RS-16-233, Fifth Six-Month Status Report for Phases 1&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.

Fifth Six-Month Status Report for Phases 1&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.

ML16349A439
Person / Time
Site:	LaSalle
Issue date:	12/14/2016
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-16-233
Download: ML16349A439 (15)

Text

ExeLon Generation.,

Order No. EA-13-109 RS-16-233 December 14, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Fifth 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-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 14, 2013

3. 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

4. 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

5. 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

6. Exelon Generation Company, LLC Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (RS-14-059)

7. Exelon Generation Company, LLC First Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 17, 2014 (RS-14-303)

8. Exelon Generation Company, LLC Second Six-Month Status Report Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2015 (RS-15-149)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 14, 2016 Page 2

9. Exelon Generation Company, LLC Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 16, 2015 (RS-15-300)

10. Exelon Generation Company, LLC 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), dated June 30, 2016 (RS-16-107)

11. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4456 and MF4457), dated March 31, 2015

12. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4456 and MF4457), dated August 2, 2016 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 (References 2 and 3) provide direction regarding the content of the OIP for Phase 1 and Phase 2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions identified in References 2 and 3. Reference 5 provided the EGC initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 provided the LaSalle County Station, Units 1 and 2, Phase 1 OIP pursuant to Section IV, Condition DA of Reference 1. References 7 and 8 provided the first and second six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for LaSalle County Station. Reference 9 provided the LaSalle County Station, Units 1 and 2, Phase 1 updated and Phase 2 OIP pursuant to Section IV, Conditions D.2 and D.3 of Reference 1. Reference 10 provided the fourth six-month status report pursuant to Section IV, Condition D.3 of Reference 1 for LaSalle County Station.

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 14, 2016 Page 3 any. The enclosed report also addresses the NRC Interim Staff Evaluation open items contained in References 11 and 12.

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

declare under penalty of perjury that the foregoing is true and correct. Executed on the 14"' day of December 2016.

Respectfully submitted, T1, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

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

Enclosure LaSalle County Station, Units 1 and 2 Fifth 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)

COMBINED PHASES 1 AND 2 SIX MONTH UPDATE Enclosure LaSalle's Fifth Six Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions" 1 Introduction LaSalle developed an Overall Integrated Plan (Reference 1), 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 NRC Order EA-13-109 (Reference 2). Updates of milestone accomplishments are based on the combined Phases 1 and 2 Overall Integrated Plan (Reference 7), 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 latest status report, 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 May 15, 2016, and are current as of November 11, 2016:

• Fifth Six-Month Update (complete with this submittal)

• Begin Phase 1 Online Installation for Unit 2 3 Milestone Schedule Status The following provides an update to Attachment 2 of the combined Phases 1 and 2 Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

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

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Target ---

Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Submit Phase 1 Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates Update 1 Dec 2014 Complete Update 2 Jun 2015 Complete Update 3 and Phase 2 Overall Dec 2015 Complete Integrated Plan Update 4 Jun 2016 Complete Update 5 Dec 2016 Complete This submittal Update 6 Jun 2017 Not Started Update 7 Dec 2017 Not Started Update 8 Jun 2018 Not Started Update 9 Dec 2018 Not Started Phase 1 Specific Milestones Phase 1 Unit 2 Modifications Begin Conceptual Design Jun 2014 Complete Complete Conceptual Design Jun 2014 Complete Begin Detailed Design Jun 2015 Complete New target: Jan 2017 based on Complete Detailed Design and Issue revising the Nov 2016 Started Modification Package design for tying-in to primary containment Begin Online Installation Jun 2016 Complete Complete Online Installation Feb 2017 Started Begin Outage Installation Feb 2017 Not Started Page 2 of 11

--- ---_ Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Complete Outage Installation and put Mar 2017 Not Started system into service Phase 1 Unit 2 Procedure Changes Operations Procedures Developed Dec 2016 Started Maintenance Procedures Developed Dec 2016 Started Procedure Changes Active Mar 2017 Not Started v

