Text

Report of Full Compliance with Phase 1 and Phase 2 of June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
	ML18318A024
Person / Time
Site:	Limerick
Issue date:	11/14/2018
From:	David Helker; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-13-109, RS-18-106
	Download: ML18318A024 (87)
	v • d • e

Exelon Generation .

Order No. EA-13-109 RS-18-106 November 14, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Unit 2 Renewed Facility Operating License No. NPF-85 NRC Docket No. 50-353

Subject:

Report of Full Compliance with Phase 1 and Phase 2 of 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. 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

3. NRC Interim Staff Guidance JLD-ISG-2015-01, "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 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. Limerick Generating Station, Units 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, 2014

6. Exelon Generation Company, LLC, First Six-Month Status Report for 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

7. Exelon Generation Company, LLC, Second Six-Month Status Report for 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

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 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-15-301)

9. 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 1O. 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

11. 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

12. Exelon Generation Company, LLC, 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) dated December 15, 2017

13. Exelon Generation Company, LLC, Eighth 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 29, 2018

14. NRC letter to Exelon Generation Company, LLC, Limerick Generating 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.

MF4418 and MF4419), dated April 1, 2015

15. NRC letter to Exelon Generation Company, LLC, Limerick Generating 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.

MF4418 and MF4419), dated August 2, 2016

16. NRC letter to Exelon Generation Company, LLC, Limerick Generating Station, Units 1 and 2 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to N RC Order EA-13-109 to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated May 29, 2018 On June 6, 2013, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," (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

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 3 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 2 provided EGC's initial answer to the Order.

Reference 3 provided the NRC interim staff guidance on methodologies for compliance with Phases 1 and 2 of Reference 1 and endorsed industry guidance document NEI 13-02, Revision 1 (Reference 4) with clarifications and exceptions. Reference 5 provided the Limerick Generating Station, Unit 2 Phase 1 Overall Integrated Plan (OIP), which was replaced with the Phase 1 (Updated) and Phase 2 OIP (Reference 8). References 14 and 15 provided the NRC review of the Phase 1 and Phase 2 OIP, respectively, in an Interim Staff Evaluation (ISE).

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 6, 7, 8, 9, 10, 11, 12, and 13 provided the first, second, third, fourth, fifth, sixth, seventh, and eighth six-month status reports, respectively, pursuant to Section IV, Condition D.3, of Reference 1 for Limerick Generating Station, Unit 2.

The purpose of this letter is to provide the report of full compliance with Phase 1 and Phase 2 of the 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) (Reference 1) pursuant to Section IV, Condition D.4 of the Order for Limerick Generating Station, Unit 2.

Limerick Generating Station, Unit 2 has designed and installed a venting system that provides venting capability from the wetwell during severe accident conditions in response to Phase 1 of NRC Order EA-13-109. Limerick Generating Station, Unit 2 has implemented a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywall before alternative reliable containment heat removal and pressure control is reestablished in response to Phase 2 of NRC Order EA-13-109. The information provided herein documents full compliance for Limerick Generating Station, Unit 2 with NRC Order EA-13-109.

EGC's response to the NRC Interim Staff Evaluation (ISE) Phase 1 Open Items identified in Reference 14 have been addressed and closed as documented in Reference 13 and as described below, and are considered complete per Reference 16. The following table provides completion references for each OIP and ISE Phase 1 Open Item.

Reference 16 provides the results of the audit of ISE Open Item closure information provided in Reference 13. All Phase 1 and Phase 2 ISE Open Items are statused as closed as discussed in Reference 16.

There were no Phase 2 OIP Open Items.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 4 Combined Phase 1 and Phase 2 OIP Open Items Status Phase 1 Open Items 01-1 Determine how Motive Power and/or HCVS Battery Power Closed to /SE -1 will be disabled during normal operation.

01-2 Confirm that the Remote Operating Station (ROS) will be in Closed to ISE-3 an accessible area followinR a Severe Accident (SA).

0 1-3 Determine wetwell line size to meet I % venting criteria. Closed to lSE- 4 0 1-4 Confir111 suppression pool heat capacity. Closed to ISE-4 01-5 Determine the approach for combustible gases. Closed to ISE-9 and /SE- 10 0 1-6 Provide procedures for HCVS Operation. Closed to lSE- 13 01-7 Verify the external piping consists solely of large bore Complete. (Reference EC piping and its supports have less than 300 square feet of 423331, Attachment 8 (formally cross section. known as ECR 16-00011 )). EC 423331 is available in ePortal.

0 1-8 Evaluate drywell pressure indication for environ111ental Complete.

qualifications to ensure this instrument can survive for 7 EC 423381 is available in davs after an event. ePortal.

01-9 Determine Pe1formance Criteria for Motive gas Cylinders, Co111plete.

Argon Cylinders, FLEX Diesel Generator, and FLEX The pe1formance criteria for the (SA WA) pump pressure at 500 gpm. Motive gas Cylinders and the Argon Cylinder has been defined and the system will meet the requirements of the order.

(Reference EC 423333 sections 3.5 and 3.33. EC 423333 is available in ePortal.)

See ISEP2-6for FLEX SAWA response.

01-10 Pe1form radiological evaluation for Phase 1 vent line Co111plete.

impact on ERO response actions. The peak dose rates and 7-day integrated doses at operating stations, equipment locations, and along transit pathways required for sustained operation of the HCVS have been calculated. The peak dose rates along potential operator transit pathways external to the Reactor Building are bounded by the peak dose rate outside the FLEX storaRe buildinR. (Reference

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 5 Combined Phase 1 and Phase 2 OIP Open Items Status Phase 1 Open Items Calculation LM-0721 ).

Calculation LM-0721 is available in ePortal.

Phase 1 Interim Staff Evaluation Open Items Status lSE-1 Make available for NRC staff audit documentation of a Complete.

method to disable HCVS duri11g normal operation to The system is designed to provide assurances agai11st inadvertent operation that preve11t inadvertent operation.

also minimizes actions to enable HCVS operation The new control switch HS-following a11 ELAP. 057V-283 installed in the MCR panel 20-C689 is a key-lock switch. The switch is kept locked in "OFF" position (with key removed) to prevent inadvertent powering of the HCVS components from 125 Vdc HCVS batte1y source.

Additionally, locked valves are used with the gas bottles to prevent inadvertent operation.

(Reference EC 423333 section 3.19). EC 423333 is available in ePortal.

lSE-2 Make available for NRC staff audit the final sizing Complete.

evaluation for HCVS batterieslbatte1)* charger including The HCVS batteries have been inc01poration into FLEX DG loading calculation. sized to meet the requirements of the HCVS system and fu11ctionfor the initial 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months into the eve11t. (Reference Calculation LE-0128).

The FLEX diesel generator loading is acceptable a11d rated loading of the FLEX diesel generator will not be exceeded due to the additional HCVS loading. (Reference EC 423333 section 3.35). LE-0128 and EC 423333 are available in ePortal.

lSE-3 Make available for NRC staff audit an evaluation of Complete.

temperature and radiological co11ditions to ensure that The prima1y operating station operating personnel can safely access and operate for HCVS operatio11 is located co11trols and support equipment. in the Main Control Room. A remote operatin!? station

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 6 Phase 1 Interim Staff Evaluation Open Items Status (ROS) is located in the EDG Corridor, EL. 217' (Room 317). The ROS location and travel path to ROS location were evaluated for habitability and accessibility during a severe accident. (Reference EC 423281section3.19). EC 423281 is available in ePortal.

See Note 1 on page 15 of this Order response for ROS temJJerature discussion.

ISE-4 Make available for NRC staff audit analyses Complete.

demonstrating that HCVS has the capacity to vent the The required one percent steam/energy equivalent of one percent of licensed/rated capacity at the lower of thermal power (unless a lower value is justified), and Primary Containment Pressure that the suppression pool and the HCVS together are Limit or containment design able to absorb and reject decay heat, such that following pressure is verified using a reactor shutdown from full power containment Reactor Excursion and Leak pressure is restored and then maintained below the Analysis Program (REI.AP). In primal)' containment design pressure and the primW)' addition, Modular Accident containment pressure limit. Analysis Program (MAAP) analyses are credited to verify that venting can be delayed for at least three hours and that anticipatOI)' venting can be credited to maintain Reactor Core Isolation Cooling (RCIC) functional.

(Reference EC 423281 section 3.33 and LM-709).

EC 423281 and LM-709 are available in ePortal.

!SE-5 Make available for NRC staff audit the seismic and Complete.

tornado missile final design criteria for the HCVS stack. (Reference EC 423331 section 3.2, 3.5, 3.9, and 3.38 (formally known as 16-00011) and EC 423332 section 3.38 (formally known as 16-00012),

and EC 422831 section 3.24 (formally known as13-264 ))

describe seismic and tornado missile design criteria for HCVS stack. EC pkgs 423331, 423332, and 422831 are available in ePortal for review.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 7 Phase 1 Interim Staff Evaluation Open Items Status

/SE-6 Make available for NRC staff audit the descriptions of Complete.

focal conditions (temperature, radiation and humidity) HCVS is designed to minimi:e anticipated during ELAP and severe accident for the the impact of elevated components (valves, instrumentation, sensors, temperatures, due to the transmitters, indicators, electro11ics, control devices, potential loss of ventilation, etc.) required for HCVS venting including confirmation radiation and humidity impact that the components are capable of pe1forming their on the ability of operators to functions during ELAP and severe accident conditions. initiate and maintain the functionality of the HCVS. The locations of system equipment that require operator actio11 and the travel paths to reach the controls and indications are in mild environments.

(Reference EC 423281 section 3.19 and 3.24). EC 423281 is available in ePortal for review.

The loss of all general area lighting, coincident with the ELAP, does not pose a threat to the operators' ability to access and operate HCVS, since self-contained emergency lights illuminate the travel paths and handheld or portable lighting is available to manipulate HCVS equipme11t.

ISE-7 Make available for NRC staff audit documentation of the Complete.

HCVS nitrogen p11e11matic system design includi11g sizing HCVS is designed to operate and location. forfirst 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with installed independe11t pneumatic air supply, thereby eliminating the reliance on portable equipment. HCVS is also designed for multiple venting and purge cycles during the first 24-hour period without the need to recharge pneumatic air supplies. The pneumatic air supply is located in the emergency diesel corridor.

(Reference EC 423333 section 3.19 and Calculation LM-

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 8 Phase 1 Interim Staff Evaluation Open Items Status 0723). EC 423333 and Calculation LM-0723 are available in ePortalfor review.

!SE-8 Make available for NRC staff audit documentation that Complete.

demonstrates adequate communication between the This communication method is remote HCVS operation locations and HCVS decision the same as accepted in Order makers during ELAP and severe accident conditions. EA-12-049. These items will be powered and remain powered using the same methods as evaluated under EA-12-049 for the period of sustained operation, which may be longer than identified for EA-12-049.

Communication will be via the plant radio system if available.

lf the radio system is not available, the Plant page system can be used. The page system was modifiedfor FLEX to include a UPS that can be manually aligned to repower the system. (Reference AR 2492527-42). AR 2492527-42 is available in ePortal for review.

!SE-9 Provide a description of the final design of the HCVS to Complete.

address hydrogen detonation and deflagration. HCVS has been designed to ensure the flammability limits of gases passing through the system are not reached. A purge gas (argon) supply system has been provided to displace potentially flammable/ detonable mixtures of gases that may be present in the vent after system actuation.

The purge gas supply system is designed for four purge cycles during the first 24-hour period without the need to recharge.

(Reference EC 423333 section 3.19) EC 423333 is available in ePortal for review.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 9 Phase 1 Interim Staff Evaluation Open Items Status ISE-10 Provide a description of the strategies for hydrogen Complete.

control that minimizes the potential for hydrogen gas As discussed in the December migration and ingress into the reactor building or other 2015 OIP, the Limerick buildings. wetwell vent line for each unit has a dedicated HCVS flow path from the wetwell penetration to the outside with no interconnected system. The discharge point meets the guidance of "HCVS Release Point", HCVS-FAQ-04 (Reference 11).

(Reference EC 423281 and Calculation LM-0709).

EC 423281 and Calculation LM-0709 are available in ePortalfor review.

ISE-11 Make available for NRC staff audit documentation of a Complete.

seismic qualification evaluation of HCVS components. Seismic documentation has been provided in Reference EC 423331 section 3.4 and 3.38, EC 423333 section 3.4, 3.38, and attachment 45. EC 423331 and EC 423333 are available in ePortal for review.

ISE-12 Make available for NRC staff audit descriptions of all Complete.

instrumentation and controls (existing and planned) EC 423333 installed and necessary to implement this order including qualification qualified the following methods. components in the MCR and in the plant:

valve position indicating lights, power key-locked switch, temperature indicator displays, radiation monitoring system consisting of an element Local to the HCVS vent pipe, and a monitor.

(Reference EC 423333 section 3.19 and 3.36)

Existing pressure instrument PI-042-270-1 will be used to monitor containment pressure in the drywell. See EC 617568 section 3.2 for qualification of the component.

EC 423333 and EC 617568

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 10 Phase 1 Interim Staff Evaluation Open Items Status are available in ePortal for review.

