RS-16-109, Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 6/6/2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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Fourth Six-Month Status Report for Phases 1 & 2 Overall Integrated Plan in Response to 6/6/2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML16182A012
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/30/2016
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-16-109
Download: ML16182A012 (15)
v • d • e


Text

Exelon Generation ~,

Order No. EA-13-109 RS-16-109 June 30, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

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-14-062)
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 19, 2014 (RS-14-305)
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-15-151)

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 15, 2015 (RS-15-303)
9. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - 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.

MF4416 and MF4417), dated February 12, 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 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 Peach Bottom Atomic Power Station, Units 2 and 3, 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 Peach Bottom Atomic Power Station. Reference 8 provided the Peach Bottom Atomic Power Station, Units 2 and 3, 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 Peach Bottom Atomic Power Station, Units 2 and 3. 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 Plan 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.

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

Enclosure:

Peach Bottom Atomic Power Station, Units 2 and 3 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 I NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Peter Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection S. T. Gray, State of Maryland

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 (11 pages)

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 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 Peach Bottom Atomic Power Station (PBAPS) 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. 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 15, 2015.

PBAPS developed an updated and combined Phases 1 and 2 Overall Integrated Plan (Reference 6 in Section 8), documenting:

1. The installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2.
2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2 This enclosure provides an update of milestone accomplishments since submittal of the 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 6), 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.

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Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milest9ne Table Submit Overall Integrated Plan (Phase 1) Jun. 2014 Complete Submit 6 Month Updates Update 1 Dec.2014 Complete Update 2 Jun.2015 Complete Update 3 [Simultaneous with Phase 2 Dec.2015 Complete OIP]

Complete Update 4 Jun.2016 with 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 Date Change:

Submit Completion Report Jan.2019 Not Started Previously Dec.2018 Phase 1 Specific Milestones Phase 1 Unit 2 Modifications Begin Conceptual Design Apr. 2014 Complete Complete Conceptual Design Jun.2015 Complete Begin Detailed Design Jun.2015 Complete Date Change:

Complete Detailed Design and Issue Jun.2016 Started Previously Modification Package Apr. 2016 Begin Online Portion of the Installation Jun.2016 Started Complete Online Installation Oct. 2016 Not Started '

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Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Begin Outage Portion of the Installation Oct. 2016 Not Started Complete Outage Installation Nov. 2016 Not Started Phase 1 Procedure Changes Active Operations Procedure Changes Nov. 2016 Started Developed Site Specific Maintenance Procedure Nov. 2016 Started Developed Procedure Changes Active Nov. 2016 Not Started Phase 1 Training Training Complete Nov. 2016 Not Started Phase 1 Completion Unit 2 Phase 1 HCVS Implementation Nov.2016 Started Submit Completion Report Jan.2019 Not Started Phase 1 Unit 3 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Begin Detailed Design May 2016 Complete Date Change:

Complete Detailed Design and Issue Oct. 2016 Started Previously Modification Package Sep.2016 Begin Online Portion of the Installation Feb.2017 Not Started Complete Online Installation Jun.2017 Not Started Begin Outage Portion of the Installation Oct. 2017 Not Started Date Change:

Complete Outage Installation Nov. 2017 Not Started Previously Oct. 2017 Phase 1 Procedure Changes Active Page 3of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Comments Activity Milestone Completion Status Date II Phases 1 and 2 HCVS Milestone Table Date Change:

Operations Procedure Changes Nov. 2017 Not Started Previously Developed Oct. 2017 Date Change:

Site Specific Maintenance Procedure Nov. 2017 Not Started Previously Developed Oct. 2017 Date Change:

Procedure Changes Active Nov. 2017 Not Started Previously Oct. 2017 Phase 1 Training Date Change:

Training Complete Nov. 2017 Not Started Previously Oct. 2017 Phase 1 Completion Unit 3 Phase 1 HCVS Implementation Nov. 2017 Not Started Full Site HCVS Phase 1 Implementation Nov. 2017 Not Started Date Change:

