RS-16-111, 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 Conditions

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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 Conditions
ML16182A013
Person / Time
Site: Nine Mile Point  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-16-111
Download: ML16182A013 (32)
v • d • e


Text

Exelon Generation ~,

Order No. EA-13-109 RS-16-111 June 30, 2016 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 50-41 O

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 27, 2014
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 (FLL-14-035)
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-13-109), dated June 30, 2015 (RS-15-153)

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-15-302)
9. 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

10. 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 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 01 P 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 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 Nine Mile Point Nuclear Station. Reference 8 provided the Nine Mile Point Nuclear 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 reports 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 Nine Mile Point Nuclear Station, Units 1 and 2.

The enclosed reports provide 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 reports also address the NRC Interim Staff Evaluation open items contained in References 9 and 10.

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 30 1h day of June 2016.

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

Enclosures:

1. Nine Mile Point Nuclear Station, Unit 1 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
2. Nine Mile Point Nuclear Station, Unit 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 I NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC

Enclosure 1 Nine Mile Point Nuclear Station, Unit 1 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 1 Nine Mile Point Nuclear Station, Unit 1 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 Nine Mile Point Unit 1 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.

Nine Mile Point Unit 1 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.
2. An alternative venting strategy that makes it unlikely that a drywall 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 Overall Integrated Plan (Reference 7), and are current as of June 6, 2016.

  • Engineering Change Package was issued February 17, 2016 to allow for the initial planning and installation of portions of the HCVS.

Page 1

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 3 Milestone Schedule Status The following provides an update to the Part 5 Milestone Schedule of the 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 Design Engineering Complete date shown below does not impact the Order implementation date.

NMP1 - Phase 1 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Hold preliminary/conceptual design meeting November Complete 2013 Submit Overall Integrated Implementation Plan June 2014 Complete Submit 6 Month Status Report Dec 2014 Complete Submit 6 Month Status Report June 2015 Complete Submit 6 Month Status Report Dec 2015 Complete Simultaneous with Phase 2 OIP Submit Combined Phases 1 & 2 Six-Month Status June 2016 Complete Complete with this Report submittal Design Engineering Complete Af:}Fil 2Q~ e Started Design Package issued July 2016 Feb 2016. Revised package in progress to capture lessons learned from NMP2 Submit Combined Phases 1 & 2 Six-Month Status Dec 2016 Not Report Started Maintenance and Operation Procedure Changes February Not Developed, Training Complete 2017 Started Implementation Outage April 2017 Not Started Procedure Changes Active, Walk-Through April 2017 Not Demonstration/Functional Test Started Submit Completion Report June 2019 Not Started NMP1 - Phase 2 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Submit Overall Integrated Implementation Plan December Complete Simultaneous with Page 2

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 2015 Phase 1 Updated OIP Hold preliminary/conceptual design meeting June 2015 Complete Submit 6 Month Status Report June 2016 Complete Complete with this submittal Submit 6 Month Status Report Dec 2016 Not Started Submit 6 Month Status Report June 2017 Not Started Submit 6 Month Status Report Dec 2017 Not Started Submit 6 Month Status Report June 2018 Not Started Submit 6 Month Status Report Dec 2018 Not Started 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 Phase 1 and Phase 2 Completion Report June 2019 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phases 1 and 2 Overall Integrated Plan (Reference 7).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Nine Mile Point Unit 1 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 Attachment 7 of the combined Phases 1 and 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Page 3

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Open Items from OIP Status Item

1. Perform final sizing evaluation for HCVS Deleted (closed to ISE open item number 7 batteries and battery charger and include in below}

FLEX DG loading calculation.

2. Perform final vent capacity calculation for the Deleted (closed to ISE open item number 2 Torus HCVS piping confirming 1 % minimum below}

capacity.

3. Perform final sizing evaluation for pneumatic Deleted (closed to ISE open item number 8 Nitrogen (N2} supply. below}
4. Perform confirmatory environmental condition Deleted (closed to ISE open item numbers 6 evaluation for the Turbine Building in the and 11 below}

vicinity of the Remote Operating Station (ROS} and HCVS dedicated pneumatic supply and batteries.

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

necessary to address the control of combustible gases downstream of the HCVS control valve.

6. Complete evaluation for Deleted (closed to ISE open item numbers 9 environmental/seismic qualification of HCVS and 11 below}

components.

7. Complete evaluation for environmental Deleted (closed to ISE open item number 6 conditions and confirm the travel path below}

accessibility.