!SE-13 Make available for NRC staff audit the procedures for Complete.

HCVS operation. Reference the following procedures.

SAMP-1: RPV Control SAM P-2: Containment and Radioactivity Release Control T-101: RPV Control T-102: Prima1y Containment Control SP!T, SP/L, PCIP, DW!T, PCIH T-341: Prima/)' Containment Venting Via Hardened Containment Vent System.

These procedures are in ePortal for review.

EGC's response to the NRC ISE Phase 2 Open Items identified in Reference 15 have been addressed and closed as documented in Reference 13 and as described below, and are considered complete per Reference 16. The following table provides completion references for each ISE Phase 2 Open Item.

Phase 2 Interim Staff Evaluation Open Items Status ISEP2-I Licensee to demonstrate that the HCVS components Complete.

meeting reasonable protection from tornado missiles is Per Drawing HBD-842-01, at least 30 feet above the highest grade within 300 HCVS pipe leaves the yards. protected structure more than 120 feet above grade elevation, which is 217 feet MSL, as indicated on site topographical drawing C-0062 that shows grade elevation referenced to MSL within 300 yards of the HCVS components evaluated.

ISEP2-2 Licensee to confirm through analysis the temperature Complete.

and radiological conditions to ensure that operating Actions taken within the first personnel can safely access and operate controls and hour (prior to start of core support equipment. damage) from the start of the EL.AP are acceptable from an environmental and radiological perspective without further evaluation.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 11 Phase 2 Interim Staff Evaluation Open Items Status Actions within the MCR are acceptable for the entire period of Sustained Operation per HCVS-FAQ-01.

Actions within the Reactor Building and between 1 and 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , evaluation of expected temperatures and dose rates has been pe1formed and determined them to be acceptable. (Reference EC 622673, and calculations LM-0721 and LM-0725).

For locations outside the Reactor Building between 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and 7 days, Limerick pe1formed evaluations for the temperature and radiological conditions for the equipment and deployment locations, including ingress/egress paths and determined them to be acceptable. (Reference EC 622673, and calculations LM-0721 and LM-0725). EC 622673, LM-0721 and LM-0725 are available in ePortal for review.

ISEP2-3 Licensee to evaluate the SA WA equipment and Complete.

controls, as well as the ingress and egress paths for the Equipment and Controls:

expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period. Plant instrumentation for SAWAISA WM that is qualified to RG 1.97 or equivalent is considered qualified for the sustained operating period without further evaluation.

Passive components that do not need to change state after initially establishing SA WA flow do not require evaluation beyond the first 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , at

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 12 Phase 2 Interim Staff Evaluation Open Items Status which time they are expected to be installed and ready for use to support SA WA/SA WM.

The following additional equipment pe1for111ing an active SA WA/SA WM function is considered:

SA WA/SA WM flow instrument SA WA/SA WM/FLEX pump SA WA/SA WM/FLEX generator Active valves in SA WA flow path.

Ingress and Egress:

For locations outside the Reactor Building between 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and 7 days when SA WA is being utilized, Limerick pe1for111ed evaluations of expected temperatures, humidity and the dose rates and determined them to be acceptable. (Reference EC 622673, and calculations LM-0721 and LM-0725).

EC 622673, LM-0721 and LM-0725 are available in ePortal for review.

ISEP2-4 Licensee to demonstrate that containment failure as a Complete.

result of ove1pressure can be prevented without a The wetwell vent has been drywell vent during severe accident conditions. designed and installed to meet NE! 13-02 Rev 1 guidance, which will ensure that it is adequately sized to prevent containment ove1pressure under severe accident conditions.

The SA WM strategy will ensure that the wetwell vent remains functional for the period of sustained operation.

LGS will follow the guidance (flow rate and timinf!) for

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 13 Phase 2 Interim Staff Evaluation Open Items Status SA WA/SA WM described in BWROG-TP-15-008 and BWROG-TP-15-011.These documents have been posted to the ePortalfor NRC staff review. The wetwell vent will be opened prior to exceeding the PCPL value of 60 PSIG.

Therefore, containment over pressurization is prevented without the need for a drywell vent.

ISEP2-5 Licensee shall demonstrate how the plant is bounded Complete.

by the reference plant analysis that shows the SA WM Using Figure 2.1.Cji"0111 the strategy is successful in making it unlikely that a combined Phases 1 and 2 Of P, drywell vent is needed. compare the reference plant parameters to the plant specific parameters.

Reference LGS Plant Torus Suppression freeboard Pool volume is ji-eeboard 525,000 volume is gallons 147,670ft3

(/,104,572 Ra lions)

SAWAflow SA WA.flow is is 500 GPM 500 GPM at at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months followed by followed by lOOGPM 100 GPM from 12 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to hours to 168 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months hours The above parameters for LGS compared to the reference plant that determine success of the SA WM strategy demonstrate that the reference plant values are bounding.

Therefore, the SA WM strategy implemented at LGS makes it unlikely that a DW vent is needed to prevent containment

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 14 Phase 2 Interim Staff Evaluation Open Items Status overpressure related failure.

ISEP2-6 licensee to demonstrate that there is adequate Complete.

communication between the MCR and the operator at This communication method is the FLEX pump durillg severe accidellt conditions. the same as accepted in Order EA-12-049. These items will be powered and remain powered using the same methods as evaluated under EA-12-049 for the period of sustained operation, which may be longer thall identified for EA-12-049.

Co111111w1ication will be via the plant radio system if available.

If the radio system is not available, the Plant page system can be used. The page system was modified for FLEX to include a UPS that can be manually aligned to repower the system. (Reference AR 2492527-42)

ISEP2-7 licensee to demonstrate the SA WM flow Complete.

instrumentation qualification for the expected For locations outside the environmental conditions Reactor Building between 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and 7 days when SAWA is being utilized, limerick Generating Station pe1formed evaluation of expected temperatures, humidity and the dose rates and determined them to be acceptable.

(Reference EC 622673 ).

SAWA Pump Expected Flow SAWA Instrument Parameter Qualification RanRe 37 to 1246 JOO to 500 GPM GPM 32 to 140 °F 32 to 95 °F fluid fluid temperature temperature 14 to 122 °F 0 to JOO °F

/11strume11t Ambient air Electro11icsf 2 J temve ratu re

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 15 Phase 2 Interim Staff Evaluation Open Items Status 275 PSI 239.7 PSI 111axi11111111 Ill (/xi 11111111 21

' Below14 °F, the LCD may become sluggish or unresponsive; however, it will continue to measure and function to at least -4 ° F.

(Reference MS2500-DataSheet).

MS2500-DataSheet and EC 622673 are available in ePortalfor review.

Note 1:

For the location of the ROS in the DG corridor, there is a maximum expected temperature of 121 °F.

This temperature is expected to occur due to a non-safety related heating steam pipe rupturing during a seismic event. To mitigate this issue, the heating steam pipe was analyzed and additional supports have been installed to ensure the piping will not rupture (EC 423333). There are no additional process fluid piping or heat generating equipment that would add significant heat to this area.

Therefore, the area will then be at outside ambient conditions which does not normally exceed 100 OF.

The performance validation for T-341 to align the HCVS for operation determined the longest duration of 16 minutes in the EOG corridor would be required to align the system. Activation of the system included opening the argon and air bottles and repositioning a three-way valve. This would be the longest duration of any operator at the ROS during the event. If required, operating personnel working in high temperature areas will be protected using SA-AA-111, Heat Stress Control. With the use of SA-AA-111 heat stress controls, it is reasonable to assume the operator actions required to implement the HCVS and SAWA/SAWM strategies can be accomplished. SA-AA-111 and the validation study are available in ePortal.

MILESTONE SCHEDULE - ITEMS COMPLETE Limerick Generating Station, Unit 2 - Phases 1 and 2 Specific Milestone Schedule Milestone Completion Date Submit Overall Integrated Plan June 2014 Submit 6 Month Updates Update 1 December 2014 Update 2 June 2015

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 16 Milestone Completion Date Update 3 [Simultaneous with Phase 2 OIP] December 2015 Update 4 June 2016 Update 5 December 2016 Update 6 June 2017 Update 7 December 2017 Update 8 June 2018 Phase 1 Modifications Hold preliminary/conceptual design meeting June 2014 Unit 2 Modifications Evaluation March 2017 Unit 2 Design Engineering On-site/Complete May 2017 Unit 2 Implementation Outage May 2017 Unit 2 Walk Through Demonstration/Functional May 2017 Test Phase 1 Procedure Changes Active Unit 2 Operations Procedure Changes Developed February 2017 Unit 2 Site Specific Maintenance Procedure February 2017 Developed Unit 2 Procedure Changes Active May 2017 Phase 1 Training Unit 2 Training Complete February 2017 Phase 1 Completion Unit 2 HCVS Implementation May 2017 Phase 2 Modifications Hold preliminary/conceptual design meeting June 2016 Modifications Evaluation March 2018 Unit 2 Design Engineering On-site/Complete March 2018 Unit 2 Implementation Outage N/A Unit 2 Walk Through Demonstration/Functional Test September 2018 Phase 2 Procedure Changes Active Unit 2 Operations Procedure Changes Developed September 2018 Unit 2 Site Specific Maintenance Procedure September 2018 Developed Unit 2 Procedure Changes Active September 2018

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 17 Milestone Completion Date Phase 2 Training Unit 2 Training Complete September 2018 Phase 2 Completion Unit 2 HCVS Implementation September 28, 2018 November 2018 Submit Unit 2, Phase 1 & Phase 2, Completion Report (60 days after Unit 2 compliance] Completed with this submitial ORDER EA-13-109 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Limerick Generating Station, Unit 2, Phase 1 and Phase 2 OIP response submittal (References 5 and 8), and the 6-Month Status Reports (References 6, 7, 8, 9, 10, 11, 12, and 13), demonstrate compliance with NRC Order EA-13-109. The Limerick Generating Station, Units 1 and 2 Final Integrated Plan for reliable hardened containment vent Phase 1 and Phase 2 strategies is provided in the enclosure to this letter.

HCVS PHASE 1 AND PHASE 2 FUNCTIONAL REQUIREMENTS AND DESIGN FEATURES - COMPLETE The Limerick Generating Station, Unit 2, Phase 1 HCVS provides a vent path from the wetwell to remove decay heat, vent the containment atmosphere, and control containment pressure within acceptable limits. The Phase 1 HCVS will function for those accident conditions for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of active containment heat removal capability during an extended loss of alternating current power.

The Limerick Generating Station, Unit 2, Phase 2 HCVS provides a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywell before alternative reliable containment heat removal and pressure control is reestablished. The Limerick Generating Station, Unit 2, Phase 2 HCVS strategies implement Severe Accident Water Addition (SAWA) with Severe Accident Water Management (SAWM) as an alternative venting strategy. This strategy consists of the use of the Phase 1 wetwell vent and SAWA hardware to implement a water management strategy that will preseNe the wetwell vent path until alternate reliable containment heat removal can be established.

The Limerick Generating Station, Unit 2, Phase 1 and Phase 2 HCVS strategies are in compliance with Order EA-13-109. The modifications required to support the HCVS strategies for Limerick Generating Station, Unit 2 have been fully implemented in accordance with the station processes.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 18 HCVS PHASE 1 AND PHASE 2 QUALITY ST AND ARDS - COMPLETE The design and operational considerations of the Phase 1 and Phase 2 HCVS installed at Limerick Generating Station, Unit 2 complies with the requirements specified in the Order and described in NEI 13-02, Revision 1, "Industry Guidance for Compliance with Order EA-13-109". The Phase 1 and Phase 2 HCVS has been installed in accordance with the station design control process.

The Phase 1 and Phase 2 HCVS components including piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication have been designed consistent with the design basis of the plant. All other Phase 1 and Phase 2 HCVS components including electrical power supply, valve actuator pneumatic supply and instrumentation have been designed for reliable and rugged performance that is capable of ensuring Phase 1 and Phase 2 HCVS functionality following a seismic event.

HCVS PHASE 1 AND PHASE 2 PROGRAMMATIC FEATURES - COMPLETE Storage of portable equipment for Limerick Generating Station, Unit 2 Phase 1 and Phase 2 HCVS use provides adequate protection from applicable site hazards.

Procedurally identified paths and deployment areas will be accessible during all modes of operation and during severe accidents, as recommended in NEI 13-02, Revision 1, Section 6.1.2.

Training in the use of the Phase 1 and Phase 2 HCVS for Limerick Generating Station, Unit 2 has been completed in accordance with an accepted training process as recommended in NEI 13-02, Revision 1, Section 6.1.3.

Operating procedures for Limerick Generating Station, Unit 2 have been developed and integrated with existing procedures to ensure safe operation of the Phase 1 and Phase 2 HCVS. Procedures have been verified and are available for use in accordance with the site procedure control program. Maintenance procedures for Limerick Generating Station, Unit 2 have been developed or have open tracking mechanisms created so that the procedures will be issued prior to being required. Limerick Generating Station, Unit 2 has implemented operation, testing, and inspection requirements for the HCVS and SAWA that follows the existing plant procedures and process to ensure reliable operation of the systems. The existing plant maintenance program will be applied to the HCVS and SAWA valves, instead of the maintenance frequency that has been listed in NEI 13-02, Section 6.2.4. The maintenance program uses PCM (Performance Centered Maintenance) template which is currently used to maintain the plant's safety related and non-safety related systems.

