RS-15-302, Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident..

Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident..

ML15364A075
Person / Time
Site:	Nine Mile Point
Issue date:	12/15/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-15-302, TAC MF4481
Download: ML15364A075 (135)

Text

" Exe LnGeneration Order No. EA-13-109 RS- 15-302 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and DPR-69 NRC Docket Nos. 50-220 and 50-410

Subject:

Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-1 3-1 09)

References:

1. NRC Order Number EA-13-109, "Issuance of Order to Modify 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-2015-01, "Compliance with Phase 2 Order EA-1 3-1 09, Order Modifying Licenses with Regard to Reliable Hardened Containment SVents Capable of Operation under Severe Accident Conditions", Revision 0, dated April 2015

3. NEI 13-02, "Industry Guidance for Compliance With Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions", Revision 1, dated April 2015

4. Exelon Generation Company, LLC's Answer 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-13-1 09), dated June 26, 2013

5. Exelon Generation Company, LLC Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 27, 2014

6. Exelon Generation Company, LLC December 2014 (First) Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09), dated December 16, 2014 (FLL-1 4-035)

7. Exelon Generation Company, LLC Second Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09), dated June 30, 2015 (RS-15-153)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 3-109 December 15, 2015 Page 2

8. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 1

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4481), dated March 26, 2015

9. NRC letter to Exelon Generation Company, LLC, Nine Mile Point Nuclear Station, Unit 2

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4482), dated February 11,2015 On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to require their BWRs with Mark I and Mark II containments to take certain actions to ensure that these facilities have a hardened containment vent system (HCVS) to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident (sA) conditions resulting from an Extended Loss of AC Power (ELAP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan (OIP) by June 30, 2014 for Phase 1 of the Order, and an OIP by December 31, 2015 for Phase 2 of the Order. The interim staff guidance (Reference 2) provides direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 2 endorses industry guidance document NEI 13-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 5 provided the Nine Mile Point Nuclear Station, Units 1 and 2, Phase 10OIP. References 6 and 7 provided the first and second six-month status reports pursuant to Section IV, Condition 0.3 of Reference 1 for Nine Mile Point Station.

The purpose of this letter is to provide both the third six-month update for Phase 1 of the Order pursuant to Section IV, Condition D.3, of Reference 1, and the OIP for Phase 2 of the Order pursuant to Section IV, Condition D.2 of Reference 1, for Nine Mile Point Nuclear Station, Units 1 and 2. The third six-month update for Phase 1 of the Order is incorporated into the HCVS Phase 1 and Phase 2 overall integrated plan document which provides a complete updated Phase I OIP, a list of the Phase 10OIP open items, and addresses the NRC Interim Staff Evaluation open items for Phase 1 contained in References 8 and 9. Future six-month status reports will provide the updates for both Phase 1 and Phase 20OIP implementation in a single status report.

Reference 3, Section 7.0 contains the specific reporting requirements for the Phase 1 and Phase 20OIP. The information provided in Enclosures 1 and 2 provides the Nine Mile Point Nuclear Station, Units 1 and 2 HCVS Phase 1 and Phase 20OIP, respectively, pursuant to Reference 2. The enclosed Phase 1 and Phase 20IlPs are based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosures, will be provided in the six-month Phase 1 and Phase 20OIP updates required by Section IV, Condition D.3, of Reference 1.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 3-1 09 December 15, 2015 Page 3 This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 15 th day of December 2015.

Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosures:

1. Nine Mile Point Nuclear Station, Unit 1, Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions

2. Nine Mile Point Nuclear Station, Unit 2, Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station Mr. Charles H. Norton, NRRIJLD/PPSD/JOMB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC

Enclosure 1 Nine Mile Point Nuclear Station, Unit 1 Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions (64 pages),

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Table of Contents:

Introduction Part 1: General Integrated Plan Elements and Assumptions Part 2: Boundary Conditions for Wet Well Vent Part 3: Boundarly Conditions for EA-13-109, Option B.2 Part 3.1 Boundary Conditions for SAWA Part 3.1A Boundary Conditions for SAWA/SAWM Part 3.1B Boundary Conditions for SAWA/SADV Part 4: Programmatic Controls, Training, Drills and Maintenance Part 5: Implementation Schedule Milestones : HCVS/SAWA Portable Equipment A: Sequence of Events Timeline - HCVS .1.A: Sequence of Events Timeline - SAWA I SAWM .1.B: Sequence of Events Timeline - SADV .1.C: SAWA / SAWM Plant-Specific Datum .1.D: SAWM SAMG Approved Language : Conceptual Sketches : Failure Evaluation Table : References : Changes/Updates to this Overall Integrated Implementation Plan : List of Overall Integrated Plan Open Items Page 1 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Introduction In 1989, the NRC issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," (Reference 2) to all licensees of Boiling Water Reactors (BWRs) with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the suppression pool to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell.

On'March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff per Staff Requirements Memorandum (SRMv) for SECY-12-0157 (Reference 26) to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013 (Reference 4). The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent 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 while maintaining 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 vents to assist in preventing core damage and, if necessary, to provide 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 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 (Reference 6) and JLD-ISG-2015-01 issued in April 2015 (Reference 31). These 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 (Reference 9), with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA-13-109, the NRC staff will use the methods described in these 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. This document provides the Overall Integrated Plan (OTP) 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. Six month progress reports will be provided consistent with the requirements of Order EA- 13-109.

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Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents The submittals required are:

• OIP for Phase 1 of EA-13-109 was required to be submitted by Licensees to the NRC by June 30, 2014. The NRC requires periodic (6-month) updates for the HICVS actions being taken. The first update for Phase 1 was due December 2014, with the second due June 2015.

O IP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31, 2015. It is expected the December 2015 six month update for Phase 1 will be combined with the Phase 2 OIP submittal by means of a dombined Phase 1 and 20OP.

• Thereafter, the 6-month updates will be for both the Phase 1 and Phase 2 actions until complete, consistent with the requirements of Order EA-13-109.

Note: Per the Generic OIP, at the Licensee's option, the December 2015 six month update for Phase 1 may be independent of the Phase 2 OIP submittal, but will require separate six month updates for Phases 1 and 2 until each phase is in compliance. Exelon has not selected this option.

The Nine Mile Point'Unit 1 (NMP1) venting actions for the EA-13-109, Phase 1 severe accident capable ventingscenario can be summarized by the following:

• The Hardened Containment Vent System (HCVS) will be initiated via manual action from either the Main Control Room (MCR) and/or from a Remote Operating Station (ROS) at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms. Specifically, valves located at the ROS are required to be manually opened before operation from the MCR can commence. Also, in case the HCVS flow path valves or the Argon purge flow cannot be opened from the MCR, the ROS provides a back-up means of opening the valve(s) that does not require electrical power or control circuitry.

• The vent will utilize Containment Parameters of Pressure and Suppression Pool Level from the MCR instrumentation to monitor effectiveness of the venting actions.

• The vent operation will be monitored by HCVS valve position, temperature and effluent radiation levels.

• The HCVS motive force will be monitored and have the capacity to operate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with installed equipment. Replenishment of the motive force will be by use of spare N2 bottles prior to the installed motive force being exhausted. Also, connections will be installed if it is desired to connect a portable air compressor.

• Venting actions will be capable of being maintained for a sustained period of up to 7 days.

The Phase 2 actions can be summarized as follows:

• Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV). Although SAWA to the Drywell (DW) is an option, Exelon has selected SAWA injection to the RPV.

• Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for the removal of decay heat from containment.

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Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents

• Ensure that the decay heat can be removed from the containment for seven (7) days using the HCVS or describe the alternate method(s) to remove decay heat from the containment from the time the HCVS is no longer functional until alternate means of decay heat removal are established that make it unlikely the drywell vent will be required for DW pressure control.

• The SAWA and SAWM actions will be manually activated and controlled from areas that are accessible during severe accident conditions.

• Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate and the HCVS parameters listed above.

Note: Although EA-13-109 Phase 2 allows selecting SAWA and a Severe Accident Capable Drywell Vent (SADV) strategy, Exelon has selected SAWA and SAWM.

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Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 1: General Integrated Plan Elements and Assumptions

~Extent to which the guidance, JLD-ISG-2013-02, JLDISG-2015-01, and NET 13-02, are being followed.

Identify any deviations.

Include a description of any alternatives to the guidance. A technicalijustifcationand basisfor the alternative needs to be provided. This will likely require a pre-meeting with the NRC to review the alternative.

Ref: JLD-ISG-2013-02, JLD-ISG-2015-01 Compliance will be attained for NMP1 with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-ISG-2015-01, and NEI 13-02 for each phase as follows:

• The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment and operating guidance:

• Severe Accident Wetwell Vent (SAWV) - Permanently installed vent from the Suppression Pool to the top of the Reactor Building.

• Severe Accident Water Addition (SAWA) - A combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and monitor system and plant conditions.

• Severe Accident Water Management (SAWM) strategies and guidance for controlling the water addition to the RPV for the sustained operating period. (Reference attachment 2.1 .D)

• Unit 1 Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Currently scheduled for 2Q2017.

• Unit 1 Phase 2: (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first. Currently scheduled for 2Q20 19.

If deviations are identified at a later date, then the deviations will be communicated in a future 6-month update following identification.

State Applicable Extreme External Hazard from NET 12-06, Section 4.0-9.0 List resultant determination of screened in hazardsfrom the EA-12-049 Compliance.

Ref: NEL 13-02 Section 5.2.3 and D.1.2 The following extreme external hazards screen in for NMP1:

• Seismic, tornado, external flooding, extreme cold temperature, extreme high temperature, and ice!/snow The following extreme external hazards screen out for NMPI"

• Straight wind Key Site assumptions to implement NET 13-02 strategies.

Provide key assumptions associatedwith implementation of HCVS Phase 1 Strategies.

Ref: NEI 13-02, Revision 1, Section 2 NEL 12-06, Revision 0 Mark I/II Generic HCVS Related Assumptions:

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Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 1: General Integrated Plan Elements and Assumptions Applicable EA- 12-049 (Reference 3) assumptions:

049-1. Assumed initial plant conditions are as identified in NEI 12-06, §3.2.1.2, items 1 and 2 (Reference 8).

049-2. Assumed initial conditions are as identified in NEI 12-06, §3.2.1.3, items 1, 2, 4, 5, 6 and 8 (Reference 8).

049-3. Assumed reactor transient boundary conditions are as identified in NEL 12-06, §3.2.1.4, items 1, 2, 3 and 4 049-4. No additional events or failures are assumed to occur immediately prior to or during the event, including security events, except for the failure of the Emergency Cooling System (ECS) (Reference NEI 12-06,

§3.2.1.3, item 9)(Reference 8).

049-5. At time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP is occurring at any or all of the units.

049-6. At time=l hour (time sensitive at a time greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) an ELAP is declared and actions begin as defined in EA- 12-049 compliance.

049-7. The HCVS system will include a dedicated 125 VDC battery panel sized for 24-hours of HCVS operation.

Beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FLEX power will be provided via the #12 station battery board. (NEI 12-06, section 3.2.1.3 item 8) 049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

049-9. All activities associated with EA-12-049 (FLEX) that are not specific to implementation of the HCVS, including such items as debris removal, communication, notifications, Spent Fuel Pool (SFP) level and makeup, security response, opening doors for cooling, and initiating conditions for the events, can be credited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity on SAWA) (HC VS-FAQ- 11.)

Applicable EA-13-109 (Reference 4) generic assumptions:

109-1. Site response activities associated with EA-13-109 actions are considered to have no access limitations associated with radiological conditions while Reactor Pressure Vessel (RPV) level is above 2/3 core height (core damage is not expected). This is further addressed in HCVS-FAQ-12.

109-2. Additional N2 bottles will be available and meet the criteria applicable to HCVS to provide motive force beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, portable equipment can supplement the installed equipment after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the portable equipment credited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supply equipment that can be connected to recharge air lines for HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The FLEX portable air supply if used must be demonstrated to meet the "SA Capable" criteria that are defined in NEI 13-02 Section 4.2.4.2 and Appendix D Section D.1.3 (Reference 9). This assumption does not apply to Phase 2 SAWAISAWM because SAWA equipment needs to be connected and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time of the loss of RPV injection. (Reference HCVS-FAQ-12).

109-3. SEP Level is maintained with either on-site or off-site resources such that the SEP does not contribute to the analyzed source term (Reference HCVS-FAQ-07 [18]).

109-4. Existing containment components design and testing values are governed by existing plant containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (Reference HCVS-FAQ-O5 [16] and NEI 13-02, §6.2.2 [9]).

109-5. Classical design basis evaluations and assumptions are not required when assessing the operation of the HCVS. The reason that this is not required is that the order postulates an unsuccessful mitigation of an Page 6 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 1: General Integrated Plan Elements and Assumptions event such that an ELAP progresses to a severe accident with ex-vessel core debris that classical design basis evaluations are intended to prevent (Reference NEI 13-02, §2.3.1 [9]).

109-6. HCVS manual actions require minimal operator steps and can be performed in the postulated thermal radiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation, valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality (Reference HCVS-FAQ-01l[12]). This assumption does not apply to Phase 2 SAWAISAWM because SAWA equipment needs to be connected and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time of the loss of RPV injection and will require more than minimal operator action.

109-7. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to function in an ELAP event that progresses to core melt ex-vessel (Reference HCVS-FAQ-02 [13] and White Paper HCVS-WP-01 [21]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment is not dedicated to HCVS but shared to support FLEX functions. This is further addressed in HCVS-FAQ- 11.

109-8. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV water level, temperatures, etc.) assumed for Order EA-13-109 Beyond Design Basis External Event (BDBEE) and SA HCVS operation (Reference FLEX MAAP Endorsement ML13190A201 [29]). Additional analysis using RELAP5/MOD 3, GOTHIC, and MICROSHIELD, etc., are acceptable methods for evaluating environmental conditions in other portions of the plant, provided that the specific version utilized is documented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 to support drywell temperature response to SAWA under severe accident conditions.

109-9. NRC Published Accident evaluations (e.g. SOARCA, SECY-12-0157, NUREG 1465) as related to Order EA-13-109 conditions are acceptable as references (Reference NEI 13-02, §8 [9]).

109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may be credited for use in Order EA-13-109 response.

109-11. This Overall Integrated Plan is based on Emergency Operating Procedure (EOP) changes consistent with Emergency Procedures Guidelines/Severe Accident Guidelines (EPG/SAGs) Revision 3 as incorporated per the site's EOP/Severe Accident Procedure (SAP) procedure change process. This assumption does not apply to Phase 2 SAWM because SAWM is not part of revision 3. (Refer to Attachment 2.1.D for SAWM SAMG changes approved by the BWROG Emergency Procedures Committee.)

109-12. Under the postulated scenarios of Order EA-13-109, thle Main Control Room is adequately protected from excessive radiation dose as per General Design Criterion (GDC) 19 in 10CFR50 Appendix A and no further evaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is a sufficient distance away from the MCR or is shielded to minimize impact to the MCR dose. In addition, adequate protective clothing and respiratory protection are available if required to address contamination issues (Reference HCVS-FAQ-01 [12] and HCVS-FAQ-09).

109-13. The suppression pool/wetwell of a BWR Mark 1/II containment is considered to be bounded by assuming a saturated environment for the duration of the event response because of the water/steam interactions.

109-14. RPV depressurization is directed by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1 §1.1.3) 109-15. The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure the capability to protect containment exists for each unit. (HCVS-FAQ-0 I) This is further addressed in HCVS-Page 7 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 1: General Integrated Plan Elements and Assumptions FAQ-10.

Plant Specific IJCVS Related Assumptions/Characteristics:

NMP 1-1 EA-12-049 (FLEX) actions to restore power are sufficient to ensure continuous operation of non-dedicated containment instrumentation identified in Part 2, Key Venting Parameters of the OIP.

NMP1-2 Modifications that allow a FLEX generator to be connected to a 600 volt safety related bus are assumed to have been installed such that a FLEX generator can be credited for HCVS operation beyond the initial 24-hour sustained operational period.

NMPl-3 The rupture disk will be manually breached from the MCR and/or ROS if required for anticipatory venting during an ELAP.

NMP1-4 The Plant layout of buildings and structures are depicted in Sketch 2C. Note the Main Control Room is located in the turbine building and has substantial structural walls and features independent of the Reactor Building. The HCVS vent routing is all internal to the Reactor Building up to where it penetrates the Reactor Building roof and exhausts to the atmosphere (see Sketch 2A).

NMP1-5 The HCVS internal piping above the metal sided non-missile protected refueling floor and the HCVS external piping is all above 30-feet from ground level, consists solely of large bore (10-inch nominal diameter) piping and its piping supports, and the piping has less than 300 square feet of cross section.

The HCVS external piping meets the reasonable protection requirements of HCVS-WP-04 (Reference 32).

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Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint.

HCVS Actions that have a time constraint to be successful should be identified with a technical basis and a justificationprovided that the time can reasonably be met (for example, action to open vent valves).

HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or High Dose areas) should be evaluatedper guidance.

Describe in detail in this section the technical basisfor the constraints identified on the sequence of events timeline attachment.

See attached sequence of events timeline (Attachment 2A).

Ref: EA-13-109, Section 1.1.1, 1.1.2, 1.1.3 I NET 13-02, Section 4.2.5, 4.2.6. 6.1.1 NMP1 plans to install a WW flow path that has two dedicated primary containment isolation valves and a downstream rupture disc that is routed totally separate from the other unit and with no interconnected systems.

The discharge is routed separately through a pipe that discharges above the unit's Reactor Building roof and is totally separate from NMP2. Each NMP unit will have dedicated motive power (Pressurized N2) for ,HCVS valves, Argon Purge system, and DC power for HCVS components that is not shared with any other function and that does not rely on FLEX for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with the clarification that existing containment instrumentation (pressure and WW level) are not considered HCVS components and power for existing containment instrumentation is through the FLEX Diesel Generator (DG) provided through the actions for EA-12-049. Also, the FLEX DG may be credited for recharging the HCVS battery after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The operation of the HCVS will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by trained plant personnel and will include the capability for remote-manual initiation from the HCVS control station. A list of the remote manual actions performed by plant personnel to open the HCVS vent path can be found in the following table (Table 2-1). A HCVS ELAP Failure Evaluation table, which shows alternate actions that can be performed, is included in Attachment 4.

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Plandiin for ReibeHrenwedl Vents Bontertdar Overall Part 2: Boundary Conditions for Wetwell Vent Table 2-1 TICVS Remote Manual Actions Primary Action Primary Location / Notes Component

1. Enable the N2 motive air MCR & ROS I.Required step to open N2 and Argon manual for the HCVS valves and isolation valves before commencing operation enable the Argon purge from the control room. Alternate control via system. manual valves at the ROS.

2. Isolate leak-off ROS Required step to prevent venting into the Reactor connection upstream of Building through the small leak-off path (3-way the rupture disc. valve).

3. Breach the Rupture Disc MCR or ROS Required for anticipatory venting and potentially by opening the Argon for severe accident containment pressure Purge Line for the .depending on the final selected rupture disc burst specified amount of pressure.

time.

4. Open Wetwell PCIVs. Key locked hand switches in To meet Requirement 1.2.5, PCIV operation at the MCR panel. the ROS can be done with reposition of motive air valves.

5. Al.5UXign generator to.......... At........

ROS........................................... Prior to depletion of the HCVS battery supply, HCVS battery charger. actions will be required to recharge the battery at a time greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

6. Replace N2 motive Replacement Nitrogen bottles Prior to depletion of the pressurized gas sources, power bottles or align will be located at the ROS or actions will be required to connect back-up portable compressor, another hardened location, sources at a time greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Replenish Argon bottles. Replacement Argon bottles will be at ROS or another Argon replenishment only required if severe hardened location such as the acdn odtosaepeet FLEX building. A branch connection will be installed to allow foJr connecting a portable air compressor for HCVS valve motive force. A, Sequence of Events Timeline, was developed to identify required operator response times and potential environmental constraints. This timeline is based upon the following three sequences:

1. Sequence 1 is based upon the action response times developed for FLEX when utilizing anticipatory venting in a BDBEE without core damage.

2. Sequence 2 is based on SECY-12-0157 long-term station blackout (LTSBO) (or ELAP) with a failure of RCIC after a black start where failure occurs because of subjectively assuming over injection. For NMP1, which does not have RCIC, it is assumed that the Emergency Cooling System (ECS) fails to operate at 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> due to a lack of makeup water for cooling. This time could be as soon as 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />,,should FLEX fail to provide makeup water for the ECS condensers.

3. Sequence 3 is based on NUREG-1935 (SOARCA) results for a prolonged SBO (or ELAP) with Page 10 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent loss of RCIC case without black start. For NMPl, it is assumed that the ECs fail to operate.

The following is a discussion of time constraints identified in Attachment 2A for the 3 timeline sequences identified above:

Approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, initiate use of the HCVS per site procedures to maintain containment pressure below the lower of the primary containment pressure limit (PCPL) or containment design pressure.

Initiation of the HCVS can be completed with the actions outlined in Table 2-1. The reliable operation of HCVS will be met because HCVS meets the seismic requirements identified in NEI 13-02 and will be powered by dedicated HCVS batteries with motive force supplied to HCVS valves from installed nitrogen storage bottles. HCVS controls and HCVS instrumentation will be provided from a panel installed in the MCR. Other containment parameter instrumentation associated with operation of the HCVS is available in the MCR. Operation of the system will be available from the MCR and/or a ROS.

Dedicated HCVS batteries will provide power for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, initiation of the HCVS from the MCR and/or the ROS within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is acceptable because of the simplicity and limited number of operator actions. Placing the HCVS in operation to maintain containment parameters within design limits for either BDBEE or SA venting would occur at a time further removed from ELAP declaration as shown in Attachment 2.

• 24 hours, replace/install additional nitrogen bottles or install portable air compressor. The nitrogen station will have an extra connection to allow for connection of a portable air compressor in lieu of replacing N2 bottles. This can be performed at any time prior to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure adequate capacity is maintained so this time constraint is not limiting.

• 24 hours, connect back-up power to HCVS battery charger. The HCVS batteries are calculated to last a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ISE Open Item #7). The HCVS battery charger will be able to be re-powered from the 600 VAC bus that will be re-powered from a portable diesel generator (DG) put in place for FLEX.

The DG will be staged and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Reference 1) and therefore will be available prior to being required. In the event that the DG is not available, a local connection will allow a small portable generator staged outside of the turbine building to be connected to the battery charger to provide power.

• Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the permanently installed Argon bottles at the ROS will be replaced, as required, to maintain sustained operation. Note that Argon purging is required only if the ELAP progresses to severe accident conditions.

[ISE OPEN ITEM-7: Perform final sizing evaluation for HCVS batteries/batter~y charger and incorporate into FLEX DG loading calculation.]

Discussion of radiological, temperature, other environmental constraints identified in Attachment 2A

• Actions to initiate HCVS operation are taken from the MCR and/or from the ROS in the Turbine Building. Both locations have significant shielding and/or physical separation from radiological sources.

Non-radiological habitability for the MCR is being addressed as part of the NMP1 FLEX response. The ROS location in the Turbine Building has no heat sources as the area is opened to the turbine building surrounding areas (i.e., ROS is not enclosed in a separate room).

• Actions to replenish the pneumatic supply will be completed from the Turbine Building. The HCVS pneumatic supply, HCVS batteries and ROS are located on grade elevation 261' in the Turbine Building.

The HCVS piping will exit the Reactor Building on the east side of the Reactor Building approximately 140' from ground elevation. Therefore, the location for pneumatic supply replenishment is shielded from page- 1-1 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent the HCVS piping by the Reactor and Turbine Buildings.

• Actions to install the FLEX Portable DG will occur on the south side of the NMP1 Turbine Building and within the south end of the Turbine Building itself. The locations for installation (and control) of the DG are therefore shielded from HCVS piping by the Reactor Building and the Turbine Building. In the event that this DG cannot be operated, the backup portable generator would be connected to the battery charger in the Turbine Building, similar to replacement of the pneumatic supply.

Provide Details on the Vent characteristics.

Vent Size and Basis (EA-13-109. Section 1.2.1 / NEI 13-02. Section 4.1.1)

What is the plants licensed power? Discuss any plansforpossible increases in licensed power (e.g. MUR, EPU). What is the nominal diameter of the vent pipe in inches? Is the basis determined by venting at containment design pressure, PCPL, or some other criteria (e.g. anticipatoryventing)?

Vent Capacity (EA-13-109. Section 1.2.1/INEI 13-02, Section 4.1.1)

Indicate any exceptions to the 1% decay heat removal criteria, including reasonsfor the exception. Provide the heat capacity of the suppressionpool in terms of time versus pressurizationcapacity, assuming suppression pool is the injection source.

Vent Path and Discharge (EA-13-109. Section 1.1.4, 1.2.2/INEI 13-02, Section 4.1.3. 4.1.5 and Appendix FIG)

Provide a description of Vent path, releasepath, and impact of vent path on other vent element items.

Power and Pneumatic Supply Sources (EA-13-109. Section 1.2.5 & 1.2.6/ NEI 13-02. Section 4.2.3, 2.5.

4.2.2. 4.2.6. 6.1)

Provide a discussion of electricalpower requirements, including a description of dedicated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power supply from permanently installed sources. Include a similar discussion as above for the valve motive force requirements. Indicate the area in the plantfrom where the installed/dedicatedpower and pneumatic supply sources are coming.

Indicate the areas where portable equipment will be staged after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the dose fields in the area, and any shielding that would be necessary in that area.

Location of Control Panels (EA-13-109. Section 1.1.1, 1.1.2. 1.1.3. 1.1.4. 1.2.4. 1.2.5/ NEI113-02. Section 4.1.3, 4.2.2, 4.2.3. 4.2.5. 4.2.6, 6.1.1. and Appendix FIG)

Indicate the location of the panels, and the dose fields in the area during severe accidents and any shielding that would be required in the area. This can be a qualitative assessment based on criteriain NEI 13-02.

Hvdroffen (EA-13-1 09. Section 1.2.10. &l.2.11. and 1.2.12/INEI 13-02, Section 2.3,2.4. 4.1.1, 4.1.6, 4.1.7, 5.1 & AppendixH1)

State which approach or combination of approaches the plant will take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies.