Phase 1 Unit 2 Training New Target: Jan 2017 based on Training Complete Dec 2016 Started completion of simulator training Phase 1 Unit 2 Completion Unit 2 HCVS Phase 1 Implementation Mar 2017 Not Started-T Phase 1 Unit 1 Modifications Begin Conceptual Design Jun 2014 Complete Complete Conceptual Design Jun 2014 Complete Begin Detailed Design Jun 2015 Complete Complete Detailed Design and Issue Mar 2017 Started Modification Package Begin Online Installation May 2017 Not Started Complete Online Installation Feb 2018 Not Started Begin Outage Installation Feb 2018 Not Started Complete Outage Installation and put Mar 2018 Not Started system into service Phase 1 Unit 1 Procedure Changes Operations Procedures Developed Dec 2017 Not Started Maintenance Procedures Developed Dec 2017 Not Started Page 3 of 11

Target Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Procedure Changes Active Mar 2018 Not Started Phase 1 Unit 1 Training Training Complete Dec 2017 Not Started Phase 1 Completion Phase 1 Unit 1 Implementation Mar 2018 Not Started Phase 2 Specific Milestones Phase 2 Unit 1 Modifications Begin Conceptual Design Jun 2015 Complete Complete Conceptual Design Jun 2015 Complete New Target: Jan Begin Detailed Design Jun 2016 Not Started 2017 Complete Detailed Design and Issue New Target: Aug Mar 2017 Not Started Modification Package 2017 New Target: Aug Begin Online Installation May 2017 Not Started 2017 Complete Online Installation Feb 2018 Not Started Begin Outage Installation Feb 2018 Not Started Complete Outage Installation and put Mar 2018 Not Started system into service Phase 2 Unit 1 Procedure Changes Operations Procedures Developed Dec 2017 Not Started Maintenance Procedures Developed Dec 2017 Not Started Procedure Changes Active Mar 2018 Not Started Phase 2 Unit 1 Training Training Complete Dec 2017 Not Started Phase 2 Unit 1 Completion Page 4 of 11

Target A Activity Milestone Completion Comments Status Date Phases 1 and 2 HCVS Milestone Table Phase 2 Unit 1 Implementation Mar 2018 Not Started Submit Unit 1 Phases 1 & 2 Full May 2018 Not Started Compliance Report Phase 2 Unit 2 Modifications Begin Conceptual Design Jun 2015 Complete Complete Conceptual Design Jun 2015 Complete Begin Detailed Design Jun 2017 Not Started Complete Detailed Design and Issue Mar 2018 Not Started Modification Package Begin Online Installation May 2018 Not Started Complete Online Installation Feb 2019 Not Started Begin Outage Installation Feb 2019 Not Started Complete Outage Installation and put Mar 2019 Not Started system into service Phase 2 Unit 2 Procedure Changes Operations Procedures Developed Dec 2018 Not Started Maintenance Procedures Developed Dec 2018 Not Started Procedure Changes Active Mar 2019 Not Started Phase 2 Unit 2 Training Training Complete Dec 2018 Not Started Phase 2 Completion Phase 2 Unit 2 Implementation Mar 2019 Not Started Submit Unit 2 Phases 1 & 2 Full May 2019 Not Started Compliance Report Page 5 of 11

4 Changes to Compliance Method

1. Rather than "as close as possible" (Ref. 7, pg. 14), the PCIVs will be located "as close as reasonably possible" (Ref. 3, Step 4.1.2.1.2) or as close "as practical" (UFSAR Ch. 3.2, GDC 56) to the penetration into primary containment. (Ref. 9)

2. The motive gas supply to the PCIVs will be nitrogen, not argon. (Ref. 7, pg. 15; Ref. 9)

3. Downstream of the outboard PCIV, the piping classification changes from Safety Related to Seismically Supported and Augmented Quality (including the rupture disc). This is similar to safety classification changes for the existing Containment Vent & Purge System where piping downstream of the outboard PCIV is Seismically Supported and Non-Safety Related and then penetrates through Secondary Containment. (Ref. 7, pg. 17; Ref. 9, DCS Sec. 4.1.4.2) 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation LaSalle expects to comply with the order implementation date and no relief/relaxation is required at this time.

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.

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Combined Phases 1 and 2 OIP Open Items Status Phase 1 Open Items 7 Perform radiological evaluation for Phase 1 Started. The calculation is vent line impact on ERO actions. currently under review.