Site processes have been established to ensure the Phase 1 and Phase 2 HCVS is tested and maintained as recommended in NEI 13-02, Revision 1, Sections 5.4 and 6.2.

Limerick Generating Station, Unit 2 has completed validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for HCVS strategies are feasible and may be executed within the constraints

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-13-109 November 14, 2018 Page 19 identified in the HCVS Phases 1and2 OIP for Order EA-13-109 (Reference 8).

Limerick Generating Station, Unit 2 has completed evaluations to confirm accessibility, habitability, staffing sufficiency, and communication capability in accordance with NEI 13-02, Revision 1, Sections 4.2.2 and 4.2.3.

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 141h day of November 2018.

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

Enclosure:

Limerick Generating Station, Units 1 and 2 Final Integrated Plan Document -

Hardened Containment Vent System NRC Order EA-13-109 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Limerick Generating Station NRC Project Manager, NRR - Limerick Generating Station Mr. Peter J. Bamford, NRR/JLD/JOMB, NRC Mr. Brian E. Lee, NRR/JLD/JCBB, NRC Mr. Rajender Auluck, NRR/JLD/JCBB, 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

Enclosure Limerick Generating Station, Units 1 and 2 Final Integrated Plan Document - Hardened Containment Vent System NRC Order EA-13-109 (64 pages)

Final Integrated Plan HCVS Order EA-13-109 for Limerick Generating Station (LGS)

November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Table of Contents Section I: Introduction .................................................................... ........................................................... 1 Section I.A: Summary of Compliance ................................................................................................ 3 Section l.A.1 : Summary of Phase 1 Compliance ......................................................................... 3 Section l.A.2: Summary of Phase 2 Compliance ......................................................................... 3 Section II: List of Acronyms ...................................................................................................................... 5 Section Ill: Phase 1 Final Integrated Plan Details ................................................................................. 7 Section 111.A: HCVS Phase 1 Compliance Overview ........................................................................ 7 Section 111.A.1: Generic Letter 89-16 Vent System ...................................................................... 7 Section 111.A.2: EA-13-109 Hardened Containment Vent System (HCVS) ............................... 7 Section 111.8: HCVS Phase 1 Evaluation Against Requirements: ................................................... 9

1. HCVS Functional Requirements .............................................................................................. 9

2. HCVS Quality Standards: ........................................................................................................ 23 Section IV: HCVS Phase 2 Final Integrated Plan ................................................................................ 24 Section IV.A: The requirements of EA-13-109, Attachment 2, Section 8 for Phase 2 ............. 24

1. HCVS Drywall Vent Functional Requirements ..................................................................... 24

2. Containment Venting Strategy Requirements ...................................................................... 24 Section IV.B: HCVS Existing System ............................................................................................... 25 Section IV.C: HCVS Phase 2 SAWA System and SAWM Strategy ............................................ 25 Section IV.C.1: Detailed SAWA Flow Path Description ............................................................. 26 Section IV.C.2: Severe Accident Assessment of Flow Path ...................................................... 26 Section IV.C.3: Severe Accident Assessment of Safety-Relief Valves .................................... 27 Section IV.C.4: Available Freeboard Use ..................................................................................... 27 Section IV.C.5: Upper range of wetwell level indication ............................................................. 27 Section IV.C.6: Wetwell vent service time .................................................................................... 27 Section IV.C.7: Strategy time line .................................................................................................. 27 Section IV.C.8: SAWA Flow Control ............................................................................................. 28 Section IV.C.9: SAWA/SAWM Element Assessment.. ............................................................... 28 Section IV.C.10: SAWA/SAWM lnstrumentation ........................................................................ 30 Section IV.C.11: SAWA/SAWM Severe Accident Considerations ........................................... 31 Section V: HCVS Programmatic Requirements .................................................................................. 32 Section V.A: HCVS Procedure Requirements ............................................................................ .... 32 Section V.B: HCVS Out of Service Requirements ......................................................................... 34 Section V.C: HCVS Training Requirements .................................................................................... 35 Revision 0 Page ii November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Section V.D: Demonstration with other Post Fukushima Measures ...... ............. ...... ...... ........ ..... 37 Section VI: References ............... ......................... ....... ..... ........ ...... ......................................................... 38 : Phase 2 Freeboard diagram ..... ................................................................................... 42 : One Line Diagram of HCVS Vent Path (Unit 1 shown, Typical Unit 2) (Reference

44) ......... ....................... ....................... ................ .................. .... .... .............. ........ ...... ........ ..... ............. ........ 43 : One Line Diagram of HCVS Electrical Power Supply (Unit 1 shown, Unit 2 typical) (Reference 48 and 59) .............................. .. ...... .................. ........... ........................... .. ............... 44 A: One Line Diagram of SAWA/FLEX Electrical Power Supply Div 1 .. .. ................. 46 B: One Line Diagram of SAWA/FLEX Electrical Power Supply Div 2 .............. .. ..... 47 A: Plant Layout Showing Operator Action Locations General plant layout... ..........48 B: Plant Layout Showing Operator Action Locations RB and DG El. 217' .............. 49 C: Plant Layout Showing Operator Action Locations RB and Control Enclosure El.

239' ........................................................................... ........................................................... ...... .. .... ... ........ 50 D: Plant Layout Showing Operator Action Locations RE El. 201' ........ .. .. ................ 51 E: Plant Layout Showing Operator Action Locations RE El. 283' ................. ........... 52 E: Plant Layout Showing Operator Action Locations RE El. 313' .............. .... .......... 53 F: Plant Layout Showing Operator Action Locations RE El. 269' ............... ........... ... 54 Table 1: List of HCVS Component, Control and Instrument Qualifications (Reference 31) ........ 55 Table 2: Operator Actions Evaluation (Reference 31) .............. ...... .... .................... .... ... ............ ... ... .. 61 Revision 0 Page iii November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Section I: Introduction In 1989, the NRG issued Generic Letter 89-16, "Installation of a Hardened Wetwell Vent,"

(Reference 1) to all licensees of BWRs with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the wetwell to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell.

On March 19, 2013, the Nuclear Regulatory Commission (NRG) Commissioners directed the staff per Staff Requirements Memorandum (SRM) for SECY-12-0157, Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark 11 Containments (References 2 and 3) to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents (Reference 4) with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013 (Reference 5). The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent to remove decay heat from the containment, and to maintain control of containment pressure within acceptable limits following events that result in the 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).

Limerick Generating Station (LGS) is required by NRG Order EA-13-109 to have a reliable, severe accident capable Hardened Containment Venting System (HCVS).

Order EA-13-109 allows implementation of the HCVS Order in two phases.

Phase 1 upgraded the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened vent to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. LGS achieved Phase 1 compliance on April 15, 2018.

Phase 2 provided additional protections for severe accident conditions through the development of a reliable containment venting strategy that makes it unlikely that LGS would need to vent from the containment drywell during severe accident conditions. LGS achieved Phase 2 compliance on September 28, 2018.

NEI developed guidance for complying with NRG Order EA-13-109 in 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 0 (Reference 6) with significant interaction with the NRG and Licensees. NEI Revision 0 Page 1 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 issued Revision 1 to NEI 13-02 in April 2015 (Reference 7) which contained guidance for compliance with both Phase 1 and Phase 2 of the order. NEI 13-02, Revision 1 also includes HCVS- Frequently Asked Questions (FAQs) 01 through 09 and reference to white papers (HCVS-WP-01 through 03 (References 8 through 10)). The NRC endorsed NEI 13-02 Revision 0 as an acceptable approach for complying with Order EA-13-109 through 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, issued in November 2013 (Reference 12) and JLD-ISG-2015-01, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions issued in April 2015 (Reference 13) for NEI 13-02 Revision 1 with some clarifications and exceptions. NEI 13-02 Revision 1 provides an acceptable method of compliance for both Phases of Order EA-13-109.

In addition to the endorsed guidance in NEI 13-02, the NRG staff endorsed several other documents that provide guidance for specific areas. HCVS-FAQs 10 through 13 (References 14 through 17) were endorsed by the NRC after NEI 13-02 Revision 1 on October 8, 2015. NRG staff also endorsed four White Papers, HCVS-WP-01 through 04 (References 8 through 11 ), which cover broader or more complex topics than the FAQs.

As required by the order, LGS submitted a phase 1 Overall Integrated Plan (OIP) in June of 2014 (Reference 18) and subsequently submitted a combined Phase 1 and 2 OIP in December 2015 (Reference 19). These OIPs followed the guidance of NEI 13-02 Revision 0 and 1 respectively, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents. The NRC staff used the methods described in the Interim Staff Guidance (ISG) to evaluate licensee compliance as presented in the Order EA-13-109 OIPs. While the Phase 1 and combined Phase 1 and 2 OIPs were written to different revisions of NEI 13-02, LGS conforms to NEI 13-02 Revision 1 for both Phases of Order EA-13-109.

The NRC performed a review of each OIP submittal and provided LGS with Interim Staff Evaluations (ISEs) (References 20 and 21) assessing the site's compliance methods. In the ISEs the NRC identified open items which the site needed to address before that phase of compliance was reached. Six-month progress reports (References 23 through 29) were provided consistent with the requirements of Order EA-13-109. These status reports were used to close many of the ISE open items. In addition, the site participated in NRC ISE Open Item audit calls where the information provided in the six-month updates and on the E-Portal were used by the NRC staff to determine whether the ISE Open Item appeared to be addressed.

By submittal of this Final Integrated Plan LGS has addressed all the elements of NRC Order EA-13-109 utilizing the endorsed guidance in NEI 13-02, Rev 1 and the related HCVS-FAQs and HCVS-WPs documents. In addition, the site has addressed the NRG Phase 1 and Phase 2 ISE Open Items as documented in previous six-month updates or within the Phase 1 and 2 Compliance Letter for the first compliance of LGS (References 30).

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Final Integrated Plan HCVS Order EA-13-109 Section Ill contains the LGS Final Integrated Plan details for Phase 1 of the Order.

Section IV contains the Final Integrated Plan details for Phase 2 of the Order. Section V details the programmatic elements of compliance.

Section I.A: Summary of Compliance Section l.A.1: Summary of Phase 1 Compliance The plant venting actions tor the EA-13-109, Phase 1, severe accident capable venting scenario can be summarized by the following:

The HCVS is initiated via manual action from the Main Control Room (MCR) or Remote Operating Station (ROS) at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms.

The vent utilizes containment parameters of pressure and suppression pool level from the MCR instrumentation to monitor effectiveness of the venting actions.

The vent operation is monitored by HCVS valve position, temperature and effluent radiation levels.

The HCVS motive force is monitored and has the capacity to operate tor 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with installed equipment. Replenishment of the motive force will be by use of portable equipment once the installed motive force is exhausted.

Venting actions are capable of being maintained for a sustained period of at least 7 days.

The operation of the HCVS is designed to minimize the reliance on operator actions in response to external hazards. The screened in external hazards for LGS are seismic, external flooding (Storage and Transportation of Equipment during a Local Intense Precipitation), Severe Storms with High Winds, Tornados, Snow, Ice, Extreme Cold and High Temperature. Initial operator actions are completed by plant personnel and include the capability for remote-manual initiation from the HCVS ROS. contains a one-line diagram of the HCVS vent flowpath.

Section l.A.2: Summary of Phase 2 Compliance The Phase 2 actions can be summarized as follows:

Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV).

Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS Phase 1 suppression pool vent will remain functional for the removal of heat from the containment.

Revision 0 Page 3 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109

Heat can be removed from the containment for at least seven (7) days using the HCVS or until alternate means of heat removal are established that make it unlikely the drywell vent will be required for containment pressure control.

The SAWA and SAWM actions can be manually activated and controlled from areas that are accessible during severe accident conditions.

Parameters measured are drywell pressure, suppression pool level, SAWA flowrate and the HCVS Phase 1 vent path parameters.

The locations of the SAWA equipment and controls, as well as ingress and egress paths have been evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period. Equipment has been evaluated to remain operational throughout the Sustained Operating period. Personnel radiological exposure, temperature and humidity conditions for operation of SAWA equipment will not exceed the limits for Emergency Response Organization (ERO) dose or plant safety guidelines for temperature and humidity.

The SAWA flow path is the same as the primary FLEX flow path. The SAWA flow path starts from the spray pond into the FLEX pump. The SAWA flow passes through the discharge hose, into the RHRSW piping near the RHRSW pumps. From there the flow goes into the Reactor Enclosure (RE). The flow bypasses AHR heat exchangers via AHR valves HV-051-1 F073/2F073 and HV-051-1 F075/2F075 to the RPV through AHR Low Pressure Core Injection valve (LPCI) valve HV-051-1F017B/2F017A. OW pressure and suppression pool level are monitored and the flow rate is adjusted by varying pump speed or by other means described in the station procedures (Reference 37).

Communication is established between the MCA and the FLEX pump location. contains a one-line diagram of the SAWA flowpath.