Page 12 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Unintended Cross Flow of'Vented Fluids (EA-13-109, Section 1.2.3, 1.2.12 INEI 13-02, Section 4.1.2, 4.1.4, 4.1.6 and Appendix H)

Provide a description to eliminate/minimize unintended cross flow of ventedfluids with emphasis on interfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakage through interfacing valves or Appendix J type testingfeatures?

Prevention of Inadvertent Actuation (EA-13-1 09, Section 1.2. 7/NEI 13-02, Section 4.2.1)

The HCVS shall include means to prevent inadvertent actuation.

Component Qualifications (EA-13-109. Section 2.1/INEI 13-02, Section 5.1)

State qualification criteria based on use of a combination of safety related and augmented quality dependent on the location,function and interconnected system requirements.

Monitoring'of HCVS (Order Elements 1.1.4, 1.2.8, 1.2 .9/NEI 13-02 4.1.3, 4.2.2, 4.2.4. and Appendix FIG)

Provide a description of instruments used to monitor HCVS operationand effluent. Powerfor an instrument will require the intrinsically safe equipment installed as part of the power sourcing.

Component reliable and rugged performance (EA-13-109. Section 2.2 I NEI 13-02, Section 5.2. 5.3)

HCVS components including instrumentation should be designed, as a minimum, to meet the seismic design requirements of the plant.

Components including instrumentation that are not requiredto be seismicalhly designed by the design basis of the plant should be designedfor reliable and rugged performance that is capable of ensuring HCVS functionalityfollowing a seismic event. (Reference JLD-ISG-2012-O1 and JLD-ISG-2012-O3for seismic details.)

The components including instrumentation external to a seismic category 1 (or equivalent building or enclosure should be designed to meet the external hazards that screen in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-O1 for Order EA-12-049.

Use of instruments and supporting components with known operatingprinciples that are supplied by manu~facturers with commercial quality assuranceprograms, such as 1809001. The procurementspecifications shall include the seismic requirements and/or instrument design requirements, and specify the need for commercial design standardsand testing under seismic loadings consistent with design basis values at the instrument locations.

Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidancefor these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-2004, "IEEE Recommended Practicefor Seismic Qualificationof Class JE Equipmentfor Nuclear Power Generating Stations," or a substantially similarindustrial standardcould be used.

Demonstration that the instrumentationis substantially similar in design to instrumentationthat has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performedfor the plant licensing basis.

Page 13 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Vent Size and Basis The HCVS wetwell path is designed for venting steam/energy at a minimum capacity of 1% of 1850 MW thermal power at pressure of 35 psig (ISE Open Item #2). This pressure is the lower of the drywell design pressure (62 psig), the PCPL (43.4 psig) and the torus design pressure (35 psig). The size of the wetwell vent piping for the majority of HCVS piping is 10 inches in diameter with two short 8-inch diameter sections through existing floor penetrations which provides adequate capacity to meet or exceed the Order criteria.

[ISE OPEN LTEM-2: Perform final vent capacity calculation for the Torus HCVS piping confirming 1%

minimum capacity.]

Vent Capacity The 1% value at NMP1 assumes that the Torus has sufficient capacity to absorb the decay heat generated for a minimum of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> without allowing containment pressure to exceed 43 psig (PCPL) after which point decay heat is less than or equal to 1%. The vent would then be able to prevent containment pressure from increasing above the PCPL. The duration of Torus dec-ay heat absorption capability has been confirmed (Reference 30).

The sizing for 1% assumes nominal suppression pool water level.

Vent Path and Discharge The HCVS vent path at NMP1 utilizes the existing penetration piping for the Containment Vent and Purge System from the Torus up to the first Primary Containment Isolation Valve, VLV-201-16. The torus (wetwell) vent piping tees off from the existing penetration piping described above. The dedicated HCVS piping then continues up through the Reactor Building and exits the Reactor Building roof on the east side to a discharge point approximately 3' above the highest point of the Reactor Building roof or any nearby structure.

The HCVS vent path will include two PCIVs dedicated to the HCVS function with a downstream rupture disc.

After the HCVS flow path is opened, the downstream PCIV will be used to control HCVS flow by closing and reopening. The rupture disc will serve as the secondary containment pressure boundary to prevent PCIV leakage from being released to the outside during a design basis loss of coolant accident (DB LOCA). The Argon purge system can be used to breach the rupture disc if HCVS venting is required prior to the containment pressure exceeding the rupture disc setpoint. The NMP1 vent path is completely separate from the Nine Mile Point Unit 2 (NMP2) vent path.

The current design for the external piping meets the reasonable tornado missile protection criteria of HCVS-WP-04. The HCVS internal piping above the metal sided non-missile protected refueling floor and the external piping consists solely of large bore piping and its supports, is above 30 feet from ground level, and these internal and external pipe sections have less than 300 square feet of cross section.

Power and Pneumatic Supply Sources All electrical power required for operation of HCVS components will be provided by dedicated HCVS batteries with a minimum capacity capable of providing power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without recharging. A preliminary sizing evaluation has been completed. A final confirmatory evaluation will be completed as part of the detailed design process when selection of electrical components is finalized (Ref ISE Open Item #7). A battery charger is provided that requires a 240 VAC supply. This will be provided by a dedicated 600 VAC to 120/240 VAC transformer, which will be powered from a 600 VAC bus that will be re-powered by a diesel generator as part of the FLEX response. In addition, a connection point that utilizes standard electrical connections will be provided for a portable generator for sustained operation of the HCVS.

Page 14 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent For the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the event, the motive supply for the AOVs will be dedicated nitrogen gas bottles that will be permanently installed and available. These bottles will be sized such that they can provide motive force for at least 8 cycles of vent path operation (2 Primary Containment Isolation Valves (PC1Vs)).

Eight cycles is defined as the initial opening of the two PCIVs followed by closing and reopening the downstream PCIV. A preliminary sizing evaluation has been completed. A final evaluation will be completed as part of the detailed design process when selection of the system AOVs is finalized (ISE Open Item #8).

[ISE OPEN ITEM-8: Perform final sizing evaluation for pneumatic Nitrogen (N2) supply.]

Supplemental motive force (e.g., additional nitrogen gas bottles and/or air compressor), portable generators, and enough fuel for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of operation will be stored on site in an area that is reasonably protected from assumed hazards consistent with the requirements of NEI 12-06. Pre-engineered quick disconnects will be provided to connect a portable air compressor as supplemental motive force supply.

1. The HCVS flow path valves are air-operated valves (AOV) that are air-to-open and spring-to-shut.

Opening the valves requires energizing a DC powered solenoid operated valve (SOV) and providing motive air/gas. A backup means of operation is also available that does not require energizing or repositioning the SOy.

2. An assessment of temperature and radiological conditions will be performed to ensure operating personnel can safely access and operate controls at the ROS based on time constraints listed in Attachment 2. (ISE Open Item #6)

[ISE OPEN ITEM-6: Perform confirmatory environmental condition evaluation for the Turbine Building in the vicinity of the ROS and HCVS dedicated pneumatic supply and batteries.]

3. All permanently installed HCVS equipment, including any connections required to supplement the HCVS operation during an ELAP (electric power, N2/air) will be located in areas reasonably protected from the hazards listed in Part 1 of this report.

4. All valves required to open the flow path will be designed for remote manual operation following an ELAP, such that the primary means of valve manipulation does not rely on use of a handwheel, reachrod, or similar means requiring close proximity to the valve (HCVS-FAQ-03, Reference 14). Any supplemental connections will be pre-engineered to minimize man-power resources and address environmental concerns. Required portable equipment will be reasonably protected from screened in hazards in Part 1 of this OIP.

5. Access to the locations described above will not require temPorary ladders or scaffolding.

Location of Control Panels The HCVS design allows for initiation, operation, and monitoring of the HCVS from either the MCR and/or the ROS. The MCR location is protected from adverse natural phenomena and is the normal control point for HCVS operation and Plant Emergency Response actions.

The ROS will be located in the Turbine Building. This location is protected from adverse natural phenomena, is readily accessible, well ventilated and is shielded from the HCVS piping by the Reactor Building. The NMPI1 Turbine Building was designed to seismic loads in accordance with the building code and is considered Page 15 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetweil Vent seismically robust. The ROS area includes the location of the HCVS support equipment - nitrogen pneumatic supply, argon purge supply, and dedicated battery.

Hydrogen As required by EA-13-109, Section 1.2.11, the HCVS design will include an Argon purge system that will be connected just downstream of the second PCIV. It will be designed to prevent hydrogen detonation downstream of the second PCIV. The Argon purge system will have a switch for the control valve in the MCR to allow opening the purge for the designated time, but it will also allow for local operation in the ROS in case of a DC power or control circuit failure. The Argon purge will only be utilized following severe accident conditions when hydrogen is being vented: The installed capacity for the Argon purge system will be sized for 8 purges within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the ELAP. This number of vent cycles is the same value used for sizing the PCJV motive air supply. The number of purge cycles may be reduced based on plant-specific analysis. The design will allow for Argon bottle replacement for continued operation past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The Argon purge system can also be used to breach the rupture disc if venting is required before reaching the rupture disc setpoint. The MCR panel will include an indication of Argon pressure to the HCVS path to verify that the Argon purge system flow is occurring.

Unintended Cross Flow of Vented Fluids The HCVS for NMP 1 is fully independent of NMP2 with separate discharge points. Therefore, the capacity at each unit is independent of the status of the other unit's HCVS.

Refer to the P&TD (Sketch 2A). The NMP1 HCVS flowpath is dedicated to the HCVS function. Although the HCVS flow path primary containment penetration is shared with the Containment Vent and Purge System, the HCVS and the Containment Vent and Purge System flow paths have separate PCIVs. The Containment Vent and Purge System PCJVs are normally closed, except during infrequent vent and purge operations, and fail closed upon loss of electrical power, instrument air and upon a containment isolation signal. The PCIVS are leak tight and tested in accordance with the 10CFR50 Appendix J program. They are safety related and fully qualified in accordance with the Environmental Qualification (EQ) Program for NMP1. Since the HCVS flow path does not share any PCJVS with another flowpath and has no connections downstream of the PCTVs, the HCVS flowpath is considered a dedicated flow path with no interconnected systems.

Prevention of Inadvertent Actuation EOP/EPG operating procedures provide clear guidance that the HCVS is not to be used to defeat containment integrity during any design basis transients and accident. In addition, the HCVS will be designed to provide features to prevent inadvertent actuation due to a design error, equipment malfunction, or operator error. These design features include two normally closed/fail closed, in-series PCIVs that are air-to-open and spring-to-shut.

A DC SOV must be energized to allow the motive air to open the valve. Although the same DC and motive air source will be used for each valve, separate control circuits including key-locked switches will be used for the two redundant valves to address single point vulnerabilities that may cause the flow path to inadvertently open.

Power to the DC SOVs will be maintained de-energized and the key-lock switch will be required to be actuated to power the solenoids. Manual valves on the pneumatic supply from the nitrogen tanks will be locked in their normal position to maintain the valve closed. In addition, the NMP1 design has a rupture disc.

Note that NMP1 does not credit containment accident pressure (CAP) for its DB LOCA. Regardless, preventing inadvertent operation is addressed.

Page 16 of 64

Nine Mile Point Unit. 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Component Qualifications HCVS components that directly interface with the primary containment pressure boundary and the HCVS rupture disc will be classified as safety-related in accordance with the design basis for NMP1. Likewise, any electrical or controls component which interfaces with Class lE power sources will be classified as safety related up to applicable isolation devices (e.g., fuses, breakers), as their failure could adversely impact containment isolation and/or a safety-related power source. All safety-related components will be seismically and environmentally qualified in accordance with the design basis of the plant. Additional functionality evaluations for severe accident/boundary conditions specified in NEI 13-02 will be performed. All remaining HCVS components will be classified as augmented quality.

The HCVS components downstream of the PCIVs, are located in seismically designed and constructed structures, including the ROS, pneumatic supply station, HCVS batteries, and HCVS battery charger.

Qualification includes consideration of environmental conditions specified in NEI 13-02. HCVS components will be evaluated to ensure functionality following a design basis earthquake. Components that interface with the HCVS will be routed in seismically qualified structures or the structure will be analyzed for seismic ruggedness to ensure that any potential failure would not adversely impact the function of the HCVS or other safety related structures or components.

Instrumentation and controls components will also be evaluated for environmental conditions postulated for a severe accident, although these evaluations will not be considered part of the site Environmental Qualification (EQ) program.

HCVS instrumentation performance (e.g., accuracy and precision) need not exceed that of similar plant installed equipment. Additionally, radiation monitoring instrumentation accuracy and range will be sufficient to determine a transition from no core damage to core damage. The HCVS components and components that interface with the HCVS are routed in seismically qualified structures.

The HCVS instruments, including valve position indication, process instrumentation, radiation monitoring, and support system monitoring, will be qualified by using one or more of the three methods described in the ISG, which includes:

1. Purchase of instruments and supporting components with known operating principles from manufacturers with commercial quality assurance programs (e.g., 1S09001) where the procurement specifications include the applicable seismic requirements, design requirements, and applicable testing.

2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-2004.

3. Demonstration that instrumentation is substantially similar to the design of instrumentation previously qualified.

Instrument Qualification Method*

HCVS Process Temperature 1S09001 / IEEE 344-2004 / Demonstration HCVS Process Radiation Monitor 1SO9001 / IEEE 344-2004 / Demonstration HCVS Valve Position Indication I1SO9001 / IEEE 344-2004 / Demonstration Page 17 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent HCVS Pneumatic Supply Pressure 1SO9001 / IEEE 344-2004 / Demonstration HCVS Electrical Power Supply Availability ISO9001 / IEEE 344-2004 / Demonstration HCVS Argon System Purge Pressure 1SO9001 / IEEE 344-2004 / Demonstration

• The specific qualification method used for each required HCVS instrument will be reported in future 6-month status reports.

[ISE OPEN ITEM-11: Complete evaluation for environmental/seismic qualification of HCVS components.I Monitoring of HCVS The NMP1 wetwell HCVS will be capable of being remote-manually operated during sustained operations from a control panel located in the main control room (MCR) after manual operation of a 3-way valve and N2 and Argon isolation valves at the ROS is complete and will meet the requirements of Order element 1.2.4. The MCR is a readily accessible location with no further evaluation required (Generic Assumption 109-12).

Additionally, to meet the intent for a secondary control location of section 1.2.5 of the Order, a readily accessible Remote Operating Station (ROS) will also be incorporated into the HCVS design as described in NEI 13-02 section 4.2.2.1.2.1. The controls and indications at the ROS location will be accessible and functional under a range of plant conditions, including severe accident conditions with due consideration to source term and dose impact on operator exposure, extended loss of AC power (ELAP), and inadequate containment cooling. An evaluation will be performed to determine accessibility to the location, habitability, staffing sufficiency, and communication capability with Vent-use decision makers.

The wetwell HCVS will include means to monitor the status of the vent system in the MCR and to monitor DC power, Argon pressure, and N2 pressure at the ROS. The proposed design for the HCVS includes control switches in the MCR with valve position indication. The HCVS controls will meet the environmental and seismic requirements of the Order for the plant severe accident with an ELAP. The ability to open/close these valves multiple times during the event's first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be provided by dedicated motive air and DC power.

Beyond the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the ability to maintain these valves open or closed will be maintained by sustaining the motive air and DC power.

The wetwell HCVS will include indications for effluent temperature, valve position, and effluent radiation levels at the MCR. Other important information on the status of supporting systems (i.e., DC power source status, Argon pressure, and pneumatic supply pressure) will also be included in the design and located to support HCVS operation.

Other instrumentation that supports HCVS function will be provided in the MCR. This includes existing containment pressure and wetwell level indication. This instrumentation is not required to validate HCVS function and is therefore not powered from the dedicated HCVS batteries. However, these instruments are expected to be available since the FLEX DG supplies the station battery charger for these instruments and will be installed prior to depletion of the station batteries.

Component reliable and rugged performance The HCVS vent path components that directly interface with the containment pressure boundary and the HCVS rupture disc and downstream piping will be classified as safety-related in accordance with the design basis for the plant. In addition, any electrical or controls component which interfaces with Class 1E power sources will Page 18of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent be classified as safety related, as their failure could adversely impact containment isolation and/or a safety related power source. All safety-related components will be seismically qualified in accordance with the NMP1 design basis. All other HCVS components, including piping and supports, electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) will be designed for reliable and rugged operational performance that is capable of ensuring HCVS functionality following a design basis earthquake as required per Section 2.2 of EA- 13-109.

For the HCVS instruments that are required after a potential seismic event, the following methods will be used to verify that the design and installation is reliable / rugged and therefore capable of ensuring HCVS functionality following a seismic event. Applicable instruments are rated by the manufacturer (or otherwise tested) for seismic impact at levels commensurate with those of postulated severe accident event conditions in the area of instrument component use using one or more of the following methods:

• demonstration of seismic motion consistent with that of existing design basis loads at the installed location.

• substantial history of operational reliability in environments with significant vibration with a design envelope inclusive of the effects of seismic motion imparted to the instruments proposed at the location.

• adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class lE Equipment for Nuclear Power Generating Stations (Reference 28), or a substantially similar industrial standard.

• demonstration that proposed devices are substantially similar in design to models that have been previously tested for seismic effects in excess of the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges)

• seismic qualification using seismic motion consistent with that of existing design basis loading at the installation location.

HCVS components are located in the Reactor Building and Turbine Building. The Reactor Building and Control Building are safety-related, seismic class I structures. The Turbine Building is seismically designed in accordance with the plant design basis and will be evaluated for the external hazards that screen in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-01 for Order EA-12-049.

The instrumentation/power supplies/cables/connections (components) will be qualified for temperature, pressure, radiation level, and total integrated radiation dose up to 7 days for the Effluent Vent Pipe and HCVS ROS location. The qualification for the equipment by the supplier will be validated by NMP for the specific location at NMP1 to ensure that the bounding conditions envelope the specific plant conditions.

Conduit design will be in accordance with Seismic Class 1 criteria.

The HCVS components mounted external to seismic 1, concrete structures meet the reasonable protection criteria of HCVS-WP-04. Specifically, large bore piping and its supports, located above 30 feet from grade level and not protected from missiles have less than 300 square feet of piping cross section.

Augmented quality requirements will be applied to the components installed in response to this Order unless higher quality requirements apply.

Page 19 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting Determine venting capability for BDBEE Venting, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109, Section 1.1.4 /NEI 13-02, Section 2.2 First 24 Hour Coping Detail Provide a general description of the venting actionsfor first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.6 I NEI 13-02, Section 2.5, 4.2.2 The operation of the HCVS will be designed to minimize reliance on operator actions for response to an ELAP and severe accident events. Immediate operator actions will be completed by qualified plant personnel from either the MCR or the HCVS ROS using remote-manual actions. The operator actions required to open a vent path are as described in Table 2-1. Remote-manual is defined in this report as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting.

The HCVS will be designed to allow initiation, control, and monitoring of venting from the MCR and/or will be able to be operated from an installed ROS as part of the response to this Order. Both locations minimize plant operators' exposure to adverse temperature and radiological conditions and are protected from hazards assumed in Part 1 of this report.

Permanently installed electrical power and motive air/gas capability will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Power will be provided by installed batteries for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before generators will be required to be functional.

System control:

i. Active: The PCIVs are operated in accordance with EOPs/SOPs to control containment pressure.

The HCVS will be designed for 8 vent cycles under ELAP conditions over the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following an ELAP. Controlled venting will be permitted in the revised EPGs and associated implementing EOPs.

ii. Passive: Inadvertent actuation protection is provided by use of key-locked switches for both the HCVS power supply actuation and valve operation. The normal state of the system is de-energized and isolated. In addition, a rupture disc is located downstream of the PCTVs to prevent secondary containment bypass leakage.

Greater Than 24 Hour Coping Detail Provide a general description of the venting actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.4 / NEI 13-02, Section 4.2.2 Actions required to extend venting beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> include replenishment of pneumatic supplies, replenishment of electrical supply, and if severe accident conditions are reached, replenishment of the Argon purge gas.

Page 20 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting The pneumatic supply station will be installed in the Turbine Building ROS area and will include a nitrogen bottle station and a connection for a portable air compressor. The connection will utilize pre-engineered quick disconnect fitting. The location of the pneumatic supply station will be evaluated for reasonable protection per Part 1 of this OIP and modified as required for compliance. Actions to replenish the pneumatic supplies include replacement of nitrogen bottles or installation and refueling of a portable air compressor. Sufficient nitrogen bottles will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The Argon supply station will be installed in the Turbine Building ROS area and will include an Argon bottle station with additional connections for extra Argon bottles. Connections will utilize pre-engineered quick disconnect fittings. The location of the Argon supply station will be evaluated for reasonable protection per Part 1 of this GIP and modified as required for compliance. Actions to replenish the Argon supplies include replacement of Argon bottles. Sufficient Argon bottles will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The HCVS batteries and battery charger will also be installed in the Turbine Building ROS area. This will include battery capacity sufficient for 24-hour operation. The normal power supply to the HCVS controls and instruments will be provided by the #12 Station Battery Bus, which in turn is re-powered by a 600 VAC diesel generator connected to the #12 Station Battery Charger as part of the FLEX response. A design change to install portable generator connections to this bus has been completed in support of EA-12-049 (Reference 1). In the event that power is not restored to the bus, a local 240 VAC connection to the UPS will allow the UPS to receive power from a small portable generator. Actions to replenish the electrical supply include refueling the DG or connecting and refueling a small portable generator.

These actions provide long term support for HCVS operation for the period beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days (sustained operation time period) because on-site and off-site personnel and resources will have access to the unit to provide needed action and supplies.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Primary Containment Control Flowcharts exist to direct operations in protection and control of containment integrity. These flowcharts have been revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAP implementation. HCVS-specific procedure guidance will be developed and implemented to support HCVS implementation.

Identify modifications:

List modifications and describe how they support the HCVS Actions.

EA- 12-049 Modifications

• A modification to install a connection point to allowv a FLEX portable diesel generator to be connected to electrical DC power bus #12 has been installed. This will allow the DG to power the HCVS equipment and battery charger....

Page -of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting EA- 13-109 Modifications:

• A modification will be required to install the HCVS pneumatic supply station.

• A modification will be required to install the dedicated HCVS batteries and battery charger.

• A modification will be required to install required HCVS instrumentation and controls, including a radiation monitor. This also includes installation of control panels in the MCR and the ROS.

• A modification will be required to install dedicated HCVS piping and PCIVs and rupture disc.

• A modification will be required to install the dedicated Argon purge system needed to prevent hydrogen detonation in the piping.

Key Venting Parameters:

List instrumentation creditedfor this venting actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order).

Initiation, operation and monitoring of the HCVS venting will rely on the following key parameters and indicators. Indication for these parameters will be installed at the locations indicated below to comply with EA-13-109.

Key Parameter Component Identifier Indication Location HCVS Effluent temperature TBD MCR HCVS Effluent radiation TBD MCR HCVS Valve position indication TBD MCR HCVS DC Power Voltage/Conditions TBD ROS HCVS Pneumatic supply pressure TBD ROS HCVS Purge System pressure TBD MCR/ROS Initiation and cycling of the HCVS will be controlled based on several existing MCR key parameters and indicators which are qualified to the existing plant design basis. (Reference NEI 13-02 Section 4.2.2.1.9 [9])

Key Parameter Component Identifier Indication Location Drywell pressure MCR P1 201.2-106A P1 201.2-483A Torus pressure P1 201.2-595A MCR Torus level LI 201.2-595D MCR LI_58-05A __________

Notes: None Part 2: Boundary Conditions for WW Vent - Severe Accident Venting Page 22 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may he used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109, Section 1.2.10 /NEI 13-02, Section 2.3 First 24 Hour Coping Detail Provide a general description of the venting actionsforfirst 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.6 I NET 13-02, Section 2.5, 4.2.2 The operation of the HCVS will be designed to minimize the reliance on operator actions for response to an ELAP and severe accident events. Progression of the ELAP into a severe accident assumes that the FLEX strategies identified in the response to Order EA-12-049 have not been effective. Access to the Reactor Building will be restricted as determined by the RPV water level and core damage conditions. Immediate operator actions will be completed by operators from both the MCR and the ROS using manual actions. The operator actions required to open a vent path are as described in Table 2-1. Remote-manual is defined in this plan as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting under primary procedural protocol.

The HCVS will be designed to allow initiation, control, and monitoring of venting from the MCR and will be able to be operated from an installed ROS as part of the response to this Order. Both locations minimize plant operators' exposure to adverse temperature and radiological conditions and are protected from hazards assumed in Part 1 of this. report. A preliminary evaluation of travel pathways for dose and temperature concerns has been completed and travel paths identified. A final evaluation of environmental conditions will be completed as part of detailed design for confirmation.

[ISE OPEN ITEM-6: Complete evaluation for environmental conditions and confirm the travel path accessibility.]

Permanently installed power, Argon purge, and motive air/gas capable will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Power will be provided by the installed batteries for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before generators will be required to recharge the HCVS batteries.

System control:

i. Active: Same as for BDBEE Venting Part 2.

ii. Passive: Same as for BDBEE Venting Part 2 Greater Than 24 Hour Coping Detail Provide a general description of the venting actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.4, 1.2.8 / NET 13-02, Section 4.2.2 Specifics are the same as for BDBEE Venting Part 2 with the clarification that Argon resupply is necessary following severe accident conditions.

These actions provide long term support for HCVS operation for the period beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days (sustained operation time period) bec~ause on-site and off-site personnel and resources will have access to the-unit to provide Page 23 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Severe Accident Venting needed action and supplies.

The ROS is located in the Turbine Building. The Turbine Building is outside of the secondary containment boundary. The HCVS piping will exit the Reactor Building on the east side. Therefore, the Reactor Building provides shielding for the Turbine Building. A preliminary evaluation of radiological and temperature concerns was completed. A final evaluation will be completed when the location of the ROS is finalized.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

The operation of the HCVS will be governed under the same for SA conditions as for BDBEE conditions.