8. Perform radiological evaluation for Phase 1 Started vent line impact on ERO response actions.

Page 4

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items 1 Make available for NRG staff audit the Complete seismic and tornado missile final design criteria for the HCVS stack. Seismic Design of HCVS stack The HCVS vent piping system has been evaluated to Seismic Category I requirements in pipe stress calculations S22.4-201 .1 P002 and S22.4-201 .13P003 consistent with the plants seismic design basis to comply with NEI 13-02, Section 5.2 seismic design guidance. Per NRG Letter, May 9, 2014 "

Subject:

Screening and Prioritization Results Regarding Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", the NRG concluded that NMP1 "screened out" of performing the seismic risk evaluation as part of the HCVS seismic analysis. Therefore, use of current licensing basis and design basis seismic information (i.e., response spectra) is considered acceptable for the BOB analysis of the HCVS piping system at NMP1. The above referenced pipe stress calculations are available for NRG review in the ePortal.

Missile Protection of the HCVS stack NEI 13-02, Section 5.1.1.6 requires that missile impacts are to be considered for portions of the HCVS. The Nuclear Energy Institute (NEI) issued a white paper HCVS-WP-04, endorsed by the NRG, which provides a risk-informed approach to evaluate the threat posed to exposed portions of the HCVS by wind-borne missiles. The white paper concludes that the HCVS is unlikely to be damaged in a manner that prevents containment venting by wind-generated missiles coincident with an ELAP or LUHS, for plants that are enveloped by the assumptions in the white paper.

A NMP1 specific missile evaluation is documented in the Engineering Change Package (ECP) consistent with HCVS-WP-04.

The conclusion of the evaluation is that NMP1 meets all of the tornado missile assumptions identified in HCVS-WP-004 and as such, supplementary protection is not required for the HCVS piping and components. The ECP missile evaluation is available in the ePortal for NRG Page 5

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items review.

2 Make available for NRC staff audit analyses Complete demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one The HCVS is sized to provide sufficient venting percent of licensed/rated thermal power capacity to prevent a long-term overpressure (unless a lower value is justified), and that failure of the containment by keeping the the suppression pool and the HCVS together containment pressure below the containment are able to absorb and reject decay heat, design pressure and the primary containment such that following a reactor shutdown from pressure limit. The HCVS has been full power containment pressure is restored demonstrated by calculation S22.4-201.13F004 and then maintained below the primary to have the capacity to vent the steam/energy containment design pressure and the primary equivalent of 1 percent of licensed/rated thermal containment pressure limit. power. The calculation indicates that a vent capacity of approximately 68,300 lbm/hour of saturated steam at the primary containment design pressure is required. The results of this calculation show that the capacity of the HCVS exceeds this value.

The suppression pool thermal capacity must be sufficient to absorb the decay heat generated during at least the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following reactor shutdown. The total decay heat available to the suppression pool for the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following reactor shutdown, when starting at 102%

reactor thermal power, is 2.91 OE8 BTU; and the suppression pool thermal capacity, i.e., its capacity to absorb energy, is 6.299E8 BTU.

Therefore, there is sufficient suppression pool capacity to absorb the decay heat during the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following reactor shutdown, and the EA-13-109, Attachment 2, Requirement 1.21 and NEI 13-02, Section 4.1.1 are satisfied.

The calculations supporting the above response are available for NRC review in the ePortal.

3 Provide a description of the final design of Started the HCVS to address hydrogen detonation and deflagration. As discussed in the December 2015 OIP submittal, the NMP1 design will use an Argon purge system to prevent the possibility of hydrogen detonation and deflagration. The argon purge system design is illustrated on Piping and Instrumentation Drawing C-18014-C, Sht. 7, and is available for NRC review in the ePortal. Design of the argon purge system will be considered final when the purge system sizing calculation is finalized.

4 Make available for NRC staff audit Complete documentation that demonstrates adequate communication between the remote HCVS At NMP1, the primary operating station for operation locations and HCVS decision HCVS operation is located in the Auxiliary Page 6

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items makers during ELAP and severe accident Control Room. A HCVS remote operating station conditions. (ROS) is located in the turbine building. The location was evaluated for habitability and accessibility during a severe accident. Onsite communications will be performed using either the installed sound powered headset system or the 450 MHz radios in the talk around mode, or a combination thereof. A sound powered phone jack is available near the ROS to communicate with the rest of the plant.