There are no additional electrical loads on the FLEX DG due to SAWA/SAWM. The FLEX DGs are located south of the RE and are a significant distance from the discharge of the HCVS piping on the south side on the REs. See Attachment 6 for applicable locations. Refueling of the FLEX DG is accomplished from the Emergency Diesel Generator (EOG) underground fuel oil tanks as described in the procedure T-360 (Reference 60).

Evaluations for projected SA conditions (radiation I temperature) indicate that personnel can complete the initial and support activities without exceeding the ERO-allowable dose for equipment operation or site safety standards.

Electrical equipment and instrumentation is powered from the existing station batteries, and from AC distribution systems that are powered from the FLEX generator(s). The battery chargers are also powered from the FLEX generator(s) to maintain the battery capacities during the sustained operating period.

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Final Integrated Plan HCVS Order EA-13-109 Section II: List of Acronyms AC Alternating Current AOV Air Operated Valve BDBEE Beyond Design Basis External Event BWROG Boiling Water Reactor Owners' Group CAC Containment Atmospheric Control System CAP Containment Accident Pressure DC Direct Current ECCS Emergency Core Cooling Systems ELAP Extended Loss of AC Power EOP Emergency Operating Procedure EPG/SAG Emergency Procedure and Severe Accident Guidelines EPRI Electric Power Research Institute ERO Emergency Response Organization FAQ Frequently Asked Question FIP Final Integrated Plan FLEX Diverse & Flexible Coping Strategy FPSB FLEX Pump Storage Building GPM Gallons per minute HCVS Hardened Containment Vent System ISE Interim Staff Evaluation ISG Interim Staff Guidance JLD Japan Lessons Learned Project Directorate Revision 0 Page 5 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 LPCI Low Pressure Coolant Injection LGS Limerick Generating Station MAAP Modular Accident Analysis Program MCR Main Control Room NEI Nuclear Energy Institute NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission OIP Overall Integrated Plan PCIV Primary Containment Isolation Valve PCPL Primary Containment Pressure Limit RCIC Reactor Core Isolation Cooling System RE Reactor Enclosure RHR Residual Heat Removal System RHRSW Residual Heat Removal Service Water System RM Radiation Monitor ROS Remote Operating Station RPV Reactor Pressure Vessel RWCU Reactor Water Cleanup SA Severe Accident SAMP Severe Accident Management Procedure SAWA Severe Accident Water Addition SAWM Severe Accident Water Management SFP Spent Fuel Pool Revision 0 Page 6 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 SRV Safety-Relief Valve UFSAR Updated Final Safety Analysis Report VAC Voltage AC voe Voltage DC WW Wetwell Section Ill: Phase 1 Final Integrated Plan Details Section Ill.A: HCVS Phase 1 Compliance Overview LGS installed a hardened suppression pool vent path to comply with NRC Order EA 109.

Section 111.A.1: Generic Letter 89-16 Vent System LGS has a Mark II primary containment design and was not required to comply with NRC Generic Letter 89-16.

Section 111.A.2: EA-13-109 Hardened Containment Vent System (HCVS)

LGS installed a suppression pool vent flow path in each unit that has two dedicated primary containment isolation valves and a downstream rupture disc that is routed separate from the other unit. The discharge from each unit is routed separately through a pipe that discharges above the Reactor Enclosure's roof. Each unit has dedicated motive gas bottles for HCVS valves, Argon Purge system, and DC power for HCVS components that are not shared with any other system or function. The HCVS operation does not rely on FLEX for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operations. The existing containment instrumentation (pressure and suppression pool level) are not considered HCVS components, and power for containment instrumentation is through the FLEX Diesel Generator (DG) provided through the actions for EA-12-049. Also, the FLEX DG will be credited for recharging the HCVS battery after the initial 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the event.

The operation of the HCVS has been designed to minimize the reliance on operator actions in response to hazards. Initial operator actions will be completed by trained plant personnel and will include the capability for remote-manual initiation from the HCVS ROS.

The vent system is normally operated and monitored from the MCR. A ROS has been installed in a readily accessible location and provides a means to manually operate the suppression pool vent. The controls available at the ROS are accessible and functional under a range of plant conditions, including severe accident conditions. The ROS Revision 0 Page 7 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 location is in the diesel generator corridor 217' elevation, accessible from outside the Reactor Enclosure. Table 2 contains the evaluation of the acceptability of the ROS location with respect to severe accident conditions.

The HCVS does not contain any new electrical circuitry for bypassing isolation signals.

The ROS can open the Primary Containment Isolation Valves (PCIV's) directly with compressed air so that no electrical signal overrides are needed.

The MCA is the primary operating station for the HCVS. During an ELAP, electric power to operate the vent valves will be provided by batteries with a capacity to supply required loads for at least the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Before the batteries are depleted, the FLEX generator will supplement and recharge batteries to support operation of the vent valves. The ROS is designated as the alternate control location and method. Since the ROS does not require any electrical power to operate, the valve solenoids do not need any additional backup electrical power. Attachment 2 shows the HCVS vent flow path.

At the MCA location, the operators can operate the HCVS power control, PCIVs switches, monitor HCVS PCIV position, vent pipe temperature, argon pressure, argon purge control switch, and the HCVS radiation monitor.

The ROS consists of manual valves that directly port air to the PCIV actuators and argon purge system. The ROS has local pressure indication available for the pneumatics air supply and argon supply, but no other indication is available. Table 1 contains a complete list of instruments available to the operators for operating and monitoring the HCVS. contains a one-line diagram of the HCVS electrical distribution system.

The suppression pool vent up to, and including, the second containment isolation barrier is designed consistent with the design basis of the plant. These items include piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication components.

NEI 13-02 suggests a 350°F value for HCVS design temperature based on the highest Primary Containment Pressure Limit (PCPL) among the Mark I and II plants. Unit 1 HCVS piping follows the guidance from NEI 13-02 for all the components and valves.

Unit 2 HCVS has been designed to a PCPL of 60 psig and a minimum corresponding saturation temperature of 308°F. Per NEI 13-02, it is acceptable to assume saturation conditions in containment so that these design parameters are acceptable.

To prevent leakage of vented effluent to other parts of the Reactor Enclosure or other systems, Unit 1 HCVS does not share a containment penetration with any other system.

Therefore, leakage of vented effluent to other parts of the Unit 1 Reactor Enclosure or other systems is not a concern.

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Final Integrated Plan HCVS Order EA-13-109 To prevent leakage of vented effluent to other parts of the Reactor Enclosure or other systems for Unit 2, the Containment Atmospheric Control (CAC) HV-057-224 and HV-057-231 valves are required to be closed. These valves are normally closed, HV-057-224 fails closed, and neither are required to change state in order to perform their safety related containment isolation function; therefore, they can be assumed to be closed when required. The Unit 2 CAC valves are part of the In-Service Testing (IST) program and are leak tested in accordance with 10CFR50, Appendix J. This is acceptable for prevention of inadvertent cross-flow of vented fluids per HCVS-FAQ-05.

HCVS features to prevent inadvertent actuation include a key lock switch at the primary control station and locked closed valves at the ROS which is an acceptable method of preventing inadvertent actuation per NEI 13-02. In addition, the argon and pneumatic bottles are normally isolated from the main header at the ROS.

As required by EA-13-109, Section 1.2.11, the suppression pool vent is designed to prevent air/oxygen backflow into the discharge piping to ensure the flammability limits of hydrogen, and other non-condensable gases, are not reached. The LGS design includes a purge system that injects inert gas (Argon) into the vent piping (Reference 43). Guidance for this design is contained in HCVS-WP-03. The relevant design calculations conclude that the purge system will preclude a flammable mixture from occurring in the vent pipe.

The HCVS Radiation Monitor (RM) with an ion chamber detector is qualified for the ELAP and external event conditions. In addition to the RM, a temperature element is installed on the vent line to allow the operators to monitor operation of the HCVS.

Electrical and controls components are seismically qualified and include the ability to handle harsh environmental conditions (although they are not considered part of the site Environmental Qualification (EQ) program).

Section 111.B: HCVS Phase 1 Evaluation Against Requirements:

The functional requirements of Phase 1 of NRG Order EA-13-109 are outlined below along with an evaluation of the LGS response to maintain compliance with the Order and guidance from JLD-ISG-2015-01. Due to the difference between NEI 13-02, Revision 0 and Revision 1, only Revision 1 will be evaluated. Per JLD-ISG-2015-01, this is acceptable as Revision 1 provides acceptable guidance for compliance with Phase 1 and Phase 2 of the Order.

1. HCVS Functional Requirements 1.1 The design of the HCVS shall consider the following performance objectives:

1.1.1 The HCVS shall be designed to minimize the reliance on operator actions.

Evaluation:

The operation of the HCVS was designed to minimize the reliance on Revision 0 Page 9 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 operator actions in response to hazards identified in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Reference 33), which are applicable to the plant site. Operator actions to initiate the HCVS vent path can be completed by plant personnel and include the capability for remote-manual initiation from the HCVS control station. A list of the remote manual actions performed by plant personnel to open the HCVS vent path is in the following table:

T a bl e 3 1.. HCVS 0 1perator Acfions Primary Location/

Primary Action Notes Component

1. Open argon and EOG corridor ROS pneumatic air supply valves

2. Turn on power to the Key switch in MCR HCVS system

3. Open Hardened Hand-switch located in the Suppression Pool Vent MCA or via manual valves Waive HV-057V- located at the ROS.

181/281 and HV-057V-180/280

~. Replenish Pneumatics and Argon Action required to pneumatics and Argon bottle supply have been supplement the bottle supply located in FLEX Pump pneumatics and Storage Building that Argon backup accessible to operators system after a during a severe accident. minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

5. Re-power the HCVS FLEX diesels are located Action required to battery chargers for in an area that meets the provide power to sustained operations requirements of EA-12-049 HCVS equipment (post-24 hours). and is accessible to after a minimum of operators during a severe 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months accident.

Permanently installed electrical power and pneumatic supplies are available to support operation and monitoring of the HCVS for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

After 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , available personnel will be able to connect supplemental electric power and pneumatic supplies for sustained operation of the HCVS for a minimum of 7 days. The FLEX generators and pneumatics and Argon bottle supply provide this motive force. In all likelihood, these Revision 0 Page 10 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 actions will be completed in less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . However, the HCVS can be operated for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months without any supplementation. Additional argon and pneumatics bottle supply has been stored in the FLEX pump storage building to replenish the HCVS after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The above set of actions conform to the guidance in NEI 13-02 Revision 1 Section 4.2.6 for minimizing reliance on Operator actions and are acceptable for compliance with Order element A.1.1 .1. These were identified in the OIP and subsequent NRG ISE.

Table 3-2 below provides a list of functional failure modes and the corresponding mitigating actions.

Table 3-2: Failure Evaluation Failure with Alternate Functional Action Failure Failure Cause Alternate Action Prevents Mode Containment Venting?

Valves fail to open/close due to None required - HCVS utilize loss of normal plant AC a dedicated 24-hour battery No power/DC batteries. power supply.

Valves fail to open/close due to Recharge system with FLEX depletion of dedicated battery No diesel generators.

power supply.

Valves fail to open/close due to Manually operate backup Fail to Vent complete loss of dedicated pneumatic supply/vent No (Open) on battery power supply. lines/valves at ROS.

Demand No action needed. Valves are Valves fail to open/close due to provided with dedicated loss of normal plant pneumatic No pneumatic supply capable of supply.

24-hour operation.

Valve fails to open/close due to Manually operate backup component failure (solenoid pneumatic supply/vent No valve, key switch, ect.) failure. lines/valves at ROS.

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Final Integrated Plan HCVS Order EA-13-109 Failure with Alternate Functional Action Failure Failure Cause Alternate Action Prevents Mode Containment Venting?

Not credible as there is not a Fail to stop common mode failure that would venting prevent the closure of at least 1 N/A No (Close) on of the 2 - PCIVs needed for demand venting. Both PCIVs are designed to fail close.

Not credible as key-locked switches prevent mispositioning Spurious of the HCVS PCIVs.

N/A No Opening Additionally, DC power for the HCVS is de-energized during normal plant operation.

Valves fail to remain open due to Recharge the dedicated depletion of dedicated power power supply with FLEX No supply. diesel generators.

Manually operate backup Valves fail to remain open due to pneumatic supply/vent No Spurious complete loss of power supplies.

lines/valves at ROS.

Closure Valves fail to remain open due to Replace pneumatic supply as No loss of pneumatic supply. needed.

1.1.2 The HCVS shall be designed to minimize plant operators' exposure to occupational hazards, such as extreme heat stress, while operating the HCVS system.

Evaluation:

Primary control of the HCVS is accomplished from the main control room.

Alternate control of the HCVS is accomplished from the ROS at the EOG corridor outside of RE. FLEX actions that will maintain the MCA habitable were implemented in response to NRC Order EA-12-049 (Reference 34).

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Final Integrated Plan HCVS Order EA-13-109 The ROS has been evaluated to be acceptable during the event and no action is required to keep ROS habitable. These include opening MCR doors to the Turbine Enclosure and operating portable generators and fans to move air through the MCR (if required). (Refence 58) The ROS was evaluated, and no additional actions are required.