Existing guidance in the SAMGs directs the plant staff to consider changing radiological conditions in a severe accident.

Identify modifications:

List modifications and describe how they support'the HCVS Actions.

Modifications are the same as for BDBEE Venting Part 2.

Key Venting Parameters:

List instrumentation creditedfor the HCVS Actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order).

Key venting parameters are the same as for BDBEE Venting Part 2.

Notes: None Page 24-of 64*

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: BonayConditions for WW Vent - Support Equipment Functions Determine venting capability support functions needed.

Ref: EA-13-109, Section 1.2.8, 1.2.9 /NEI 13-02, Section 2.5, 4.2.4, 6.1.2 BDBEE Venting Provide a general description of the BDBEE Venting actions supportfunctions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109, Section 1.2.9 / NET 13-02, Section 2.5, 4.2.2, 4.2.4, 6.1.2 Same as BDBEE Venting Part 2.

Severe Accident Venting Provide a general description of the Severe Accident Venting actions supportfunctions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109, Section 1.2.8, 1.2.9 / NEI 13-02, Section 2.5, 4.2.2, 4.2.4, 6.1.2 The same support functions that are used in the BDBEE scenario would be used for severe accident venting.

The ROS (the location of the HCVS DC power source, Argon purge, and motive force) and the FLEX DG location will be evaluated to confirm accessibility under severe accident conditions.

, Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

The operation of the HCVS will be governed the same for SA conditions as for BDBEE conditions. Existing guidance in the SAMG directs the plant staff to consider changes in radiological conditions in a severe accident.

Identify modifications:

List modifications and describe how they support the HCVS Actions.

The same as for BDBEE Venting Part 2.

Key Support Equipment Parameters:

List instrumentation creditedfor the support equipment utilized in the venting operation. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order).

The same as for BDBEE Venting Part 2.

Notes: None Page 25 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Venting Portable Equipment Deployment Provide a general description of the venting actions using portable equipment including modifications that are proposed to maintain and/or support safety functions.

Ref: EA-13-109, Section 3.1 / NET 13-02, Section 6.1.2, D.1.3.1 Venting actions using portable equipment include the following:

• Replacement and replenishment of pneumatic supply sources. This includes the option of replacing nitrogen bottles or connecting a portable air compressor. Equipment sufficient for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of vent operation beyond the 24-hour installed supply would be pre-staged in the FLEX storage building.

Installation of the HCVS includes installation of a pneumatic supply header that includes pneumatic regulators and utilizes standard pneumatic connections.

• Replacement and replenishment of Argon purge gas supply sources. This includes replacing the Argon bottles. Equipment sufficient for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of vent operation beyond the 24-hour installed supply would be pre-staged in the FLEX storage building.

o Establishing temporary power to repower the battery charger. Option 1 is to connect the FLEX DG to Station Battery Charger # 12, which provides power to Station Battery Bus # 12 that in turn powers the HCVS equipment and battery charger. Option 1 would be completed as part of the FLEX response strategy and occurs to the south and inside the NMP1 Turbine Building. Option 2, to be taken if the FLEX DG cannot be connected to the Station Battery Charger #12, is to connect a small portable generator to the HCVS battery charger. Option 2 would be taken locally at the battery charger. Either of these actions will also require the generators to be refueled. A one line diagram of the electrical system to be installed is included in sketch 1A.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Implementation procedures are being developed to address all HCVS operating strategies, including deployment of portable equipment. Direction to enter the procedure for HCVS operation will be given in the EOPs, the site ELAP procedure, and the SAPs (refer to Part 4 for general information on procedures).

There is minimal impact to deployment actions since the HCVS discharge pipe will be located on the east side of the Reactor Building and deployment areas are the Northwest or on the South side of the Turbine Building.

Therefore, the procedures/guidelines for HCVS actions are the same as for support equipment section.

Strategy Modifications Protection of connections Per compliance with Order EA- N/A Per compliance with Order EA-12-049 12-049 (FLEX) (FLEX)

Notes: None Page 26 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

General Licensees that use Option B.]1 of EA-13-109 (SA Capable DW Vent without SA WA) must develop their own QIP.

This template does not provide guidancefor that option.

Licensees using Option B.2 of FA 1 09 (SA WA and SA WM or 5415°F SADW Vent (SADV) with SA WA) may use this template for their QIP submittal. Both SA WM and SADV require the use of SA WA and may not be done independently. The HCVS actions under Part 2 apply to all of the following:

This Partis divided into the following sections:

3.1." Severe Accident Water Addition (SA WA) 3.1.A: Severe Accident Water Management (SA WM) 3.1].B: Severe Accident DW Vent (545 deg F)

Provide a sequence of events and identify any time constraint required for success including the basis for the time constraint.

SA WA and SA WM or SADV Actions supporting SA conditions that have a time constraintto be successful should be identified with a technical basis and a justi~ficationprovided that the time can reasonably be met (for example, a walkthrough of deployment). Actions already identified under the HCVS part of this template need not be repeated here.

The time to establish the water addition capability into the RPV or DW should be less than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />sfrom the onset of the loss of all injection sources.

• Electrical generatorssatisfying the requirements of EA-12-049 may be creditedfor powering components and instrumentationneeded to establish aflow path.

• Time Sensitive Actions (TSAs) for the purpose of SA WA are those actions needed to transport, connect and startportable equipment needed to provide SA WA flow or provide power to SA WA components in the flow path between the connection point and the RPV or drywell1. Actions needed to establishpower to SA WA instrumentationshould also be included as TSAs.

Ref: NET 13-02 Section 6.1.1.7.4.1, 1.1.4, 1.1.5 The operation of the HCVS using SAWA and SAWM/SADV will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and will include the capability for remote-manual initiation from the MCR using control switches with minor manual operation from the ROS first. In addition, HCVS valve operation, as required by EA-13-109 Requirement 1.2.5, may occur at the ROS.

Timelines (see attachments 2.1 .A for SAWA/SAWM) were developed to identify required operator response times and actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWMV). The timelines do not assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damage conditions.

Page 27 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Part 3.1: Boundary Conditions for SAWA (The flooding condition is not the limiting external event since the flooding event will have greater than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning allowing the Unit to be shutdown, placed in Mode 4, and mitigating equipment deployed prior to the flood induced ELAP)

Table 3.1 - SAWA Manual Actions Primary Action Primary Location!/Component Notes

1. Establish HCVS capability in

• MCR and/or ROS.

• Applicable to SAWA/SAWM accordance with Part 2 of this strategy.

OIP

2. Connect FLEX (SAWA) pump

• Flow path is thru a permanent

• No hose connections within the discharge to FLEX injection standpipe in the 261' elevation Reactor Building or entry into piping. of the Turbine Building grade the Reactor Building are elevation (Outside of the Reactor required for RPV make-up.

Building). *A hose connection is provided

• Flow path is thru the NMP1 on the standpipe.

Feedwater System. No power operated valves are required to be operated.

• Five small manual valves will need to be verified closed to provide boundary isolation points for SAWA.

3. Connect FLEX (SAWA) pump

• At the Screen House, connect *The location of this source, as to water source. suction hose to diesel driven well as the location of the pump, and connect pump FLEX (SAWA) pump, is not discharge to hose. challenged by severe accident radiological conditions. From this location, the flow is to the Turbine Building standpipe (action #2, above).

4. Power SAWA/HCVS

• At Turbine Building south side *No changes required to the components with EA-12-049 close to the battery board room original EA-12-049 strategy.

(FLEX) generator. doors.

5. Inject to RPV using FLEX

• SAWA flow control is at the

• No MOVs or other power (SAWA) pump (diesel). FLEX (SAWA) pump discharge operated valves required.

3-valve manifold.

• Initial SAWA flow rate is 263

• Requires opening and then gpm.

controlling flow using a manual valve.

6. Monitor SAWA indications.

• Local SAWA flow indicator by *The proposed solution is to FLEX (SAWA) pump provide a flow instrument in the

• Containment parameters SAWA flow path and to use

___________________ monitored at MCR. technology that does not require Page 28 of 64

,Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2) electrical power or that can be supplied with electrical power

' using a small DC battery for extended periods (minimum of 7 days).

7. Use SAWM to maintain '

• MCR for indication of

• Monitor DW pressure and availability of the WW vent (Part containment parameters. Suppression Pool level.

3.1.A).

• FLEX (SAWA) pump location

• Control SAWA flow with for flow control. manual valve at FLEX

________________(SAWA) pump.

'Discussion,

• of*timeline SA,WA identified. items. ,:!

' ,.*, C HCVS operations are discussed under Phase 1 of EA-13-109 (Part 2 of this OTP).

• 8 Hours - Establish electrical power and other EA- 12-049 actions needed to support the strategies for EA-13-109, Phase 1 and Phase 2. Action being taken within the Reactor Building under EA-12-049 conditions after RPV level lowers to 2/3 core height must be evaluated for radiological conditions assuming permanent containment shielding remains intact (HCVS-FAQ-12). All other actions required are assumed to be in-line

)with the FLEX timeline submitted in accordance with the EA- 12-049 requirements.

• Less than 8 Hours - Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizing the peak DW pressure during the initial cooling conditions provided by SAWA.

Part 3.1: Boundary Conditions for SAWA:

,:::: : . . :' .*'::: ... ': : *:Seycere iA ccident

.... Operation ' ,°  : . . . ..  :: : * , / :

Determine operating requirementsfor SA WA, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02, Section 1.1.6, 1.1.4.4 It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systems or presumed failure of injection systems in a timely manner. This does not preclude the use of the SAWA system to supplement or replace the EA-12-049 injection systems if desired. SAWA will consist of both portable and installed equipment.

The motive force equipment needed to support the SAWA strategy shall be available prior to T=8 hours from the loss 'of injection (assumed at T=0).

The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids / gases and potentially flammable conditions by inclusion of backflow prevention. The FLEX (SAWA) pump check valve is integral with the pump skid and will close and prevent leakage when the FLEX (SAWA) pump is secured. The Feedwater lines have installed check valves qualified for accident scenarios to prevent reverse flow from the RPV.'

• * ~Description of SAWA actions for first 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

Page 29 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Table 3.2 - SAWA Manual Actions Timeline Time Action Notes T<l hour

• Connect SAWA hose at the Turbine Building

• No evaluation required for standpipe (outside of the Reactor Building) (Step 2 of actions inside Reactor Table 3.1). Building.

T=1-7" hours

• Complete actions started at T<I hour (Step 2 of Table

• Evaluate core gap and early in 3.1). vessel release impact to

• Connect FLEX (SAWA) pump to water supply at Reactor Building access for screen house (Step 3 of Table 3.1). SAWA actions. It is assumed

• Establish electrical power to HCVS and SAWA that Reactor Building access using EA-12-049 generator (Step 4 of Table 3.1). is limited due to the source

• Establish flow of 263 gpm to the RPV using SAWA term at this time unless systems. (Step 5 of Table 3.1). otherwise noted. (Refer to HCVS-FAQ-12 for actions in T=l1-8 hour timeframe.

T<8-12 hours

• Monitor and Maintain SAWA flow at 263 gpm for *SAWA flow must commence four hours Step 6 of Table 3.1). at T=8 hours but should be done as soon as motive force is available.

T< 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

• Proceed to SAWM actions per Part 3.1 .A (Step 7 of

• SAWA flow may be reduced Table 3.1). to 53 gpm four hours following SAWA initiation.

• The assumed times of T=I hour to T=8 hours to establish the bounds of applicability of radiological evaluations have been reduced to T=I1 hour to T=7 hours in order to provide sufficient margin to inform operator action feasibility evaluations and will be further informed by emergency response dose assessment activities during an actual event. This accounts for the one hour gap between 7 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in this time line.

Greater Than 24 Hour Coping Detail Provide a general description of the SA WA actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NET 13-02, Section 4.2.2.4.1.3.1, 1.1.4 SAWA Operation is the same for the full period of sustained operation. If SAWM is employed, flow rates will be directed to preserve the availability of the HCVS wetwell vent (see 3.1 .A).

Details:

Details of Design Characteristics/Performance Specifications SA WA shall be capable of providing an RPV injection rate of 500 gpm within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a loss of all RPV injection following an ELAP/Severe Accident. SA WA shall meet the design characteristicsof the HCVS with the exception of the dedicated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power source. Hydrogen mitigation is provided by backflow prevention for SA WA.

Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NET 13-02, Section 1.1.4 Equipment Locations/Controls/Instrumentation NMP1 has not performed a site specific evaluation to justify the Page 30 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2) use of a lower site unique initial SAWA flow rate. Consequently, NMP1 will assume an initial flow rate of 263 gpm. This is based on the Industry generic value of 500 gpm multiplied by (NMP1 rated thermal power [1850 MWt]/reference plant thermal power [3514 MWt]). This initial flow rate will be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of all RPV injection following an ELAP/Severe Accident and will be maintained for four hours before reduction to the Wetwell vent preservation flow rate.

The locations of the SAWA equipment and controls, as well as ingress and egress paths will be evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period.

Equipment will be evaluated to remain operational throughout the Sustained Operating period. Personnel exposure and temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERO dose and plant safety guidelines for temperature and humidity.

The flow path will be from the FLEX (SAWA) pump suction at the screen house, through the FLEX (SAWA) pump hoses to the riser at the 261' elevation of the Turbine Building (grade elevation), by hardpipe through the Feedwater System to the RPV. This flow path does not require energizing any power operated valves. Backflow from the reactor/containment through the SAWA firewater to Feedwater piping is prevented by the Feedwater system isolation check valves (CKV-31-01R and CKV-31-02R).

DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by throttling the manual valves located on the FLEX (SAWA) pump manifold or throttled at valve BV-29-412 in the Turbine Building if final dose assessments determine throttling at the pump is not acceptable. Communication will be established between the MCR and the SAWA flow control location.

The FLEX (SAWA) pump suction source is a significant distance from the discharge of the HCVS pipe with substantial structural shielding between the HCVS pipe and the pump deployment location. FLEX (SAWA) pump and diesel driven generator refueling will also be accomplished using portable transfer pumps, towable fuel containers, and fuel from the NMP2 Emergency Diesel Generator (EDG) fuel oil storage tanks. NMP1 EDG storage tanks would be also available except in a flood condition. See mechanical and electrical sketches in attachments, plant layout sketches in the assumptions part and a list of actions elsewhere in this part.

Evaluations of actions outside the Reactor Building for projected SA conditions (radiation / temperature) indicate that personnel can complete the initial and support activities without exceeding the ERG-allowable dose for equipment operation or site safety standards (reference HCVS-WP-02, Plant Specific Dose Analysis for the Venting of Containment during SA Conditions). Evaluation of actions inside the Reactor Building for projected SA conditions (radiation/temperature) will be performed to determine that personnel can complete the initial and support activities without exceeding the ERG-allowable dose for equipment operation or site safety standards (reference HCVS-FAQ- 12).

Electrical equipment and instrumentation will be powered from the power sources noted in the table below with portable generators to maintain battery capacities during the Sustained Operating period. The indications noted with an

• are minimum required instruments.

Parameter Instrument {Location [Power Source / Notes DW Pressure* MCR RPS Channel 12 PI 201.2-106A (Battery 12) via EA 049 generator and battery charger RG 1.97 qualified Page. 31 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Suppression Pool Level* LI 201 .2-595D MCR RPS Channel 12 (Battery 12 via EA 049 generator and battery charger RG 1.97 qualified SAWA Flow*

__ _ _ _ _w

• FLEX (SAWA) Pump indicator T[

FLEX (SAWA)

Pump

• Self-powered from internal battery The instrumentation and equipment being used for SAWA and supporting equipment has been evaluated to perform for the Sustained Operating period under the expected radiological and temperature conditions.

Equipment Protection SAWA installed component and connections external to protected buildings will be protected against the screened-in hazards of EA-12-049 for the station. Portable equipment used for SAWA implementation will meet the protection requirements for storage in accordance with the criteria in NEI 12-06, Revision 0.

Ref: EA-13-109 Attachment 2, Section B .2.2, B .2.3 / NET 13-02, Section 5.1.1, 5.4.6, 1.1.6 Provide a brief description of Procedures / Guidelines:

Confirm thatprocedure/guidance exists or will be developed to support implementation.

Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NET 13-02, Section 1.3, 6.1.2 Procedural guidance will be developed for the following:

1. Connect FLEX (SAWA) pump discharge to Turbine Building standpipe that leads to Feedwater System.

2. Power SAWA/HCVS components with EA-12-049 (FLEX) generator using FSG.

3. Start FLEX (SAWA) pump to establish SAWA flow.

4. Adjust SAWA flow using SAWA flow indication to establish and maintain an initial flow of 263 gpm.

• Where an FSG is referenced, it will be the same FSG reference with the same steps used for FLEX.

Identify modifications:

List modifications and describe how they support the SA WA Actions.

Ref: EA-13-109 Attachment 2, Section B.2.2, / NET 13-02, Section 4.2.4.4, 7.2.1.8, Appendix I The list of modifications, below, is limited to those required to upgrade EA-12-049 equipment to meet EA-13-109 Phase 2 requirements.

Electrical Modifications:

• None Mechanical Modifications:

• None Instrument Modifications:

• No permanent modification to the station. Flow Meter will be a temporary instrument installed in the hose Page 32 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2) or pump discharge manifold.

Component Qualifications:

State the qualificationused for equipment supporting SA WA.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 1.1.6 Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this O11T.

Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06, Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 design conditions.

Notes:

None Part 3.1.A: Boundary Conditions for SAWA/SAWM Time periods for the maintaining SAWM actions such that the WW vent SA WM Actions supporting SA conditions that have a time constraint to be successful should be identified with a technical basis and a justificationprovided that the time can reasonably be met (for example, a walkthrough of deployment). Actions already identified under the HCVS part of this template need not be repeated here.

There are three time periodsfor the maintainingSA WM actions such that the WW vent remains available to remove decay heatfrom the containment."

• SAWM can be maintainedfor >7 dlays without the need for a drywell vent to maintainpressure below PCPL or containment design pressure, whichever is lower.

o Under this approach, no detail concerningplant modifications or procedures is necessary with respect to how alternate containment heat removal will be provided.

• SA WM can be maintainedfor at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, but less than 7 dlays before DWpressure reaches PCPL or design pressure, whichever is lower.

o Under this approach, a functional description is requiredof how alternate containment heat removal might be establishedbefore DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are not necessary, butt written descriptions of possible approachesfor achieving alternate containment heat removal and pressure control will be provided.

• SAWM can be maintainedfor <72 hours SAWM strategy can be implemented but for less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before DW pressure reaches PCPL or design pressure whichever is lower.

o Under this approach, a functional descriptionis required of how alternate containment heat removal might be established before DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant mnodifications and detailed procedures are required to be implemented to insure achieving alternate containment heat removal and pressure control will be providedfor the sustained operatingperiod.

Ref: NET 13-02 Appendix C.7 SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.

Page 33 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Basis for SAWM time frame SAWM can be maintained >7 days:

NMP1 has not performed a site specific evaluation to justify the use of a lower site unique initial SAWA flow rate.

Consequently, NMP1 will assume an initial flow rate of 263 gpm.

This initial flow rate will be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of all RPV injection following an ELAP/Severe Accident and will be maintained for four hours before reduction to the Wetwell vent preservation flow rate.

Instrumentation relied upon for SAWM operations is Drywell Pressure and Suppression Pool level and SAWA flow. Except for SAWA flow, SAWM instruments are initially powered by station batteries and then by the FLEX (EA-12-049) generator which is placed in-service prior to core breach. The DG will provide power throughout the Sustained Operation period (7 days). The SAWA flow instrument will be a local indication on the FLEX (SAWA) pump that is self-powered from an internal power supply capable of being replenished, if needed, through the Sustained Operation period. If SAWA flow must be controlled from within the Turbine Building by feedwater valve BV-29-412 then an alternate flow instrument location will also be required.

DW Temperature monitoring is not a requirement for compliance with Phase 2 of the order, but some knowledge of temperature characteristics provides information for the operation staff to evaluate plant conditions under a severe accident and provide confirmation to. adjust SAWA flow rates (C.7.l.4.2, C.8.3.l).

Suppression Pool level indication is maintained throughout the Sustained Operation period, so the HCVS remains in-service. The current NMP1 Suppression Pool level indication spans to the HCVS wetwell penetration. The time to reach the level at which the WW vent must be secured is >7 days using SAWIM flowrates (C.6.3, C.7.1.4.3).

Procedures will be developed that control the Suppression Pool level, while ensuring the DW pressure indicates the core is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which SAWM flowrate should be adjusted (up or down) using suppression pool level and DW pressure as controlling parameters to remove the decay heat from the containment (this is similar to the guidance currently provided in the BWROG SAMGs) (C.7. 1.4.3). .1.A shows the timeline of events for SAWA!/ SAWM (C.7.1.4.4).

Table 3.1.B " SAWM Manual Actions

[Primary Action [Primary Location!/Component ]Notes

1. Lower SAWA injection rate to

• Containment parameters at the e Control to maintain control Suppression Pool Level MCR. containment and WW and decay heat removal. *Flow control at FLEX (SAWA) parameters to ensure WW vent pump valve manifold or remains functional.

throttled at valve BV-29-412 in *53 gpm minimum capability is the Turbine Building if dose maintained for greater than 7 assessments determine days.

throttling from the pump is not acceptable.

2. Control SAWM flowrate for

• Flow control at FLEX (SAWA)

• SAWM flowrate will be containment control/decay heat pump valve manifold or monitored using the following removal, throttled at valve BV-29-412 in instruments:

Page 34 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2) the Turbine Building if dose - SAWA Flow Meter assessments determine -. Suppression Pool Level throttling from the pump is not - Drywell Pressure acceptable. e SAWM flowrate will be controlled by throttling the

_________________________manual valve.

3. Establish alternate decay heat Various locations SAWM strategy can preserve the removal. wetwell vent path for >7 days.

4. Secure SAWA / SAWM. Various locations When alternat* decay heat removal is established.

SAWM.Tim..Senitive Action Time Sensitive SAWM Actions:

12 Hours - Initiate actions to maintain the Wetwell (WW) vent capability by lowering injection rate, while maintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the WW vent remains available.

SAWM Severe Accident Operation Determine operating requirementsfor SA WM, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109 Attachment 2, section B.2.2, B.2.3 / NET 13-02, Appendix C It is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plant injection systems per direction by the plant SAMGs. Refer to Attachment 2.1 .D for SAWM SAMG language additions.

First 24 Hour Coping Detail Provide a general description of the SA WM actionsfor first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that are proposed.

Given the initial conditionsfor EA 1 09:

• BDBEE occurs with FLAP

• Failureof all injection systems, including steam-powered injection systems Ref: EA-13-109, Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 I NET 13-02 2.5, 4.2.2, Appendix C, Section C.7 SAWA will be established as described as stated above. SAWM will use the installed instrumentation to .monitor and adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWM strategy.

Once the SAWA initial low rate has been established for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the flow will be reduced while monitoring DW pressure and Suppression Pool level. SAWM flowrate can be lowered to maintain containment parameters and preserve the WW vent path. SAWMV will be capable of injection for the period of Sustained Operation.

• ~Greater Than 24 Hour Coping Detail Page 35 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Provide a generaldescription of the SA WM actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 4.2.2, Appendix C, Section C.7 SAWM can be maintained >7 days:

The SAWM flow strategy will be the same as the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> until 'alternate reliable containment heat removal and pressure control' is reestablished. SAWM flow strategy uses the SAWA flow path. No additional modifications are being made for SAWM.

Details:

Details of Design Characteristics/Performance Specifications Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section Appendix C SAWM shall be capable of monitoring the containment parameters (DW pressure and Suppression Pool Level) to provide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control is established. SAWA will be capable of injection for the period of Sustained Operation.

Equipment Locations/Controls/Instrumentation Describe locationfor SA WM monitoring and control.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Appendix C, Section C.8, Appendix I The SAWM control location is the same as the SAWA control location. The SAWA flow instrument is available at the FLEX (SAWA) pump.

Injection flowrate is controlled by throttling a manual valve at the FLEX (SAWA) pump valve manifold or throttled at valve BV-29-412 in the Turbine Building if dose assessments determine throttling from the pump is not acceptable.

Suppression Pool level and DW pressure are read in the control room using indicators powered by the FLEX DG installed under EA-12-049. These indications are used to control SAWM flowrate to the RPV.

Key Parameters:

List instrumentationcreditedfor the SA WM Actions.

Parameters used for SAWM are:

• Drywell Pressure

• Suppression Pool Level

• SAWM Flowrate The Drywell pressure and Suppression Pool level instruments are qualified to RG 1.97 and are the same as listed in Part 2 of this OWP The SAWM flow instrumentation will be qualified for the expected environmental conditions expected when needed.

Notes:

None Page 36 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 (Phase 2)

Part 3.1.B: Boundary Conditions for SAWA/SADV Applicability of WW Design Considerations This section is not applicable to NMPl.

Table 3.1.C - SADV Manual Actions Timneline for SADV Severe Accident Venting First 24 Hour Coping Detail Greater Than 24 Hour Coping, Detail Details:

Page 37 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls, Training, Drills and Maintenance Identify how the programmatic controls will be met.

Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality addressing the impact of temperature and environment.

Ref: EA-13-109, Section 3.1, 3.20 I NEI 13-02, Section 6.1.2, 6.1.3, 6.2 Program Controls."

The HCVS venting actions will include:

• Site procedures and programs are being developed in accordance with NEI 13-02 to address use and storage of portable equipment relative to the Severe Accident defined in NRC Order EA 109 and the hazards applicable to the site per Part 1 of this GIP.

• Routes for transporting portable equipment from storage location(s) to deployment areas will be developed as the response details are identified and finalized. The identified paths and deployment areas will be accessible when the HCVS is required to be functional including during Severe Accidents.

Procedures:

Procedures will be established for system operations when normal and backup power is available, and during ELAP conditions.

The HCVS and SAWA procedures will be developed and implemented following plant processes for initiating or revising procedures and contain the following details:

• appropriate conditions and criteria for use of the HCVS and SAWA

• when and how to place the HCVS and SAWA in operation

• location of system components

• instrumentation available

• normal and backup power supplies

• directions for sustained operation (Reference 9), including the storage and location of portable equipment

• location of the remote control HCVS operating station (panel)

• training on operating the portable equipment

• testing of portable equipment NMP1 does not credit Containment Accident Pressure (CAP) for ECCS pump NPSH.