Submit Completion Report Jan.2018 Not Started Previously Dec.2017 Phase 2 Specific Milestones Phase 2 Unit 3 Modifications Begin Conceptual Design May 2016 Complete Complete Conceptual Design Jul. 2016 Started Begin Detailed Design Jul. 2016 Not Started Date Change:

Complete Detailed Design and Issue Oct. 2016 Not Started Previously Modification Package Sep.2017 Begin Online Portion of the Installation Feb.2017 Not Started Complete Online Installation Jun.2017 Not Started Page 4of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Begin Outage Portion of the Installation Oct. 2017 Not Started Date Change:

Complete Outage Installation Nov. 2017 Not Started Previously Oct. 2017 Phase 2 Procedure Changes Active Date Change:

Operations Procedure Changes Nov. 2017 Not Started Previously Developed Oct. 2017 Date Change:

Site Specific Maintenance Procedure Nov.2017 Not Started Previously Developed Oct. 2017 Date Change:

Procedure Changes Active Nov.2017 Not Started Previously Oct. 2017 Phase 2 Training Date Change:

Training Complete Nov. 2017 Not Started Previously Oct. 2017 Phase 2 Completion Unit 3 Phase 2 HCVS Implementation Nov. 2017 Not Started Submit Phase 1 and Phase 2 Completion Jan.2018 Not Started Report Phase 2 Unit 2 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Begin Detailed Design Mar. 2017 Not Started Complete Detailed Design and Issue Sep.2017 Not Started Modification Package Begin Online Portion of the Installation Feb.2018 Not Started Page 5of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Complete Online Installation Jun.2018 Not Started Begin Outage Portion of the Installation Oct. 2018 Not Started Complete Outage Installation Nov.2018 Not Started Phase 2 Procedure Changes Active Operations Procedure Changes Nov.2018 Not Started Developed Site Specific Maintenance Procedure Nov.2018 Not Started Developed Procedure Changes Active Nov. 2018 Not Started Phase 2 Training Training Complete Nov. 2018 Not Started Phase 2 Completion Unit 2 Phase 2 HCVS Implementation Nov.2018 Not Started Full Site HCVS Phase 2 Implementation Nov. 2018 Not Started Date Change:

Submit Phase 1 and Phase 2 Completion Jan.2019 Not Started Previously Report Dec. 2018 4 Changes to Compliance Method It was previously communicated in the combined Phases 1 and 2 Overall Integrated Plan (Reference 6) that the Remote Operating Station (ROS) location is in the Radwaste Building, elevation 150'. This location has been changed in order to further minimize plant operator's exposure to occupational hazards and also due to existing sample tanks located in the vicinity which could potentially challenge the functionality of the ROS equipment if the tanks were to rupture. The HCVS dedicated nitrogen and argon supply is relocated to elevation 135' of the Radwaste Building and the HCVS DC power supply is relocated to the 3A/C station battery room (battery) and E33 switchgear room (battery charger) on elevation 135'. These locations are not affected by a rupture of the sample tanks due to an existing open hatch adjacent to the sample tanks, which is open down to elevation 91 '-6. If a rupture of the sample tanks were to occur, the water would drain from elevation 150' down to elevation 91 '-6" via the open hatch. Any collection of water on elevation 135' would reach an existing floor drain prior to reaching the HCVS equipment relocated to El. 135'. These Page 6of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 locations also have significant shielding and/or distance from radiological sources and will be evaluated for Severe Accident (SA) temperature and radiation conditions to ensure access to the equipment is maintained.

