RS-17-155, Seventh 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 ...

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Seventh 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 ...
ML17349A038
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 12/15/2017
From: David Helker
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, RS-17-155
Download: ML17349A038 (15)
v • d • e


Text

Exelon Generation Order No. EA-13-109 RS-17-155 December 15, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRG Docket No. 50-277

Subject:

Seventh 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. NRG 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. 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 O, dated November 14, 2013
3. NRG 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-14-062)
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 19, 2014 (RS-14-305)
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-15-151)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 15, 2017 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 15, 2015 (RS-15-303)
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-16-109)
11. Exelon Generation Company, LLC 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), dated December 15, 2016 (RS-16-235)
12. Exelon Generation Company, LLC Sixth 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, 2017 (RS-17-068)
13. NRG 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

14. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3- lnterim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos.

MF4416 and MF4417), dated August 2, 2016

15. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Report for the Audit of Licensee Responses to Interim Staff Evaluation Open Items Related to NRG Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated November 30, 2017 On June 6, 2013, the Nuclear Regulatory Commission ("NRG" or "Commission") issued an Order (Reference 1) to Exelon Generation Company, LLC (EGG). Reference 1 was immediately effective and directs EGG 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 15, 2017 Page 3 provided the EGC initial response regarding reliable hardened containment vents capable of operation under severe accident conditions. Reference 6 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 7 and 8 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 9 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. References 1O, 11, and 12 provided the fourth, fifth, and sixth six-month status reports pursuant to Section IV, Condition D.3 of Reference 1 for Peach Bottom Atomic Power Station.

The purpose of this letter is to provide the seventh 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, Unit 2.

The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation open items contained in References 13, 14, and 15.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David J. Distel at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 151h day of December 2017.

Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Peach Bottom Atomic Power Station, Unit 2 Seventh 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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-13-109 December 15, 2017 Page 4 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Project Manager, NRA - Peach Bottom Atomic Power Station Mr. Raj Auluck, NRR/JLD/TSD/JCBB, NRC Mr. Brian E. Lee, NRR/JLD/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, Unit 2 Seventh 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 (10 pages)

Enclosure Peach Bottom Atomic Power Station, Unit 2 Seventh 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. This is the seventh six-month status report updating milestone accomplishments 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 Sixth Six-Month Status Report for Phase 1 and Phase 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 December 1, 2017:

  • Seventh Six-Month Update (complete with this submittal)
  • Unit 3 achieved compliance with Phase 1 and Phase 2 requirements on November 6, 2017 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, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Submit Overall Integrated Plan 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]

Update 4 Jun.2016 Complete Update 5 Dec. 2016 Complete Update 6 Jun. 2017 Complete Complete Update 7 Dec.2017 with this submittal Update 8 Jun. 2018 Not Started Update 9 Dec.2018 Not Started 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 Complete Detailed Design and Issue Jun.2016 Complete Modification Package Begin Online Portion of the Installation Jun. 2016 Complete Complete Online Installation Oct. 2016 Complete Begin Outage Portion of the Installation Oct. 2016 Complete Complete Outage Installation Nov.2016 Complete Phase 1 Procedure Changes Active Operations Procedure Changes Nov. 2016 Complete Developed Page 2of10

Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Site Specific Maintenance Procedure Nov. 2016 Complete Developed Procedure Changes Active Nov. 2016 Complete Phase 1 Training Training Complete Nov.2016 Complete Phase 1 Completion Unit 2 Phase 1 HCVS Implementation Nov. 2016 Complete 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 Complete Detailed Design and Issue Feb.2017 Complete Modification Package Begin Online Portion of the Installation Mar. 2017 Complete Complete Online Installation Oct. 2017 Complete Begin Outage Portion of the Installation Oct. 2017 Complete Complete Outage Installation Nov.2017 Complete Phase 1 Procedure Changes Active Operations Procedure Changes Nov. 2017 Complete Developed Site Specific Maintenance Procedure Nov. 2017 Complete Developed Procedure Changes Active Nov. 2017 Complete Phase 1 Training Training Complete Nov. 2017 Complete Phase 1 Completion Unit 3 Phase 1 HCVS Implementation Nov. 2017 Complete Page 3of10

Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Phase 2 Specific Milestones Phase 2 Unit 3 Modifications Begin Conceptual Design May 2016 Complete Complete Conceptual Design Nov. 2016 Complete Begin Detailed Design Dec.2016 Complete Complete Detailed Design and Issue Jul. 2017 Complete Modification Package Begin Online Portion of the Installation Sep.2017 Complete Complete Online Installation Oct. 2017 Complete Begin Outage Portion of the Installation Oct. 2017 Complete Complete Outage Installation Nov.2017 Complete Phase 2 Procedure Changes Active Operations Procedure Changes Nov.2017 Complete Developed Site Specific Maintenance Procedure Nov. 2017 Complete Developed Procedure Changes Active Nov.2017 Complete Phase 2 Training Training Complete Nov.2017 Complete Phase 2 Completion Unit 3 Phase 2 HCVS Implementation Nov. 2017 Complete Submit Full Compliance Report for Phase 1 Jan.2018 Started

& Phase 2 for Unit 3 Phase 2 Unit 2 Modifications Begin Conceptual Design N/A N/A Complete Conceptual Design N/A N/A Begin Detailed Design Jun.2017 Complete Page 4of10

Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Target Comments Activity Milestone Completion Status Date Phases 1 and 2 HCVS Milestone Table Complete Detailed Design and Issue Sep.2017 Complete Modification Package Begin Online Portion of the Installation Feb.2018 Not Started Complete Online Installation Oct. 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 Started Developed Site Specific Maintenance Procedure Nov. 2018 Started Developed Procedure Changes Active Nov. 2018 Started Phase 2 Training Training Complete Nov. 2018 Started Phase 2 Completion Unit 2 Phase 2 HCVS Implementation Nov. 2018 Not Started Submit Full Compliance Report for Phase 1 Jan.2019 Not Started

& Phase 2 for Unit 2 4 Changes to Compliance Method There are no changes to the compliance method outlined in Reference 6 in addition to those communicated in the previous six-month updates.

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.

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Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 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) for Phase 1 and Phase 2 and the status of each item. Phase 1 open item responses were discussed with the NRC on May 18, 2017, and all items were adequately addressed and resolved. All additional information has been provided, and the Phase 1 open items are considered closed based on NRC review.

Combined Phases 1 and 2 OIP Open Item Status Phase 1 Open Items 01-1. Confirm that the Remote Operating Station Deleted. Closed to ISE Open Item number 09.

(ROS) will be in an accessible area following a Severe Accident (SA).

Ol-2. Provide procedures for HCVS Operation Deleted. Closed to ISE Open Item number 01 .

01-3. Identify site specific controlling document for Deleted. Closed to ISE Open Item number 02.

HCVS out of service and compensatory measures 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 Complete line impact on ERO response actions.

Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

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Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Phase 1 Interim Staff Evaluation Open Item Status ISE-1. Make available for NRC staff audit guidelines Complete and procedures for HCVS operation. (Section 3.2.3.1)

Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-2. Make available for the N RC staff audit the site Complete specific controlling document for HCVS out of service and compensatory measures. (Section 3.4.1) Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8) .

ISE-3. Make available for NRC staff audit a technical Complete justification for use of jumpers in the HCVS strategy.

(Section 3.1.3) Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-4. Make available for NRC staff audit analyses Complete demonstrating that the HCVS has the, capacity to vent the steam/energy equivalent of one percent of Completion support information is contained in the fifth six licensed/rated thermal power (unless a lower value is month update dated December 15, 2016 (Reference 8).

justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit. (Sections 3.2.2.1 and 3.2.2.2)

ISE-5. Make available for NRC staff audit descriptions Complete or diagrams of reactor building ventilation including exhaust dampers failure modes to support licensee Completion support information is contained in the fifth six justification for the HVAC release point being below and month update dated December 15, 2016 (Reference 8).

150 feet from the reactor building ventilation release point. (Section 3.2.2.3)

ISE-6. Make available for NRC staff audit details to Complete justify the deviation from tornado protection standards provided in NEI 13-02 or make available a description of Completion support information is contained in the fifth six how the HCVS will comply with the tornado protection month update dated December 15, 2016 (Reference 8).

standards provided in NEl-13-02. (Section 3.2.2.3)

ISE-7. Make available for NRC staff audit Complete documentation that demonstrates adequate communication between the remote HCVS operation Completion support information is contained in the fifth six locations and HCVS decision makers during ELAP and month update dated December 15, 2016 (Reference 8).

severe accident condition. (Section 3.2.2.5)

ISE-8. Provide a description of the final design of the Complete HCVS to address hydrogen detonation and deflagration.