Provisions will be established for out-of-service requirements of-the HCVS and compensatory measures that comply with the criteria from NEI 13-02 (Reference 9).

NMP1 will establish provisions for out-of-service requirements of the HCVS and compensatory measures.

The following provisions will be documented in the HCVS Program Document:

The provisions for out-of-service requirements for HCVSISAWA are applicable in Modes 1, 2 and 3

• If for up to 90. consecutive days, the primary or alternate means of HCVS/SAWA operation are non-Page.38 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls, Training, Drills and Maintenance functional, no compensatory actions are necessary.

• If for up to 30 days, the primary and alternate means of HCVS/SA'WA operation are non-functional, no compensatory actions are necessary.

• If the out of service times exceed 30 or 90 days as described above, the following actions will be performed through the site corrective action program:

• Determine the cause(s) of the non-functionality,

• Establish the actions to be taken and the schedule for restoring the system to functional Status and to prevent recurrence,

• Initiate action to implement appropriate compensatory actions, and

• Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle.

Describe training plan List trainingplansfor affected organizationsor describe the plan for trainingdevelopment.

Ref: EA-13-109, Section 3.2 / NEI 13-02, Section 6.1.3 Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receive necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS/SAWA/SAWM actions, systems or strategies. Training content and frequency will be established using the Systematic Approach to Training (SAT) process.

Identify how the drills and exercise parameters will be met.

Alignment with NEI 13-06 and 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking.

The Licensee should demonstrate use in drills, tabletops, or exercises for HCVS operation asfollows:

• Hardened containment vent operation on normal power sources (no FLAP).

• During FLEX demonstrations (as requiredby FA-12-049): Hardenedcontainment vent operation on backup power andfrom primary or alternate location during conditions of ELAP/loss of UHS with no core damage. System use is for containment heat removal AND containmentpressure control.

• HCVS operationon backup power andfrom primary or alternate location during conditions of ELA P/loss of UHS with core damage. System use is for containment heat removal AND containment pressure control with potentialfor combustible gases (Demonstrationmay be in conjunction with SAG change).

• Operation for sustainedperiod with SA WA and SA WM to provide decay heat removal and containmentpressure control.

Ref: EA-13-109, Section 3.1 / NEI 13-02, Section 6.1.3 Page 39 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 4~: Programmatic Controls, Training, Drills and Maintenance NIVPi will utilize the guidance provided in NEI 13-06 and 14-01 (References 10 and 11) for guidance related to drills, tabletops, or exercises for HCVS operation. In addition, NMP1 will integrate these requirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9.

Describe maintenance plan:

• The maintenanceprogram should ensure that the HC VS/SA WA/SAWM equipment reliability is being achieved in a manner similarto that requiredfor FLEX equipment. Standard industry templates (e.g.,

EPRI) and associated bases may be developed to define specific maintenance and testing.

o Periodictesting and frequency should be determined based on equipment type and expected use (furtherdetails are provided in Part6 of this document).

o Testing should be done to verify design requirements and/or basis. The basis should be documented and deviationsfrom vendor recommendations and applicable standardsshould be justified.

o Preventive maintenance should be determined based on equipment type and expected use. The basis should be documented and deviationsfrom vendor recommendations and applicable standardsshould be justified.

o Existing work control processes may be used to control maintenance and testing.

• HCVS/SAWA permanent installed equipment should be maintained in a manner that is consistent with assuring that it performs its function when required.

o HCVS/SAWA permanently installed equipment should be subject to maintenance and testing guidanceprovided to verify properfunction.

• HCVS/SAWA non-installed equipment should 'be stored and maintained in a manner that is consistent with assuring that it does not degrade over long periods of storage and that it is accessiblefor periodic maintenance and testing.

Ref: EA-13-109, Section 1.2.13 / NEI 13-02, Section 5.4, 6.2 NMP1 will utilize the standard EPRI industry PM process (similar to the Preventive Maintenance Basis Database) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SA'WIV components. The control program will include maintenance guidance, testing procedures and frequencies established based on type of equipment and considerations made within the EPRI guidelines.

NMP1 will implement the following operation, testing and inspection requirements for the HCVS and SAWA to ensure reliable operation of the system.

Table 4-1: Testing and Inspection Requirements Description Frequency Cycle the HCVS and installed SAWA valves' Once per every2 operating cycle and the interfacing system valves not used to maintain containment integrity during Mode 1, 2 and 3. For HCVS valves, this test may be performed concurrently with the control logic test described below.

Cycle the HCVS and installed SAWA check Once per every other4 operating cycle valves not used to maintain containment Page 40 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls~, Training, Drills and Maintenance integrity during unit operations 3 .

Perform visual inspections and a walk down of Once per every other 4 operating cycle HCVS and installed SAWA components.

Functionally test the HCVS radiation monitors. Once per operating cycle Leak test the HCVS. (1) Prior to first declaring the system functional; (2) Once every three operating cycles thereafter; and (3) After restoration of any breach of system boundary within the buildings Validate the HCVS operating procedures by Once per every other operating cycle conducting an open/close test of the HCVS control function from its control location and ensuring that all HCVS vent path and interfacing system valves 5 move to their proper (intended) positions.

2'Not required for HCVS and SAWA check valves.

After two consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle.

3 o required if integrity of check function (open and closed) is demonstrated by other plant testing requirements.

4After two consecutive successful performances, the test frequency may be reduced by one operating cycle to a maximum of once per every fourth operating cycle.

5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (loss of power andlor air) do not require control function testing under this part. Performing existing plant design basis function testing or system operation that reposition the valve(s) to the HCVS required position will meet this requirement without the need for additional testing.

Notes:

PCIVs are required for containment integrity during Modes 1-3 and thus are excluded from EA-13-109 testing requirements. However, these PCIVs are tested per by the NMP1 design basis requirements to ensure valve operability and leakage tightness. Refer to generic assumption 109-4.

Page 41 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 5: Milestone Schedule Provide a milestone schedule. This schedule should include:

• Modifications timeline

• Procedure guidance development complete o HCVS Actions o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion

• Long term use equipment acquisition timeline

• Training completion for the HCVS Actions The dates specifically requiredby the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

Ref: EA-13-109, Section D.1, D.3 / NET 13-02, Section 7.2.1 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent 6-month status reports.

Phase 1 Milestones:

Milestone Target Activity Comments Completion Status Date Hold preliminary/conceptual design meeting November Complete 2013 Submit Overall Integrated Implementation Plan Jun 2014 Complete Submit 6 Month Status Report Dec 2014 Complete Submit 6 Month Status Report Jun 2015 Complete Submit 6 Month Status Report Dec. 2015 Complete Simultaneous with Phase 2 with this OIP submittal Design Engineering Complete April 2016 Started Maintenance and Operation Procedure Changes February Not Started Developed, Training Complete 2017 Implementation Outage April.2017 Not Started Procedure Changes Active, Walk-Through April 2017 Not Started Demonstrationl/Functional Test Submit Completion Report June 2017 Not started Page 42 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Part 5: Milestone Schedule Phase 2 Milestone Schedule:

Phase 2 Milestone Schedule Milestone Target Activity Comments Completion Status Date Submit Overall Integrated Implementation Plan December Complete Simultaneous with Phase 2015 with this 1 Updated OJIP submittal Hold preliminary/conceptual design meeting June 2015 Complete Submit 6 Month Status Report June 2016 Submit 6 Month Status Report Dec 2016 Submit 6 Month Status Report June 2017 Submit 6 Month Status Report Dec 2017 Submit 6 Month Status Report June 2018 Submit 6 Month Status Report Dec 2018 Design Engineering Complete April 2018 Not Started Maintenance and Operation Procedure Changes February Not Developed, Training Complete 2019 Started Implementation Outage April 2019 Not Started Procedure Changes Active, Walk-Through April 2019 Not Demonstration/Functional Test Started Submit Completion Report June 2019 Not started Notes:

None Page 43 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents

~Attachment 1: HCVS/SAWA/SADV Portable Eu uipment BDBEE Severe Performance Maintenance/ PM requirements List portable equipment Venting Accident Criteria

" Venting Nitrogen Cylinders X X X Bottles @ Check periodically for pressure, replace or "X psig (Later) replenish as needed Argon Cylinders NA X X Bottles @ Check periodically for pressure, replace or X psig (Later) replenish as needed FLEX DG X X 450 KW Per response to EA-12-049

"

• 600 VAC

':'FLEX/SAWA Pump X X 263 gpm @ Per response to EA-12-049

• 260 psig (2000 rpm)

Portable Air Compressor (optional) X X Later Per vendor manual Small Portable Generator (optional) X X Later Per vendor manual Page 44 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 2A: S&iuence of Events Timeline HCVS -

Begin monitoring HCVS support systems. No replenishment expected Replenishment of HCVS End of Sustained ELAP ECs start to be required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. supports systems required. Oneration Sequence I NieMiePon Ui

• FLEX successful

- w T=0s Tzz0.5m T~ l 8hrs Ref: Station FLEX ISAWA No Injection Injection begins Injection Lost Level at TAF Sequence 2

• EC Late Failure Ref: SECY-12-0157 T zz23 hrs Tz*24 hrs I Containment Venting (based on preventing exceeding PCPL)

Start containment venting (based on preventing exceeding PCPL)

-'-~Sequence 3 EC Early Failure Tzzl1hr T 8 hrs T

• 168 hrs Ref: SOARCA T 12 hrs 2f SAWA 4hr Injection begins 4 Not to Page Scale Legend No core damage; adequate core cooling maintained Injection lost Core damage but no venting; containment shine dose in Rx Bldg but not from HCVS pipe Post-RPV breach Page 45 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 2.1.A: Sequence of Events Timeline - SAWA / SAWM Time Action T=O hours Start of ELAP T=8 hours Initiate SAWA flow at 263 gpm as soon as possible but no later than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> T= 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Throttle SAWA flow to 53 gpm 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after initiation of SAWA flow T= 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> End of Sustained Operation Sustained Operation Period T=168 hours I

SAWA T=168 hours Monitor containment parameters and conditions Page 46 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents .1 .B Sequence of Events Timeline - SADV This Attachment is not applicable to NMP1 Page 47 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 2.1.C: SAWAISAWM Plant-Specific Datum Loss of vent function -

Estimated maximum SAWM Drywell floor EL. 225.5' gallons.

15.5 feet of available freeboard Minimum Wetweli level 11.5 ft1658,467 gallons-Containment Level instrument range 0 to 27' DRAWING NOT TO SCALE Notes:

1. NMP1 torus level indication is to top of torus (27 feet), the same elevation as the vent line tap.

2. The SAWM maximum level shown at 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> is a conservative calculation based on water addition only. It does not reflect mass loss due to venting. This is preliminary, bounding information only.

st

3. SAWA injection flowrates are 263 gpm for the 1 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and lowered to 53 gpm for the remainder. Once torus level reaches 6 feet above nominal height:

• At a flowrate of 263 gpm the average rate of rise is 0.241 ftihour*

• At a flowrate of 53 gpm the average rate of rise is 0.049 ft/hour*

• Does not consider mass loss rate of steam leaving containment through wetwell vent path.

Page 48 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 2.1 .D: SAWM SAMG Approved Language The following general cautions, prioritiesand methods will be evaluatedfor plant specific applicabilityand incorporatedas appropriateinto the plant specific SAMGs using administrativeproceduresfor EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefore address a wide variety of possible plant conditions and capabilitieswhile these changes are intended to accommodate those specific conditions assumed in Order EA 109. The changes will be made in a way that maintains the use of SAMGs in a symptom based mode while at the same time addressing those conditions that may exist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris.

Actual Approved Language that will be incorporated into site SAMG*

Cautions:

• Addressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapid steam generation.

• Addressing the plant impact that raising suppression pooi water level above the elevation of the suppression chamber vent opening elevation will flood the suppression chamber vent path.

Priorities:

with significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases as follows:

• Core debris in the primary containment is stabilized by water addition (SAWA).

• Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting).

• Water addition is managed to preserve the Mark I/Il suppression chamber vent paths, thereby retaining the benefits of suppression pool scrubbing and

• minimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM).

Methods:

Identify systems and capabilities to add water to the RPV or drywell, with the following generic guidance:

• Use controlled injection if possible.

• Inject into the RPV if possible.

Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.

• Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.

Page 49 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 3: Conceptual Sketches (Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies)

Sketch 1A and 1B: Electrical Layout of System (preliminary)

• Instrumentation Process Flow

• Electrical Connections Sketch 2A, 2B, and 2C: P&ID Layout of WW Vent, ROS, and HCVS Plan Overview (preliminary)

• Piping routing for vent path - WW Vent

• Demarcate the valves (in the vent piping) between the currently existing and new ones

• WW Vent Instrumentation Process Flow Diagram

• Egress and Ingress Pathways to ROS, Battery Transfer Switch, DG Connections and Deployment location

• Site layout sketch to show location/routing of WW vent piping and associated components. This should include relative locations both horizontally S and vertically.

Sketch 3A.l, 3.A.2, and 3A.3: P&ID Layout of SAWA (preliminary)

• Piping routing for SAWA path

• SAWA instrumentation process paths.

• SAWA connections.

• Include a piping and instrumentation diagram of the vent system. Demarcate the valves (in the vent piping) between the currently existing and new ones.

• Ingress and egress paths to and from control locations and manual action locations.

• Site layout sketch to show locations of piping and associated components. This should include relative locations both horizontally and vertically.

Page 50 of 64

Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 1A: Electrical Layout of System - I-CVS LIGHTLNG PANEL PN'L-LP106, CKT #16 I. Breaker will normally be open 120 VAC POWER during normal plant operation.

MANUAL TRANSFER SWITCH IHDS-HCV'S-PG PLUG FOR PORTABLE BATTERY BUS #12, CUB C12 GENERATOR 125VD*C OL'TLET-HC VS-PG (FLEX POWER)

]F-(BB12)2 4 125VDC BATTERY BAT-HCVS F 10A HCVS PA.NEL PNL-HCVS I Note 1 BKR-(HCVS)2 0 IO 125VDlC Bus 2A4 4A 4A IA

'VS 125 VDC!24 VDC HCVS Rec~order Power Battery Voltage HCVS Valve HC' ition CONV'ERTER HCVS VALVE Indicator Indication CONTROL itorI Page 51 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 1B: Electrical Connections - HCYS and SAWA NEW DIESEL

• PORT ABLE GENERATOR 150A TPC 4/C #410 Existin~g Q #2/0 I'E N200A SW -,

I iNO I Existing 3SC #2K)

ACSW 171A i NC ,

171B Exisling 3SC #2K0 #2J0 SBC 171A SBC 171B DCSW l71A DCSW 171B NO NC 1600A 500A F02 1 25VDC Battery Board #12 G0)3 Page 52 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 2A: P&ID Layout of WW Vent Is s KEY-Wc SUT1OE$:

POC-2G01-7,4..S OlN DC2~-3 I

1

,t7 wwr __ I f

P*CLi*E V~gilS TO PI A Y CoNTr 1(NIINUL ATO*

L PA 6 L H1Y .. .. ... . ........................................... ...............................

1 1lJU*G/ . . . . .. .... ..

2011-R

~VtTAGE I~GAlON rce OTUCA~DI

__________- - EidSTh.O£O~RPI~i1 AND PIPING = NEWELECTRICAL INSTALL SEPARATE VENT

- NEWHCV$ ~~4T PIPP~Ga EOUWNENT _________ - NEWP~JR~ 1~JUINO & EgApNE~fl LINES WITH NEW ISOLATION

- NEWMO1T~ GAS 1I4N~ & EOUWNENT VALVES Page 53 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 2B: Remote Operating Station HWC PANEL ELECTRICAL PANEL F--

FLOOR PENETRATIONS*

SIn Turbine Building CONTROL PANEL (TOP)

RAD MONITOR (BOTTOM)-

CHARGER. 37 3/8' H----_ WALL PENETRATION BATTERIES. 46 3/8' H -

FORPENETRATION WITH PIPE 0-4 PLAN ABOVE EL 261'-0Z" REF DWG 0-18795-C Page 54 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 2C: HCVS Plan Overview UNIT NO. 1 HCVS Plan Overview SAWA Pump FLEX DQ Page 55 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 3A.l: P&ID Layout of SAWA 3Y 81w 2.5" NHS x adaptor SAWA Flow Indicator am 4rf anige~

and groin Ve6"ca redciuc*

Pg go 6" Hose wi cam and groove fttlgs Pump Vendo By Ij I

6" NPMHose(in) wi 6" NPSM (t)

Page 56 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Qeif Iboundary isolation closed points fi to provide 1 Sketch 3A.2: P&ID Layout of SAWA

+ +@........ -1 ... - _....

S- " -- Passive boundary isolation points forSW

-+. ,,+ * - J*' ++++*- ..

. ...... ... .. ... ... . .. ... . .. . ...... - / ICTE*

3+ ' _ . .*

V - J,.!,

i ......

- + ..........I+-÷

• +'+ +_-

Feedwater System Page 57 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Sketch 3A.3: P&ID Layout of SAWA

~-4I~Z i~

a*

A i

TEUWU FU L__I aze*tl*n

~ r, tl ii V I  !

Check Valves * ...

.ma .mo fAf~ThV~\ I~VV~P\

~

4----.--

t/A ts*

Feedwater System Page 58 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 4: Failure Evaluation Table Table 4A: Wetwell HCVS Failure Evaluation Table Functional Failure Failure Cause Alternate Action Failure with Alternate Mode Action Prevents Containment Venting?

Fail to Vent (Open) Valves fail to open/close due to loss of normal None required - system SOVs utilize No on Demand AC power/DC batteries, dedicated 24-hour power supply.____________

Valves fail to open/close due to depletion of Recharge system with provided portable No dedicated power supply. generators. ____________

Valves fail to open/close due to complete loss Manually operate backup pneumatic No of power supplies, supply/vent lines at ROS. ____________

Valves fail to open/close due to loss of normal No action needed. Valves are provided with No pneumatic supply. dedicated motive force capable of 24-hour operation.____________

Valves fail to open/close due to loss of Replace bottles as needed and/or recharge No alternate pneumatic supply (long term). with portable air compressors. ____________

Valve fails to open/close due to SOV failure. Manually operate backup pneumatic No

________________________________supply/vent lines at ROS. ____________

Fail to stop venting Not credible as there is not a common mode N/A No (Close) on demand failure that would prevent the closure of at least 1 of the 2 valves needed for venting.

Both valves designed to fail shut. ____________

Spurious Opening Not credible as key-locked switches prevent N/A No mispositioning of the HCVS PCI~s and additionally, DC power for the solenoid valve is normally de-energized. ____________

Spurious Closure Valves fail to remain open due to depletion of Recharge system with provided portable No dedicated power supply, generators. ____________

Valves fail to remain open due to complete Manually operate backup pneumatic No loss of power supplies, supply/vent lines at ROS. ____________

Valves fail to remain open due to loss of Replace bottles as needed and/or recharge No alternate pneumatic supply (long term). with portable air compressors.

Page 59 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 5: References

1. Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated June 8, 2015 (ML15159A385) for NMP1

2. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989

3. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

4. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 2013

5. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012

6. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated November 14, 2013

7. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-TSG-2012-02: Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012

8. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

9. NET 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 2015

10. NET 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014

11. NET 14-0 1, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014

12. NET HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations

13. NET HCVS-FAQ-02, HCVS Dedicated Equipment

14. NET HCVS-FAQ-03, HCVS Alternate Control Operating Mechanisms

15. NET HCVS-FAQ-04, HCVS Release Point

16. NET HCVS-FAQ-05, HCVS Control and 'Boundary Valves'

17. NET HCVS-FAQ-06, FLEX Assumptions/HCVS Generic Assumptions

18. NET HCVS-FAQ-07, Consideration of Release from Spent Fuel Pool Anomalies

19. NET HCVS-FAQ-08, HCVS Instrument Qualifications

20. NET HCVS-FAQ-09, Use of Toolbox Actions for Personnel

21. NET White Paper HCVS-WP-01, HCVS Dedicated Power and Motive Force

22. NET White Paper HCVS-WP-02, HCVS Cyclic Operations Approach

23. NET White Paper HCVS-WP-03, Hydrogen/CO Control Measures

24. Not Used

25. NUREG/CR-7110, Rev. 1, State-of-the-Art Reactor Consequence Analysis Project, Volume 1: Peach Bottom Integrated Analysis

26. SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark ITContainments, 11/26/12

27. NMP1 UFSAR, Rev. 23, Updated Final Safety Analysis Report

28. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations

29. FLEX MAAP Endorsement ML13190A201

30. N1-2014-004, MAAP 4.0.6 Analysis of Nine Mile Point Unit 1 Loss of All AC Power Scenario With Successful FLEX Short Term

31. JLD-ISG-20 15-01, 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, dated April 2015

32. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade, Revision 0, dated August 17, 2015

33. NET HCVS-FAQ-10, Severe Accident Multiple Unit Response

34. NET HCVS-FAQ-1 1, Plant Response During a Severe Accident Page 60 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents

35. NEI HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial use

36. NET HCVS-FAQ-13, Severe Accident Venting Actions Validation Page 61 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 6: Changes/Updates to this Overall Integrated Implementation Plan This Overall IntegratedPlan has been updated in format and content to encompass both Phase 1 and Phase 2 of Order EA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6-Month Status Reports.

Page 62 of 64

Enclosure 1 - Nine Mile Point Unit 1 Overall Integrated Plan for Reliable Hardened Vents Attachment 7: List of Overall Integrated Plan Open Items Th'e followving tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each~itenm.

qpen Open Items from O1P Status Item

1. Performfinal sizing evaluationfor HCVS batteries and battery charger and include in FLEX DG Deleted (closed to ISE open item number 7 below)

-' :. loading calculation.

2. Performfinal vent capacity calculationfor the Torus HCVS piping confirming 1 % minimum Deleted (closed to ISE open item number 2 below)

, capacity.

3. Performfinal sizing evaluationfor pneumatic Nitrogen (N2) supply. Deleted (closed to ISE open item number 8 below)

4. Perform confirmatory environmental condition evaluationfor the Turbine Building in the vicinity Deleted (closed to ISE open item numbers 6 and 11

• , of the Remote OperatingStation (ROS) and HCVS dedicatedpneumatic supply and batteries, below)

5. State which approach or combination of approaches the plant determines is necessary to address Deleted (closed to ISE open item number 3 below)

• ' the control of combustible gases downstream of the HCVS control valve.

6. Complete evaluationfor environmental/seismicqualificationof HCVS components. Deleted (closed to ISE open item numbers 9 and i1 below)

7. Complete evaluationfor environmental conditions and confirm the travel path accessibility. Deleted (closed to ISE open item number 6 below)

8. ,, Perform radiologicalevaluationfor Phase 1Ivent line impact on ERO response actions. Not Started Op~en: Interim Staff Evaluation (ISE) Open Items Status Item",

.I1 Make availablefor NRC staff audit the seismic and tornado missile final design criteriafor the Started. As discussed in the December 2015 OIP

,* HCVS stack. submittal, the NMP1 design complies with the reasonable tornadoprotection criteriaof HCVS-WP-04.

2 Make availablefor NRC staff audit analyses demonstrating that HCVS has the capacity to vent Started.

.the steam/energy equivalent of one percent of licensed/rated thermalpower (unless a lower value

, .. is justified), and that the suppression pool and the HCVS together are able to absorb and reject Page 63 of 64

!,. Enclosure 1 - Nine Mile Point Unit 1

~Overall Integrated Plan for Reliable Hardened Vents decay heat, such thatfollowing a reactorshutdown from full power containmentpressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

3Provide a description of the final design of the HCVS to address hydrogen detonation and Started. As discussed in the December 2015 QIP deflagration. submittal, the NMP1 design will use an Argon purge system to prevent the possibility of hydrogen

~detonation and deflagration.

4 Make availablefor NRC staff audit documentation that demonstrates.adequatecommunication Not Started

'* between the remote HCVS operation locations and HCVS decision makers during FLAP and

' severe accident conditions.

5 Provide a description of the strategiesfor hydrogen control that minimizes the potentialfor Started. As discussed in the December 2015 OIP,

• hydrogen gas migrationand ingress into the reactor building or other buildings. the NMP1 wetwell vent line has a dedicated HCVS

, "flowpath from the wetwell penetration PCIVs to the outside with no interconnected system. The dischargepoint meets the guidance of HCVS-FAQ-04.

6 Make availablefor NRC staff audit an evaluation of temperature and radiologicalconditions to Started

• ensure that operatingpersonnel can safely access and operate controls and support equipment.

7 Make availablefor NRC staff audit the final sizing evaluationfor HCVS batteries/batterycharger Started

/' including incorporationinto FLEX DG loading calculation.

8 Make availablefor NRC staff audit documentation of the HCVS nitrogenpneumatic system Started design including sizing and location.

9 Make availablefor NRC staff audit documentation of a seismic qualification evaluation of HCVS Not Started

! components.

10 !. Make availablefor NRC staff audit descriptions of all instrumentationand controls (existing and Started

" planned) necessary to implement this order including qualification methods.