Offsite communications will utilize fixed satellite phones in the Control Room and Technical Support Center (TSC). Both locations also have portable satellite phones staged.

Communications protocol for beyond design basis events are documented in CC-NM-118 and procedure N1-0P-51 and are available for NRC review in the ePortal.

These communication methods are consistent with FLEX communication practices at NMP1 and have been previously reviewed by the staff as documented in a communications safety assessment regarding NTTF Rec 9.3 Communications for NMP (ML 131 OOA236).

5 Provide a description of the strategies for Complete hydrogen control that minimizes the potential for hydrogen gas migration and ingress into P&IDs C18014C, Sheets 1 and 7 are available the reactor building or other buildings. to the NRC for review on the ePortal. The P&IDs combined with the following system description provides a summary of the system design intended to minimize the potential for hydrogen gas migration and ingress into the reactor building or other buildings:

The new HCVS wetwell pipe has a dedicated HCVS flowpath from the wetwell penetration PCIVs to the outside with no interconnected downstream piping. The HCVS discharges the effluent to a release point above main plant structures. The new HCVS vent interfaces with lines 201.1-20-LT (upstream of PCIVs IV-201-16 and IV-201-17) and 201.1-3-LT (upstream of PCIV IV-201.2-33 and IV-201.2-06) of the Containment System.

Line 201.1-20-LT is utilized for supplying nitrogen to the torus through isolation valves IV-201-16 and IV-201-17 during primary containment inerting. Similarly, the containment Page 7

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items purge fan takes suction through this flow path when de-inerting containment. IV-201-16 and IV-201-17 are normally closed and automatically close upon receipt of a containment isolation signal from the Reactor Protection System or a high radiation signal from the Off-Gas System monitors.

Line 201.1-3-LT provides nitrogen makeup to the torus through isolation valves IV-201.2-33 and IV-201.2-06 during normal operation.

IV-201.2-33 and IV-201.2-06 are normally closed and automatically close upon receipt of a containment isolation signal from the Reactor Protection System or a loss of nitrogen to the valve actuator.

The new HCVS vent will be normally isolated from the Containment System by two new normally closed PCIVs (IV-201.13-74 and IV-201.13-71) and will not impact the operation of these interfacing systems. The new HCVS piping is designed as an independent, isolable branch off of Line 201 .1-20-LT. There are no branch lines downstream of the HCVS vent piping PCIVs (IV-201.13-71 and IV-201.13-74),

which interface with existing plant systems and there is no potential for cross flow from the HCVS, thereby meeting the requirements of NEI 13-02, Section 1.2.3. Therefore, valves IV-201.2-33, IV-201.2-06, IV-201-16 and IV-201-17 are not considered boundary valves. These valves are exposed to the containment atmosphere, as a result of the original plant desiQn, independent of the addition of HCVS.

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

7 Make available for NRG staff audit the final Complete sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG The new battery selected is a sixty (60) cell loading calculation. GNB battery with the battery cells connected in series to create 125VDC nominal voltage. The battery is a Valve Regulated Lead Acid (VRLA) type rated for 104 ampere-hours. The battery is selected in accordance with IEEE-485. The Battery Sizing Requirements indicates that based on 1.5 ampere loading requirements for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duty period, a minimum of a sixty (60) cell, 55 ampere-hours battery is required to Page 8

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items bound the required battery duty cycle and end-of-cycle battery terminal voltage requirements.

The selected battery capacity of 104 ampere-hours is more than the minimum required 55 ampere-hours battery capacity. Therefore, the selected battery is adequate.

The battery charger is rated for 130 volts nominal DC output voltage, 1O amperes nominal DC output current, 120 volts AC input voltage and a current limit adjustment range of 50% -

120%.

The HCVS loads are powered via 125 VDC battery board 12 which is downstream of the station battery charger 12 (DC side). The FLEX DG sizing calc. 600VACDGES-FLEX-BDB was already sized to accommodate the station battery charger 12 full load rating (AC side).

Additionally, the HCVS loads will be powered by FLEX portable power sources at T;::: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the station battery would have been fully charged and load shedding would have been completed during ELAP. Therefore, there will be no impact on the FLEX DG loading calculation 600VACDGES-FLEX-BDB. A minor revision to the FLEX portable battery charger equipment sizing calculation 125VDCSCES-FLEX-BDB was completed to address the addition of the HCVS loads. The calculation concluded that the HCVS panel load addition of 1.5 amperes DC is negligible and still within the 400 ampere rating of the portable battery charger BC-BOB.