Table 2 contains a thermal evaluation of all the operator actions that may be required to support HCVS operation. The relevant evaluation (Reference 31) demonstrate that the final design meets the order requirements to minimize the plant operators' exposure to occupational hazards.

1.1.3 The HCVS shall also be designed to minimize radiological consequences that would impede personnel actions needed for event response.

Evaluation:

Primary control of the HCVS is accomplished from the main control room.

Under the postulated scenarios of order EA-13-109 the control room is adequately protected from excessive radiation dose and no further evaluation of its use is required. (Reference 7)

Alternate control of the HCVS is accomplished from the ROS. The ROS was evaluated for radiation effects due to a severe accident and determined to be acceptable. The ROS is located outside of the RE. The distance and concrete RE walls combined with the short duration of actions required at the ROS, show the ROS to be an acceptable location for alternate control.

Table 2 contains a radiological evaluation of the operator actions that may be required to support HCVS operation in a severe accident. There are no abnormal radiological conditions present for HCVS operation without core damage. The evaluation of radiological hazards demonstrates that the final design meets the order requirements to minimize the plant operators' exposure to radiological hazards.

The HCVS vent is routed away from the MCR such that building structures provide shielding, thus per HCVS-FAQ-01 the MCR is the preferred control location. If venting operations create the potential for airborne contamination, the ERO will provide personal protective equipment to minimize any operator exposure.

1.1 .4 The HCVS controls and indications shall be accessible and functional under a range of plant conditions, including severe accident conditions, extended loss of AC power, and inadequate containment cooling.

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Final Integrated Plan HCVS Order EA-13-109 Evaluation:

Primary control of the HCVS is accomplished from the main control room.

Under the postulated scenarios of order EA-13-109 the control room is adequately protected from excessive radiation dose and no further evaluation of its use is required (Reference 7).

Alternate control of the HCVS is accomplished from the ROS in the EDG Corridor. The ROS EDG corridor is in an area evaluated to be accessible before and during a severe accident.

For ELAP with injection, the HCVS suppression pool vent will be opened to protect the containment from overpressure. The operator actions and timing of those actions to perform this function under ELAP conditions were evaluated as part of the engineering change that installed the HCVS at LGS.

Table 2 contains a thermal and radiological evaluation of all the operator actions at the MGR or alternate location that may be required to support HCVS operation during a severe accident. The relevant ventilation evaluation (Reference 31) demonstrates that the final design meets the order requirements to minimize the plant operators' exposure to occupational and radiological hazards.

Table 1 contains an evaluation of the controls and indications that are or may be required to operate the HCVS during a severe accident. The evaluation demonstrates that the controls and indications are accessible and functional during a severe accident with a loss of AC power and inadequate containment cooling.

1.2 The HCVS shall include the following design features:

1.2.1 The HCVS shall have the capacity to vent the steam/energy equivalent of 1 percent of licensed /rated thermal power (unless a lower value is justified by analysis) and be able to maintain containment pressure below the primary containment design pressure.

Evaluation Calculation LM-709 (Reference 45) contains the verification of 1% power flow capacity at design pressure for Unit 1 and 2. This calculation models all the piping, elbows, valves and components using either specific or industry standard flow coefficients to determine an equivalent length of piping. All of the 1O" (Unit 1 only), 12" and 14" piping sections are modeled. The model is input into RELAP5 code which is an industry standard program for modeling compressible flow in piping. At 1% reactor thermal power, the required vent capacity is 147,783 lbm/hour. Calculation Revision 0 Page 14 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 LM-709 verities that the piping can pass greater than 1% flow. Additional assumptions and modeling details are contained in Calculation LM-709.

The decay heat absorbing capacity of the suppression pool and the selection of venting pressure were made such that the HCVS will have sufficient capacity to maintain containment pressure at or below the lower of the containment design pressure PCPL. This calculation of containment response is contained in calculation LM-0709 that was submitted in Reference 28 and shows that containment is maintained below the design pressure once the vent is opened, even if it is not opened until PCPL is reached.

1.2.2 The HCVS shall discharge the effluent to a release point above main plant structures.

Evaluation The HCVS vent pipe release point to the outside atmosphere is at an elevation that is higher than the adjacent power block structures. The 14" diameter HCVS vent pipe runs vertically outside of the RE above the South Stack and extends approximately 4 feet above the roof of the South Stack Instrument Room (El. 426'). The release point is on the south side of the RE. Since the effluent release velocity of the vent exceeds 8000 fpm (Reference 45), then it is assured that the effluent plume will not be entrained into the recirculation zone of the RE and CE, or LGS Units 1 and 2 ventilation systems, and open doors used for natural circulation in the BDBEE/severe accident response. The routing of the vent pipe and the location of the release point has been established to minimize the radiological impact on plant operators and off-site help arriving at the plant. The HCVS vent pipe design meets the standard for a risk-informed approach to evaluate the threat posed to exposed portions of the HCVS vent pipe by wind-borne missiles, as provided in HCVS-WP-04. The HCVS vent pipe design meets the criteria set forth in HCVS-WP-04:

a. The exposed portion of vent pipe is greater than 30 feet above grade. (Reference 47 and 50)

b. The target area of that portion of pipe not housed in a missile protected structure is less than 300 ft 2 . (Reference 50)

c. The vent pipe is substantial and robust.

d. There is no source of obvious potential missiles in the proximity.

Based on the above description of the vent pipe design, the LGS HCVS vent pipe design meets the order requirement to be robust with respect to all external hazards including wind-borne missiles.

1.2.3 The HCVS shall include design features to minimize unintended cross flow Revision 0 Page 15 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 of vented fluids within a unit and between units on the site.

Evaluation The HCVS for Units 1 & 2 are fully independent of each other.

Therefore, the status at each unit is independent of the status of the other unit.

The HCVS design has effectively eliminated the cross flow of fluids and gases, from the HCVS into other systems or buildings. The HCVS vent pipe has been designed with two PCIVs, in series, in compliance with GDC-56. The valves are located outside of primary containment, as close to the suppression pool air space attached piping as practical and are normally held closed by their actuator spring. Furthermore, to prevent inadvertent opening, the PCIVs are isolated from their motive force supply by locked closed manual valves and require manual operation of a key-lock control switch at the primary operating station in the MCA to provide 125 Vdc control power to HCVS components including PCIVs. The PCIVs and vent pipe have been designed and procured as fully qualified components for their use in the HCVS. HCVS for any LGS Unit is free of physical and control interfaces with the opposite LGS Unit plant system. The vent pipe, adjacent to the PCIVs, has been designed with test connections to facilitate periodic Appendix J testing of the PCIVs, in compliance with GDC-54.

(Reference 47, 46, 49, 51, and 59)

The existing PCIVs on the Containment Atmospheric Control (CAC) piping which the Unit 2 HCVS ties into are already exposed to design basis and beyond design basis conditions even without the installation of the new HCVS piping and PCIVs. Therefore, no new system boundaries are created.

Based on the above description, the LGS design meets the requirements to minimize unintended cross-flow of vented fluids within a unit and between units on site.

1.2.4 The HCVS shall be designed to be manually operated during sustained operations from a control panel located in the main control room or a remote but readily accessible location.

Evaluation HCVS design allows for remote manual operation of the system. HCVS can be aligned by opening pneumatic and purge manual isolation valves at the ROS. (Reference 47 and 50)

Attachment 6 shows the location of ROS and MCA. Table 2 contains a list Revision 0 Page 16 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 and evaluation of the HCVS required actions. These evaluations demonstrate that the design meets the requirement to be manually operated from a readily accessible location during sustained operation.

1.2.5 The HCVS shall be capable of manual operation (e.g., reach-rod with hand wheel or manual operation of pneumatic supply valves from a shielded location), which is accessible to plant operators during sustained operations.

Evaluation To meet the requirement for an alternate means of operation, the ROS has been located in the Diesel Corridor. The pneumatic supply valves are in a readily accessible at the ROS. The ROS contains manually operated valves that supply pneumatics to the HCVS flow path valve actuators so that these valves may be opened without power to the valve actuator solenoids and regardless of any containment isolation signals that may be actuated. This provides a diverse method of valve operation, improving system reliability.

The location for the ROS is in the respective units Diesel Generator Corridor south of the REs. The ROS is located outside of the RE and removed from the outside portion of the HCVS vent pipe by more than 100 ft and concrete walls. Refer to the sketch provided in Attachment 6 for the HCVS site layout. The controls available at the ROS location are accessible and functional under a range of plant conditions, including severe accident conditions with due consideration to source term and dose impact on operator exposure, extended loss of AC power (ELAP),

inadequate containment cooling, and loss of RE ventilation. Table 1 contains an evaluation of all the required controls and instruments that are required for severe accident response and demonstrates that all these controls and instruments will be functional during a loss of AC power and severe accident. Table 2 contains a thermal and radiological evaluation of all the operator actions that may be required to support HCVS operation during a loss of AC power and severe accident and demonstrates that these actions will be possible without undue hazard to the operators.

Attachment 6 contains a site layout showing the location of these HCVS actions.

1.2.6 The HCVS shall be capable of operating with dedicated and permanently installed equipment for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the loss of normal power or loss of normal pneumatic supplies to air operated components during an extended loss of AC power.

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Final Integrated Plan HCVS Order EA-13-109 Evaluation HCVS-WP-01 contains clarification on the definition of "dedicated and permanently installed" with respect to the order. In summary, it is acceptable to use plant equipment that is used for other functions, but it is not acceptable to credit portable equipment that must be moved and connected for the first 24-hour period of the ELAP.

HCVS design consists of a fully dedicated and permanently installed system of components that are capable of operating for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . When required to be in operation, HCVS operates independent of any other plant system. The system is designed for multiple vent and purge cycles during the first 24-hour period without the need to recharge pneumatic and electrical power supplies. Additional gas bottles are readily available for installation to support sustained operation beyond the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . HCVS controls and indications have been designed to meet the requirement for monitoring system status to support sustained operations during an Extended Loss of AC Power (ELAP). The MCR is provided with a primary operating station, equipped with manually operated control switches for system operation, valve position indicating lights, and indicators that will display purge pneumatic supply pressure, HCVS vent temperature, and HCVS vent radiation. Local gauges and indicators at the ROS provide indication of purge pneumatic supply and discharge pressure, valve motive force pneumatic supply and discharge pressure. The battery charger located at the ROS provides voltage indication for the dedicated HCVS batteries. Controls and indications are powered by a bank of dedicated batteries that can provide power for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Primary back up power, to support sustained operation, is provided by the FLEX diesel generator. (Reference 46 to 51 and Reference 59) 1.2.7 The HCVS shall include a means to prevent inadvertent actuation.

Evaluation HCVS design precludes inadvertent actuation of the system the system through passive design features. The HCVS vent pipe has been designed with two PCIVs, in series, in compliance with GDC-56. The PCIVs are operated independent of other components, thereby precluding inadvertent actuation by a single component failure or misalignment. Each PCIV isolates the vent line through its normally held closed actuator spring. A rupture disk is installed downstream of the PCIVs. Furthermore, to prevent inadvertent opening, the PCIVs are isolated from their motive pneumatic supply by locked closed manual valves. Similarly, purge gas supply is isolated from the vent line by locked closed manual valve and a locked closed manual valve to bypass the primary operating station. Additionally, Revision 0 Page 18 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 the control panel in the MCR has a key locked power switch, which controls power for the HCVS system and prevents power to the PCIV and argon purge valves. Since there are no interfacing systems downstream of the PCIVs, no inadvertent venting cross flow can occur. Additionally, for Unit 2, the existing CAC PCIVs are fail closed. (Reference 46 to 51 and Reference 59) 1.2.8 The HCVS shall include a means to monitor the status of the vent system (e.g., valve position indication) from the control panel required by 1.2.4. The monitoring system shall be designed for sustained operation during an extended loss of AC power.

Evaluation HCVS controls and indications have been designed to meet the requirement for monitoring system status to support sustained operations during an ELAP. The MCR is provided with a primary operating station, equipped with manually operated control switches for system operation, valve position indicating lights, and indicators that will display purge pneumatic supply pressure, HCVS vent temperature, and HCVS vent radiation. Local gauges and indicators at the ROS provide indication of purge pneumatic supply and discharge pressure, valve motive force pneumatic supply and discharge pressure. The battery charger located at the ROS provides voltage indication for the dedicated HCVS batteries.

Controls and indications are powered by a bank of dedicated batteries that can provide power for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Primary back up power, to support sustained operation during an ELAP, is provided by the FLEX diesel generator. This power source will provide power to the system, as well as, an installed HCVS battery charger, to re-charge the batteries. This ensures power to PCIV controls and indication for the period of sustained operation. The controls and indication are and have been designed for the environmental and radiological effects of BOB/severe accident conditions.

(Reference 46 to 51 and Reference 59)

The HCVS instruments, including valve position indication, vent pipe temperature, radiation monitoring, and support system monitoring, are indicated in Table 1 and they include the ability to handle harsh environmental conditions (although they may not be considered part of the site Environmental Qualification (EQ) program.) All the components listed in Table 1 have been seismically qualified for their installed location.

1.2.9 The HCVS shall include a means to monitor the effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication from the control panel required by 1.2.4 and shall be designed for sustained operation during an Revision 0 Page 19 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 extended loss of AC power.