I1 Make availablefor NRC staff audit the descriptionsof local conditions (temperature, radiation Started

, and humidity) anticipatedduring ELAP and severe accidentfor the components (valves, instrumentation,sensors, transmitters, indicators, electronics, control devices, etc.) requiredfor HCVS venting including confirmation that the components are capable ofperforming their

• functions during FLAP and severe accident conditions.________________________

Phase 2 Action Comment Open Item

_______-Perform radiologicalevaluation to determine the SA WA flow control point location. Not Started 2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Page 64 of 64

Enclosure 2 Nine Mile Point Nuclear Station, Unit 2 Overall Integrated Plan for Phase 1 and Phase 2 Requirements for Reliable Hardened Containment Vent System (HCVS) Capable of Operation Under Severe Accident Conditions (66 pages)

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Table of Contents:

Introduction Part 1: General Integrated Plan Elements and Assumptions Part 2: Boundary Conditions for Wet Well Vent Part 3: Boundary Conditions for EA-13-109, Option B.2 Part 301 Boundary Conditions for SAWA Part 3.1A Boundary Conditions for SAWAISAWM Part 3.1B Boundary Conditions for SAWA/SADV Part 4: Programmatic Controls, Training, Drills and Maintenance Part 5: Implementation Schedule Milestones : HCVS/SAWA Portable Equipment A: Sequence of Events Timeline - HCVS .1.A: Sequence of Events Timeline - SAWA / SAWM .1.B: Sequence of Events Timeline - SADV .1.C: SAWA / SAWM Plant-Specific Datum .1.D: SAWM SAMG Approved Language : Conceptual Sketches : Failure Evaluation Table : References : Changes/Updates to this Overall Integrated Implementation Plan : List of Overall Integrated Plan Open Items Page 1 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Introduction In 1989, the NRC issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent," (Reference 2) to all licensees of Boiling Water Reactors (BWRs) with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the suppression pooi to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell.

On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff per Staff Requirements Memorandum (SRM) for SECY-12-0 157 (Reference 26) to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013 (Reference 4). The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent 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 while maintaining 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 vents to assist in preventing core damage and, if necessary, to provide 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 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 (IS G) (JLD-IS G-2013-02) issued in November 2013 (Reference 6) and JLD -ISG-2015-01 issued in April 2015 (Reference 31). These ISGs endorse the compliance approach presented in NEI 13-02 Revisions 0 and 1, Compliance with Order EA-13-1 09, Severe Accident Reliable Hardened Containment Vents (Reference 9), with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA-13-109, the NRC staff will use the methods described in these JSGs 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. This document provides the Overall Integrated Plan (0Th:)

for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRC Page 2 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents JLD-ISG-2013-02 and JLD-ISG-2015-01. Six month progress reports will be provided consistent with the requirements of Order EA- 13-109.

The submittals required are:

• OIP for Phase 1 of EA-13-109 was required to be submitted by Licensees to the NRC by June 30, 2014. The NRC requires periodic (6-month) updates for the HCVS actions being taken. The first update for Phase 1 was due December 2014, with the second due June 2015.

• OIP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31, 2015. It is expected the December 2015 six month update for Phase 1 will be combined with the Phase 20OIP submittal by means of a combined Phase 1 and 20GIP.

• Thereafter, the 6-month updates will be for both the Phase 1 and Phase 2 actions until complete, consistent with the requirements of Order EA-13-109.

Note: At the Licensee's option, the December 2015 six month update for Phase 1 may be independent of the Phase 20GIP submittal, but will require separate six month updates for Phases 1 and 2 until each phase is in compliance. NMP2 is providing a combined OIP for December 2015 submittal.

NMP2 venting actions for the EA-13-109, Phase 1 severe accident capable venting scenario can be summarized by the following:

• The Hardened Containment Vent System (HCVS) will be initiated via manual action at the Remote Operating Station (ROS) combined with control from either the Main Control Room (MCR) or the ROS at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms. The ROS provides backup manual operation of the HCVS valves and purge system as required per Order EA-13-109 Requirement 1.2.5. The vent will utilize Containment Parameters of Pressure and Level from the MCR instrumentation to monitor effectiveness of the venting actions.

• The vent operation will be monitored by HCVS valve position, temperature and effluent radiation levels.

• The HCVS motive force has the capacity to operate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with installed equipment.

Replenishment of the motive force will be by use of portable equipment once the installed motive force is exhausted.

• Venting actions will be capable of being maintained for a sustained period of up to 7 days.

The Phase 2 actions can be summarized as follows:

• Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV) or Drywell.

• Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for the removal of decay heat from containment.

• Ensure that the decay heat can be removed from the containment for seven (7) days using the HCVS or describe the alternate method(s) to remove decay heat from the containment from the

-Pa-ge 3 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents time the HCVS is no longer functional until alternate means of decay heat removal are established that make it unlikely the drywell vent will be required for DW pressure control.

• The SAWA and SAWM actions will be manually activated and controlled from areas that are accessible during severe accident conditions.

• Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate and the HCVS parameters listed above.

Note: Although EA-13-109 Phase 2 allows selecting SAWA and a Severe Accident Capable Drywell Vent (SADV) strategy, Exelon has selected SAWA and SAWM.

Page 4 of 66-

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 1: General Integrated Plan Elements and Assumptions Extent to which the guidance, JLD-ISG-2013-02, JLD-ISG-2015-01, and NET 13-02 (Revision 1), are being followed. Identify any deviations.

Include a description of any alternatives to the guidance. A technicaljustification and basisfor the alternative needs to be provided. This will likely require a pre-meeting with the NRC to review the alternative.

Ref: JLD-LSG-2013-02, JLD-2015-01 Compliance will be attained for Nine Mile Point Unit 2 (NMP2) with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-2015-01, and NHI 13-02 for each phase as follows:

• The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment and operating guidance:

• Severe Accident Wetwell Vent (SAWV) - Permanently installed vent from the Suppression Pool to the top of the Reactor Building.

• Severe Accident Water Addition (SAWA) - A combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and monitor system and plant conditions.

• Severe Accident Water Management (SAWM) strategies and guidance for controlling the water addition to the RPV for the sustained operating period. (reference attachment 2.1 .D)

• Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Currently scheduled for 2 nd quarter 2016.

• Phase 2 (alternate strategy): by the startup from first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first. Currently scheduled for 2 nd quarter 2018.

If deviations are identified at a later date, then the deviations will be communicated in a future 6-month update following identification.

State Applicable Extreme External Hazard from NET 12-06, Section 4.0-9.0 List resultant determination of screened in hazardsfrom the EA-12-049 Compliance.

Ref: NEI 13-02, Section 5.2.3 and D.1.2 The following extreme external hazards screen in for NMP2:

• Seismic, external flooding, tornado, extreme cold, extreme high temperature, and ice/snow The following extreme external hazards screen out for NMP2:

• Straight wind Key Site assumptions to implement NET 13-02 strategies.

Provide key assumptions associated with implementation of HCVS Phase 1Strategies Ref: NEI 13-02, Revision 1, Section 2 NEL 12-06, Revision 0 Page 5 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Mark TIll Generic HCVS Related Assumptions:

Applicable EA-12-049 (Reference 3) assumptions:

049-1. Assumed initial plant conditions are as identified in NEI 12-06, §3.2.1.2, items 1 and 2 (Reference 8).

049-2. Assumed initial conditions are as identified in NEI 12-06, §3.2.1.3, items 1, 2, 4, 5, 6 and 8 (Reference 8).

049-3. Assumed reactor transient boundary conditions are as identified in NET 12-06, §3.2.1.4, items 1, 2, 3 and 4.

049-4. No additional events or failures are assumed to occur immediately prior to or during the event, including security events, except for the failure of Reactor Core Isolation Cooling (RCIC) (Reference NEI 12-06,

§3.2.1.3, item 9 [8]).

049-5. At time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP is occurring at any or all of the units.

049-6. At time=l hour actions begin as defined in EA-12-049 compliance.

049-7. The HCVS system will include a dedicated 125 VDC battery panel sized for 24-hours of HCVS operation.

Beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FLEX power will be provided from a 600 VAC bus that will be repowered from the portable FLEX diesel generator. (NEI 12-06, section 3.2.1.3 item 8) 049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

049-9. All activities associated with EA-12-049 (FLEX) that are not specific to implementation of the HCVS, including such items as debris removal, communication, notifications, Spent Fuel Pool (SFP) level and makeup, security response, opening doors for cooling, and initiating conditions for the events, can be credited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity on SAWA)(HCVS-FAQ-i11.)

Applicable EA-13-109 (Reference 4) generic assumptions:

109-1. Site response activities associated with EA-13-109 actions are considered to have no access limitations associated with radiological conditions while Reactor Pressure Vessel (RPV) level is above 2/3 core height (core damage is not expected). This is further addressed in HCVS-FAQ-12.

109-2. Portable equipment can supplement the installed equipment after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the portable equipment credited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supply equipment that is credited to recharge air lines for HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The FLEX portable air supply used must be demonstrated to meet the "SA Capable" criteria that are defined in NEI 13-02 Section 4.2.4.2 and Appendix D Section D.1.3 (Reference 9). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time of the loss of RPV injection (Reference HCVS-FAQ-12).

109-3. SFP Level is maintained with either on-site or off-site resources such that the SFP does not contribute to the analyzed source term (Reference HCVS-FAQ-07 [18]).

109-4. Existing containment components design and testing values are governed by existing plant containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NET 13-02 (Reference HCVS-FAQ-O5 [16] and NET 13-02, §6.2.2 [9]).

109-5. Classical design basis evaluations and assumptions are not required when assessing the operation of the HCVS. The reason that this is not required is that the order postulates an unsuccessful mitigation of an event such that an ELAP progresses to a severe accident with ex-vessel core debris that classical design basis evaluations are intended to prevent (Reference NEI 13-02, §2.3.1 [91).

109-6. HCVS manual actions require minimal operator steps and can be performed in the postulated thermal radiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation, Page 6of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality (Reference HCVS-FAQ-01l[12]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time of the loss of RPV injection and will require more than minimal operator action.

109-7. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to function in an ELAP event that progresses to core melt ex-vessel (Reference HCVS-FAQ-02 [13] and White Paper HCVS-WP-01 [21]). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment is not dedicated to HCVS but shared to support FLEX functionfs. This is further addressed in HCVS-FAQ-i11.

109-8. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV water level, temperatures, etc.) assumed for Order EA-13-109 Beyond Design Basis External Event (BDBEE) and SA HCVS operation (Reference FLEX MAAP Endorsement ML13190A201 [29]). Additional analysis using RELAP5/MOD 3, GOTHIC, and MICROSHIELD, etc., are acceptable methods for evaluating environmental conditions in other portions of the plant, provided that the specific version utilized is documented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 to support drywell temperature response to SAWA under severe accident conditions.

109-9. NRC Published Accident evaluations (e.g., SOARCA, SECY-12-0157, NUREG 1465) as related to Order.

EA-13-109 conditions are acceptable as references (Reference NEI 13-02, §8 [9]).

109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may be credited for use in Order EA-13-109 response.

109-11. This Overall Integrated Plan is based on Emergency Operating Procedure (EOP) changes consistent with Emergency Procedures Guidelines/Severe Accident Guidelines (EPG/SAGs) Revision 3 as incorporated per the site's EOP/Severe Accident Procedure (SAP) procedure change process. This assumption does not apply to Phase 2 SAWMV because SAWM is not part of revision 3. (Refer to Attachment 2.1 .D for SAWM SAMG changes approved by the BWROG Emergency Procedures Committee.)

109-12. Under the postulated scenarios of Order EA-13-109, the Main Control Room is adequately protected from excessive radiation dose as per General Design Criterion (GDC) 19 in 10CFR50 Appendix A and no further evaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is a sufficient distance away from, the MCR or is shielded to minimize impact to the MCR dose. In addition, adequate protective clothing and respiratory protection are available if required to address contamination issues (Reference HCVS-FAQ-01 [12] and HCVS-FAQ-09).

109-13. The suppression pool/wetwell of a BWR Mark 111I containment is considered to be bounded by assuming a saturated environment for the duration of the event response because of the water/steam interactions.

109-14. RPV depressurization is directed by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1 §I. 1.3) 109-15. The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure the capability to protect containment exists for each unit. (HCVS-FAQ-01) This is further addressed in HCVS-FAQ-1O.

Plant Specific HCVS Related Assumptions/Characteristics:

NMP2-1 EA-12-049 (FLEX) actions to restore power are sufficient to ensure continuous operation of non-dedicated containment instrumentation identified in the instrument table under the Component Qualification section of this OIP'.

NMP2-2 Modifications that allow a FLEX generator to be connected to a 600 volt safety related bus are assumed

-Page 7 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents to have been installed such that a FLEX generator can be credited for HCVS operation beyond the initial 24-hour sustained operational period.

NMP2-3 The rupture disk will be manually breached if required for anticipatory venting during an ELAP.

NMP2-4 The Plant layout of buildings and structures are depicted in Sketches 3B and 3C. Note the Main Control Room is located on the turbine deck elevation. The Control Building has substantial structural walls and features independent of the Reactor Building. The FIGVS vent stack external to the Reactor Building is indicated on Sketch 2A.

NMP2-5 The HCVS external piping is all above 30-feet from ground level, consists solely of large bore (16-inches nominal diameter) piping and its piping supports, and has less than 300 square feet of cross section. The HCVS external piping meets the reasonable protection requirements of HCVS-WP-04.

Page 8 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint.

HCVS Actions that have a time constraint to be successful should be identified with a technical basis and a justificationprovided that the time can reasonably be met (for example, action to open vent valves).

HCVS Actions that have an environmental constraint(e.g. actions in areas of High Thermal stress or High Dose areas) should be evaluatedper guidance.

Describe in detail in this section the technical basisfor the constraints identified on the sequence of events timeline attachment.

See attached sequence of events time line (Attachment 2A).

Ref: EA-13-109, Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02, Section 4.2.5, 4.2.6. 6.1.1 The operation of the HCVS has been designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by trained plant personnel and will include the capability for remote-manual initiation from the HCVS control station. A list of the remote manual actions performed by plant personnel to open the HCVS vent path can be found in the following table (Table 2-1). A HCVS ELAP Failure Evaluation table, which shows alternate actions that can be performed, is included in Attachment 4.

Table 2-1 HCVS Remote Manual Actions Primary Action Primary Location/ Notes SComponent _ _ _

1. Open inner track bay door. i Reactor Building Track Bay iAction only required i i in winter months to i i keep Track bay i >50 °F.

2. Isolate three-way valve leak-off iROS, 2CPS-V 168 (Three-way Required step to connection upstream of the rupture iValve) iprevent venting into disc. Open Nitrogen and Argon i2CPS-V 150 (Nitrogen Isolation ithe Reactor Building isolation valves, ave through the small Valve)leak-off path.

i2CPS-V 160A thru F (Argon isolation valves)

3. Breach the rupture disc by ROS, 2CPS-V140A; or unlocking and opening the purge MC isolation valve. i MR 2CPS-SOVl40O

4. As soon as disc is breached, close iROS, 2CPS-V140A or MCR, purge isolation valve.! 2CPS-SOV 140

5. Open Suppression Chamber iKey-locked switch for 2CPS- iAlternate control via inboard Containment Isolation iSOV109A at HCVS Control imanual valves at Valve (CIV) 2CPS*AOVI109. Panel in MCR ROS.

Page 9 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent

6. Open Suppression Chamber SKey-locked switch for 2CPS- Alternate control via outboard Containment Isolation !SOVll1lA at HCVS Control manual valves at Valve (CIV) 2CPS*AOVl 11. iPanel in MCR ROS.

7. Open HCVS Isolation Valve Key-locked switch for 2CPS- Alternate control via

[2CPS-AOV134]. AOVl34A at HCVS Control manual valves at SPanel in MCR ROS.

8... Mionitor electrical power status ...........iHCVS ControliPanelin MCR ......This....

action not .................

and t1-VS conditions. requirea control. ror aiternate

9. Connect back-up power to HCVS Reactor Building Track Bay IIPrior to depletion of battery charger. the dedicated HCVS power supply batteries (no less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from Sinitiation of ELAP).

Not necessary if FLEX diesel generator is ne~ratiniY

10. Replenish pneumatic supply with Reactor Building Track Bay Prior to depletion of replaceable Nitrogen bottles or the pneumatic/purge portable air compressor. Replenish supply (no less than purge supply with replaceable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from Argon bottles. initiation of ELAP). A, Sequence of Events Timeline, was developed to identify required operator response times and potential environmental constraints. This timeline is based upon the following three sequences:

1. Sequence 1 is based upon the action response times developed for FLEX when utilizing anticipatory venting in a BDBEE without core damage.

2. Sequence 2 is based on NUREG-1935 (SOARCA) results for an ELAP with early loss of RCIC.

3. Sequence 3 is based on a SECY-12-0 157 SBO (ELAP) with failure of RCIC because of subjectively assuming over injection.

The following is a discussion of time constraints identified in Attachment 2A for the 3 timeline sequences identified above:

• 7 Hours, Initiate use of HCVS per site procedures to maintain containment parameters within the limits that allow continued use of RCIC (Section A4.3 Reference 24). Initiation of the HCVS is completed first with manipulation of a three way valve and isolation valves at the ROS, then the manipulation of 4 switches located within the MCR or manipulation of manual bypass valves at the ROS. The reliable operation of HCVS will be met because HCVS meets the seismic requirements identified in NEI 13-02 and will be powered by dedicated HCVS batteries with motive force supplied to HCVS valves from installed nitrogen storage bottles. HCVS controls and HCVS instrumentation will be provided from a panel installed in the MCR. Other containment parameter instrumentation associated with operation of Page 10 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent the HCVS is available in the MCR. Operation of the system will be available from either the MCR or a ROS. Dedicated HCVS batteries will provide power for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, as action is only required in one location other than the MCR, initiation of the HCVS within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> is achievable due to the simplicity and limited number of operator actions. Placing the HCVS in operation to maintain containment parameters within design limits for either BDBEE or SA venting would occur at a time further removed from ELAP declaration as shown in Attachment 2.

• 24 Hours, Replace additional nitrogen bottles. Also, the nitrogen station will have a connection so that an air compressor can be connected; however, this is not the planned method to replenish the motive air supply beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• 24 Hours, Replace Argon bottles, as required, to maintain sustained operation. Note that Argon purging is required only if the ELAP progresses to severe accident conditions.

• 24 Hours, Connect back-up power to HCVS battery charger. The HCVS batteries are calculated to last a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (ISE Open Item #8). The HCVS battery charger will be able to be re-powered either from a 600VAC bus that will be re-powered from a portable diesel generator (DG) put in place for FLEX or locally (Reactor Building Track Bay) from a small portable generator. The DG will be staged and placed in service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Reference 1) and therefore will be available prior to being required.

In the event that the DG is not available, a local connection will allow a small portable generator to be connected to the battery charger to provide power. Connection of a small portable generator is achievable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

[ISF OPEN ITEM-8: Perform final sizing evaluation for TICVS batteries/battery charger and incorporate in FLEX DG loading calculation.]

Discussion of radiological, temperature, other environmental constraints identified in Attachment 2A

• Actions to initiate HCVS operation are taken from the MCR or from the ROS in the Reactor Building Track Bay. Both locations have significant shielding and physical separation from radiological sources.

Non-radiological habitability for the MCR has been addressed as part of the FLEX response (Reference 1). The location in the Reactor Building Track Bay has no heat sources and will have open doors to provide ventilation if necessary.

• Actions to replenish the pneumatic and Argon purge supplies will be completed from the Reactor Building Track Bay. The Reactor Building Track Bay is located on the Northeast side of the Reactor Building. The HCVS will exit the Reactor Building on the west side of the Reactor Building approximately 60' from ground elevation which is at elevation 261'. Therefore, the location for pneumatic and Argon supply replenishment is shielded from the HCVS piping by the Reactor Building itself and is greater than 100' away from the piping.

• Actions to install the DG will occur on the East side of the NMP2 Control Building and within the Control Building itself. The Control Building is located on the south side of the Reactor Building. The locations for installation (and control) of the DG are therefore shielded from HCVS piping by the Reactor Building and is greater than 100' away from the piping. In the event that this DG cannot be operated, the backup portable generator would be connected to the UPS in the Reactor Building Track Bay, which is also a shielded location.

~Page 11 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent Provide Details on the Vent characteristics Vent Size and Basis (EA 1 09. Section 1.2.1/INEI 13-02. Section 4.1.1)

What is the plants licensed power? Discuss any plansfor possible increases in licensed power (e.g. MUR, EPU). What is the nominal diameter of the vent pipe in inches? Is the basis determined by venting at containment design pressure, PCPL, or some other criteria (e.g. anticipatory venting)?

Vent Capacity (EA-13-1 09. Section 1.2.1/INEI 13-02. Section 4.1.1)

Indicate any exceptions to the 1% decay heat removal criteria,including reasonsfor the exception. Provide the heat capacity of the suppressionpool in terms of time versus pressurizationcapacity, assuming suppression pool is the injection source.

Vent Path and Discharge (EA-13-109, Section 1.1.4. 1.2.2 I NEI 13-02, Section 4.1.3, 4.1.5 and Appendix FIG)

Provide a description of Vent path, releasepath, and impact of vent path on other vent element items.

Power and Pneumatic Supply Sources (EA-13-1 09, Section 1.2.5 & 1.2.6/INEI 13-02, Section 4.2.3, 2.5.

4.2.2. 4.2.6, 6.1)

Provide a discussion of electricalpower requirements, including a description of dedicated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power supply from permanently installedsources. Include a similar discussion as above for the valve motive force requirements. Indicate the area in the plantfrom where the installed/dedicatedpower and pneumatic supply sources are coming.

Indicate the areas where portable equipment will be staged after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the dose fields in the area, and any shielding that would be necessary in that area.

Location of Control Panels (EA-13-109, Section 1.1.1, 1.1.2, 1.1.3. 1.1.4, 1.2.4, 1.2.5 /NEI113-02, Section 4.1.3, 4.2.2. 4.2.3, 4.2.5, 4.2.6, 6.1.1. and Appendix FIG)

Indicate the location of the panels, and the dose fields in the area during severe accidents and any shielding that would be requiredin the area. This can be a qualitative assessment based on criteriain NEI 13-02.

Hydrogen (EA-13-109,Section 1.2.10, &l.2.11, and 1.2.12/INEI 13-02, Section 2.3,2.4, 4.1.1, 4.1.6, 4.1.7, 5.1, &Appendix H)

State which approach or combination of approaches the plant will take to address the control offlammable gases, clearly demarcating the segments of vent system to which an approachapplies.

Unintended Cross Flow of Vented Fluids (EA-13-109. Section 1.2.3, 1.2.12 I/NEI 13-02, Section 4.1.2, 4.1.4, 4.1.6 and Appendix H)

Provide a description to eliminate/minimize unintended crossflow of vented fluids with emphasis on interfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakage through interfacing valves or Appendix]J type testingfeatures?

Prevention of Inadvertent Actuation (EA-13-109, Section 1.2. 7/NEI 13-02, Section 4.2.1)

The HCVS shall include means to prevent inadvertent actuation.

Component Qualifications (EA-13-109, Section 2.1/INEI 13-02, Section 5.1)

State qualificationcriteriabased on use of a combination of safety related and atugmented quality dependent on Page 12 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent the location,function and interconnected system requiremnents.

Monitoring~of HCVS (Order Elements 1.1.4, 1.2.8. 1.2.9/NEI 13-02 4.1.3, 4.2.2. 4.2.4. and Appendix FIG)

Provide a description of instruments used to monitor HCVS operation and effluent. Powerfor an instrument will require the intrinsically safe equipment installed as part of the power sourcing Component reliableand rug~ged performance (EA-13-109. Section 2.2 I/NEI 13-02. Section 5.2, 5.3)

HCVS components including instrumentation should be designed, as a minimum, to meet the seismic design requirements of the plant.

Components including instrumentation that are not required to be seismically designed by the design basis of the plant should be designedfor reliable and rugged performance that is capable of ensuring HCVS Iinctionalityfollowing a seismic event. (Reference JLD-ISG-2012-01 and JLD-ISG-2012-03 for seismic details.)

The components including instrumentation external to a seismic category 1 (or equivalent building or enclosure should be designed to meet the external hazards that screen in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-OJfor Order EA-12-049.

Use of instruments and supporting components with known operatingprinciples that are supplied by manufacturers with commercial quality assurance prograins, such as 1509001. The procurementspecifications shall include the seismic requirements and/or instrument design requirements, and specify the needfor commercial design standards and testing under seismic loadings consistent with design basis values at the instrument locations.

Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualificationtesting under simnulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-2004, "IEEE Recommended Practicefor Seismic Qualification of Class 1E Equipmentfor Nuclear Power Generating Stations," or a substantially similar industrialstandard could be used.

Demonstration that the instrumentation is substantially similar in design to instrumentation that has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performedfor the plant licensing basis.

Vent Size and Basis NMP2 is licensed to operate at a thermal power of 3988MW due to a recent extended power uprate project.

There are no current plans to further increase the power level.

The HCVS wetwell path is designed for venting steam/energy at a minimum capacity of 1% of 3988 MW thermal power at pressure of 45 psig (ISF Open Item #3) assuming nominal suppression pooi water level. This pressure is the lower of the containment design pressure and the Primary Containment Pressure Limit (PCPL) value, which are both 45 psig. The size of the wetwell portion of the HCVS is > 12 inches in diameter which provides adequate capacity to meet or exceed the Order criteria, as confirmed in the vent capacity calculation.

• Page 13 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent

[ISE OPEN ITEM-3: Perform final vent capacity calculation for the HCVS piping confirming 1%

minimum capacity.]

Vent Capacity The 1% value at NMP2 assumes that the suppression pool has sufficient capacity to absorb the decay heat generated for a minimum of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> without allowing containment pressure to exceed 45 psig (PCPL) after which point decay heat is less than or equal to 1%. The vent would then be able to prevent containment pressure from increasing above the PCPL. The duration of suppression pooi decay heat absorption capability has been confirmed (Reference 30).

Vent Path and Discharge The HCVS vent path at NMP2 utilizes existing Containment Purge System piping from the suppression chamber and drywell up to the Standby Gas Treatment System isolation valves (2GTS*AOV101 and 2GTS*SOV102). The inboard primary containment isolation valves (PCIV) on the suppression chamber line will be relocated from inside the containment to outside the containment. The outboard PCIV will be relocated to provide room for the inboard valve. The suppression chamber piping exits the containment into the Reactor Building and continues for approximately 140' until it ties into a combined Drywell/Wetwell 20" header. New 16" piping will tie into this header upstream of 2GTS*AOV 101/SOV 102. A new air-operated valve will be provided in this piping, which will serve as the means to control HCVS flow. Although this control valve is not a PCIV, it is designed and fabricated to the same requirements as the HCV$S PCIVs. A rupture disc will be added downstream of this control valve to serve as the secondary containment pressure boundary and to prevent secondary containment bypass leakage due to valve leakage during a design basis LOCA. The discharge piping will exit through the Reactor Building wall approximately 60' above ground elevation and will be routed over to and up the Northwest side of the Reactor Building to a discharge point approximately 3' above the highest point of the Reactor Building roof. The NMP2 vent path is completely separate from the Nine Mile Point Unit 1 (NMP1) vent path. The external piping meets the reasonable protection requirements of HCVS-WP-04 for tornado missiles (Refer to NMP2-5 assumption).