The battery/battery charger sizing requirements evaluation and the minor revision to calculation 125VDCSCES-FLEX-BDB are in the ePortal for NRC review.

8 Make available for NRC staff audit Complete documentation of the HCVS nitrogen pneumatic system design including sizing As discussed in the December 2015 OIP and location. submittal, the NMP1 design will use a nitrogen bottle station to supply motive force to the HCVS isolation valves. The bottle station will be located in a readily accessible protected area in the turbine building. The nitrogen supply system design is illustrated on Piping and Instrumentation Drawing C-18014-C, Sht. 7, and is available for NRC review in the ePortal.

A calculation was completed to determine the required pneumatic supply storage volume and Page 9

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Open Phase 1 Interim Staff Evaluation (ISE)

Status Item Open Items supply pressure required to operate the HCVS isolation valves (IV-201.13-71 and IV-201.13-

74) for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a loss of normal pneumatic supplies during an ELAP. Calculation S22.4-201.13M002 is available for NRG review in the ePortal.

9 Make available for NRG staff audit Started documentation of a seismic qualification evaluation of HCVS components.

10 Make available for NRG staff audit Started descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

11 Make available for NRG 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.

Phase 2 01 P Open Items Open Phase 2 OIP Open Item Description Status Item 1 Perform radiological evaluation to determine Started the SAWA flow control point location.

7 Interim Staff Evaluation Impacts The Reference 6 ISE states that a new air-operated HCVS control valve will be provided in this piping, which will serve as both the primary method to control HCVS flow, thereby controlling containment pressure, and as a secondary containment isolation valve, as required by design basis. The NMP1 vent path is completely separate from the Nine Mile Point Unit 2 (NMP2) vent path.

The ISE statement above originated from the original OIP (Reference 1). This description was previously revised in the Reference 7 combined Phase 1 and Phase 2 OIP as follows:

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 will be used to breach the rupture disc if HCVS venting is required prior to the Page 10

Nine Mile Point Nuclear Station, Unit 1 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 containment pressure exceeding the rupture disc setpoint. The NMP1 vent path is completely separate from the Nine Mile Point Unit 2 (NMP2) vent path.

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

1. Nine Mile Point Unit 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.

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.
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. ML133048836).
5. NRC 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. NRC Interim Staff Evaluation, "Nine Mile Point Nuclear Station, Unit 1 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO. MF4481)", dated March 26, 2015.
7. Nine Mile Point Unit 1, 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.
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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Enclosure 2 Nine Mile Point Nuclear Station, Unit 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 (16 pages)

Enclosure 2 Nine Mile Point Nuclear Station, Unit 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 Nine Mile Point Unit 2 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.

Nine Mile Point Unit 2 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.
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 Overall Integrated Plan (Reference 7), and are current as of June 6, 2016.

  • Fourth Six-Month Update (complete with this submittal) 3 Milestone Schedule Status The following provides an update to the Part 5 Milestone Schedule of the 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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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 NMP2 - Phase 1 Specific Milestone Schedule Target Activity Milestone Completion Comments Status Date Hold preliminary/conceptual design meeting Nov 2013 Complete Submit Overall Integrated Implementation June 2014 Complete Plan Submit 6 Month Status Report Dec 2014 Complete Design Engineering Complete Mar 2015 Complete Submit 6 Month Status Report June 2015 Complete Operations Procedure Changes Developed Dec 2015 Complete Submit 6 Month Status Report Dec 2015 Complete Simultaneous with Phase 2 OIP Training Complete Feb 2016 Complete NMP2 Implementation Outage Apr2016 Complete Maintenance and Operations Procedure Apr2016 Complete Changes Developed Walk Through Demonstration/Functional Test Apr2016 Complete Submit 6-Month Status Report June 2016 Complete with this submittal Submit Completion Report June 2018 Not Started Changed from June 2016 NMP2 - Phase 2 Specific Milestone Schedule Target Activity Comments Milestone Completion Status Date Submit Overall Integrated Implementation Plan Dec 2015 Complete Hold preliminary/conceptual design meeting Jan 2016 Complete Submit 6 Month Status Report June 2016 Complete with this submittal 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 Site Specific Maintenance Procedure Developed Dec 2017 Page 2

Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Target Activity Comments Milestone Completion Status Date 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 Phase 1 and Phase 2 Completion Report June 2018 4 Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phases 1 and 2 Overall Integrated Plan (Reference 7).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Nine Mile Point Unit 2 complied with the Phase 1 order implementation date and expects to comply with the Phase 2 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.

