross Flow & Hydrogen Detonation". been leak tested in accordance Specifically, see the associated with NEI 13-02. The staff's subsection entitled "Interconnecting review of the proposed system Systems". indicates that the licensee's design aooears to minimize the
References have been provided on the potential for hydrogen gas ePortal. migration and ingress into the reactor building or other buildings.
No follow-up questions.
Phase 1 ISE 01 7 The required instrumentation and controls The NRC staff reviewed the Closed (existing and new) are identified as part of information provided in the 6-Make available for NRC staff the JAF OIP, Part 2. The qualification of month updates and on the [Staff evaluation to be audit descriptions of all the equipment has been described within ePortal. included in SE Section instrumentation and controls the approved design change package EC 3.1.2.8]
(existing and planned) 52721; however, additional The existing plant instuments necessary to implement this documentation must be supplied by required for HCVS (i.e. wetwell order including qualification vendors before this item is completed. level instruments and drywell methods. pressure instruments) meet the Upon completion, the evaluations will be requirements of RG 1.97.
posted to ePortal.
EC 52721 discusses the qualifications for new HCVS l&C components. The NRC staff's review indicated that the qualification met the order requirements.
No follow-up questions.
Phase 1 ISE 01 8 The qualification of the equipment has The NRC staff reviewed the Closed been described within the approved information provided in the 6-Make available for NRC staff design change package EC 52721; month updates and on the [Staff evaluation to be audit documentation of a however, additional documentation must ePortal. included in SE Section seismic qualification evaluation be supplied by vendors before this item is 3.2.2]
of HCVS components. completed. EC 52721 and Engineering Report JAF-RPT-17-00029, Upon completion, the evaluations will be "Hardened Containment Vent posted to ePortal. System Equipment Seismic Evaluations," demonstrate the seismic adequacy of the HCVS components. Evaluations support the qualifications of HCVS components to withstand a seismic event.
No follow-up questions.
Phase 1 ISE 01 9 The approved design change package EC The NRC staff reviewed the Closed 52721 describes the conditions and information provided in the 6-Make available for NRC staff capability of the equipment to function month updates and on the [Staff evaluation to be audit the descriptions of local within the stated conditions. The ePortal. included in SE Section conditions (temperature, qualification of the equipment has been 3.1.1.4]
radiation and humidity) described within the approved design EC 52721 and Calculation JAF-anticipated during ELAP and change package EC 52721; however, CALC-14-00029, "Hardened severe accident for the additional documentation must be Containment Vent System: Dose components (valves, supplied by vendors before this item is Assessment," Revision O instrumentation, sensors, completed. discusses the environmental transmitters, indicators, conditions during an accident at electronics, control devices, Upon completion, the evaluations will be the locations containing l&C and etc.) required for HCVS posted to ePortal. components. The staff's review venting including confirmation indicated that the environmental that the components are qualification met the order capable of performing their requirements.
functions during ELAP and severe accident conditions. No follow-up questions.
Phase 1 ISE 01 10 At JAF, the existing Primary Containment The NRC staff reviewed the Closed Isolation Valves (PCIVs) (27AOV-117 and information provided in the 6-Make available for NRC staff - 118) that will be part of the EA-13-109 month updates and on the [Staff evaluation to be audit an evaluation verifying HCVS flow path are currently a part of the ePortal. included in SE Section the existing containment Generic Letter (GL) 89-16 containment 3.2.1]
isolation valves, relied upon for hardened pipe flow path. Calculation Calculation 14620.9011-US(N)-
the HCVS, will open under the 14620.9011-US(N)-004 "Suppression 004 determined that the existing maximum expected differential Chamber (20") & Drywall (24") Vent & PCIVs can be used as part of the pressure during BDBEE and Purge Butterfly Valves based on RELAP Vent order event. The licensee severe accident wetwell 5/MOD2 56 psig and 62 psig Results" did not have to provide any venting. concludes the valves can be opened modifications or operational against the maximum expected changes to the functionality of differential pressure during an Order EA- these PCIVs.13-109 event, the primary containment pressure limit of 62 psig. No follow-up questions.