Phase 2 Open Items 1 Evaluate feasibility of strategy due to Started. The calculation is radiological conditions. currently under review, but preliminary results indicate a portion of the water injection pathway in the Reactor Building may need to be hard piped, rather than flexible hose.

Additional shielding may not be required for the personnel operating the Flex pump (used for SAWA).

2 Verify required modifications to support Started SAWA/SAWM.

No. Phase 1 Interim Staff Evaluation Open Item Status 1 Make available for NRC staff audit Started. The motive and purge documentation of a method to disable HCVS gas systems will be isolated by during normal operation to provide assurances one locked-closed manual valve against inadvertent operation that also in each system during normal minimizes actions to enable HCVS operation operation. Main Control Room following an FLAP. (MCR) controls will be via key-locked switches. PCIVs are air-to-open, spring/fail closed.

2 Make available for NRC staff audit the final Started. The sizing evaluation of sizing evaluation for HCVS batteries/battery the HCVS batteries is complete.

charger including incorporation into FLEX DG The results show a margin of loading calculation. approximately 7% after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with all Unit 1 and Unit 2 HCVS loads drawing maximum current.

The revision to the FLEX DG loading calculation is not complete.

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

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4 Make available for NRC staff audit an Started. Preliminary results from evaluation of temperature and radiological the radiological evaluation show conditions to ensure that operating personnel no additional shielding is can safely access and operate controls and required to safely access and support equipment. operate controls and equipment.

The evaluation of temperature is in progress.

5 Make available for NRC staff audit analyses Started. Analyses are in demonstrating that HCVS has the capacity to progress to show that the HCVS vent the steam/energy equivalent of one has the capacity to vent the percent of licensed/rated thermal power steam/energy equivalent of 1 %

(unless a lower value is justified), and that the of rated thermal power while suppression pool and the HCVS together are maintaining containment able to absorb and reject decay heat, such that pressure below PCPL.

following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

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

7 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.

8 Make available for NRC staff audit Started documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

9 Provide a description of the final design of the Started. LaSalle design will use HCVS to address hydrogen detonation and argon purge system to ensure deflagration. the flammability limits of gases passing through the system are not reached.

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

J of Reference 3).

11 Make available for NRC staff audit Started documentation of a seismic qualification evaluation of HCVS components.

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

13 Make available for NRC staff audit the Started procedures for HCVS operation.

Phase 2 Interim Staff Evaluation Open Item Status 1 Licensee to confirm through analysis the Started. Preliminary results from temperature and radiological conditions to the radiological evaluation show ensure that operating personnel can safely no additional shielding is access and operate controls and support required to safely access and equipment. (ISE Section 3.3.1) operate controls and equipment.

2 Licensee to evaluate the ingress and egress Not started paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period. (ISE Section 3.3.2 3 3 Licensee to demonstrate that containment Not started failure as a result of overpressure can be prevented without a DW vent during severe accident conditions ISE Section 3.3.3 4 Licensee shall demonstrate how the plant is Not started bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a DW vent is needed.

ISE Section 3.3.3.1 5 Licensee to demonstrate that there is Not started adequate communication between the MCR and the operator at the FLEX pump during severe accident conditions. (ISE Section 3.3.3.4 Page 9 of 11

6 Licensee to demonstrate the SAWM flow Not started instrumentation qualification for the expected environmental conditions. (ISG- Section 3.3.3.4 7 Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation(s) identified at this time.

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

1. LaSalle's "Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014 (Accession No. ML14184A016).

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

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

4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 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. ML1330413836).

5. NRC Endorsement of industry "Hardened Containment Venting System (RCVS)

Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0" (Accession No. ML14128A219).

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

7. LaSalle's "Phase 1 (Updated) and Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 16, 2015 (Accession No. ML15352A109).

8. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions,"

Revision 0, dated April 2015 (Accession No. ML15104A118).

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9. Engineering Change EC 392353 Revisions 0, 1, and 2, T2 Hardened Containment Vent System (HCVS)." Revision 2 approved 11/11/16.

10.NRC "Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109," dated March 31, 2015.

11.NRC "Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109," dated August 2, 2016.

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