Phase 1 Open Items from OIP Status 01 P Phase 1 Open Item No. 1 Deleted (closed to ISE open item number 8 below) 01 P Phase 1 Open Item No. 2 Deleted (closed to ISE open item number 3 below) 01 P Phase 1 Open Item No. 3 Deleted (closed to ISE open item number 9 below) 01 P Phase 1 Open Item No. 4 Deleted (closed to ISE open item number 2 below) 01 P Phase 1 Open Item No. 5 Deleted (closed to ISE open item number 4 below)

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 OI P Phase 1 Open Item No. 6 Deleted (closed to ISE open item numbers 1O and 12 below) 01 P Phase 1 Open Item No. 7 Deleted (closed to ISE open item number 7 below) 01 P Phase 1 Open Item No. 8 Deleted (closed to ISE open item number 7 below)

OIP Phase 1 Open Item No. 9 Complete with this submittal as provided below ISE Phase 1 Open Items Status ISE Phase 1 Open Item No. 1 Submitted for closure with this update as provided below ISE Phase 1 Open Item No. 2 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 3 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 4 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 5 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 6 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 7 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 8 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 9 Submitted for Closure in Reference 7 ISE Phase 1 Open Item No. 10 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 11 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 12 Submitted for closure with this update as provided below.

ISE Phase 1 Open Item No. 13 Submitted for closure with this update as provided below.

The table below documents the completion of the final remaining open items as listed above.

As stated above, EGC provides the response for the following items and considers them to be complete for Nine Mile Point Nuclear Station, Unit 2.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 1 Open Items Item Description Status OIP Phase 1 Open Complete Item No. 9 Radiological Calculation H21 C-114 has been completed Perform radiological to provide assurance that personnel can safely operate evaluation for Phase the NMP2 HCVS and respond to required ERO response 1 vent line impact on actions during severe accident conditions. Calculation ERO response was performed using NRC endorsed HCVS-WP-02 and actions. HCVS-FAQ-12 methodologies.

Calculation H21C-114 has been posted in ePortal for NRC's review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open Seismic Design of the outdoor HCVS stack Complete Item No.1 The HCVS piping contains ASME Class 2, 3 and ANSI Make available for B31.1 piping. The entire HCVS system has been NRC staff audit the evaluated to Seismic Category I requirements in pipe seismic and tornado stress calculation AX-515B consistent with the plants missile final design seismic design basis to comply with NEI 13-02, Section criteria for the HCVS 5.2 seismic design guidance. Per NRC Letter, May 9, stack. 2014 "

Subject:

Screening and Prioritization Results Regarding Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", the NRC concluded that NMP2 "screened out" of performing the seismic risk evaluation as part of the Containment Purge System (CPS) I HCVS seismic analysis. Therefore, the more severe seismic load case (2xSSE) is not required as part of the BOB analysis of the CPS/HCVS system. Pipe stress calculation AX-515B is available in the ePortal for NRC review.

Missile Protection of the outdoor HCVS stack NEI 13-02, Section 5.1.1.6 requires that missile impacts are to be considered for portions of the HCVS. The Nuclear Energy Institute (NEI) issued a white paper HCVS-WP-04, endorsed by the NRC, which provides a risk-informed approach to evaluate the threat posed to exposed portions of the HCVS by wind-borne missiles.

The white paper concludes that the HCVS is unlikely to be damaged in a manner that prevents containment venting by wind-generated missiles coincident with an ELAP or LUHS, for plants that are enveloped by the assumptions in the white paper.

A NMP2 specific missile evaluation is documented in the Engineering Change Package (ECP) consistent with HCVS-WP-04. The conclusion of the evaluation is that NMP2 meets all of the tornado missile assumptions identified in HCVS-WP-04 and as such, supplementary protection is not required for the HCVS piping and components. The ECP missile evaluation is available in the eportal for NRC review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open The HCVS was designed to have the capacity to vent the Complete Item No. 3 steam equivalent of a decay heat rate of 1% of the rated Make available for thermal power at a pressure equivalent to the lessor of NRC staff audit containment design pressure or the PCPL consistent with analyses NEI 13-02 Section 4.1.1.1 guidance. The design pressure demonstrating that was used which is 45 psig at NMP2. This is equivalent to HCVS has the a flow rate of approximately 148,600 lbm/hr. The current capacity to vent the design has been evaluated considering pipe diameter, steam/energy length, and geometry as well as vendor provided valve equivalent of one (1) Cv's, and the losses associated with a burst rupture disc.