(Section 3.2.2.6) Completion support information is contained in the fifth six month update dated December 15, 2016 (Reference 8).

ISE-9. Make available for NRC staff audit an Complete evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and Completion support information is contained in the fifth six operate controls and support equipment. (Sections month update dated December 15, 2016 (Reference 8).

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}

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Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Phase 1 Interim Staff Evaluation Open Item Status ISE-10. Make available for NRC staff audit descriptions Complete of all instrumentation and controls (existing and planned) necessary to implement this order including Completion support information is contained in the fifth six qualification methods. (Sections 3.2.2.9 and 3.2.2.10) month update dated December 15, 2016 (Reference 8).

ISE-11. Make available for NRC staff audit the final Complete sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading Completion support information is contained in the fifth six calculation. (Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, month update dated December 15, 2016 (Reference 8).

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 Complete descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe Completion support information is contained in the fifth six accident for the components (valves, instrumentation, month update dated December 15, 2016 (Reference 8).

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 Complete documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, Completion support information is contained in the fifth six will open under the maximum expected differential month update dated December 15, 2016 (Reference 8).

pressure during BDBEE and severe accident wetwell venting. (Section 3.2.2.9)

ISE-14. Provide a description of the strategies for Complete hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor Completion support information is contained in the fifth six building or other buildings. (Section 3.2.2.6 and 3.2.2.7) month update dated December 15, 2016 (Reference 8).

ISE-15. Make available for NRC audit documentation Complete confirming that HCVS will remain isolated from standby gas treatment system during ELAP and severe accident Completion support information is contained in the fifth six conditions. (Section 3.2.2.7) month update dated December 15, 2016 (Reference 8).

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Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017 Phase 2 Interim Staff Evaluation Open Status Item ISE-1. Licensee to demonstrate the SAWA equipment Complete and controls, as well as ingress and egress paths for the expected severe accident conditions (temperature, Completion support information is contained in the sixth humidity, radiation) remain operational throughout the six-month update dated June 30, 2017 (Reference 9).

sustained operating period. (Section 3.3.2.3)

ISE-2. Licensee to demonstrate that instrumentation Complete and equipment being used for SAWA and supporting equipment is capable to perform for the sustained Completion support information is contained in the sixth operating period under the expected temperature and six-month update dated June 30, 2017 (Reference 9).

radioloqical conditions. (Section 3.3.2.3)

ISE-3 Licensee to demonstrate that containment Complete failure as a result of overpressure can be prevented without a drywell vent during severe accident Completion support information is contained in the sixth conditions. (Section 3.3.3) six-month update dated June 30, 2017 (Reference 9).

ISE-4 Licensee shall demonstrate whether a site Complete specific MAAP evaluation will be used to determine an initial SAWA flow rate. If the evaluations performed in Completion support information is contained in the sixth BWROG TP-15-011 is considered, provide a six-month update dated June 30, 2017 (Reference 9).

description of how the plant is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed. (Section 3.3.3.1)

ISE-5 Licensee to demonstrate that there is Complete adequate communication between the MCA and the Intake Structure operator at the FLEX manual valve Completion support information is contained in the sixth during severe accident conditions. (Section 3.3.3.4) six-month update dated June 30, 2017 (Reference 9).

ISE-6 Licensee to demonstrate the SAWM flow Complete instrumentation qualification for the expected environmental conditions. (Section 3.3.3.4) Completion support information is contained in the sixth six-month update dated June 30, 2017 (Reference 9).

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. 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.

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Peach Bottom Atomic Power Station, Unit 2 Seventh Six-Month Status Report for the Implementation of HCVS Phases 1 and 2 December 15, 2017

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," 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" (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," Revision 0, dated April 2015 (Accession No. ML15104A118).
8. Peach Bottom Atomic Power Station, Units 2 and 3, Fifth Six-Month Status Report for Phase 1 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, 2016 (RS-16-235).

9. Peach Bottom Atomic Power Station, Units 2 and 3, Sixth Six-Month Status Report for Phase 1 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 June 30, 2017 (RS-17-068).

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