Power and Pneumatic Supply Sources All electrical power required for operation of HCVS components will be provided by dedicated HCVS batteries with a minimum capacity capable of providing power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without recharging. An evaluation has been completed as part of the detailed design process (ISE Open Item #8). A battery charger is provided that requires a 120 VAC supply. This will be provided by a 120 VAC bus that will be re-powered by a diesel generator as part of the FLEX response. In addition, a connection point that utilizes standard electrical connections will be provided for a portable generator for sustained operation of the HCVS.

For the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the event, the motive supply for the air-operated valves (AOVs) will be nitrogen gas bottles that will be pre-installed and available. These bottles will be sized such that they can provide motive force for at least 8 cycles of a vent path, which includes two openings for each of the two PCIVs (2CPS*AOV109 and *AOVl111) and at least 8 openings of the HCVS isolation valve, 2CPS-AOV134.

A final evaluation will be completed as part of the detailed design process when selection of the system AOVs is finalized (1SE Open Item #9).

[ISE OPEN ITEM-9: Perform final sizing evaluation for pneumatic Nitrogen (N2) supply.]

The permanent motive force supply and HCVS batteries will be located at the ROS in the Reactor Building Track Bay. Supplemental motive force (e.g., additional nit'rogen gas bottles, air compressor.), portable Page 14 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent generators, and enough fuel for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of operation will be stored on site in an area that is reasonably protected from assumed hazards consistent with the requirements of NEI 12-06. Pre-engineered quick disconnects will be provided to connect the supplemental motive force supply.

1. The FICVS flow path valves are AOVs that are air-to-open and spring-to-shut. Opening the valves requires energizing a DC powered solenoid operated valve (SOV) and providing motive air/gas. A backup means of operation is also available that does not require energizing or repositioning the SOV.

2. An assessment of temperature and radiological conditions has been performed in ECP-13-000087 and calculation H21C-1 14 to ensure operating personnel can safely access and operate controls at the ROS based on time constraints listed in Attachment 2A.

3. All permanently installed HCVS equipment, including any connections required to supplement the HCVS operation during an ELAP (electric power, N2/air) will be located in areas reasonably protected from the hazards listed in Part 1 of this report.

4. All valves required tO open the flow path will be designed for remote manual operation following an ELAP, such that the primary means of valve manipulation does not rely on use of a handwheel, reach-rod, or similar means requiring close proximity to the valve (Reference FAQ HCVS-03, Reference 14).

In addition, the PCIVs and HCVS isolation valve will have a handwheel as an optional means of operation. Any supplemental connections will be pre-engineered to minimize man-power resources and address environmental concerns. Required portable equipment will be reasonably protected from screened in hazards listed in Part 1 of this OIP.

5. Access to the locations described above for the primary means of valve manipulation will not require temporary ladders or scaffolding.

Location of Control Panels A control panel is located in the MCR which allows for the operating and monitoring of the HCVS. A secondary location for HCVS operation is the ROS located in the Reactor Building Track Bay. Both locations are protected from adverse natural phenomena and are sufficiently shielded. The MCR is the normal control point for HCVS operation and Plant Emergency Response actions.

The ROS will be located in the Reactor Building Track Bay. The Track Bay is a seismic category I structure and is also designed to withstand tornado missiles (including the outer door) (ISE Open Item #2).

[ISE OPEN ITEM-2: Perform seismic evaluation of Reactor Building Track Bay.]

Hydrogen As required by EA-13-109, Section 1.2.11, the HCVS design will include an Argon purge system that will he connected just downstream of the HCVS isolation valve. It will be designed to prevent hydrogen detonation downstream of that valve. However, the Argon purge system is required to be used only if the ELAP progresses to severe accident conditions which result in the creation of hydrogen. The Argon purge system will have a switch for the control valve in the MCR to allow opening the purge for the designated time, hut it will also allow for local operation in the ROS in case of a DC power or control circuit failure. The installed capacity for the Argon purge system will be sized for 6 purges within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the ELAP. Evaluation N2-MISC-003, "MAAP Analysis to Support SAWA Strategy" shows that in a severe accident, NMP2 would not be expected to exceed 6 vent cycles in the first 24-hour period. The design allows for Argon bottle replacement for continued operation past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Page 15 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent The Argon purge system can also be used to breach the rupture disc. The MCR panel will include an indication of vent line pressure upstream of the disc to show when the disc has burst due to the increased Argon pressure.

Unintended Cross Flow of Vented Fluids The HCVS for NMP2 is fully independent of NMP1 with separate discharge points. Therefore, the capacity at each unit is independent of the status of the other unit' s HCVS. The only interfacing system with the HCVS is the Standby Gas Treatment System (SGTS). There are two parallel interface isolation valves separating the SGTS and the HCVS discharge piping (one 20" air operated butteffly valve and one 2" AC solenoid operated globe valve5.

The interface valves between the HCVS and the SGTS are normally-closed, fail-closed (spring and solenoid operated) valves. Upon initiation of an ELAP and associated loss of instrument air, the valves would automatically shut due to spring pressure or loss of power to the solenoid. Therefore, no additional power is necessary. These boundary valves are located at a high point of the SGTS piping. When closed, the leakage is minimized. At slow leakage rates, there would be no motive force to move any accumulated hydrogen away from the high point of the piping, thereby preventing a combustible mixture in any areas of the Reactor Building. A test connection will be added downstream of the boundary valves to facilitate Appendix J type testing of the interface valves. Testing and maintenance will be performed to ensure that the valves remain within established leakage criteria.

Prevention of Inadvertent Actuation EOPs/Emergency Response Guidelines provide clear guidance that the HCVS is not to be used to defeat containment integrity during any design basis transients and accident. In addition, the HCVS is designed to provide features that prevent inadvertent HCVS flow path actuation due to a design error, equipment malfunction, or operator error. The PCTVs and HCVS isolation valve are opened when a SOV is energized via a switch in the MCR. These switches are key-locked such that an Operator cannot inadvertently turn the switch. In addition, manual valves which bypass the SOV are also locked closed to prevent inadvertent actuation from actions at the ROS. The SOV and bypass valve on the purge line are also locked to prevent an inadvertent actuation of the purge system.

NMP2 does not credit containment accident pressure for ECCS operation.

Component Qualifications The replacement primary containment isolation valves will maintain their safety-related classification to meet existing design basis requirements. The valves have been specified to be designed to perform their design basis function as well as have the ability to operate in the beyond design basis scenario. Likewise, any electrical or controls component which interfaces with Class lE power sources will be classified as safety related up to applicable isolation devices (e.g., fuses, breakers), as their failure could adversely impact containment isolation and/or a safety-related power source. All safety-related components will be seismically and environmentally qualified in accordance with the design basis of the plant.

All components dedicated solely to the HCVS are classified as augmented quality.

Qualification includes consideration of environmental conditions specified in NEI 13-02. HCVS components will be evaluated to ensure functionality following a design basis earthquake.

Instrumentation and controls components have been selected such that they will be able to operate in the beyond design basis environmental conditions, although these evaluations will not be considered part of the site Environmental Qualification (EQ) program.

Page 16 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent HCVS instrumentation performance (e.g., accuracy and precision) need not exceed that of similar plant installed equipment. Radiation monitoring equipment accuracy will be sufficient to determine a transition from no core damage to core damage.

The HCVS instruments, including valve position indication, process instrumentation, radiation monitoring, and support system monitoring, will be qualified by using one or more of the three methods described in the ISG, whichi includes:

1. Purchase of instruments and supporting components with known operating principles from manufacturers with commercial quality assurance programs (e.g., 1S09001) where the procurement specifications include the applicable seismic requirements, design requirements, and applicable testing.

2. Demonstration of seismic reliability via methods that predict performance described in IEEE 344-2004.

(Reference 28)

3. Demonstration that instrumentation is substantially similar to the design of instrumentation previously qualified.

Instrument Qualification Method I-CVS Process Temperature (RTD) IEEE 344-2004 HCVS Process Pressure (Pressure IEEE 344-2004 Transmitter)

HCVS Process Radiation Monitor IEEE 344-2004 HCVS Process Valve Position IEEE 344-2004 HCVS Pneumatic Supply Pressure (Pressure IEEE 344-2004 Gauge)

HCVS Argon Pressure Indication (Pressure IEEE 344-2004 Gauge)

HCVS Electrical Power Supply Availability IEEE 344-2004 (Yokogawa Recorder)

[ISE OPEN ITEMS-10 and 12: Complete evaluation for environmental/seismic qualification of HCVS components.]

Monitorirng of HCVS The NMP2 wetwell HCVS will be capable of being manually operated during sustained operations from a control panel located in the MCR and will meet the requirements of Order element 1.2.4. The MCR is a readily accessible location with no further evaluation required. MCR dose associated with HCVS operation conforms to GDC 19/Alternate Source Term (AST) for radiation shielding considerations (HCVS-FAQ-01, Reference 12). Additionally, to meet the intent for a secondary control location of section 1.2.5 of the Order, a readily accessible ROS is incorporated into the HCVS design as described in NEI 13-02, section 4.2.2.1.2.1 (Reference 9). The controls at the ROS location will be accessible and functional under a range of plant conditions, including severe accident conditions with due consideration to source term and dose impact on operator exposure, ELAP, and inadequate containment cooling.

-Page 1-7 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent The wetwell HCVS will include indications for HCVS valve position, Argon system pressure, temperature, and effluent radiation levels to aid operator verification of HCVS function. Other important information on the status of supporting systems, such as power source status and pneumatic supply pressure, will also be included in the design and located to support HCVS operation. This instrumentation will be powered from the dedicated HCVS batteries, which provide a minimum of 24-hour supply.

Other instrumentation that supports HCVS function will be provided nearby in the MCR. This includes existing drywell pressure and Suppression Pool level indication. This instrumentation is not required to validate HCVS function and is therefore not powered from the dedicated HCVS batteries. However, these instruments are expected to be available since the DG that supports HCVS battery charger function after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> also supplies the battery charger for these instruments and will be installed prior to depletion of the station batteries. (Reference [ 1])

The HCVS instruments, including valve position indication, temperature instrumentation, radiation monitoring, and support system monitoring, are qualified as previously described.

Component reliable and rugged performance All safety-related components are seismically qualified in accordance with the NMP2 design basis. All other HCVS components, including piping and supports, electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) will be seismically designed or be designed for reliable and rugged operation performance that is capable of ensuring HCVS functionality following a design basis earthquake as required per Section 2.2 of EA-13-109.

For the HCVS instrument's that are required after a potential seismic event, the following methods will be used to verify that the design and installation is reliable / rugged and therefore capable of ensuring HCVS functionality following a seismic event. Applicable instruments are rated by the manufacturer (or otherwise tested) for seismic impact at levels commensurate with those of postulated severe accident event conditions in the area of instrument component use using one or more of the following methods:

• demonstration of seismic motion consistent with that of existing design basis loads at the installed location.

• substantial history of operational reliability in environments with significant vibration with a design envelope inclusive of the effects of seismic motion imparted to the instruments proposed at the location.

• adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practicefor Seismic Qualificationof Class JE Equipmentfor Nuclear Power Generating Stations, (Reference 28 or a substantially similar industrial standard).

• demonstration that proposed devices are substantially similar in design to models that have been previously tested for seismic effects in excess of the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges).

• seismic qualification using seismic motion consistent with that of existing design basis loading at the Page 18 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for Wetwell Vent installation location.

HCVS components are located in the Reactor Building, Control Building, and Reactor Building Track Bay which are all safety-related, seismic class I structures.

The instrumentation/power supplies/cables/connections (components)/conduits will be qualified for temperature, pressure, seismic g values, radiation level, and total integrated radiation dose up to 7 days for the Effluent Vent Pipe and HCVS ROS location. The qualification for the equipment by the supplier will be validated by NMP for the specific location at NMP2 to ensure that the bounding conditions envelope the specific plant conditions.

The only portion of the HCVS system not contained within a seismic, missile protected structure is the vent pipe external to the Reactor Building. However, the external piping meets the tornado reasonable protection criteria of HCVS-WP-04. All external components are limited to large bore piping and its supports, are located above 30' from ground level, and the piping cross section is less than 300 square feet. The vent pipe penetration through the Reactor Building wall is protected from a direct missile which would have any chance of entering the Reactor Building by the steam tunnel vent hood which is located in front of the penetration.

Augmented quality requirements will be applied to the components installed in response to this Order unless higher quality requirements apply.

Page 19 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting Determine venting capability for BDBEE Venting, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109, Section 1.1.4 /NEL 13-02, Section 2.2 First 24 Hour Coping Detail Provide a general description of the venting actionsfor first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.6 / NEI 13-02, Section 2.5, 4.2.2 The HCVS has been designed to minimize reliance on operator actions for response to an ELAP and severe accident events. Immediate operator actions will be completed by qualified plant personnel from either the MCR or the HCVS ROS using remote-manual actions. The operator actions required to open a vent path are as described in Table 2-1. Remote-manual is defined in this report as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting.

Following alignment of the three way valve and gas isolation valves (Table 2-1) at the ROS, the HCVS has been designed to allow initiation, control, and monitoring of venting from the MCR and will be able to be operated from an installed ROS as part of the response to this Order. Both locations minimize plant operators' exposure to adverse temperature and radiological conditions and are protected from hazards assumed in Part 1 of this report.

Permanently installed electrical power, Argon purge gas, and motive air/gas capability will be availableto support operation and monitoring of the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Power will be provided by installed batteries for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before generators will be required to be functional.

System control:

i. Active: PCIVs are operated in accordance with EOPs/SAPs to control containment pressure.

The HCVS is designed for a minimum of 8 open/close cycles of the vent path under ELAP conditions over the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following an ELAP. Controlled venting will be permitted in the revised EOPs.

ii. Passive: Inadvertent actuation protection is provided by use of key-locked switches for HCVS system SOVs and locked manual bypass valves. In addition, a rupture disc is provided downstream of the HCVS flow path valves to preclude valve leakage during a design basis LOCA. The rupture disc would prevent flow following inadvertent opening of the PCIVs provided containment pressure does not exceed the rupture disc setpoint.

Greater Than 24 Hour Coping Detail Provide a general description of the venting actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.4 / NEI 13-02, Section 4.2.2 Actions required to extend venting beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> include replenishment of the HCVS pneumatic and Argon purge system stored gases and recharging the electrical supply.

The pneumatic supply station will be installed in the Reactor Building Track Bay and will include a nitrogen

-Page 20 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting bottle station with an additional connection for an extra nitrogen bottle or for a portable air compressor.

Connections will utilize pre-engineered quick disconnect fittings. Actions to replenish the pneumatic supplies include replacement of nitrogen bottles or installation and fueling of a portable air compressor. Sufficient nitrogen bottles will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The Argon purge system is required only if the ELAP progresses to severe accident conditions and hydrogen is being vented. It will likewise be in the Reactor Building Track bay and will include an Argon bottle station.

Actions to replenish the Argon supplies include replacement of Argon bottles or refilling from an outside source.

Sufficient argon will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The HCVS batteries and battery charger will also be installed in the Reactor Building Track Bay. The UIPS will include battery capacity sufficient for 24-hour operation. The normal power supply to the UPS will be provided from a 120 VAC bus that will be re-powered by a diesel generator as part of the FLEX response. A design change to install portable generator connections to this bus is being completed in support of EA-12-049 (Reference 1). In the event that power is not restored to the bus, a local connection will allow the battery charger to receive power from a small portable generator. Actions to replenish the electrical supply include refueling the DG or connecting and refueling a small portable generator.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Primary Containment Control Flowcharts exist to direct operations in protection and control of containment integrity. These flowcharts are being revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAP implementation. HCVS-specific procedure guidance will be developed and implemented to support HCVS implementation.

Identify modifications."

List modifications and describe how they support the HCVS Actions.

BA- 12-049 Modifications:

• A modification to install a connection point to allow a diesel generator to be connected to electrical power bus 2EJS*US 1 is being installed. This will allow the DG to power the HCVS battery charger.

EA-i13-109 Modifications:

A single modification package has been developed to detail the following modifications:

• Relocation and replacement of the existing Containment Purge System inboard containment isolation valve 2CPS*AOV 109 to outside of containment and replacement of outboard containment isolation valve 2CPS*AOV1 111.

• Installation of dedicated HCVS piping including the HCVS isolation valve and rupture disc from the combined wetwell/drywell piping upstream of 2GTS*AOV 1/01SV 102 to the HCVS discharge

• Installation of the HCVS pneumatic supply and Argon purge station.

Page 21 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - BDBEE Venting

• Installation of a dedicated HCVS battery system including a battery charger.

• Installation of required HCVS instrumentation and controls, including radiation monitors. This also includes installation of control panels in the MCR and the ROS.

Key Venting Parameters:

List instrumentation creditedfor this venting action. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order).

Initiation, operation and monitoring of the HCVS venting will rely on the following key parameters and indicators. Indication for these parameters will he installed in the MCR or ROS to comply with EA-13-109:

Key Parameter Component Identifier Indication Location HCVS Process Temperature 2CPS-TE138 MCR HCVS Process Pressure 2CPS-PT135 MCR HCVS Process Radiation Monitor 2CPS-RE136 MCR HCVS Process Valve Position 2CPS-AOV134-O MCR

_______________________2CPS-AOV 134-C HCVS Pneumatic Supply Pressure 2CPS-P1151 ROS HCVS Argon Supply Pressure 2CPS-PI161 ROS HCVS Electrical Power Supply N/A (Each channel of the MCR Availability (Yokogawa Recorder) recorder has a component

_________________________________ identifier.)

Initiation and cycling of the HCVS will be controlled based on several existing MCR key parameters and indicators which are qualified to the existing plant design: (Reference NEI 13-02, Section 4.2.2.1.9 [91):

Key Parameter Component Identifier Indication Location Drywell pressure 2CMS*PI2A MCR Suppression Chamber pressure 2CMS*PI7A MCR I MCR 2CMS*LI11lA I

Notes: None Page~22 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109, Section 1.2.10 /NEI 13-02, Section 2.3 First 24 Hour Coping Detail Provide a general description of the venting actionsfor first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that areproposed.

Ref: EA-13-109, Section 1.2.6 / NEI 13-02, Section 2.5, 4.2.2 The HCVS has been designed to minimize reliance on operator actions for response to an ELAP and severe accident events. Progression of the ELAP into a severe accident assumes that the FLEX strategies identified in the response to Order EA- 12-049 have not been effective. Immediate operator actions will be completed by operators from either the MCR or the IHC VS ROS using remote-manual actions. The operator actions required to open a vent path are as described in Table 2-1. Remote-manual is defined in this plan as a non-automatic power operation of a component and does not require the operator to be at or in close proximity to the component. No other operator actions are required to initiate venting under primary procedural protocol.

The HCVS has been designed to allow initiation, control, and monitoring of venting from the MCR and will be able to be operated from an installed ROS as part of the response to this Order. Both locations minimize plant operators' exposure to adverse temperature and radiological conditions and are protected from hazards assumed in Part 1 of this report. A preliminary evaluation of travel pathways for dose and temperature concerns has been completed and travel paths identified (ISE Open Item #7). A final evaluation of environmental conditions will be completed as part of detailed design for confirmation.

[ISE OPEN ITEM-7: Confirm travel path accessibility.]

Permanently installed electrical power, Argon purge gas, and motive air/gas capability will be available to support operation and monitoring of the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Power will be provided by installed batteries for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before generators will be required to he functional.

System control."

i. Active: PCIVs are operated in accordance with EOPs/SOPs to control containment pressure.

The HCVS is designed for a minimum of 8 open/close cycles of the vent path under severe accident conditions over the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following an ELAP. Controlled venting will be permitted in the revised EOPs. The configuration of the new pneumatic supplies allows the HCVS system controls to override the containment isolation circuit on the PCIVs needed to vent containment.

ii. Passive: Inadvertent actuation protection is provided by use of key-locked switches for HCVS system SOVs and locked manual bypass valves. In addition, a rupture disc is provided downstream of the HCVS flow path valves to preclude valve leakage during a design basis LOCA.

Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed Page 23 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Severe Accident Venting equipment including station modifications that are proposed.

Ref: EA-13-109, Section 1.2.4, 1.2.8 / NEI 13-02, Section 4.2.2 Actions required to extend venting beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> include replenishment of the HCVS pneumatic and Argon purge system stored gases and recharging the electrical supply.

The pneumatic supply station will be installed in the Reactor Building Track Bay and will include a nitrogen bottle station with an additional connections for an extra nitrogen bottle or a for a portable air compressor.

Connections will utilize pre-engineered quick disconnect fittings. Actions to replenish the pneumatic supplies include replacement of nitrogen bottles or installation and fueling of a portable air compressor. Sufficient nitrogen bottles will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The Argon purge system is required only if the ELAP progresses to severe accident conditions and hydrogen is being vented. It will likewise be in the Reactor Building Track bay and will include an Argon bottle station.

Actions to replenish the Argon supplies include replacement of Argon bottles or refilling from an outside source.

Sufficient Argon will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The HCVS batteries and battery charger will also be installed in the Reactor Building Track Bay. The UPS will include battery capacity sufficient for 24-hour operation. The normal power supply to the UPS will be provided from a 120 VAC bus that will be re-powered by a diesel generator as part of the FLEX response. A design change to install portable generator connections to this bus is being completed in support of EA-12-049 (Reference 1). In the event that power is not restored to the 600 VAC bus, a local connection to the UPS will allow the UIPS to receive power from a small portable generator. Actions to replenish the electrical' supply include refueling the DG or connecting and refueling a small portable generator.

Both the pneumatic and Argon supply stations and the HCVS batteries/battery charger are located in the Reactor Building Track Bay on the Northeast side of the Reactor Building. The track bay is outside of the secondary containment boundary. The HCVS piping will exit the Reactor Building on the west-southwest side of the Reactor Building and be routed to the west-northwest side of the building before going vertical to the top of the building. Therefore, the Reactor Building provides shielding for the Reactor Building Track Bay. A preliminary evaluation of radiological and temperature concerns was completed (ISE Open Item #7). A final evaluation will be completed when the location of the ROS is finalized.

[ISE OPEN ITEM-7: Perform final environmental evaluation of the ROS location.]

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Primary Containment Control Flowcharts exist to direct operations in protection and control of containment integrity. Similarly, severe accident procedures exist for when EOP actions do not halt the progression of the BDBEE to severe accident. These flowcharts/procedures are being revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAP implementation. HCVS-specific procedure guidance will be developed and implemented to support HCVS implementation. "

Page 24 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Severe Accident Venting Identify modifications:

List modifications and describe how they support the HCVS Actions.

Modifications are the same as for BDBEE Venting Part 2.

Key Venting Parameters:

List instrumentation creditedfor the HCVS Actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply~with the vent order).

Key venting parameters are the same as for BDBEE Venting Part 2.

Notes: None Page 25 of 66

Nine. Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Support Equipment Functions Determine venting capability support functions needed.

Ref: EA-13-109 Section 1.2.8, 1.2.9/INEI 13-02 Section 2.5, 4.2.4, 6.1.2 BDBEE Venting Provide a general description of the BDBEE Venting actions supportfunctions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109, Section 1.2.9 / NET 13-02, Section 2.5, 4.2.2, 4.2.4, 6.1.2 Venting will require support from the HCVS batteries, battery charger, and pneumatic suppiy station being installed. These provide a minimum of 24-hour operation on installed supplies and provide connection points for additional pneumatic supplies (nitrogen bottles or compressor) and electrical supplies (portable generator).

Containment integrity is initially maintained by permanently installed equipment. All containment venting functions will be performed from the MCR or ROS.

The pneumatic supply station will be installed in the Reactor Building Track Bay and will include a nitrogen bottle station with additional connections for extra nitrogen bottles or connection of a portable air compressor.

Connections will utilize pre-engineered quick disconnect fittings. The location of the pneumatic supply station will be evaluated for reasonable protection per Part 1 of this OIP' and modified as required for compliance.

Actions to replenish the pneumatic supplies include replacement of nitrogen bottles or installation and fueling of a portable air compressor. Sufficient nitrogen bottles will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The Argon purge system is required only if the ELAP progresses to severe accident conditions and hydrogen is being vented. The Argon supply station will likewise be in the Reactor Building Track bay and will include an Argon bottle station with additional connections for extra Argon bottles or connection for replenishment from an outside source. Connections will utilize pre-engineered quick disconnect fittings. The location of the Argon supply station will be evaluated for reasonable protection per Part .1 of this OIP' and modified as required for compliance. Actions to replenish the Argon supplies include replacement of Argon bottles or refilling from an outside source. Sufficient Argon will be staged to support operations for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> beyond the initial 24-hour coping period following the ELAP event.

The HCVS batteries and battery charger will also be installed in the Reactor Building Track Bay. The UPS will include battery capacity sufficient for 24-hour operation. The normal power source for the UPS is a dedicated 600 VAC to 120/240 VAC transformer, which will be powered from a 600 VAC bus that will be re-powered by a diesel generator as part of the FLEX response. A design change to install portable generator connections to this bus is being completed in support of EA-12-049 (Reference 1). In the event that power is not restored to the 600 VAC bus, a local 240 VAC connection to the UPS will allow the UPS to receive power from a small portable generator. Actions to replenish the electrical supply include refueling the DG or connecting and refueling a small portable generator.

Severe Accident Venting Provide a general description of the Severe Accident Venting actions supportfunctions. Identify methods and strategy(ies) utilized to achieve venting results.