percent of Calculation A 10.1-A-050 concludes that the design licensed/rated provides margin to the minimum required flow rate.

thermal power Calculation A 10.1-A-050 is available for NRC review in (unless a lower value the ePortal.

is justified) and that the suppression pool Additionally, MAAP 4.0.6 analyses in Calculation N2-and the HCVS 2014-004 were performed to investigate the response of together are able to the NMP2 containment venting using the new HCVS vent absorb and reject parameters and the use of RPV alternate injection with decay heat, such that assumed RCIC failure at 240 °F in the suppression pool.

following a reactor The objective of the analysis was to understand the shutdown from full overall accident response signature and key containment power containment (wetwell and drywell) thermal-hydraulic behavior. The pressure is restored MAAP analyses demonstrate that the suppression pool and then maintained and the HCVS together are able to absorb and reject below the primary decay heat, such that following a reactor shutdown from containment design full power containment pressure is restored and then pressure and the maintained below the primary containment design primary containment pressure and the primary containment pressure limit.

pressure limit. Calculation N2-2014-004 is available for NRC review in the ePortal.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open At NMP2, the primary operating station for HCVS Complete Item No. 5 operation is located in the MCR. A HCVS remote Make available for operating station (ROS) is located in the RB Track Bay.

NRC staff audit The location was evaluated for habitability and documentation that accessibility during a severe accident. Onsite demonstrates communications will be performed using either the adequate installed sound powered headset system or the 450 MHz communication radios in the talk around mode, or a combination thereof.

between the remote A sound powered phone jack is available near the ROS HCVS operation to communicate with the rest of the plant.

locations and HCVS decision makers Offsite communications will utilize fixed satellite phones during ELAP and in the Control Room and Technical Support Center severe accident {TSC). Both locations also have portable satellite phones conditions. staged.

Communications protocol for beyond design basis events are documented in CC-NM-118 and procedure N2-0P-76 which are available for NRC review in the ePortal.

These communication methods are consistent with FLEX communication practices at NMP2 and have been previously reviewed by the staff as documented in a communications safety assessment regarding NTTF Rec 9.3 Communications for NMP (ML 131 OOA236).

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open Temperature Evaluation: Complete Item No. 7 Make available for Accessing HCVS equipment, following an external event NRC staff audit an that results in an ELAP, will subject the operator to evaluation of prevailing area temperatures. The majority of the temperature and operator travel path from the MCR to the ROS is radiological outdoors. Therefore, the travel path does not pose any conditions to ensure habitability concerns, with respect to temperature. The that operating MCR and ROS are expected to remain habitable, with personnel can safely respect to temperature, during the event. During the access and operate ELAP, as with the station blackout, normal ventilation controls and support systems are inoperable and non-vital equipment is not equipment. contributing to the area heat load. Therefore, area temperatures in the MCR will be higher than that for normal operation and likely more in line with that for station blackout. The expected peak area temperature for the MCR is 100 °F. This is based on Calculation ES-198 which predicts the control room heat-up following a station blackout. The area temperature for the ROS in the Track Bay is not expected to undergo any appreciable change as a result of the event. There is no vital equipment in the area that would be operating, adding to the heat load, and the space has a 20' vertical height, which will moderate the area temperature.

Additionally, the Track Bay door to the outside can be opened to moderate the temperature, if needed.

Radiological Evaluation:

The radiological dose Calculation H21C-114 is described in detail under the response to OIP Phase 1, Open Item No. 9 above.

In accordance with the definition of sustained operations in NEI 13-02, the integrated radiation dose due to HCVS operation over a 7-day period was determined in Calculation H21C-114. The 7-day dose determined in the calculation due to HCVS operation is a conservative maximum integrated radiation dose over a 7-day period with ELAP and fuel failure starting at reactor shutdown.

For the sources considered and the methodology used in the calculation, the timing of HCVS vent operation or cycling of the vent will not create higher doses at personnel habitability and equipment locations (i.e.,

maximum doses determined in the calculation bound operational considerations for HCVS vent operation).