References have been provided on the ePortal.
Phase 1 ISE 01 11 JAF utilizes the site Ultra-High Frequency The NRC staff reviewed the Closed (UHF) security radio system (Ref. EC information provided in the 6-53903) to communicate between the
Make available for NRC staff MCR and the operator at the HCVS month updates and on the [Staff evaluation to be audit documentation that control location. This communication ePortal. included in SE Section demonstrates adequate method is the same as accepted in Order 3.1.1.1]
communication between the EA-12-049. These items will be powered The communication methods are remote HCVS operation and remain powered using the same the same as accepted in Order locations and HCVS decision methods as evaluated under EA-12-049 EA-12-049.
makers during ELAP and for the period of sustained operation.
severe accident conditions. No follow-up questions.
References have been provided on the ePortal.
Phase 1 ISE 01 12 The approved design change package EC The NRC staff reviewed the Closed 52721, along with supporting calculations, information provided in the 6-Make available for NRC staff has identified the anticipated conditions month updates and on the [Staff evaluation to be audit an evaluation of during ELAP and a Severe Accident and ePortal. included in SE Sections temperature and radiological confirm the capability for operating 3.1.1.2 and 3.1.1.3]
conditions to ensure that personnel to safely access and operate The main control room (MCR) operating personnel can safely controls and support equipment. For temperatures have been access and operate controls additional discussion, see EC 52721 addressed as part of the FLEX and support equipment Topic Notes Section 3.1.11.3 entitled order and were found to be "HCVS Manual Actions". acceptable by the NRC staff.
References have been provided on the EC 52721 discusses the ePortal. environmental conditions for the remote operating station (ROS) as it relates to personnel habitability and equipment operability.
The ROS is located in an administration control building corridor between the turbine building and reactor building.
Calculation JAF-CALC-15-00025, "Reactor Building Heat UP During Extended Loss of AC Power (ELAP)," indicates that with compensatory actions of opening selected doors, the temperature in the corridor does not exceed 110°F, and with a constant
outdoor temperature of 93°F the calculated corridor temperature is roughly 105°F.
Calculation JAF-CALC-14-00029, "Hardened Containment Vent System: Dose Assessment,"
Revision O was performed to determine the integrated radiation dose due to HCVS operation.
The NRC staff reviewed this calculation and determined that the licensee used conservative assumptions and followed the guidance outlined in NEI 13-02 Revision 1 and HCVS-WP-02 Revision 0. Based on the expected integrated whole body dose equivalent in the MCR 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.
Based on the these evaluations, the 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 2 ISE 01 1 Temperature and Humidity The NRC staff reviewed the Closed information provided in the 6-Licensee to evaluate the The location of SAWA [severe accident month updates and on the [Staff evaluation to be SAWA equipment and water addition] equipment and controls ePortal. included in SE Sections controls, as well as the inqress including ingress and eqress paths that 4.1.1.4 and 4.2.1.4]
and egress paths for the are the same or similar as FLEX and are For temperature review of the expected severe accident bounded by the FLEX evaluations for MCR and ROS, see Phase 1 ISE conditions (temperature, temperature and humidity (see EC Open ltem-12 above. The NRC humidity, radiation) for the 52736). staff reviewed Attachment 10.07 sustained operating period. ("Manual Actions Table") to EC Ingress and Egress 620605 and determined that it is reasonable to assume the Specific SAWA dose values are operator actions required to calculated in calculation JAF-CALC implement the HCVS and 00029 updated as part of EC 620605. SAWNSAWM [severe accident water management] strategies For locations inside the Reactor Building can be accomplished.
between 1 and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> when SAWA is being deployed, JAF has performed a The NRC staff reviewed quantitative evaluation of expected dose calculation JAF-CALC-14-00029, rates per HCVS-FAQ-12 and found the "Hardened Containment Vent dose rates at deployment locations System: Dose Assessment,"
including ingress/egress paths are Revision O and determined that acceptable. the licensee used conservative assumptions and followed the For locations outside the Reactor Building guidance outlined in NEI 13-02 between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA Rev.1 and HCVS-WP-02 Rev.O.
is being utilized, JAF has performed a Based on the expected integrated quantitative evaluation of expected dose whole body dose equivalent in the rates per HCVS-WP-02 and found the MCR and ROS and the expected dose rates at deployment locations integrated whole body dose including ingress/egress paths are equivalent for expected actions acceptable. during the sustained operating period, the NRC staff believes Attachment 10.07 ("Manual Actions that the order requirements are Table") to EC 620605 provides a list of met.