Evaluation The HCVS radiation monitoring system consists of element local to the HCVS vent pipe, and a monitor located in the MCA on panel. This system is used to monitor vent pipe radiation as a gross instrumentation means to verify venting. The RM element is fully qualified for the expected environment at the vent pipe during accident conditions, and the monitor is qualified for the mild environment in the MCA. Both components are qualified for the seismic requirements. Table 1 includes a description and qualification information on the radiation monitor. (Reference 48 and 50) 1.2.10 The HCVS shall be designed to withstand and remain functional during severe accident conditions, including containment pressure, temperature, and radiation while venting steam, hydrogen, and other non-condensable gases and aerosols. The design is not required to exceed the current capability of the limiting containment components.

Evaluation The wetwell vent up to, and including, the second containment isolation valve is designed consistent with the design basis of the plant. These items include piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication components.

HCVS has been designed to fulfill its design function and withstand the effects of BDBEE/severe accident conditions. The HCVS piping and components have been selected based on their ability to withstand the pressure, temperature and radiation expected. The vent line and components subjected to venting pressure have been designed to a pressure equal to the PCPL. The piping and associated components have been designed to withstand the dynamic loading resulting from the actuation of the system during multiple venting cycles. A purge gas (argon) supply system has been provided to displace potentially flammable/denotable mixtures of gases that may be present in the vent after system actuation. (Reference 46 to 51 and Reference 59)

HCVS provides sufficient venting capacity to prevent a long-term overpressure failure of the containment by keeping the containment pressure below the containment design pressure. HCVS has the capacity to vent the steam/energy equivalent of 1 percent of licensed/rated thermal power. (Reference 45) The HCVS piping and components have been selected based on their ability to withstand the pressure and temperature expected during a BOB/severe accident.

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Final Integrated Plan HCVS Order EA-13-109 HCVS equipment required for operation of the vent system has been located in areas of the plant where impact from environmental conditions will be minimal. The equipment that comprises the system is selected to withstand the environmental conditions to which they will be subjected and their ability to withstand the pressure and temperature expected during a severe accident. HCVS components are protected from the effects of tornado winds.

HCVS is designed consistent with the design basis of the plant up to the second containment isolation barrier. All suppression pool air space attached piping has been analyzed for seismic loading using the Primary Containment Structure seismic spectra from Specification G-019 and including applicable hydrodynamic load cases for containment attached piping to the first structural anchor. The remaining HCVS piping was evaluated using the Adjacent Structure (Reactor Enclosure) for seismic spectra. All of the new HCVS components, solely dedicated to HCVS operation, including pneumatic supplies, batteries, and control panels, are designed to the seismic design requirements of LGS and are evaluated as Seismic I systems. The MCR, where the primary operating station is located, is classified as a Seismic Category I area. The ROS is located in the Seismic Category I EOG Corridor.

1.2.11 The HCVS shall be designed and operated to ensure the flammability limits of gases passing through the system are not reached; otherwise, the system shall be designed to withstand dynamic loading resulting from hydrogen deflagration and detonation.

Evaluation HCVS has been designed to ensure the flammability limits of gases passing through the system are not reached. The vent piping is routed with a continuously upward slope. A purge gas (argon) supply system has been provided to displace potentially flammable/denotable mixtures of gases that may be present in the vent after system actuation. The purge gas supply system is designed for four purge cycles during the first 24-hour period without the need to recharge. The argon purge system is utilized to provide the pressure needed to burst the rupture disc, which has been considered as part of the volume of argon gas. Therefore, considerations of dynamic loading, resulting from hydrogen deflagration and detonation on the vent piping is not required.

The use of a purge system meets the requirement to ensure the flammability limits of gases passing through the vent pipe will not be reached.

The HCVS design has effectively eliminated the cross flow of fluids and Revision 0 Page 21 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 gases, from the HCVS into other systems or buildings. The HCVS has been designed with two PCIVs, in series, which are located outside of primary containment, as close to the suppression pool air space attached piping as practical. The vent pipe, adjacent to the PCIVs, has been designed with branch connections to facilitate periodic Appendix J testing of the PCIVs, ensuring leakage of flammable gases remain very low. The vent pipe has also been designed with a branch connection to facilitate the introduction of an inert gas purge. HCVS is designed for multiple venting and purge cycles during the first 24-hour period. Purging the vent line following each venting cycle will eliminate the combustible gases and render the line free of any detonable gas mixture. As a result, oxygen infiltration resulting from steam collapse is not a concern. The portion of the line between the PCIVs is steam inerted, such that any combustible gas is below the flammability limit. (Reference 60 and 56) 1.2.12 The HCVS shall be designed to minimize the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

Evaluation The response under Order element 1.2.3 explains how the potential for hydrogen migration into other systems, the RE or other buildings is minimized.

1.2.13 The HCVS shall include features and provisions for the operation, testing, inspection and maintenance adequate to ensure that reliable function and capability are maintained.

Evaluation:

As endorsed in the ISG, sections 5.4 and 6.2 of NEI 13-02 provide acceptable method(s) for satisfying the requirements for operation, testing, inspection, and maintenance of the HCVS.

Primary and secondary containment required leakage testing is covered under existing design basis testing programs. The HCVS outboard the containment boundary shall be tested to ensure that vent flow is released to the outside with minimal leakage, if any, through the interfacing boundaries with other systems or units.

LGS implemented operation, testing, and inspection requirements for the HCVS and SAWA that follows the existing plant procedures and process to ensure reliable operation of the systems. The existing plant maintenance program is applied to the HCVS and SAWA valves, instead of the maintenance frequency that has been listed in NEI 13-02, Section 6.2.4.

The maintenance program uses PCM (Performance Centered Revision 0 Page 22 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Maintenance) templates, which are used to develop preventive maintenance tasks to maintain the plant's components.

2. HCVS Quality Standards:

2.1. The HCVS vent path up to and including the second containment isolation barrier shall be designed consistent with the design basis of the plant. Items in this path include piping, piping supports, containment isolation valves, containment isolation valve actuators, and containment isolation valve position indication components.

Evaluation:

The HCVS components are selected to ensure system reliability and functionality, through the quality of design and materials. The HCVS vent path up to and including the second containment isolation barrier is designed and procured as suitable for the BDBEE/severe accident environmental and process conditions, and HCVS mission time. The components incorporated in this portion of the system design are designed to the seismic design requirements of the plant and are evaluated as a Seismic I system. All suppression pool air space attached piping, which includes a segment of the HCVS piping downstream of the second containment isolation barrier, is designed as ASME Section Ill, Class 2 piping.

This is consistent with the existing design basis of the plant. Electrical power to HCVS components is supplied from a dedicated battery and does not impact existing Class 1E station battery system. The HCVS battery charger is supplied electrical power from an existing Class 1E MCC and will be shunt tripped on a LOCA signal. There is a minimal impact on Class 1E MCC loading during normal operating mode of the plant. All documentation and analyses supporting the quality of system design is maintained in the site document control system.

(Reference 46 to 51 and Reference 59) 2.2. All other HCVS components shall be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. These items include electrical power supply, valve actuator pneumatic supply, and instrumentation (local and remote) components.

Evaluation:

The HCVS components were selected to ensure system reliability and functionality, through the quality of design and materials. All HCVS components are designed and procured as suitable for the BDBEE/severe accident environmental and process conditions, and HCVS mission time. The HCVS vent path up to and including the second containment isolation valve are designed consistent with the design basis of the current containment isolation systems. All other HCVS components have been procured and designed for reliable and rugged performance. All of the new HCVS components, solely dedicated to HCVS operation, including pneumatic supplies, batteries, and control panels, are procured with augmented requirements, designed to the seismic design requirements of the Revision 0 Page 23 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 plant and are evaluated as a Seismic Category I system. Vent piping beyond the second containment isolation valve (the outboard PCIV) is designed to ANSl/ASME 831.1 and Seismic Category I criteria. The application of ANSl/ASME 831.1 is consistent with the site design basis and the code of record. (Reference 46 to 51 and Reference 59)

Section IV: HCVS Phase 2 Final Integrated Plan Section IV.A: The requirements of EA-13-109, Attachment 2, Section B for Phase 2

Licensees with 8WRs Mark 1 and Mark II containments shall either:

(1) Design and install a HCVS, using a vent path from the containment drywell, that meets the requirements in section 8.1 below, or (2) Develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell before alternate reliable containment heat removal and pressure control is reestablished and meets the requirements in Section 8.2 below.

1. HCVS Drywell Vent Functional Requirements 1.1 The drywell venting system shall be designed to vent the containment atmosphere (including steam, hydrogen, non-condensable gases, aerosols, and fission products), and control containment pressure within acceptable limits during severe accident conditions.

1.2 The same functional requirements (reflecting accident conditions in the drywell),

quality requirements, and programmatic requirements defined in Section A of this Attachment for the suppression pool venting system shall also apply to the drywell venting system.

2. Containment Venting Strategy Requirements Licensees choosing to develop and implement a reliable containment venting strategy that does not require a reliable, severe accident capable drywell venting system shall meet the following requirements:

2.1 The strategy making it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions shall be part of the overall accident management plan for Mark I and Mark 11 containments.

2.2 The licensee shall provide supporting documentation demonstrating that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.

2.3 Implementation of the strategy shall include licensees preparing the necessary Revision 0 Page 24 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 procedures, defining and fulfilling functional requirements for installed or portable equipment (e.g., pumps and valves), and installing needed instrumentation.

Because the order contains just three requirements for the containment venting strategy, the compliance elements are in NEI 13-02, Revision 1. NEI 13-02, Revision 1, endorsed by NRC in JLD-ISG-2015-01, provides the guidance for the containment venting strategy (B.2) of the order. NEI 13-02, Revision 1, provides SAWA in conjunction with Severe Accident Water Management (SAWM), which is designed to maintain the suppression pool vent in service until alternate reliable containment heat removal and pressure control are established, as the means for compliance with part B of the order.

LGS has implemented Containment Venting Strategy (B.2), as the compliance method tor Phase 2 of the Order and conforms to the associated guidance in NEI 13-02 Revision 1 for this compliance method.

Section IV.B: HCVS Existing System There previously was neither a hardened drywell vent nor a strategy at LGS that complied with Phase 2 of the order.

Section IV.C: HCVS Phase 2 SAWA System and SAWM Strategy The HCVS Phase 2 SAWA system and SAWM strategy utilize the FLEX mitigation equipment and strategies to the extent practical. This approach is reasonable because the external hazards and the event initiator (ELAP) are the same for both FLEX mitigation strategies and HCVS. For SAWA, it is assumed that the initial FLEX response actions are unsuccessful in providing core cooling such that core damage contributes to significant radiological impacts that may impede the deployment, connection and use of FLEX equipment. These radiological impacts, including dose from containment and HCVS vent line shine were evaluated and modifications made as necessary to mitigate the radiological impacts such that the actions needed to implement SAWA and SAWM are feasible in the timeframes necessary to protect the containment from overpressure related failure. To the extent practical, the SAWA equipment, connection points, deployment locations and access routes are the same as the FLEX primary strategies so that a Unit that initially implements FLEX actions that later degrades to severe accident conditions can readily transition between FLEX and SAWA strategies. This approach further enhances the feasibility of SAWA under a variety of event sequences including timing.

LGS has implemented the containment venting strategy utilizing SAWA and SAWM. The SAWA system consists of a FLEX (SAWA) pump injecting into the Reactor Pressure Vessel (RPV) and SAWM consists of flow control at the FLEX (SAWA) pump along with instrumentation and procedures to ensure that the suppression pool vent is not submerged (SAWM). Procedures have been issued to implement this strategy. This strategy has been shown via Modular Accident Revision 0 Page 25 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Analysis Program (MAAP) analysis to protect containment without requiring a drywell vent for at least seven days which is the guidance from NEI 13-02 for the period of sustained operation.

Section IV.C.1: Detailed SAWA Flow Path Description The SAWA flow path is the same as the FLEX primary injection path. The SAWA system, shown on Attachment 4, consists of a FLEX pump injecting into the Reactor Pressure Vessel (RPV) and SAWM consists of flow control at the FLEX pump along with suppression pool level indication to ensure that the suppression pool vent is not submerged (SAWM). The SAWA injection path, starts at the Spray Pond, goes to the FLEX pump via suction hoses, goes through the FLEX pump to a flexible discharge hose, then to the RHRSW piping near RHRSW pumps. From there the flow is going into the RE. In the RE the flow bypassing AHR heat exchangers via AHR valves to the RPV through AHR Low Pressure Coolant Injection valve (LPCI) valve (Reference 37). The hoses and pumps are stored in the FLEX Pump Storage Building (FPSB) which is protected from all hazards.

BWROG generic assessment, BWROG-TP-15-008, provides the principles of Severe Accident Water Addition to ensure protection of containment. This SAWA injection path is qualified for the all the screened in hazards (Section Ill) in addition to severe accident conditions.