The Phase 2 Severe Accident Water Addition (SAWA) flow path was described in the combined Phases 1 and 2 Overall Integrated Plan (Reference 6) to be from the FLEX suction at the Emergency Cooling Tower (ECT) basin through the FLEX (SAWA) pump to the permanent SAWA connection point. This connection point was described as connecting to the Residual Heat Removal (RHR) System Loop A (Low Pressure Coolant Injection (LPCI)). This connection point is only applicable for Unit 3; RHR System Loop B (LPCI) is planned to be used for Unit 2. These connection points are existing FLEX connection points and will only be used for SAWA during a flooding hazard. For all other hazards, the existing FLEX connection points to the High Pressure Service Water (HPSW) system will be used as the permanent SAWA connection points for Units 2 and 3. These connection points tie into the RHR System Loop A for Unit 3 and will tie into Loop B for Unit 2. The connection actions will be completed in the first eight hours of the event, and as soon as practical. Motor-operated valve (MOV) alignment required for all SAWA flow paths will be powered from the FLEX Diesel Generators (DGs).

Table 4-1 of the combined Phases 1 and 2 Overall Integrated Plan (Reference 6) communicated that the performance of visual inspections and a walk down of HCVS and installed SAWA components would be performed on a frequency of once per every other operating cycle. However, the performance of this requirement will be on a frequency of once per operating cycle to align with the guidance provided in NEI 13-02, Rev. 1 (Reference 3).

There are no other changes to the compliance method outlined in Reference 6.

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

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 Phases 1 and 2 OIP Open Item Status Phase 1 Open Items 01-1. Confirm that the Remote Operating Station (ROS) Deleted. Closed to ISE Open Item will be in an accessible area following a Severe Accident number 09.

(SA).

01-2. Provide procedures for HCVS Operation Deleted. Closed to ISE Open Item Page 7of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Combined Phases 1 and 2 OIP Open Item Status number 01.

01-3. Identify site specific controlling document for HCVS Deleted. Closed to ISE Open Item out of service and compensatory measures number 02.

01-4. Determine the approach for combustible gases. Deleted. Closed to ISE Open Item number 08.

01-5. Perform radiological evaluation for Phase 1 vent Started.

line impact on ERO response actions.

Phase 1 Interim Staff Evaluation Open Item Status ISE-1. Make available for NRC staff audit guidelines Started.

and procedures for HCVS operation. (Section 3.2.3.1)

ISE-2. Make available for the NRC staff audit the site Not Started.

specific controlling document for HCVS out of service and compensatory measures. (Section 3.4.1)

ISE-3. Make available for NRC staff audit a technical Complete - The design of the justification for use of jumpers in the HCVS strategy. HCVS includes a control switch in (Section 3.1.3) the MCR for transferring power to the solenoid valve (SV) that does not include a PCIS isolation signal, eliminating the need for jumpers.

ISE-4. Make available for NRC staff audit analyses Complete - Calculation PM-0546, demonstrating that the HCVS has the, capacity to vent Torus Hardened Vent-Flow the steam/energy equivalent of one percent of demonstrates that the HCVS has licensed/rated thermal power (unless a lower value is the capacity to vent the justified), and that the suppression pool and the HCVS steam/energy equivalent of one together are able to absorb and reject decay heat, such percent licensed/rated thermal that following a reactor shutdown from full power power.

containment pressure is restored and then maintained below the primary containment design pressure and the The primary containment design primary containment pressure limit. (Sections 3.2.2.1 pressure is 56 psig (U FSAR and 3.2.2.2) 5.2.3.1 ). The primary containment pressure limit is 60 psig (UFSAR 5.2.3.6). PM-0546 shows that the HCVS capacity exceeds one percent of licensed/rated thermal power at the lower of these values.

Calculation PM-0546 is available for NRC review on the ePortal.

ISE-5. Make available for NRC staff audit descriptions Complete - Reference Drawing M-or diagrams of reactor building ventilation including 395: The Reactor Building Page 8of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 1 Interim Staff Evaluation Open Item Status exhaust dampers failure modes to support licensee Exhaust System. The RB Exhaust justification for the HVAC release point being below and System Fans, including the Refuel 150 feet from the reactor building ventilation release Floor Exhaust Fans, RB Exhaust point. (Section 3.2.2.3) Fans, and RB Equipment Exhaust Fans, have Fail-Close dampers in exhaust ducts to prevent uncontrolled or unmonitored release from the RB in the event of loss of power to the solenoid valves associated with the dampers. Fail-Close dampers will eliminate pathway into the RB in the event of use of the HCVS in an ELAP.