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status The operator travel path is designed to minimize the dose to the operator from shine off of the HCVS vent pipe on the west side of the Reactor Building. The dose rates along the majority of the path are heavily shielded from the HCVS vent pipe and would not be significant (< 1 mR/hr). The dose rate between the Control Building and the Maintenance Building could be significant (several R/hr). However, the exposure to this dose rate would be for a few seconds and the accumulated dose would not be significant.

Peak maximum dose rates and 7-day total integrated dose have been calculated for the POS and the ROS in Calculation H21 C-114. The radiation dose to personnel occupying defined habitability locations, resulting from HCVS operation are below the 5 rem acceptance criteria as shown below:

MGR: 7-day Total Integrated Dose= 4.1 rem ROS: 7-day Total Integrated Dose < 1 rem Therefore, during the 7 days of sustained operation for BDBEE, the predicted environmental and radiological conditions will be acceptable for the operators to gain access to areas required for HCVS operation in the MGR and ROS. The above referenced calculations are available in the ePortal for NRG review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report tor the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open Batteries/Battery Charger Sizing: Complete Item No. 8 Make available for The new battery selected is a sixty (60) cell GNB battery, NRC staff audit the with the battery cells connected in series to create final sizing evaluation 125VDC nominal voltage. The battery is a Valve forHCVS Regulated Lead Acid (VALA) type rated for 104 ampere-batteries/battery hours. The battery is selected in accordance to IEEE-charger including 485. The Battery Sizing Requirements indicates that incorporation into based on 2.3 ampere loading requirements for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FLEX DG loading duty period, a minimum of a sixty (60) cell, 90.3 ampere-calculation. hours battery is required to bound the required battery duty cycle and end-of-cycle battery terminal voltage requirements. The selected battery capacity of 104 ampere-hours is more than the minimum required 90.3 ampere-hours battery capacity. Therefore, the selected battery is adequate.

The battery charger is rated for 130 volts nominal DC output voltage, 1O amperes nominal DC output current, 120 volts AC input voltage and a current limit adjustment range of 50% - 120%. The battery/battery charger sizing requirements evaluation is available in the ePortal for NRC review.

Incorporation into FLEX DG Loading Calculation:

Following a BOBE, the battery charger is expected to draw a maximum load of 2.9 kVA. This load will be credited in the NMP2 FLEX Portable Diesel Generator Calculation EC-206 which was revised to reflect the load addition of the battery charger. The additional load added is still within the capability of the NMP2 FLEX Diesel Generator and therefore, this change is acceptable.

Calculation EC-206 is available in the ePortal for NRC review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open New components related to HCVS operation are required Complete Item No.10 to be designed to operate following a seismic event.

Make available for Most equipment came qualified or evaluated by the NRC staff audit vendor. However, some equipment was purchased as documentation of a commercial grade (non-safety related) and was shake seismic qualification tested in order to prove the components' ability to evaluation of HCVS withstand a bounding seismic event.

components.

Qualification/evaluation documentation provided by the vendor, or test results from shake tests were compiled into a single report for HCVS dedicated equipment (Ref.

VENRPT-15-000013) with the exception of separate seismic design reports for the PCIVs and HCVS pressure control valve 2CPS-AOV134. These reports are available in the ePortal for NRC review.

ISE Phase 1 Open Existing Instrumentation: Complete Item No.11 Make available for Existing control room indications for drywall pressure and NRC staff audit wetwell level are used for HCVS venting operation.

descriptions of all Containment pressure indication is needed to determine instrumentation and the need, timing and effectiveness of the venting controls (existing and operation following a BDBEE, in order to ensure that planned) necessary containment pressure does not exceed the containment to implement this design pressure and/or the primary containment pressure order including limit (PCPL). Containment pressure is displayed on qualification indicator 2CMS*Pl2A (Division 1), which receives a methods. pressure signal from pressure transmitter 2CMS*PT2A; and recorder 2CMS*PR2B (Division 2), which receives a pressure signal from pressure transmitter 2CMS*PT2B.

Wetwell level indication is needed to determine that the wetwell vent path is preserved. Wetwell level is displayed on indicator 2CMS*Ll9A (Division 1), which receives a level signal from level transmitter 2CMS*LT9A; and recorder 2CMS*LR9B (Division 2), which receives a level signal from level transmitter 2CMS*LT9B.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status The FLEX Phase 2 primary strategy is to provide power using a FLEX generator to Division 1 600 VAC unit substation to maintain instrumentation power supply and the back-up is Division 2. Depending on availability, either loop may be used for containment pressure and wetwell level determination. Additionally, containment pressure and/or wetwell level can be obtained from a Transmation 1045 (or similar loop calibrator) at the associated transmitter or in the relay room panel.