Section IV.C.2: Severe Accident Assessment of Flow Path The actions inside the RE where there could be a high radiation field due to a severe accident will be to manipulate valves, perform load shedding and other activities in various locations. The FLEX (SAWA) pump deployment time is the same as the deployment time for FLEX. The action inside the RE can be performed before the dose is unacceptable, under the worst-case scenario within the first seven hours into the event. Procedures T-300 and T-301 direct accomplishment of actions without delay that must be done early in the severe accident event where there is a loss of all AC power and a loss of all high-pressure injection to the core. In this event, core damage is not expected for at least one hour and vessel breach for another six hours (assumed at T=7 hours after the ELAP) so that there will be no excessive radiation levels or heat related concerns in the RE when the actions are performed (Reference 56 and 39). The other SAWA actions beyond 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months all take place outside the RE at the MCA, Spray Pond, FLEX Generators, FPSB, and the deployment pathways. Since these locations are outside the RE, they are shielded from the severe accident radiation by the thick concrete walls of the RE. Once SAWA is initiated, the operators will monitor the response of containment from the MCA to determine that venting and SAWA are operating satisfactorily, maintaining containment pressure low to avoid containment failure. Stable or slowly rising trend in suppression pool level with SAWA at the minimum flow rate indicates water on the drywell floor up to the downcommer pipes. After some period of time, as decay heat levels decrease, the operators will be able to reduce SAWA flow to keep the core debris cool while avoiding overfill the suppression pool to the point where the suppression pool vent Revision 0 Page 26 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 is submerged.

Section IV.C.3: Severe Accident Assessment of Safety-Relief Valves LGS has methods available to extend the operational capability of manual pressure control using SRVs as provided in the plant specific order EA-12-049 submittal.

Section IV.C.4: Available Freeboard Use The freeboard between 23 feet normal level and 39 feet bottom of the suppression pool vent pipe in the suppression pool provides approximately 1,104,572 gallons of water volume before the water level reaches the bottom of the vent pipe (Reference 13). BWROG generic assessment BWROG-TP-15-011 (Reference 42), provides the principles of Severe Accident Water Management to preserve the suppression pool vent for a minimum of seven days. After containment parameters are stabilized with SAWA flow, SAWA flow will be reduced to a point where containment pressure will remain low while suppression pool level is stable or very slowly rising. As shown in calculation LG-MISC-018 (Reference 41 ), the suppression pool level will not reach the suppression pool vent for at least seven days. A diagram of the available freeboard is shown on Attachment 1.

Section IV.C.5: Upper range of wetwell level indication The upper range of suppression pool level indication provided for SAWA/SAWM is 39 feet water elevation. This defines the upper limit of suppression pool volume that will preserve the suppression pool vent function as shown in Attachment 1 .

Section IV.C.6: Wetwell vent service time The LG-MISC-018 demonstrate that throttling SAWA flow after containment parameters have stabilized, in conjunction with venting containment through the suppression pool vent will result in a stable or slowly rising suppression pool level.

The LG-MISC-018 demonstrate that for the scenario analyzed, suppression pool level will remain below the suppression pool vent pipe for greater than the seven days of sustained operation allowing significant time for restoration of alternate containment pressure control and heat removal.

Section IV.C.7: Strategy time line The overall accident management plan for LGS is developed from the BWR Owner's Group Emergency Procedure Guidelines and Severe Accident Guidelines (EPG/SAG). As such, the SAWA/SAWM implementing procedures are integrated into the LGS SAMPs. In particular, EPG/SAG Revision 3, have been implemented with Emergency Procedures Committee Generic Issue 1314, allows throttling of SAWA in order to protect containment while maintaining the suppression pool vent in service. The SAMP flow charts direct use of the hardened vent as well as Revision 0 Page 27 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 SAWA/SAWM when the appropriate plant conditions have been reached.

Using NEI 12-06 Appendix E, LGS has validated that the SAWA pump can be deployed and commence injection in less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The SAWA pump deployment location is the same as the FLEX deployment location. The studies referenced in NEI 13-02 demonstrated that establishing flow within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months will protect containment. The initial SAWA flow rate will be at least 500 gpm. After a period of time, estimated to be about 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , in which the maximum flow rate is maintained, the SAWA flow will be reduced. The reduction in flow rate and the timing of the reduction will be based on stabilization of the containment parameters of drywell pressure and suppression pool level.

LG-MISC-018 demonstrated that, SAWA flow could be reduced to 100 gpm after four hours of initial SAWA flow rate and containment would be protected. At some point suppression pool level will begin to rise indicating that the SAWA flow is greater than the steaming rate due to containment heat load such that flow can be reduced. While this is expected to be 4-6 hours, no time is specified in the procedures because the SAMPs are symptom-based guidelines.

Section IV.C.8: SAWA Flow Control LGS will accomplish SAWA flow control by the use of throttle valves and variation of pump speed. A flow meter mounted on the SAWA pumps allows monitoring of injection flow. The operators at the SAWA pump will be in communication with the MCR via the plant radio system or runners and the exact time to throttle flow is not critical since there is a large margin between normal suppression pool level and the level at which the suppression pool vent will be submerged. The communications capabilities that will be used for communication between the MGR and the SAWA flow control location are the same as that evaluated and found acceptable for FLEX strategies. The communications capabilities have been tested to ensure functionality at the SAWA flow control and monitoring locations.

(Reference 29)

Section IV.C.9: SAWA/SAWM Element Assessment Section IV.C.9.1: SAWA Pump LGS uses one portable diesel-driven pump per unit for FLEX and SAWA. All pumps are capable of delivering greater than 500 gpm at the pressures required for RPV injection during an ELAP. Each of these pumps has been shown to be capable of supplying the required flow rate to the RPV and the SFP for FLEX and for SAWA scenarios. (Reference 54) The pumps are stored in the FPSB where they are protected from all screened-in hazards and are rugged, over the road, trailer-mounted units, and therefore will be available to function after a seismic event.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.9.2: SAWA analysis of flow rates and timing LGS SAWA flow is 500 gpm which is the amount assumed in NEI 13-02 Section 4.1.1.2.1. The initial SAWA flow will be injecting to the RPV within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the loss of injection. The reference power level is 3514 MWth, equivalent to the reference plant rated thermal power level used in NUREG-1935, State of the Art Reactor Consequence Analysis (SOARCA). NUREG 1935 is Reference 9 of NEI 13-02 Revision 1 .

Section IV.C.9.3: SAWA Pump Hydraulic Analysis Calculation LM-0706 analyzed the FLEX pumps and the lineup for RPV injection that would be used for SAWA. This calculation showed that the pumps have adequate capacity to meet the SAWA flow rate required to protect containment.

Section IV.C.9.4: SAWA Method of backflow prevention The LGS SAWA flow path goes through a series of check valves. One on the FLEX pump and in the rest are in the RHR system. The RHR backflow prevention valve is also Primary Containment Isolation Valve (PCIV) whose integrity of check function (open and closed) is demonstrated by other plant testing requirements such that additional testing per NEI 13-02 Revision 1 Section 6.2 is not required for this valve per NEI 13-02 Revision 1 Table 6-1 Note 3. Thus, backflow is prevented by check valves in the SAWA flow path inside the RE.

Section IV.C.9.5: SAWA Water Source The source of water for SAWA is the spray pond which can provide water injection without makeup based on the FLEX analysis. This long-term strategy of water supply was qualified for order EA-12-049 response and is available during a severe accident. Therefore, there will be sufficient water for injection to protect containment during the period of sustained operation (Reference 58).

Section IV.C.9.6: SAWA/SAWM Motive Force Section IV.C.9.6.1: SAWA Pump Power Source The SAW A/FLEX pumps are stored in the FPSB where they are protected from all screened-in hazards. The SAWA pumps are commercial pumps rated for long-term outdoor use in emergency scenarios. The pumps are diesel-driven by an engine mounted on the skid with the pump. The pumps will be refueled by the FLEX refueling equipment that has been qualified for long-term refueling operations per EA-12-049. The action to refuel the SAWA pumps was evaluated under severe accident conditions in Table 2 and demonstrated to be acceptable. Since the pumps are stored in a protected structure, are qualified for the environment in which they will be used and will be refueled by following procedures from a protected fuel source, they will perform their function to maintain SAWA flow Revision 0 Page 29 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 needed to protect primary containment per EA-13-109.

Section IV.C.9.6.2: DG loading calculation for SAWA/SAWM equipment Table 1 shows the electrical power source for the SAWA/SAWM/FLEX instruments. For the instruments powered by the HCVS 125VDC battery, calculation LE-0128 (Reference 56) demonstrates that the batteries can provide power for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months until the FLEX generator restores power to the battery charger.

The FLEX load on the FLEX DG per EA-12-049 was evaluated (Reference 48 and 49). This EC computation demonstrated there is approximately 329A at 480Vac of margin to full load. There are no additional loads on the FLEX DG due to SAWA.

Therefore, the existing evaluation of the HCVS added the FLEX DG is bounding for SAWA.

Section IV.C.10: SAWA/SAWM Instrumentation Section IV.C.10.1: SAWA/SAWM instruments Table 1 contains a listing of all the instruments needed for SAWA and SAWM implementation. This table also contains the expected environmental parameters for each instrument and its power supply for sustained operation.

Section IV.C.10.2: Describe SAWA instruments and guidance The drywell pressure and suppression pool level instruments, used to monitor the condition of containment, are qualified for post-accident use. These instruments are referenced in Severe Accident Guidelines for control of SAWA flow to maintain the suppression pool vent in service while maintaining containment protection.

These instruments are powered by station batteries and will be re-powered by FLEX generator systems for the sustained operating period. These instruments are on buses included in the FLEX generator loading calculations for EA-12-049 (Reference 57). Note that other instrument indications may be available depending on the exact scenario.

The SAWA flow meter is an electromagnetic flow meter mounted in the piping on the pumps skid and powered by the pump's electrical system.

No containment temperature instrumentation is required for compliance with HCVS Phase 2. However, most FLEX electrical strategies repower other containment instruments. The drywell temperature is directly read from a portable thermocouple reader. These instruments provide information for the operations staff to evaluate plant conditions under a severe accident and to provide confirmation for adjusting SAWA flow rates. SAMP strategies will evaluate and use drywell temperature indication if available consistent with the symptom-based approach. NEI 13-02 Revision 1 Section C.8.3 discusses installed drywell temperature indication.

Revision 0 Page 30 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Section IV.C.10.3: Qualification of SAWA/SAWM instruments The evaluation of each instrument listed in Table 1 was performed in EC 622673 (Reference 31) that demonstrated qualification of each instrument for the expected accident environmental and radiological conditions.

Section IV.C.10.4: Instrument Power Supply through Sustained Operation LGS FLEX strategies will restore the containment instruments, containment pressure and suppression pool level, necessary to successfully implement SAWA.

The strategy will be to use the FLEX generator to re-power battery chargers before the batteries supplying the instruments are depleted. Since the FLEX generators are refueled per FLEX strategies for a sustained period of operation, the instruments will be powered for the sustained operating period.

Section IV.C.11: SAWA/SAWM Severe Accident Considerations The thermal and radiological accident conditions do not impact the personnel and equipment. The radiological accident conditions would not a affect personnel access to the MCR, travel paths, HCVS ROS or FLEX/SAWA pump operation location. The components or operators performing necessary actions for the SAWA/SAWM strategy are capable of completing the operator actions during the severe accident condition. The thermal and radiological evaluation of impacts on the installed or portable equipment and instrumentation credited for SAWA/SAWM and credited operator action is listed in Table 1 and Table 2 of this FIP. (Reference 31)

Section IV.C.11.1: Severe Accident Effect on SAWA Pump and Flowpath Since the SAWA pump is stored in the FPSB and will be operated from outside the RE, on the opposite side of the RE from the vent pipe, there will be no issues with radiation dose rates at the SAWA pump control location and there will be no significant dose to the SAWA pump. The hoses used to move water from the spray pond through the pump into the RHRSW in the spray pond pump house are also stored in the FPSB and will be deployed on the opposite side of the RE from the vent pipe. The hoses are qualified for the temperatures expected in the outside areas they will be run.

Inside the RE the SAWA flow path consists of AHR and RHRSW system piping.

The AHR and RHRSW system piping is steel which will remain unaffected by the radiation or elevated temperatures inside the RE. Therefore, the SAWA flow path will not be affected by radiation or temperature effects due to a severe accident.

Section IV.C.11.2: Severe Accident Effect on SAWA/SAWM instruments The SAWA/SAWM instruments are described in section IV.C.9.3, that section provides severe accident effects.

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Final Integrated Plan HCVS Order EA-13-109 Section IV.C.11.3: Severe Accident Effect on personnel actions Section IV.C.2 describes the RE actions within the first 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . The actions including access routes outside the Reactor Building that will be performed after the first use of the vent during severe accident conditions (assumed to be 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months per HCVS-FAQ-12) are located such that they are either shielded from direct exposure to the vent line or are a significant distance from the vent line so that expected dose is maintained below the ERO exposure guidelines.

Since, in the severe accident, the core materials are contained inside the primary containment, the temperature response of the RE and CB is driven by the loss of ventilation during the ELAP and ambient conditions and are acceptable for severe accident use within the first 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . Table 2 provides a list of SAWA/SAWM operator actions as well as an evaluation of each for suitability during a severe accident. Attachment 6 shows the approximate locations of the actions.