SAWA manual actions along with the expected environmental conditions and Temperature and radiological associated operational limitations. conditions should not inhibit operator actions or SAWA References have been provided on the equipment and controls needed to ePortal. initiate and operate the HCVS during an ELAP with severe accident conditions.
No follow-up questions.
Phase 2 ISE 01 2 Eguigment and Controls The NRC staff reviewed the Closed information provided in the 6-Licensee to demonstrate how Plant instrumentation for SAWA that is month updates and on the [Staff evaluation to be instrumentation and equipment qualified to RG 1.97 or equivalent is ePortal. included in SE Sections being used for SAWA and considered qualified for the sustained 4.4.1.3 and 4.5.1.2]
supporting equipment is operating period without further The drywell pressure and torus capable to perform for the evaluation. The following plant level indications are RG 1. 97 sustained operating period instruments are qualified to RG 1. 97: compliant and are acceptable as under the expected qualified.
temperature and radiological conditions. .. Drywell Pressure: 27Pl-115A2 Torus Water Level: 23Ll-202A Calculation JAF-CALC-14-00029, "Hardened Containment Vent Passive components that do not need to System: Dose Assessment,"
change state after initially establishing Revision O was performed to SAWA flow do not require evaluations. determine the integrated radiation dose due to HCVS operation.
The following additional equipment performing an active SAWA/SAWM No follow-up questions.
function is considered for temperature and radiation effects:
. SAWA/SAWM flow instrument
. SAWA/SAWM pump (FLEX
.pump) SAW A/SAWM generator (FLEX generator)
Active valves in SAWA flow path T emgerature The location of SAWA equipment and controls that are the same or similar as FLEX will be bounded by the FLEX evaluations for temperature and humidity.
A supplementary calculation (JAF-CALC-17-00105) was completed as part of the SAWA Engineering Change (EC 620605) to evaluate the temperature conditions
local to flow meter during extreme cold conditions. See Phase 2 ISE OIP Item 5 for more information.
Radiation Specific SAWA dose values are calculated in calculation JAF-CALC 00029 updated as part of EC 620605.
For additional discussion, see EC 620605 Topic Notes Section 3.1.8 entitled "Instrumentation and Controls Characteristics" and 3.1.9 "Mechanical Requirements". Attachment 10.07
("Manual Actions Table") to EC 620605 provides a list of SAWA expected environmental conditions.
References have been provided on the ePortal.
Phase 2 ISE 01 3 The wetwell vent has been designed and The NRG staff reviewed the Closed will be installed to meet NEI 13-02 Rev 1 information provided in the 6-Licensee to demonstrate that guidance, which will ensure that it is month updates and on the [Staff evaluation to be containment failure as a result adequately sized to prevent containment ePortal. included in SE Sections of overpressure can be overpressure under severe accident 4.1 and 4.2]
prevented without a drywell conditions (Ref. JAF-CALC-14-00015). The initial SAWA flow rate of 361 vent during severe accident was determined by scaling the conditions. The SAWM strategy will ensure that the ratio of JAF licensed thermal wetwell vent remains functional for the power to that of the reference period of sustained operation. JAF will plant and applying that to the 500 follow the guidance (flow rate and timing) gallons per minute (gpm) injection for SAWNSAWM described in BWROG flow rate of the reference plant
[Boiling Water Reactor Owners Group] per the guidance in NEI 13-02.
TP-15-008 and BWROG-TP-15-011.