Ref: EA-13-109, Section 1.2.8, 1.2.9 / NEI 13-02, Section 2.5, 4.2.2, 4.2.4, 6.1.2 Page 26 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Support Equipment Functions The same support functions that are used in the BDBEE scenario would be used for severe accident venting.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Primary Containment Control Flowcharts exist to direct operations in protection and control of containment integrity. Similarly, severe accident procedures exist for when EOP actions do not halt the progression of the BDBEE to severe accident. These flowcharts/procedures are being revised as part of the EPG/SAGs Revision 3 updates and associated EOP/SAP implementation. HCVS-specific procedure guidance will be developed and implemented to support HCVS.

Identify modifications:

List modifications and describe how they support the HCVS Actions.

• The FLEX modification to add connection points for the FLEX 600 VAC generator to connect to the 600 VAC bus supports re-powering the HCVS battery charger.

• HCVS modification to add piping and connection points at a suitable location in the Reactor Building Track Bay to connect portable N2 bottles or air compressor for motive force to HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Provide the capabilities to replace Argon bottles or refill from an external Argon supply. Install HCVS batteries and battery charger with applicable connection to 600 VAC bus and connection for small portable generator.

• HCVS connections required for portable equipment will be protected from all applicable screened-in hazards and located such that operator exposure to radiation and occupational hazards will be minimized. Structures to provide protection of the HCVS connections will be constructed to meet the requirements identified in NEI-12-06 section 11 (Reference 8) for screened in hazards.

Key Support Equipment Parameters:

List instrumentation creditedfor the support equipment utilized in the venting operation. Clearly, indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order).

• Local control features of the FLEX DG electrical load and fuel supply.

• Pressure gauge on supplemental Nitrogen bottles.

• Pressure gauge on Argon Purge System supply.

Notes: None Page 27 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 2: Boundary Conditions for WW Vent - Venting Portable Equipment Deployment Provide a general description of the venting actions using portable equipment including modifications that are proposed to maintain and/or support safety functions.

Ref: EA-13-109, Section 3.1 / NEI 13-02, Section 6.1.2, D.1.3.1 Venting actions using portable equipment include the following:

• Replacement and replenishment of pneumatic supply sources. This includes the option of replacing nitrogen bottles or connecting a portable air compressor. Equipment sufficient for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of vent operation beyond the 24-hour installed supply would be pre-staged in the FLEX storage building.

Installation of the HCVS includes installation of a pneumatic supply header that includes pneumatic regulators and utilizes standard pneumatic connections.

Replacement of the Argon supply source. Equipment sufficient for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of vent operation beyond the 24-hour installed supply would be pre-staged in the FLEX storage building.

• Establishing temporary power to repower the battery charger. Option 1 is to connect the FLEX DG to 2EJS*US 1, which provides power to EHS*MCC102 that in turn powers the HCVS transformer and battery charger. Option 1 would be completed as part of the FLEX response strategy and occurs to the east and inside the NMP2 Control Building. Option 2, to be taken if the FLEX DG cannot be connected to 2EJS*US 1, is to connect a small portable generator to the battery charger. Option 2 would be taken locally at the battery charger. Either of these actions will also require the generators to be refueled. A one line diagram of the electrical system to be installed is included in Attachment 3.

Details:

Provide a brief description of Procedures / Guidelines:

Confirm thatprocedure/guidanceexists or will be developed to support implementation.

Implementation procedures are being developed to address all HCVS operating strategies, including deployment of portable equipment. Direction to enter the procedure for HCVS operation will be given in the EOPs, the site ELAP procedure, and the SAPs (refer to Part 4 for general information on procedures).

There is minimal impact to deployment actions since the HCVS discharge pipe will be located on the Northwest side of the Reactor Building and deployment areas are either on the EastlNortheast side of the Reactor Building or on the South side of the Reactor Building. Therefore, the procedures/guidelines for HCVS actions are the same as for support equipment section.

Strategy Modifications Protection of connections Per compliance with Order EA- N/A Per compliance with Order EA-12-049 12-049 (FLEX) (FLEX)

Notes: None Page 28 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 General Licensees that use Option B.] of EA 1 09 (SA Capable DW Vent without SA WA) must develop their own QIP.

This template does not provide guidancefor that option.

Licensees using Option B.2 of EA-13-109 (SAWA and SAWM or 545°F SADW Vent (SADV) with SAWA) may use this template for their OIP submittal. Both SA WM and SADV require the use of SA WA and may not be done independently. The HCVS actions under Part2 apply to all of the following:

This Part is divided into the following sections:

3.1: Severe Accident Water Addition (SA WA)

3. 1.A: Severe Accident Water Management (SA WM) 3.1.B:' Severe Accident DW Vent (545 deg F)

Provide a sequence of events and identify any time constraint required for success including the basis for the time constraint.

SA WA and SA WM or SAD V Actions supporting SA conditions that have a time constraint to be successful should be identified with a technical basis and a justificationprovided that the time can reasonably be met (for example, a walkthrough of deployment). Actions already identified under the HCVS part of this template need not be repeated here.

The time to establish the water addition capability into the RPV or DW should be less than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />sfrom the onset of the loss of all injection sources.

• Electrical generatorssatisfying the requirements of EA-12-049 may be creditedfor powering components and instrumentationneeded to establish aflow path.

• Time Sensitive Actions (TSAs) for the purpose of SA WA are those actions needed to transport,connect and start portable equipment needed to provide SA WA flow or provide power to SA WA components in the flow path between the connection point and the RPV or drywel1l. Actions needed to establishpower to SA WA instrumentation should also be included as TSAs.

Ref: NET 13-02 Section 6.1.1.7.4.1, 1.1.4, 1.1.5 The operation of the HCVS using SAWA and SAWM/SADV will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and will include the capability for remote-manual initiation from the MCR using control switches, at MCC/Busses in the Control Building and locally at the intake structure. In addition, HCVS operation may occur at the ROS on the 261l'elevation in the Reactor Building Trackbay (grade elevation).

Timelines (see attachments 2.1 .A for SAWA/SAWM) were developed to identify required operator response times and actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWM). The timelines do not assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damage conditions.

Page29 of66 :'

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 Part 3.1: Boundary Conditions for SAWA Table 3.1 - SAWA Manual Actions Primary Action Primary Location!/Component Notes

1. Establish HCVS capability in

• MCR or ROS

• Applicable to SAWA/SAWM accordance with Part 2 of this strategy.

OIP.

2. Connect FLEX (SAWA) pump

• Reactor Building 289'

• Perform Reactor Building discharge to injection piping. elevation/RHR "A" portions of deployment first.

3. Connect FLEX (SAWA) pump

• Intake/outside screenhouse to water source. building

4. Power SAWAIHCVS

• Outside Control Building/Inside

• components with EA-12-049 Control Building Division I (FLEX) generator. Switchgear Room

5. Inject to RPV using FLEX

• RB Trackbay at valve manifold

• Initial SAWA flow rate is 300 (SAWA) pump (diesel). gpm.

6. Monitor SAWA indications.

• RB Trackbay (RHR LPCI valve

• Pump flow.

__________________ position in MCR)

• Valve position indication.

7. Use SAWMV to maintain

• RB Trackbay at valve manifold

• Monitor DW pressure and availability of the WW vent (Part Suppression Pool level 3.1I.A).

• Control SAWA flow at valve

____________________________________________________ manifold.

Discussion of timeline SAWA identified items HCVS operations are discussed under Phase 1 of EA-13-109 (Part 2 of this OliP).

• 7.5 Hours - Establish electrical power and other EA-12-049 actions needed to support the strategies for EA-13-109, Phase 1 and Phase 2. Action being taken within the Reactor Building under EA-12-049 conditions after RPV level lowers to 2/3 core height must be evaluated for radiological conditions assuming permanent containment shielding remains intact. (HCVS-FAQ-12) All other actions required are assumed to be in-line with the FLEX timeline submitted in accordance with the EA-12-049 requirements.

• Less than 8 Hours - Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizing the peak DW pressure during the initial cooling conditions provided by SAWA.

Part 3.1: Boundary Conditions for SAWA Severe Accident Operation Determine operating requirementsfor SA WA, such as may be used in an ELAP scenario to mitigate core damage.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02, Section 1.1.6, 1.1.4.4 It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systems or presumed failure of injection systems in a timely manner. This does not preclude the use of the SAWA system to supplement or replace the EA- 12-049 injection systems if desired. SAWA will consist of both portable and Page 30 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 installed equipment.

The motive force equipment needed to support the SAWA strategy shall be available prior to T=8 hours from the loss of injection (assumed at T=0).

The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids / gases and potentially flammable conditions by inclusion of backflow prevention. The FLEX (SAWA) pump check valve is integral with the pump skid and will close and prevent leakage when the SAWA pump is secured. RHR LPCI injection mode has installed ECCS backflow prevention devices (2RHS*V16A) qualified for accident scenarios.

Description of SAWA actions for first 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

Table 3.2 - SAWA Manual Actions Timeline Time Action Notes T<l hour

• Connect SAWA hose in Reactor Building and route

• No evaluation required for hose to RB Trackbay (Step 2 of Table 3.1). actions inside Reactor

• Remove threaded cap and install hose fittings. Building.

• Close 2CNG-V621.

__________ Open 2RHS*V70.

T=~1-7" hours

• Complete actions started at T<I hour (Step 2 of Table

• Evaluate core gap and early in 3.1). vessel release impact to

• Connect FLEX (SAWA) pump to water supply at Reactor Building access for intake structure (Step 3 of Table 3.1). SAWA actions. It is assumed

• Establish electrical power to HCVS and SAWA using that reactor building access is EA-12-049 generator (Step 4 of Table 3.1). limited due to the source term

• Establish flow of at least 300 gpm to the RPV using at this time unless otherwise SAWA systems. (Step 5 of Table 3.1). noted. (Refer to HCVS-FAQ-12 for actions in T=l-7 hour time frame.

T<8-14 hours *Monitor and Maintain SAWA flow at 300 gpm for six

• SAWA flow must commence hours Step 6 of Table 3.1). at T=8 hours but should be done as soon as motive force is available.

T<_14 hours eProceed to SAWM actions per Part 3.1.A (Step 7 of

• SAWA flow may be reduced Table 3.1). to 100 gpm six hours following SAWA initiation.

m1e been have assumedi T=1 =1ihour timesto o1t reduced nourto toT=7 noursin toorder i =tshours estaonisn tne nounas to provide or appiicamnity sufficient of radoloiogcai margin to inform evaiuauons operator action feasibility evaluations and will be further informed by emergency response dose assessment activities during an actual event. This accounts for the one hour gap between 7 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in this time line.

Greater Than 24 Hour Coping Detail Provide a generaldescription of the SA WA actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications thatrareproposed.

Page 31 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NEI 13-02, Section 4.2.2.4.1.3.1, 1.1.4 SAWA Operation is the same for the full period of sustained operation. If SAWM is employed, flow rates will be directed to preserve the availability of the HCVS wetwell vent (see 3.1 .A).

Details:

Details of Design Characteristics/Performance Specifications SA WA shall be capable of providing an RPV injection rate of 500 gpmn within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a loss of all RPV injection following an ELA P/Severe Accident. SA WA shall meet the design characteristicsof the HCVS with the exception of the dedicated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power source. Hydrogen mitigation is provided by backflow preventionfor SA WA.

Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NEI 13-02, Section 1.1.4 Equipment Locations/Controls/Instrumentation Nine Mile Point Unit 2 performed a site specific evaluation to justify the use of a lower initial SAWA flow rate of 300 gpm. This initial flow rate will be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of all RPV injection following an~

ELAP/Severe Accident and will be maintained for six hours before reduction to the Wetwell vent preservation flow rate. The reason for this approach is to be within the capacity of a single FLEX (SAWA) pump so that the deployment time can be reduced as short as possible and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. MAAP version 5.03 was used to perform this evaluation and the results demonstrate acceptable containment performance in terms of drywell temperature, pressure and wetwell water level (Reference 37). The evaluation was performed to obtain results consistent with Figures C-2 through C-5 of NEI 13-02 Revision 1. A sensitivity case using 500 gpm for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was also performed and found that the containment response for the base case (300 gpm for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) is virtually the same as the sensitivity case (500 gpm for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />).

The locations of the SAWA equipment and controls, as well as ingress and egress paths have been evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period.

Equipment has been evaluated to remain operational throughout the Sustained Operating period. Personnel exposure and temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERO dose and plant safety guidelines for temperature and humidity.

The flow path will be from the FLEX suction at the intake structure for the plant Ultimate Heat Sink (UHS) through the FLEX (SAWA) pump and valve manifold having connections for the SAWA (FLEX) pump and the hose that will deliver SAWA flow to a second valve manifold. Hose connected to the pump valve manifold will be routed to a second valve manifold where SAWA flow indication and control will be provided. This valve manifold will also provide minimum flow and freeze protection for the pump. From this second valve manifold, hose will be routed to the permanent SAWA connection point located within the Reactor Building on the "A" loop of Residual Heat Removal (RHR) via a 3-inch connection consisting of a threaded pipe connection with cap, a manual valve (2RHS*V70) and necessary piping. The manual valve at the connection will be manually opened when the hose is connected. Once the SAWA components are deployed and connected, the SAWA flow path is completed by opening the RHR Low Pressure Coolant Injection (LPCI) valve 2RHS*MOV24A with backflow prevention provided by installed containment isolation check valve 2RHS*V 16A. Cross flow into other portions of the RHR system will be isolated by ensuring closure of the MOVs from the MCR. DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by use of the FLEX (SAWA) pump control valve at the valve manifold that also contains the SAWA flow indication. Alternately, the flow indication and flow control may be from the pump discharge. Communication will be established between the MCR and the SAWA flow control location.

Motor Operated Valves (MOVs) and containment instrumentation required for SAWA will be powered fr'om the Page 32 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 FLEX diesel generators connected in the Control Building Switchgear Rooms as described in the EA- 12-049 compliance documents. The MOV will be operated in a load sequence with other loads to limit the potentia for overloading the FLEX DGs. The FLEX DGs are located near the Control Building which is significantly away from the discharge of the HCVS at the Northwest side of the Reactor Building. Refueling of the FLEX DG will be accomplished from the EDG fuel oil tanks as described in the EA-12-049 compliance documents. The Intake structure is a significant distance from the discharge of the HCVS pipe with substantial structural shielding between the HCVS pipe and the pump deployment location. Pump refueling will also be accomplished from the EDG fuel oil tanks as described in the EA-12-049 compliance documents. See mechanical and electrical sketches in attachments, plant layout sketches in the assumptions part and a list of actions elsewhere in this part.

Evaluations of actions outside the Reactor Building for projected SA conditions (radiation / temperature) indicate that personnel can complete the initial and support activities without exceeding the ERG-allowable dose for equipment operation or site safety standards (reference HCVS-WP-02, Plant Specific Dose Analysis for the Venting of Containment during SA Conditions). Evaluation of actions inside the Reactor Building for projected SA conditions (radiation/temperature) will be performed to determine that personnel can complete the initial and support activities without exceeding the ERG-allowable dose for equipment operation or site safety standards (reference HCVS-FAQ- 12).

Electrical equipment and instrumentation will be powered from the power sources noted in the table below with portable generators to maintain battery capacities during the Sustained Operating period. The indications include

(*are minimum required instruments).

Parameter Instrument Location Power Source I Notes DW Pressure* 2CMS*PI2A Indicator in Main Division I battery via Control Room El EA-12-049 generator 306' on and battery charger 2CEC*NL6O1 RG 1.97 qualified Suppression Pool Level* 2CMS*LI9A Indicator in Main Division I battery via Control Room El EA-12-049 generator 306' on and battery charger 2CEC*NL6O1 RG 1.97 qualified SAWA Flow* FLEX (SAWA) Pump FLEX six-valve Self-powered from Flow indicator manifold deployed internal battery to RB Trackbay El 261' grade elev or at the pump discharge Valve indications and MCR Panels Main Control Room 2EHS*MCC103-1.7C controls El 306' on via 2EJS*US 1 via EA-2CEC*PNL601 12-049 generator The instrumentation and equipment being used for SAWA and supporting equipment has been evaluated to perform for the Sustained Operating period under the expected radiological and temperature conditions.

Equipment Protection Page 33 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 SAWA installed components and connections external to protected buildings will be protected against the screened-in hazards of EA-12-049 for the station. Portable equipment used for SAWA implementation will meet the protection requirements for storage in accordance with the criteria in NEI 12-06, Revision 0.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 5.1.1, 5.4.6, 1.1.6 Provide a brief description of Procedures!/Guidelines:

Confirm that procedure/guidanceexists or will be developed to support implementation.

Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NET 13-02, Section 1.3, 6.1.2

1. Connect FLEX (SAWA) pump discharge to RHR piping.

• Remove threaded cap and install hose fittings.

• Close 2CNS-V621.

• Open 2RHS*V70.

2. Connect FLEX (SAWA) pump to intake using FSG*.

3. Power SAWA/HCVS components with EA-12-049 (FLEX) generator using FSG.

4. Verify other RHR modes are isolated using Control Room switches.

5. Open 2RHS*MOV24A to lineup injection to RPV using SAWA pump.

6. Start FLEX (SAWA) pump to establish SAWA flow.

7. Adjust SAWA flow at valve manifold and using SAWA flow indication to establish and maintain 300 gpm.

• Where an FSG is referenced, it will be the same FSG reference with the same steps used for FLEX.

Identify modifications:

List modifications and describe how they support the SA WA Actions.

Ref: EA-13-109 Attachment 2, Section B.2.2, / NET 13-02, Section 4.2.4.4, 7.2.1.8, Appendix I The list of modifications reflects changes required to upgrade the modifications for EA-12-049 to meet EA-13-109 Phase 2 requirements.

Electrical Modifications:

• None Mechanical Modifications:

• Increase hose size for SAWA flow rate (300 gpm)

• Construct valve manifold

• Hose length/location of valve manifold may need changes based on hydraulic calculation/radiological evaluation Instrument Modifications:

• SAWA flow instrument Component Qualifications:

I.Page 34of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 State the qualification used for equipment supportingSA WA.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 1.1.6 Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this OTP.

Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06, Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 design conditions.

Notes:

None Part 3.1 .A: Boundary Conditions for SAWA/SAWM Time periods for the maintaining SAWM actions such that the WW vent SA WM Actions supporting SA conditions that have a time constra~intto be successful should be identified with a technical basis and ajustification provided that the time can reasonably be met (for example, a walkthrough of deployment). Actions already identified under the HC VS part of this template need not be repeatedhere.

There are three time periodsfor the maintainingSA WM actions such that the WW vent remains available to remove decay heatfrom the containment:

• SAWM can be maintainedfor >7 days without the need for a drywell vent to maintainpressure below PCPL or containment design pressure, whichever is lower.

o Under this approach, no detail concerningplant modifications or procedures is necessary with respect to how alte'rnatecontainment heat removal will be provided.

• SAWM can be maintainedfor at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, but less than 7 days before DWpressure reaches PCPL or design pressure, whichever is lower.

o Under this approach, a functional description is required of how alternate containment heat removal might be establishedbefore DW pressure reaches PCPL or design pressure whichever is lower. Under this approach,physical plant modifications and detailed procedures are not necessary, but written descriptionsof possible approachesfor achieving alternate containment heat removal and pressure control will be provided.

• SAWM can be maintainedfor <72 hours SAWM strategy can be implemented but for less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before DW pressure reaches PCPL or design pressure whichever is lower.

o Under this approach, a functional description is required of how alternate containment heat removal might be establishedbefore DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are required to be implemented to insure achieving alternate containment heat removal and pressure control will be providedfor the sustained operatingperiod.

Ref: NET 13-02 Appendix C.7 SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.

Basis for SAWM time frame SAWM can be maintained >7 days:

Page 35 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 NMP2 is not bounded by the evaluations performed in BWROG TP-2015-008 and therefore is not representative of the reference plant in NEI 13-02 figures C-2 through C-6. NMP2 will use an initial SAWA flow rate (300 gpm) that is lower than evaluated by BWROG TP-2015-008 and Reference 27 of NEI 13-02 Rev 1 (500 gpm).

NMP2 performed a site specific evaluation to justify the use of a lower initial SAWA flow rate of 300 gpm. This initial flow rate will be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the loss of all RPV injection following an ELAP/Severe Accident and will be maintained for six hours before reduction to the Wetwell vent preservation flow rate. The reason for this approach is to be within the capacity of a single FLEX pump so that the deployment time can be reduced as short as possible and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. MAAP version 5.03 was used to perform this evaluation and the results demonstrate acceptable containment performance in terms of drywell temperature, pressure and wetwell water level. The evaluation was performed to obtain results consistent with Figures C-2 through C-5 of NEI 13-02 Revision 1. A sensitivity case using 500 gpm for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was also performed and found that the containment response for the base case (300 gpm for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) is virtually the same as the sensitivity case (500 gpm for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />).

Instrumentation relied upon for SAWM operations is Drywell Pressure and Suppression Pool level and SAWA flow. Except for SAWA flow, SAWM instruments are initially powered station batteries and then by the FLEX (EA-12-049) generator which is placed in-service prior to core breach. The DG will provide power throughout the Sustained Operation period (7 days). The SAWA flow instrument will be self-powered from an internal power supply capable of being replenished, if needed, through the Sustained Operation period. DW Temperature monitoring is not a requirement for compliance with Phase 2 of the Order, but some knowledge of temperature characteristics provides information for the operation staff to evaluate plant conditions under a severe accident and provide confirmation to adjust SAWA flow rates. (C.7.1.4.2, C.8.3.l)

Suppression Pool level indication is maintained throughout the Sustained Operation period, so the HCVS remains in-service. The time to reach the level at which the WW vent must be secured is >7 days using SAWM flowrates.

(C.6.3, C.7.l.4.3)

Procedures will be developed that control the Suppression Pool level, while ensuring the DW pressure indicates the core is being cooled, whether in-vessel or ex-vessel. Procedures will dictate conditions during which SAWM flowrate should be adjusted (up or down) using suppression pool level and DW pressure as controlling parameters to remove the decay heat from the containment. (This is similar to the guidance currently provided in the BWROG SAMGs.) (C.7.1.4.3) .1.A shows the timeline of events for SAWA ! SAWM. (C.7.1.4.4)

Table 3.1.B - SAWM Manual Actions Primary Action Primary Location!/Component Notes

1. Lower SAWA injection rate to RB Trackbay at valve manifold a Control to maintain control Suppression Pool Level containment and WW and decay heat removal. parameters to ensure WW vent remains functional.

• 100 gpm minimum capability is maintained for greater than 7 days.

2. Control SAWM flowrate for MCR *SAWM flowrate will be containment controL/decay heat RB Trackbay at valve manifold monitored using the following removal. instruments:

- SAWA Flow Page 36 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2

- Suppression Pool Level

- Drywell Pressure

• SAWM flowrate will be controlled using the manual valve at the six valve' manifold.

3. Establish alternate decay heat Various locations SAWM strategy can preserve the removal. wetwell vent path for >7 days.

4. Secure SAWA / SAWM. RB Trackbay at valve manifold When alternate decay heat removal is established.

SAWM Time Sensitive Actions Time Sensitive SAWM Actions:

14 Hours - Initiate actions to maintain the Wetwell (WW) vent capability by lowering injection rate, while maintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the WW vent remains available.

SAWM Severe Accident Operation Determine operating requirementsfor SA WM, such as may be used in an EL4P scenario to mitigate core damage.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02, Appendix C It is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plant injection systems per direction by the plant SAMGs. Refer to Attachment 2.1.D for SAWM SAMG language additions.

First 24 Hour Coping Detail Provide a general description of the SA WM actionsfor first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using installed equipment including station modifications that are proposed.

Given the initial conditionsfor EA-13-109:

• BDBEE occurs with FLAP

• Failure of all injection systems, including steam-powered injection systems Ref: EA-13-109, Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 2.5, 4.2.2, Appendix C, Section C.7 SAWA will be established as described above. SAWM will use the installed instrumentation to monitor and adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWMI strategy.

Once the SAWA initial low rate has been established for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the flow will be reduced while monitoring DW pressure and Suppression Pool level. SAWM flowrate can be lowered to maintain containment parameters and preserve the WW vent path. SAWM will be capable of injection for the period of Sustained Operation.

Greater Than 24 Hour Coping Detail Provide a general description of the SA WM actionsfor greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using portable and installed equipment including station modifications that are proposed.

Page 37 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 Ref: EA-13-109, Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section 4.2.2, Appendix C, Section C.7 SAWM can be maintained >7 days:

The SAWM flow strategy will be the same as the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> until 'alternate reliable containment heat removal and pressure control' is reestablished. SAWM flow strategy uses the SAWA flow path. No additional modifications are being made for SAWM.

~Details:

Details of Design Characteristics/Performance Specifications Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Section Appendix C SAWM shall be capable of monitoring the containment parameters (DW pressure and Suppression Pool Level) to provide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control is established. SAWA will be capable of injection for the period of Sustained Operation.

Equipment Locations/Controls/Instrumentation Describe locationfor SA WM monitoring and control.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NET 13-02, Appendix C, Section C.8, Appendix I The SAWM control location is the same as the SAWA control location. Local indication of SAWM flow rate is provided at the six valve manifold by installed flow instrument qualified to operate under the expected environmental conditions. The SAWA flow instrument is self-powered by an internal power supply.

Communications will be established between the SAWM control location and the MCR.

Injection flowrate is controlled by FLEX manual valve located on the six valve manifold, or at pump discharge.

Suppression Pool level and DW pressure are read in the control room using indicators powered by the FLEX DG installed under EA-12-049. These indications are used to control SAWMI flowrate to the RPV.

Key Parameters:

List instrumentation creditedfor the SA WM Actions.

Parameters used for SAWM are:

• Drywell Pressure

• Suppression Pool Level

• SAWM Flowrate The Drywell pressure and Suppression Pool level instruments are qualified to RG 1.97 and are the same as listed in Part 2 of this OIP. The SAWM flow instrumentation will be qualified for the expected environmental conditions expected when needed.

Notes:

None Page 38 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 3: Boundary Conditions for EA-13-109, Option 2 Part 3.1 .B: Boundary Conditions for SAWA/SADY

'*i, "i,  :' Applicability of WWNDesign Considerations;: ,..:/ /:: -':*

This section is not applicable to NMP2.

Table 3.1.C -SADV Manual ACtions *  :  ; ..  :  ! i: / ', .;: ,/

Severe Accidlent venting:

First 24 Hour Coping Dtail , ", .

