RS-16-107, County, Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 06/06/13 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condi

County, Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 06/06/13 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condit

ML16182A394
Person / Time
Site:	LaSalle
Issue date:	06/30/2016
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-16-107
Download: ML16182A394 (12)

Text

AdONOW Awwpp- Exelon Generation, Order No. EA-13-109 RS-16-107 June 30, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Fourth Six-Month Status Report For Phases 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

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-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents 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-13-109), 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 30, 2014 (RS-14-059)

6. Exelon Generation Company, LLC 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-13-109), dated December 17, 2014 (RS-14-303)

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-13-109), dated June 30, 2015 (RS-15-149)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 June 30, 2016 Page 2

8. Exelon Generation Company, LLC 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-13-109), dated December 16, 2015 (RS-15-300)

9. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 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 Nos. MF4456 and MF4457), dated March 31, 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 11 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 (FLAP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required 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 LaSalle County Station, Units 1 and 2, Phase 1 OIP pursuant to Section IV, Condition D.1 of Reference 1. References 6 and 7 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for LaSalle County Station. Reference 8 provided the LaSalle County Station, Units 1 and 2, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1.

The purpose of this letter is to provide the fourth six-month update report for Phases 1 and 2, pursuant to Section IV, Condition D.3 of Reference 1, that delineates progress made in implementing the requirements of Reference 1 for LaSalle County Station, Units 1 and 2. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation open items contained in Reference 9.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

U.S. Nuclear Regulatory Commission Integrated P Ian Report to EA-13-109 June 30, 2016 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of June 2016.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - LaSalle County Station NRC Project Manager, NRR - LaSalle County Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (8 pages)

Enclosure LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for Phases 1 and 2 Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" 1 Introduction LaSalle Station developed an Overall Integrated Plan (Reference 1 in Section 8),

documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2 in Section 8. Starting with this six month status report, updates of milestone accomplishments will be based on the combined Phases 1 and 2 Overall Integrated Plan dated December 16, 2015.

LaSalle Station developed an updated and combined Phases 1 and 2 Overall Integrated Plan (Reference 7 in Section 8), documenting:

1. The installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2 in Section 8.

2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2 in Section 8.

This enclosure provides an update of milestone accomplishments since submittal of the combined Phases 1 and 2 Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the combined Phases 1 and 2 Overall Integrated Plan (Reference 7 in Section 8), and are current as of May 15, 2016:

• Fourth Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to Attachment 2 of the combined Phases 1 and 2 Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

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

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LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Submit Phase 1 Overall Integrated Plan Submit 6 Month Updates T Jun 2014 Complete Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 and Phase 2 Overall Integrated Dec 2015 Complete Plan Update 4 Jun 2016 Complete This submittal Update 5 Dec 2016 Not Started Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Unit 2 Modifications Begin Conceptual Design Jun 2014 Complete Complete Conceptual Design Jun 2014 Complete Begin Detailed Design Jun 2015 Complete Complete Detailed Design and Issue Nov 2016 Started Modification Package Begin Online Installation Jun 2016 Not Started Complete Online Installation Feb 2017 Not Started Begin Outage Installation Feb 2017 Not Started Complete Outage Installation Mar 2017 Not Started Phase 1 Unit 2 Procedure Changes Operations Procedures Developed Dec 2016 Not Started Maintenance Procedures Developed Dec 2016 Not Started Page 2 of 8

LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Procedure Changes Active Mar 2017 Not Started Phase 1 Unit 2 Training Training Complete T Dec 2016 Not Started Phase 1 Unit 2 Completion Unit 2 HCVS Phase 1 Implementation Mar 2017 Not Started Submit Completion Report May 2019 Not Started Phase 1 Unit 1 Modifications Begin Conceptual Design Jun 2014 Complete Complete Conceptual Design Jun 2014 Complete Begin Detailed Design Jun 2015 Complete Complete Detailed Design and Issue Mar 2017 Started Modification Package Begin Online Installation May 2017 Not Started Complete Online Installation Feb 2018 Not Started Begin Outage Installation Feb 2018 Not Started Complete Outage Installation Mar 2018 Not Started Phase 1 Unit 1 Procedure Changes Operations Procedures Developed Dec 2017 Not Started Maintenance Procedures Developed Dec 2017 Not Started Procedure Changes Active Mar 2018 Not Started Phase 1 Unit 1 Training Training Complete Dec 2017 Not Started Phase 1 Unit 1 Completion Phase 1 Unit 1 Implementation Mar 2018 Not Started Phase 1 Full Site Implementation Mar 2018 Not Started Page 3 of 8

LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Submit Completion Report May 2018 Not Started Phase 2 Specific Milestones Phase 2 Unit 1 Modifications Begin Conceptual Design Jun 2015 Complete Complete Conceptual Design Jun 2015 Complete Begin Detailed Design Jun 2016 Not Started Complete Detailed Design and Issue Mar 2017 Not Started Modification Package Begin Online Installation May 2017 Not Started Complete Online Installation Feb 2018 Not Started Begin Outage Installation Feb 2018 Not Started Complete Outage Installation Mar 2018 Not Started Phase 2 Unit 1 Procedure Changes Operations Procedures Developed Dec 2017 Not Started Maintenance Procedures Developed Dec 2017 Not Started Procedure Changes Active Mar 2018 Not Started Phase 2 Unit 1 Training Training Complete Phase 2 Unit 1 Completion 7 Dec 2017 Not Started Phase 2 Unit 1 Implementation Mar 2018 Not Started Submit Phase 1 and Phase 2 Completion May 2018 Not Started Report Phase 2 Unit 2 Modifications Begin Conceptual Design Jun 2015 Complete Complete Conceptual Design Jun 2015 Complete Begin Detailed Design Jun 2017 Not Started Page 4 of 8

LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Complete Detailed Design and Issue Mar 2018 Not Started Modification Package Begin Online Installation May 2018 Not Started Complete Online Installation Feb 2019 Not Started Begin Outage Installation Feb 2019 Not Started Complete Outage Installation Mar 2019 Not Started Phase 2 Unit 2 Procedure Changes Operations Procedures Developed Dec 2018 Not Started Maintenance Procedures Developed Dec 2018 Not Started Procedure Changes Active Mar 2019 Not Started Phase 2 Unit 2 Training Training Complete Dec 2018 Not Started Phase 2 Unit 2 Completion Phase 2 Unit 2 Implementation Mar 2019 Not Started Phase 2 Full Site Implementation Mar 2019 Not Started Submit Phase 1 and Phase 2 May 2019 Not Started Completion Report 4 Changes to Compliance Method None.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation LaSalle expects to comply with the Order implementation date and no relief/relaxation is required at this time.

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LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 6 Open Items from Combined Phases 1 and 2 Overall Integrated Plan and Interim Staff Evaluations The following tables provide a summary of the open items documented in the combined Phases 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Combined Phase 1 and 2 OIP Open Items Status Phase 1 Open Items 7 Perform radiological evaluation for Phase 1 vent Started line impact on ERO actions.

Phase 2 Open Items 1 Evaluate feasibility of strategy due to radiological Started conditions.

2 Verify required modifications to support Not Started SAWA/SAWM.

No. Phase 1 Interim Staff Evaluation Open Item Status 1 Make available for NRC staff audit documentation Started. The motive and purge gas of a method to disable HCVS during normal systems will be isolated by one operation to provide assurances against locked closed manual valve in each inadvertent operation that also minimizes actions to system during normal operation.

enable HCVS operation following an ELAP. Main Control Room (MCR) controls will be via key-locked switches.

PCIVs are air-to-open, spring/fail closed.

2 Make available for NRC staff audit the final sizing Started evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

3 Make available for NRC staff audit documentation Started of the HCVS argon pneumatic system design including sizing and location.

4 Make available for NRC staff audit an evaluation of Started temperature and radiological conditions to ensure that operating personnel can safely access and o erate controls and support equipment.

5 Make available for NRC staff audit analyses Started demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power unless a lower value Page 6 of 8

La8eb* County Station, Units 1 and Fourth Six-Month Status Report for the Implementation ofHCVS Phases 1 and 2 June 8O.2O18 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.

6 Make available for NRC staff audit the seismic and Started. LaSalle design will comply tornado missile final design criteria for the HCVS with the reasonable tornado stack. protection criteria of Reference 6 in Section 8.

7 Make available for NRC staff audit the descriptions Started of local 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 8 Make available for NRC staff audit documentation Not Started that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

9 Provide a description of the final design of the Started. LaSalle design will use HCVS to address hydrogen detonation and argon purge system to prevent the deflagration. possibility of hydrogen detonation and deflagration.

10 Provide a description of the strategies for hydrogen Started. LaSalle wetwell vent line control that minimizes the potential for hydrogen has a dedicated HCVS f lowpath gas migration and ingress into the reactor building from the wetwell penetration to the or other buildings. outside with no interconnected system. The discharge point meets the guidance of HCVS-FAQ-04 (Att.

J of Reference 3 in Section 8).

11 Make available for NRC staff audit documentation Started of a seismic qualification evaluation of HCVS 12 Make available for NRC staff audit descriptions of Started all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

13 Make available for NRC staff audit the procedures Not Started for HCVS operation.

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LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 2 Interim Staff Evaluation Open Item Status Phase 2 ISE not yet issued. N/A 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation(s) identified at this time.

8 References The following references support the updates to the combined Phases 1 and 2 Overall Integrated Plan described in this enclosure.

1. LaSalle County Station, Units 1 and 2, 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 30, 2014 (Accession No. ML14184A016).

2. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" dated June 6, 2013 (Accession No. ML13143A321).

3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, `To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 1, dated April 2015.

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).

5. NRC Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0," dated May 14, 2014 (Accession No. ML14128A219).

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

7. LaSalle County Station, Units 1 and 2, 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-13-109)," dated December 16, 2015 (Accession No. ML15352A109).

8. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated April 2015 (Accession No. ML15104A118).

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