New HCVS Instrumentation and Controls:

The l&C scope for the HCVS is to display the following and to control the SOVs associated with the new primary containment isolation valves from new control room panel 2CEC-PNL801 located in the main control room. The SOVs are controlled via key-lock control switches.

  • Isolation Valve Position Indication
  • Temperature, Pressure and Radiation of the HCVS Pipe
  • HCVS Purge System Supply Pressure (Local indication only)
  • Battery Voltage New track bay control panel 2CPS-PNL 100 serves as the main power distribution for all l&C components.

A detailed description of existing and new I &C components including qualification methods is included in the Engineering Change Package and is available on the ePortal for NRC review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open The HCVS is located in Primary Containment, Secondary Complete Item No. 12 Containment, the Reactor Building Track Bay, the Control Make available for Room, and outside the Reactor Building. Environmental NRC staff audit the conditions and impacts are evaluated in detail in the description of local Engineering Change Package (ECP). The ECP includes conditions a listing of the components in each area along with the (temperature, corresponding environmental conditions including radiation, and temperature, radiation and humidity. The ECP also humidity) anticipated includes a detailed listing of environmental qualification during ELAP and requirements. The complete listing and information from severe accident for the ECP is available on the ePortal for NRC review.

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.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Item Description Status ISE Phase 1 Open The existing containment isolation valves 2CPS* AOV109 Complete Item No. 13 and 2CPS* AOV111 were replaced with new valves.

Make available for Additionally, an HCVS containment pressure control N RC staff audit valve (2CPS-AOV134) located downstream of the documentation of an containment isolation valves was added to control vent evaluation verifying flow after the containment isolation valves are opened the existing during a BDBEE.

containment isolation valves relied upon for Actuator capability and margin calculations were the HCVS, will open performed using the Sargent & Lundy AirBase software under the maximum program for the three AOVs. The calculations are expected differential intended to confirm that the AOVs can open under the pressure during maximum expected differential pressure (MEDP) during BDBEE and severe BDBEE and severe accident wetwell venting.

accident wetwell venting. Under an ELAP or for severe accident wetwell venting the subject valves are closed and without their normal supply of air power. Prior to exceeding the primary containment pressure limit (PCPL), Operators open the valves remotely using the dedicated HCVS batteries and nitrogen bottles. The MEDP is determined based on assuming the maximum upstream pressure is equal to the PCPL of 45 psig and by conservatively using a downstream pressure equal to vacuum pressure (-14.7 psig) since exhausting steam may condense in the HCVS line, creating a negative pressure. Thus the MEDP used in the calculations is 59.7 psid.

Calculation A10.1-P-047 for 2CPS*AOV109/111 shows actuator torque required vs. actuator torque available margins for the closed to full open stroke in the range of 49% to 189%. Calculation A 10.1-P-052 for 2CPS-AOV134 shows margins from the closed to full open stroke in the range of 78% to 233%. The calculations demonstrate positive margin in the opening direction. The calculations are available in the ePortal for NRC review.

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Nine Mile Point Nuclear Station, Unit 2 Fourth Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 June 30, 2016 Phase 2 OIP Open Items Item Description Status OIP Phase 2 Open Perform radiological evaluation to determine feasibility of Started Item No.1 reactor building actions.

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. Nine Mile Point Unit 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 June 27, 2014.

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.
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 11 Under Severe Accident Conditions, Revision 1, dated April 2015.
4. NRC Interim Staff Guidance JLD-ISG-2013-02, Compliance with Order EA-13-109, 11 Order Modifying Licenses with Regard to Reliable Hardened Containment Vents 11 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 O," dated May 14, 2014 (Accession No. ML14128A219).
6. NRC Interim Staff Evaluation, 11 Nine Mile Point Nuclear Station, Unit 2 -_Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of the Order EA-13-109 (Severe Accident Capable Hardened Vents (TAC NO. MF4482) 11 , dated February 11, 2015.
7. Nine Mile Point Unit 1, 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.
8. NRC Interim Staff Guidance JLD-ISG-2015-01, 11 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).
9. Letter from M.G. Korsnick (GENG) to Document Control Desk (NRC), Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events, dated February 28, 2013.

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