, /Greater Than 24 HourCpn Detaili*:*,*  :,  ?:: ',*  : **..

Page 39 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls, Training. Drills and Maintenance Identify how the programmatic controls will be met.

Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality addressing the impact of temperature and environment.

Ref: EA-13-109, Section 3.1, 3.20 / NEL 13-02, Section 6.1.2, 6.1.3, 6.2 Program Controls.'

The HCVS venting actions will include:

• Site procedures and programs are being developed in accordance with NEI 13-02 to address use and storage of portable equipment relative to the Severe Accident defined in NRC Order EA 109 and the hazards applicable to the site per Part 1 of this OIP.

• Routes for transporting portable equipment from storage location(s) to deployment areas will be developed as the response details are identified and finalized. The identified paths and deployment areas will be accessible when the HCVS is required to be functional including during Severe Accidents.

Procedures:

Procedures will be established for system operations when normal and backup power is available, and during ELAP conditions.

The HCVS and SAWA procedures will be developed and implemented following plant processes for initiating or revising procedures and contain the following details:

• appropriate conditions and criteria for use of the HCVS and SAWA

• when and how to place the HCVS and SAWA in operation

• location of system components

• instrumentation available

• normal and backup power supplies

• directions for sustained operation (Reference 9), including the storage and location of portable equipment

• location of the remote control HCVS operating station (panel)

• training on operating the portable equipment

• testing of portable equipment NMP2 does not utilize Containment Accident Pressure (CAP) for ECCS pump NPSH.

Provisions will be established for out-of-service requirements of the HCVS and compensatory measures that comply with the criteria from NEI 13-02 (Reference 9).

NMP2 will establish provisions for out-of-service requirements of the HCVS and compensatory measures.

The following provisions will be documented in the HCVS Program Document:

The provisions for out-of-service requirements for HCVS/SAWA are applicable in Modes 1, 2 and 3

• If for up to 90 consecutive days, the primary or alternate means of HCVS/SAWA operation are non.

functional, no compensatory actions are necessary.

Page 40 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls, Trainingg Drills and Maintenance

• If for up to 30 days, the primary and alternate means of HCVS/SAWA operation are non-functional, no compensatory actions are necessary.

• If the out of service times exceed 30 or 90 days as described above, the following actions will be performed through the site corrective action program:

• Determine the cause(s) of the non-functionality,

• Establish the actions to be taken and the schedule for restoring the system to functional status and to prevent recurrence,

• Initiate action to implement appropriate compensatory actions, and

• Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle.

Describe training plan List trainingplansfor affected organizationsor describe the plan for trainingdevelopment.

Ref: EA-13-109, Section 3.2 I NEI 13-02, Section 6.1.3 Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receive necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS/SAWA/SAWM actions, systems or strategies. Training content and frequency will be established using the Systematic Approach to Training (SAT) process.

Identify how the drills and exercise parameters will be met.

Alignment with NE! 13-06 and 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking.

The Licensee should demonstrate use in drills, tabletops, or exercises for HCVS operation as follows:

• Hardened containment vent operation on normal power sources (no ELAP).

• During FLEX demonstrations(as required by EA-12-049)."Hardened containment vent operation on backup power andfrom primary or alternate location during conditions of ELAP/loss of UHS with no core damage. System use is for containment heat removal AND containment pressure control.

• HCVS operation on backup power andfrom primary or alternate location during conditions of ELA P/loss of UHS with core damage. System use is for containment heat removal AND containmentpressure control with potentialfor combustible gases (Demonstrationmay be in conjunction with SAG change).

• Operationfor sustainedperiod with SA WA and SA WM to provide decay heat removal and containment pressure control.

Ref: EA-13-109, Section 3.1 / NEI 13-02, Section 6.1.3 NMP2 will utilize the guidance provided in NEI 13-06 and 14-01 (References 10 and 11) for guidance related to drills, tabletops, or exercises for HCVS operation. In addition, NMP2 will integrate these requirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9.

Page 41 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls, Training, Drills and Maintenance Describe maintenance plan:

• The maintenanceprogram should ensure that the HCVS/SA WA/SA WM equipment reliability is being achieved in a manner similar to that requiredfor FLEX equipment. Standard industry templates (e.g.,

EPRI) and associatedbases may be developed to define specific maintenance and testing.

o Periodic testing andfrequency should be determined based on equipment type and expected use (furtherdetails are provided in Part 6 of this document).

o Testing should be done to verify design requirements and/or basis. The basis should be documented and deviationsfrom vendor recommendations and applicable standards should be justified.

o Preventive maintenance should be determined based on equipment type and expected use. The basis should be documented and deviationsfrom vendor recommendations and applicable standards should be justified.

o Existing work control processes may be used to control maintenance and testing.

• HCVS/SAWA permanent installed equipment should be maintained in a manner that is consistent with assuring that it performs its function when required.

o HCVS/SA WA permanently installed equipment should be subject to maintenance and testing guidance provided to verify properfunction.

• HCVS/SA WA non-installed equipment should be stored and maintained in a manner that is consistent with assuring that it does not degrade over long periods of storage and that it is accessiblefor periodic maintenance and testing.

Ref: EA-13-109, Section 1.2.13 I NET 13-02, Section 5.4, 6.2 NMP2 will utilize the standard EPRI industry PM process (similar to the Preventive Maintenance Basis Database) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SAWM components. The control program will include maintenance guidance, testing procedures and frequencies established based on type of equipment and considerations made within the EPRI guidelines.

NMP2 will implement the following operation, testing and inspection requirements for the HCVS and SAWA to ensure reliable operation of the system.

Table 4-1: Testing and Inspection Requirements Description Frequency Cycle the HCVS and installed SAWA valves' Once per every 2 operating cycle and the interfacing system valves not used to maintain containment integrity during Mode 1, 2 and 3. For HCVS valves, this test may be performed concurrently with the control logic test described below.

Cycle the HCVS and installed SAWA check Once per every other4 operating cycle valves not used to maintain containment integrity during unit operations3.

Perform visual inspections and a walk down of Once per every other 4 operating cycle HCVS and installed SAWA components.

FucinlytetteHV adainmntrs neproprtn yl Page 42 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 4: Programmatic Controls~, Training. Drills and Maintenance Leak test the HCVS. (1) Prior to first declaring the system functional; (2) Once every three operating cycles thereafter; and (3) After restoration of any breach of system boundary within the buildings Validate the HCVS operating procedures by Once per every other operating cycle conducting an open/close test of the HCVS control function from its control location and ensuring that all HCVS vent path and interfacing system valves5 move to their proper (intended) positions.

1 Not required for HCVS and SAWA check valves.

2Atrtwo consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle.

3 o required if integrity of check function (open and closed) is demonstrated by other plant testing requirements.

4 After two consecutive successful performances, the test frequency may be reduced by one operating cycle to a maximum of once per every fourth operating cycle.

5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (loss of power and/or air) do not require control function testing under this part. Performing existing plant design basis function testing or system operation that reposition the valve(s) to the HCVS required position will meet this requirement without the need for additional testing.

Notes:

Per generic assumption 109-4, existing containment component's design and testing values are governed by existing plant containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (Reference HCVS-FAQ-05 [16] and NEI 13-02, §6.2.2 [9]).

Page 43 of 66

ar vrl5 ertoed Placfrheliale Hree et Nine ~ MilesPitUi Part 5: Milestone Schedule Provide a milestone schedule. This schedule should include:

• Modifications timeline

• Procedure guidance development complete o UCYS Actions o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion

• Long term use equipment acquisition timieline

• Training completion for the HCYS Actions The dates specifically requiredby the order are obligatedor committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

Ref: EA-13-109 Section D.1, D.3 I NEI 13-02, Section 7.2.1 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent 6-month status reports.

Milestone Target Activity Comments Completion Status Date Hold preliminary/conceptual design meeting Nov 2013 Complete Submit Overall Integrated Implementation Plan Jun 2014 Complete Submit 6 Month Status Report Dec 2014 Complete Design Engineering Complete Mar 2015 Complete Submit 6 Month Status Report Jun 2015 Complete Operations Procedure Changes Developed Dec 2015 Started Site Specific Maintenance Procedure Developed Dec 2015 Started Submit 6 Month Status Report Dec. 2015 Complete Simultaneous with Phase 2 with this OIP submittal Training Complete Feb 2016 NMP2 Implementation Outage Apr 2016 Procedure Changes Active Apr 2016 Walk Through Demonstration/Functional Test Apr 2016 Submit Completion Report June 2016 Phase 2 Milestone Schedule:

Page 44 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Part 5: Milestone Schedule Phase 2 Milestone Schedule Milestone Target Activity Comments Completion Status Date Submit Overall Integrated Implementation Plan Dec 2015 Complete with this submittal Hold preliminary/conceptual design meeting Jan 2016 Submit 6 Month Status Report June 2016 Submit 6 Month Status Report Dec 2016 Design Engineering On-site/Complete Mar 2017 Submit 6 Month Status Report June 2017 Operations Procedure Changes Developed Dec 2017 SAMG Revision Site Specific Maintenance Procedure Developed Dec 2017 Expect to be N/A Submit 6 Month Status Report Dec 2017 Training Complete Feb 2018 Implementation Outage April 2018 Procedure Changes Active April 2018 Walk Through Demonstration/Functional Test April 2018 Submit Completion Report June 2018 Notes:

None Page 45 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents

., Attachment 1: HCVS/SAWA/SADV Portable Eqiuipment I "BDBEE Severe Performance Maintenance /PM requirements List portable equipment Venting Accident Criteria

... _____________________ _____ Venting

'*"Nitrogen Cylinders X X 2 x Size 300 (or Check periodically for pressure, replace or similar) cylinders, replenish as needed.

, , initial pressure of

2640 psig

.Argon Cylinders NA X 12 x Size 300 (or Check periodically for pressure, replace or

, *similar) cylinders, replenish as needed.

*'.initial pressure of

2640 psig "FLEX DG X X 450kW, 600V Per response to EA-12-049.

FLEX/SAWA Pump X X 300 gpm @ Per response to EA-12-049.

0 260 psig (2000 rpm)

Portable Air Compressor (optional) X X Later Per vendor manual.

Small Portable Generator (optional) X X Later Per vendor manual.

Page 46 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 2A: Seqiuence of Events Timeline - HCVS t,- 12hrs t - 24 hrs Begin monitoring HCVS pneumatic Replenishment of HCVS UPS supply and UPS status. No and pneumatic supplies ROIC Anticipatory replenishment expected to be required SE80 starts Venting required for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Case 1 FLEX Successful

!  !  ! I I

- a I" i-t 7 hrs -~18 hrs 'IF Containment Venting Ref: NMP2 FLEX OIP t=0s t'".5 m (anticipatory venting not represented inI No Injection SECY-12-0157) SA AIjcinBgn No Injection t -8 hrs Portable generator in place for II / II FLEX. May also be able to powei HCVS UPS'> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (NMP20QIP) Level at Dg 3

RCCLate Failure SCase t' -23 hrs t" 24b*rs t "34 hrs Ref. SECY-1 2-0157 Containment Venting (based on preventing exceeding PCPL)

Case 2 RCIC Early Failure Ref: SOARCA 1h ~hrSAwA Injection Begins

/Adequate core cooling maintained

References:

Case t : NMP2 FLEX Overall Integrated Plan case 2' SOARCA - ML!3150A053 IInjection Lost Legend Case 3 SECv-12-0157 - ML12344A030

/Increased shine and leakage of radionudlides primarily from Wetwell

-HCVS Post Core Damage Dose Evaluation Required I Not to scale I Page 47 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 2.1.A: Sequence of Events Timeline - SAWA/SAWM Sustained Operation period T=168 hours T=168 hours SAWA v'z~o dv,0 Monitor containment parameters and conditions Time Action T=O hours Start of ELAP T=8 hours Initiate SAWA flow at 300 gpm as soon as possible but no later than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> T=14 hours Throttle SAWA flow to 100 gpm 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after initiation of SAWA flow T= 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> End of Sustained Operation Page 48 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents .1 .B: Sequence of Events Timeline - SADV Not applicable to NMP2 Page 49 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents .1 .C: SAWAISAWM Plant-Specific Datum

_ Primary Containment

..... S%

llw r ...... .......

Page 50 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 2.1 .D: SAWM SAMG Approved Language The following general cautions, prioritiesand methods will be evaluatedfor plant specific applicabilityand incorporatedas appropriateinto the plant specific SAMGs using administrativeproceduresfor EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefore address a Wide variety of possible plant conditions and capabilitieswhile these changes are intended to accommodate those specific conditions assumed in Order EA 109. The changes will be made in a way that maintains the use of SAMGs in a symptom based mode while at the same time addressingthose conditions that may exist under extended loss of AC power (ELAP) conditions with significantcore damage including ex-vessel core debris.

Actual Approved Language that will be incorporated into site SAMG*

Cautions:

• Addressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapid steam generation.

• Addressing the plant impact that raising suppression pool water level above the elevation of the suppression chamber vent opening elevation will flood the suppression chamber vent path.

Priorities:

With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases as follows:

• Core debris in the primary containment is stabilized by water addition (SAWA).

• Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting).

• Water addition is managed to preserve the Mark I1II suppression chamber vent paths, thereby retaining the benefits of suppression pool scrubbing and minimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM).

Methods:

Identify systems and capabilities to add water to the RPV or drywell, with the following generic guidance:

• Use controlled injection if possible.

• Inject into the RPV if possible.

Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.

• Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.

Page 51 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 3: Conceptual Sketches (Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies)

Sketch 1A and 1B: Electrical Layout of HCVS System (preliminary) 0 Instrumentation Process Flow Electrical Connections Sketch 2A, 2B, and 2C: P&ID Layout of WW Vent, Pathways, and Site Layout (preliminary)

• Piping routing for vent path - WW Vent

• Demarcate the valves (in the vent piping) between the currently existing and new ones.

• WW Vent Instrumentation Process Flow Diagram.

• Egress and Ingress Pathways to ROS, Battery Transfer Switch, DG Connections and Deployment location.

• Site layout sketch to show location/routing of WW vent piping and associated components. This should include relative locations both horizontally and vertically.

Sketch 3: P&ID Layout of SAWA, Pathways and Site Layout (preliminary)

• Piping routing for SAWA path

• SAWA instrumentation process paths.

• SAWA connections.

• Int-l1,dp 2 ninincr 2nd in~tnlme~ntatinn diao-rarn of the. ve~nt *v~to~m lTh~marcate, the. valve.* (in the. ve~nt ninin&r] he~twe~n the. ClrrF~ntlv e~xi~tin*r 2nd ne~w OnES.

S Ingress and egress paths to and from control locations and manual action locations.

S Site layout sketch to show locations of piping and associated components. This should include relative locations both horizontally and vertically.

Page 52 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Sketch 1A: Electrical Layout of System - HtCVS 2SCV*PNL101A CKT. #11 S2CIPS*FU&SE1-HCVS 30A 2CPS*FUSE2-HCVS 30A TRANSFER SWITCH 2CPS-DS-HCVS 7-,

PLUG FOR PORTABLE GENERATOR 125VDC BATTERY 125VDC Bus 2CPS-BKR-2) 20A

)2CPS-BKR-1 S 20A 1A 2CPS-BKR-41 ZCPS-BKR-5A 125 VDC/24 VIDC 2CPS-R*,T136 BATTERY VOLTAGE VALVE CONVERTER HCX'S DIVIDER RESISTOR CONTROL 2CIPS-PWRS801 RADIAl ['ION CIRCUIT MONIZ['OR SEE DWG. ZCPS-136-0t)01 Page 53 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Sketch 2B: Remote Operating Station Page 56 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Sketch 2C: HCVS Plan Overview S\ASO0 'A*O0,-

2_

Page 57 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Sketch 3B: Site Layout, Ingress and Egress Pathways (SAWA)

Ft.EX FLEX Manifold

• 'moved to track bay for SAWA I345 r1115 I ~Switcyards Page 59 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Sketch 3C: Nine Mile Point Unit 2 Reactor Building Elevation View

~; 'r-~

- ii

'at ~ ~~aa Ii .... SAVlNIA Connection Point

• . L[*  : .... ,' tot1;LHR "A"

nE> 77 i 4-a m

K I 'I

j. Ava liable Shielding

~~a4* -

3 concrete floors lIf { Aj~1 Bio-shield wall

~*4j/

Containment

.~ ~-"

~ *, '.,ti4f~.fl*' ,~ *1

• ~(

- JF"'* Ž..s~.a, ~a. ~,. -

'--- at -"'aW

.aama.4,.a*t$ 4t - ~-. 7 L *...

_____________________ ~ '-,4 ~~HV

~

~

~Th..a 1~~~~~'~ ____________________ r

-'4 ____ ~ ~ a...

a- ~.,

.4fl-,,

4 a A t,*.n ta4 p

• 4.,,, ~

a ~ ~ ~ ~at..

-r a," _________________________________________________________________

• .*._*........'a.:

• Noble Gas Release Source Term I:

1-E

.... ___. __ K.li t = .-  ! KIT __

r. - ". , ......'4*0 ,ti t * '* "" " * . .

.... taf .... a ÷,.)*, i Page 60 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 4: Failure Evaluation Table Table 4A: Wetwell HCVS Failure Evaluation Table

!Functional Failure Failure Cause Alternate Action Failure with Alternate S Mode Action Prevents

____________ ____________________________________________________ Containment Venting?

Fail to Vent (Open) Valves fail to open/close due to loss of normal None required - system SOVs utilize No on Demand AC power/DC batteries, dedicated 24-hour power supply.____________

Valves fail to open/close due to depletion of Recharge system with FLEX provided No dedicated power supply. portable generators. ____________

Valves fail to open/close due to complete loss Manually operate backup pneumatic No of power supplies, supply/vent lines at remote panel. _____________

Valves fail to open/close due to loss of normal No action needed. Valves are provided with No pneumatic supply. dedicated motive force capable of 24-hour operation.

Valves fail to open/close due to loss of Replace bottles as needed and/or recharge No alternate pneumatic supply (long term). with portable air compressors._____________

Valve fails to open/close due to SOV failure. Manually operate backup pneumatic No

__________________________________supply/vent lines at remote panel.

,!:*j Fail to stop venting Not credible as there is not a common mode N/A No (Close) on demand failure that would prevent the closure of at least 1 of the 3 valves needed for venting. __________________________________

Spurious Opening Not credible as key-locked switches prevent N/A No

__________ mispositioning of the HCVS PCIVs. _______________________________

,Spurious Closure Valves fail to remain open due to depletion of Recharge system with FLEX provided No

,dedicated power supply, portable generators.

• Valves fail to remain open dueto complete Manually operate backup pneumatic No loss of power supplies., supply/vent lines at remote panel.

Valves fail to remain open due to loss of Replace bottles as needed and/or recharge No alternate pneumatic supply (long term). with portable air compressors.

Page 61 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 5: References

1. Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013 (ML13066A171) for Nine Mile Point Unit #2

2. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989 3.* Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

4. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 2013

5. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012

6. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated November 14, 2013

7. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-02: Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012

8. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

9. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 2015

10. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014

11. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014

12. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations

13. NEI HCVS-FAQ-02, HCVS Dedicated Equipment

14. NEI HCVS-FAQ-03, HCVS Alternate Control Operating Mechanisms

15. NEI HCVS-FAQ-04, HCVS Release Point

16. NEI HCVS-FAQ-05, HCVS Control and 'Boundary Valves'

17. NEI HCVS-FAQ-06, FLEX Assumptions/HCVS Generic Assumptions

18. NEI HCVS-FAQ-07, Consideration of Release from Spent Fuel Pool Anomalies

19. NEI HCVS-FAQ-08, HCVS Instrument Qualifications

20. NEI FHCVS-AQ-09, Use of Toolbox Actions for Personnel

21. NEI White Paper HCVS-WP-01, HCVS Dedicated Power and Motive Force

22. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach

23. NEI White Paper HCVS-WP-03, Hydrogen/CO Control Measures

24. 2015-01099, RCIC Equipment Survivability Review

25. NUREG/CR-7 110, Rev. 1, State-of-the-Art Reactor Consequence Analysis Project, Volume 1: Peach Bottom Integrated Analysis

26. SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments, 11/26/12

27. NMP2 USAR, Rev. 20, Updated Safety Analysis Report

28. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class lE Equipment for Nuclear Power Generating Stations

29. FLEX MAAP Endorsement ML13190A201

30. N2-2014-003, MAAP 4.0.6 Analysis of Nine Mile Point Unit 2 Loss of All AC Power Scenario

31. 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, dated April 2015

32. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade, Revision 0, dated August 17, 2015

33. NEI HCVS-FAQ-l0, Severe Accident Multiple Unit Response

34. NEI HCVS-FAQ-l 11, Plant Response During a Severe Accident

35. NET HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial Use

36. NET HC-VS-FAQ- 13, Severe Accident Venting Actions Validation'

37. N2-MISC:003, MAAP--Analysis to Supl~ort SAWA Strategy "..

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N Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 6: Changes/Updates to this Overall Integrated Implementation Plan This Overall IntegratedPlan has been updated informnat and content to encompass both Phase 1 and Phase 2 of Order EA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6-Month Status Reports.

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Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents Attachment 7: List of Overall Integrated Plan Open Items Phase 1 Action Status Open Item_________________________

1I Perform final sizing evaluation for HCVS batteries and battery Deleted (closed to ISE open item charger and include in FLEX DG loading calculation, number 8 below) 2 Perform final vent capacity calculation for the HCVS piping Deleted (closed to ISE open item confirming 1% minimum capacity. number 3 below) 3 Perform final sizing evaluation for pneumatic Nitrogen (N2) Deleted (closed to ISE open item supply, number 9 below)

• 4 Perform seismic evaluation of Reactor Building Track Bay. Deleted (closed to ISE open item number 2 below) 5 State which approach or combination of approaches the plant Deleted (closed to ISE open item determines is necessary to address the control of combustible number 4 below)

__________gases downstream of the HCVS control valve.

6 Complete evaluation for environmental/seismic qualification of Deleted (closed to ISE open item HCVS components. numbers 10 and 12 below) 7 Confirm evaluation for environmental conditions and confirm Deleted (closed to ISE open item travel path accessibility, number 7 below) 8 Perform final environmental evaluation of ROS location. Deleted (closed to ISE open item

number 7 below) 9 'Perform radiological evaluation for Phase ivent line impact on Not Started ERG response actions.

1.

Phase 1 Action Status ISE Open Item 1 Make available for NRC staff audit the seismic and tomnado Started. The HCVS external piping meets the reasonable missile final design criteria for the HCVS stack. protection requirements of HCVS-WP-04.

2 Make available for NRC staff review documentation of a Complete. Per the NMP2 USAR Table 3.2-1 and Section determination of seismic adequacy for the ROS location in the 3.8.4.1.9, the Reactor Building Track Bay is a seismic, tornado Reactor Building Track Bay. protected structure. The C045 Series of calculations and EC-045 Series of drawings also indicate that the Track Bay/Standby Gas Treatment Building is a Safety Related, QA Cat I structure.

In addition, the outer track bay doors are designed to withstand tornado missiles per door specification S208G.

3 Make available for NRC staff audit analyses demonstrating that Started. Calculation A10.1-P-050 confirms the vent design has Page 64 of 66

Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents HCVS has the capacity to vent the steam/energy equivalent of one the minimum required capacity. Reference 37 documents (1) percent of licensed/rated thermal power (unless a lower value venting is not required before 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

is justified) and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design

~pressure and the primary containment pressure limit.

4 Provide a description of the final design of the HCVS to address Complete. The December 2015 OIP update contains a more hydrogen detonation and deflagration. detailed description of how the design addresses hydrogen

~detonation and deflagration.

5 . Make available for NRC staff audit documentation that Started.

demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

6 Provide a description of the strategies for hydrogen control that Complete. The December 2015 OIP update contains a more minimizes the potential for hydrogen gas migration and ingress in detailed description of the strategies for hydrogen control and the reactor building or other buildings. migration.

7 Make available for NRC staff audit an evaluation of temperature Started. The Design Consideration Summary of ECP-13-000087 and radiological conditions to ensure that operating personnel can contains an evaluation of the temperatures at the ROS.

safely access and operate controls and support equipment.

Calculation ES-289 evaluates the temperatures in the Reactor Building after an ELAP and is being revised for the inclusion of an operating HCVS vent line.

Calculation H21C-l114 is being revised to contain an evaluation of the radiological conditions at the ROS and diesel generator.

SMake available for NRC staff audit the final sizing evaluation for Started. The battery sizing summary is contained within the HCVS batteries/battery charger including incorporation into FLEX Design Consideration Summary of ECP-13-00087 and is DG loading calculation, complete.

An update to calculation EC-206 for impact of the HCVS batteries on the FLEX DG loading is working.

9 Make available for NRC staff audit documentation of the HCVS Complete. P&IID 061-D outlines the functional design of the nitrogen pneumatic system design including sizing and location, pneumatic system. Calculation A10.1-P-051 determines the required amount of Nitrogen needed for the required number of vent cycles in a 24-hour period.

10 Make available for NRC staff audit documentation of a seismic Started.

qualification evaluation of HCVS components.

11 Make available for NRC staff audit descriptions of all Started. The December 2015 OIP update contains a more instrumentation and controls (existing and planned) necessary to detailed description of I&C components, including qualification

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Nine Mile Point Unit 2 Overall Integrated Plan for Reliable Hardened Vents implement this order including qualification methods. methods.

12 Make available for NRC staff audit the description of local Started.

conditions (temperature, radiation, and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

13 Make available for NRC staff audit documentation of an Started. The containment isolation valves are being replaced and evaluation verifying the existing containment isolation valves designed to ensure they can open and shut against the Maximum relied upon for the HCVS, will open under the maximum expected Expected Differential Pressure (MEDP). Vendor calculations differential pressure during BDBEE and severe accident wetwell are complete. NMP calculations are working.

_______venting._____________________________

Phase 2 Open'Item Action Comment Perform radiological evaluation to determine feasibility of reactor 1_______building actions. Not started

'2 _____________________________ ____________________________

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