Drawing M-395 is available for NRC review on the ePortal.

ISE-6. Make available for NRC staff audit details to Started - Exelon is preparing an justify the deviation from tornado protection standards analysis to demonstrate that the provided in NEI 13-02 or make available a description of location of the existing external how the HCVS will comply with the tornado protection piping already provides standards provided in NEl-13-02. (Section 3.2.2.3) reasonable protection from tornado Qenerated missiles.

ISE-7. Make available for NRC staff audit Complete - FLEX modification documentation that demonstrates adequate ECR 15-00126 improved the communication between the remote HCVS operation PBAPS communication system, to locations and HCVS decision makers during ELAP and be functional in the event of an severe accident condition. (Section 3.2.2.5) ELAP.

ECR 15-00126 is available for NRC review on the ePortal.

ISE-8. Provide a description of the final design of the Complete - PBAPS will utilize an HCVS to address hydrogen detonation and Argon purge system to address deflagration.(Section 3.2.2.6) combustible gases in the HCVS piping. A summary of the design features is included in the December 2015 OIP.

ISE-9. Make available for NRC staff audit an evaluation Started.

of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment. (Sections 3.2.1, 3.2.2.3, 3.2.2.4, 3.2.2.5, 3.2.2.10, 3.2.4.1, 3.2.4.2, 3.2.5.2, and 3.2.6)

ISE-10. Make available for NRC staff audit descriptions Started.

of all instrumentation and controls (existing and planned) necessary to implement this order including qualification Page 9of11

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 1 Interim Staff Evaluation Open Item Status methods. (Sections 3.2.2.9 and 3.2.2.10)

ISE-11. Make available for NRC staff audit the final Started.

sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation. (Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 3.2.4.2, 3.2.5.1, 3.2.5.2, and 3.2.6)

ISE-12. Make available for NRC staff audit the Started.

descriptions 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 conditions. (Sections 3.2.2.3, 3.2.2.5, 3.2.2.9, and 3.2.2.10)

ISE-13. Make available for NRC staff audit Started.

documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

ISE-14. Provide a description of the strategies for Completed - As described in the hydrogen control that minimizes the potential for 01 P, the HCVS torus vent path in hydrogen gas migration and ingress into the reactor each unit, starting at and including building or other buildings. (Section 3.2.2.6 and 3.2.2.7) the downstream PCIV, will be a dedicated HCVS flow path. There are no interconnected systems downstream of the downstream, dedicated HCVS PCIV.

Interconnected systems are upstream of the downstream HCVS PCIV and are isolated by normally shut, fail shut PCIVs which, if open, would shut on an ELAP. There is no shared HCVS piping between the two units.

The vent path will rely on an Argon purge system to prevent the formation of a combustible gas mixture in the vent line.

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Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 1 Interim Staff Evaluation Open Item Status ISE-15. Make available for NRG audit documentation Started.

confirming that HCVS will remain isolated from standby gas treatment system during ELAP and severe accident conditions. (Section 3.2.2.7)

Phase 2 Interim Staff Evaluation Open Item Status Phase 2 ISE has not been issued.

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. Peach Bottom Atomic Power Station, Units 2 and 3, 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.
2. NRG 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.
3. NEI 13-02, "Industry Guidance for Compliance with NRG Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, 11 Revision 1, dated April 2015.
4. NRG 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. ML133048836).
5. NRG Endorsement of Industry "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev O," dated May 14, 2014 (Accession No. ML14128A219).
6. Peach Bottom Atomic Power Station, Units 2 and 3, Combined 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)," dated December 15, 2015.
7. NRG 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, 11 Revision 0, dated April 2015 (Accession No. ML15104A118).

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