BWROG-TP-15-008 References have been provided on the demonstrates adding water to the ePortal. reactor vessel within 8-hours of the onset of the event will limit the peak containment drywell
The wetwell vent will be opened prior to temperature significantly reducing exceeding the PCPL value of 62 PSIG. the possibility of containment Therefore, containment over failure due to temperature.
pressurization is prevented without the Drywell pressure can be need for a drywell vent. controlled by venting the suppression chamber through the JAF is bounded by the reference plant suppression pool.
analysis that shows the SAWM strategy is successful in making it unlikely that a BWROG-TP-011 demonstrates drywell vent is needed as demonstrated that starting water addition at a by the following table. The values in this high rate of flow and throttling table are formalized in Attachment 6.004 after approximately 4-hours will to EC 620605. not increase the suppression pool level to that which could block the Reference Plant suppression chamber HCVS.
Torus freeboard volume is 525,000 As noted under Phase 1, the vent gallons is sized to pass a minimum steam flow equivalent to 1% rated core SAWA flow is 500 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power. This is sufficient permit followed by 100 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to venting to maintain containment 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> below the lower of PCPL or of design pressure.
James A FitzPatrick No follow-up questions.
Torus freeboard volume is determined to be 813,012 gallons SAWA flow is 361 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed by 73 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> The above parameters for JAF compared to the reference plant that determine success of the SAWM strategy demonstrate that the reference plant values are bounding. Therefore, the SAWM strategy implemented at JAF makes it unlikely that a DW vent is
needed to prevent containment overpressure related failure.
Phase 2 ISE 01 4 JAF utilizes the site Ultra-High Frequency The NRC staff reviewed the Closed (UHF) security radio system (Ref. EC information provided in the 6-Licensee to demonstrate that 53903) to communicate between the MCA month updates and on the [Staff evaluation to be there is adequate and the operator at the SAWA/SAWM ePortal. included in SE Section communication between the flow control location. This communication 4.1]
MCR and the operator at the method is the same as accepted in Order The communication methods are FLEX pump during severe EA-12-049. These items will be powered the same as accepted in Order accident conditions. and remain powered using the same EA-12-049.
methods as evaluated under EA-12-049 for the period of sustained operation. No follow-up questions.
References have been provided on the ePortal.
Phase 2 ISE 01 5 JAF utilizes a four inch size Seametrics The NRC staff reviewed the Closed AG2000 flowmeter. The flow meter is information provided in the 6-Licensee to demonstrate the deployed in the RHRSW 'B' I'D' room month updates and on the [Staff evaluation to be SAWM flow instrumentation which is part of the plant circulating water ePortal. included in SE Sections qualification for the expected Screen House building. This room is 4. 1.1. 3 and 4. 2. 1. 3]
environmental conditions. located a substantial distance from the The licensee provided Hardened Containment Vent System environmental conditions for (HCVS) vent line and is well shielded from radiation and temperature as well the expected HCVS vent line dose. as the qualified temperature range for the flow instrument in For locations outside the Reactor Building EN-DC-115/EC620605 and JAF between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA CALC 17-00105.
is being utilized, JAF performed a quantitative evaluation of equipment and The NRC staff found the deployment locations and confirmed they instrument appears to be qualified are protected by buildings with substantial for the anticipated conditions shielding to minimize dose rates. Specific during an ELAP for the proposed SAWA dose values are calculated in location.
calculation JAFCALC-14-00029 updated as part of EC 620605. Attachment 10.07 No follow-up questions.
("Manual Actions Table") to EC 620605 provides a list of SAWA expected environmental conditions.
The selected instrument is designed for the expected flow rate, temperature and pressure for SAWA over the period of sustained operation. The instrument qualification for pressure, temperature and flow provided in the table below is from the product technical data.
References have been provided on the ePortal.
SAWA Flow Instrument Qualification 2.21 to 736 GPM
-4 to 140 °F 0 to 285 PSI SAWA Parameter Range 0 to 400 GPM 32 to 120 "F 0 to 120 PSI
ML18166A254 *concurrence via email OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA NRR/DLP/PBEB/BC (A) NRR/DLP/PBEB/PM NAME RAuluck Slent BTitus RAuluck DATE 6/19/18 6/19/18 6/21/18 6/21/18