After the SAWA flow path is aligned inside the RE, the operators can control SAWA/SAWM as well as observe the necessary instruments from outside the RE.

The thick concrete RE walls as well as the distance to the core materials mean that there is no radiological concern with any actions outside the RE. Therefore, all SAWA controls and indications are accessible during severe accident conditions.

The SAWA pump and monitoring equipment can all be operated locally at the pump from outside the RE at ground level. The LGS FLEX response ensures that the SAWA pump, FLEX generators and other equipment can all be run for a sustained period by refueling. All the refueling locations are located in shielded or protected areas so that there is no radiation hazard from core material during a severe accident. The monitoring instrumentation includes SAWA flow at the pump, and suppression pool level and containment pressure in the MCR.

Section V: HCVS Programmatic Requirements Section V.A: HCVS Procedure Requirements Licensees shall develop, implement, and maintain procedures necessary for the safe operation of the HCVS. Procedures shall be established for system operations when normal and backup power is available, and during an extended loss of AC power.

Evaluation:

Procedures have been established for system operations when normal and backup power is available, and during ELAP conditions. The implementing design change documents contain instructions for modifying the HCVS specific procedures.

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Final Integrated Plan HCVS Order EA-13-109 The HCVS and SAWA procedures have been developed and implemented following LGS process for initiating and/or revising procedures and contain the following details:

appropriate conditions and criteria for use of the system

when and how to place the system in operation,

the location of system components,

instrumentation available,

normal and backup power supplies,

directions for sustained operation, including the storage location of portable equipment,

training on operating the portable equipment, and

testing portable equipment LGS has implemented the BWROG Emergency Procedures Committee Issue 1314 that implements the Severe Accident Water Management (SAWM) strategy in the Severe Accident Management Guidelines (SAMPs). The following general cautions, priorities and methods have been evaluated for plant specific applicability and incorporated as appropriate into the plant specific SAMPs using administrative procedures for EPG/SAG change control process and implementation. SAMPs are symptom-based guidelines and therefore address a wide variety of possible plant conditions and capabilities. While these changes are intended to accommodate those specific conditions assumed in Order EA-13-109, the changes were made in a way that maintains the use of SAMPs in a symptom-based mode while at the same time addressing those conditions that may exist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris.

Cautions

Addressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapid steam generation.

Addressing the plant impact that raising suppression pool water level above the elevation of the suppression chamber vent opening elevation will flood the suppression chamber vent path.

Priorities -With significant core damage and RPB breach, SAMPs prioritize the preservation of primary containment integrity while limiting radioactivity releases Revision 0 Page 33 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 as follows:

Core debris in the primary containment is stabilized by water addition (SAWA).

Primary containment pressure is controlled below the Primary Containment Pressure Limit (Suppression pool venting).

Water addition is managed to preserve the Mark II suppression chamber vent paths, thereby retaining the benefits of suppression pool scrubbing and minimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM).

Methods - Identify systems and capabilities to add water to the RPV or drywell, with the following generic guidance:

Use controlled injection if possible.

Inject into the RPV if possible.

Maintain injection from external sources of water as low as possible to preserve the suppression chamber vent capability.

Section V.B: HCVS Out of Service Requirements Provisions for out-of-service requirements of the HCVS and compensatory measures have been added to the site FLEX program document, CC-LG-118 (Reference 32) so that it is with the FLEX out-of-service program.

Programmatic controls have been implemented to document and control the following:

NOTE: Out of service times and required actions noted below are for HCVS and SAWA functions. Equipment that also supports a FLEX function that is found to be non-functional must also be addressed using the out of service times and actions in accordance with the FLEX program.

The provisions for out-of-service requirements for HCVS and SAWA functionality are applicable in Modes 1, 2, and 3 per NEI 13-02, 6.3.

If for up to 90 consecutive days, the primary or alternate means of HCVS operation are non-functional, no compensatory actions are necessary.

If up for to 30 days, the primary and alternate means of HCVS operation or SAWA are non-functional, no compensatory actions are necessary.

If the out of service times projected to exceed 30 or 90 days as described Revision 0 Page 34 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 above, the following actions will be performed through the corrective action system determine:

o The cause(s) of the non-functionality, o The actions to be taken and the schedule for restoring the system to functional status and prevent recurrence, o Initiate action to implement appropriate compensatory actions, and o Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle.

The HCVS system is functional when piping, valves, instrumentation and controls including motive force necessary to support system operation are available. Since the system is designed to allow a primary control and monitoring or alternate valve control by Order criteria 1.2.4 or 1.2.5, allowing for a longer out of service time with either of the functional capabilities maintained is justified. A shorter length of time when both primary control and monitoring and alternate valve control are unavailable is needed to restore system functionality in a timely manner while at the same time allowing for component repair or replacement in a time frame consistent with most high priority maintenance scheduling and repair programs, not to exceed 30 days unless compensatory actions are established per NEI 13-02 Section 6.3.1.3.3.

SAWA is functional when piping, valves, motive force, instrumentation and controls necessary to support system operation are functional.

The system functionality basis is for coping with beyond design basis events and therefore plant shutdown to address non-functional conditions is not warranted.

However, such conditions should be addressed by the corrective action program and compensatory actions to address the non-functional condition should be established. These compensatory actions may include alternative containment venting strategies or other strategies needed to reduce the likelihood of loss of fission product cladding integrity during design basis and beyond design basis events even though the severe accident capability of the vent system is degraded or non-functional. Compensatory actions may include actions to reduce the likelihood of needing the vent but may not provide redundant vent capability.

Applicability for allowed out of service time for HCVS and SAWA for system functional requirements is limited to startup, power operation and hot shutdown conditions when primary containment is required to be operable and containment integrity may be challenged by decay heat generation.

Section V.C: HCVS Training Requirements Licensee shall train appropriate personnel in the use of the HCVS. The training Revision 0 Page 35 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 curricula shall include system operations when normal and backup power is available, and during an extended loss of AC power.

Evaluation:

Personnel expected to perform direct execution of the HCVS have received necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS. The personnel trained, and the frequency of training was determined using a systematic analysis of the tasks to be performed using the Systems Approach to Training (SAT) process.

In addition, per NEI 12-06, any non-trained personnel on-site will be available to supplement trained personnel.

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Final Integrated Plan HCVS Order EA-13-109 Section V.D: Demonstration with other Post Fukushima Measures LGS will demonstrate use of the HCVS and SAWA systems in drills, tabletops or exercises as follows:

1. Hardened containment vent operation on normal power sources (no ELAP).

2. During FLEX demonstrations (as required by EA-12-049: Hardened containment vent operation on backup power and from primary or alternate locations during conditions of ELAP/loss of UHS with no core damage.)

System use is for containment heat removal AND containment pressure control.

3. HCVS operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with core damage. System use is for containment heat removal AND containment pressure control with potential for combustible gases.

Evaluation NOTE: Items 1 and 2 above are not applicable to SAWA.

The use of the HCVS and SAWA capabilities will be demonstrated during drills, tabletops or exercises consistent with NEI 13-06 and on a frequency consistent with 10 CFR 50.155(e)(4). LGS will perform the first drill demonstrating at least one of the above capabilities by April 2022 which is within four years of the first unit compliance with Phase 2 of Order EA-13-109, or consistent with the next FLEX strategy drill or exercise. Subsequent drills, tabletops or exercises will be performed to demonstrate the capabilities of different elements of Items 1, 2 and/or 3 above that is applicable to LGS in subsequent eight-year intervals.

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Final Integrated Plan HCVS Order EA-13-109 Section VI: References Number Rev Title Location 1

1. GL-89-16 0 Installation of a Hardened Wetwell Vent ML031140220 (Generic Letter 89-16), dated September 1, 1989.

2. SECY-12-0157 0 Consideration of Additional Requirements for ML12345A030 Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments

3. SRM-SECY 0 Staff Requirements - SECY-12-0157 - ML13078A017 0157 Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments

4. EA-12-050 0 Order to Modify Licenses with Regard to ML12054A694 Reliable Hardened Containment Vents

5. EA-13-109 0 Order to Modify Licenses with Regard to ML13143A321 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

6. NEI 13-02 0 Industry Guidance for Compliance with Order M L13316A853 EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

7. NEI 13-022 1 Industry Guidance for Compliance with Order ML151138318 EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

8. HCVS-WP-01 0 Hardened Containment Vent System ML14120A295 Dedicated and Permanently Installed Motive ML14126A374 Force, Revision 0, April 14, 2014

9. HCVS-WP-02 0 Sequences for HCVS Design and Method for ML14358A038 Determining Radiological Dose from HCVS ML14358A040 Piping, Revision 0, October 23, 2014

10. HCVS-WP-03 1 Hydrogen/Carbon Monoxide Control ML14302A066 Measures Revision 1 October 2014 ML15040A038 11 . HCVS-WP-04 0 Missile Evaluation for HCVS Components 30 ML15244A923 Feet Above Grade ML15240A072 1

Where two ADAMS accession numbers are listed, the first is the reference document and the second is the NRC endorsement of that document.

2 NEI 13-02 Revision 1 Appendix J contains HCVS-FAQ-01 through HCVS-FAQ-09.

Revision 0 Page 38 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location 1

12. JLD-ISG-2013- 0 Compliance with Order EA-13-109, Order ML133048836 02 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

13. JLD-ISG-2015- 0 Compliance with Order EA-13-109, Order ML15104A118 01 Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

14. HCVS-FAQ-10 1 Severe Accident Multiple Unit Response ML15273A141 ML15271A148

15. HCVS-FAQ-11 0 Plant Response During a Severe Accident ML15273A141 ML15271A148

16. HCVS-FAQ-12 0 Radiological Evaluations on Plant Actions ML15273A141 Prior to HCVS Initial Use ML15271A148

17. HCVS-FAQ-13 0 Severe Accident Venting Actions Validation ML15273A141 ML15271A148

18. Overall 0 Overall Integrated Plan in Response to March ML13059A267 Integrated Plan 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents (Order Number EA-12-050).

19. Combined OIP 0 Combined HCVS Phase 1 and 2 Overall ML14181A418 Integrated Plan (OIP)

20. Combined OIP 0 Combined HCVS Phase 1 (Updated) and 2 ML15364A014 Phase 1 Overall Integrated Plan (OIP)

(Updated) &

Ph::i~A 2

21. Phase 1 & 0 HCVS Phase 1 & Phase 2 Interim Staff ML15082A433 Phase 2 ISE Evaluation (ISE)

22. Phase 2 ISE 0 HCVS Phase 2 Interim Staff Evaluation (ISE) ML16116A320

23. 1st Update 0 First Six-Month Update ML14353A110

24. 2nd Update 0 Second Six-Month Update ML15181A016

25. 3rd Update 0 Third Six-Month Update ML18081A195

26. 4th Update 0 Fourth Six-Month Update ML16182A011

27. 5th Update 0 Fifth Six-Month Update ML16350A266

28. 5th Update 0 Sixth Six-Month Update ML17181A031

29. 7th Update 0 Seventh Six-Month Update ML17349A035

30. Compliance 0 HCVS Phase 1 and Phase 2 compliance ML18159A142 Letter letter Revision 0 Page 39 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location 1

31. EC 622673 1 Temperature, Humidity and Radiological N/A Evaluation HCVS & SAWA

32. CC-LG-118 5 Site Implementation of Diverse and Flexible N/A Coping Strategies (FLEX) and Spent Fuel Pool Instrumentation Program

33. NEI 12-06 0 Diverse and Flexible Coping Strategies ML12221A205 (FLEX) Implementation Guide

34. EA-12-049 0 Issuance of Order to Modify Licenses With ML12054A735 Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.

35. RG 1.97 3 Instrumentation for Light-Water-Cooled ML003740282 Nuclear Power Plants to Assess Conditions During and Following an Accident

36. TR-1026539 0 EPRI Investigation of Strategies for Mitigating N/A Radiological Releases in Severe Accidents BWR, Mark I and Mark II Studies, October 2012

37. EC 622483 0 Evaluation of Potential SAWA Diversionary N/A Flow Paths

38. RS-15-301 N/A Exelon Generation Company, LLC Phase 1 N/A (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 109), dated December 15, 2015

39. LM-0725 1 FLEX Activity and HCVS Phase 2 Dose N/A Assessment

40. RS-18-051 0 Report of Full Compliance with March 12, N/A 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis

41. LG-MISC-018 0 MAAP Analysis to Support HCVS Design N/A

42. BWROG-TP 0 Severe Accident Water Management N/A 011 Supporting Evaluations

43. LM-0728 0 Hardened Containment Vent Purge System Design Calculation

44. M-0057 Sheet 8 0 P&ID Containment Hardened Vent (Unit 1) N/A Revision 0 Page 40 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Number Rev Title Location 1

45. LM-0709 1 Limerick Hardened Containment Vent N/A Capacity

46. EC 423281 1 2R14 MOD: Fukushima Hardened Vent - N/A Outage Tie-In to Wetwell

47. EC 423382 2 1R17 MOD: Fukushima Hardened Vent - N/A Outage Tie-In to Wetwell

48. EC 423333 4 2R14 MOD - Fukushima Hardened Vent - N/A Online Elect/l&C Work

49. EC 423381 5 1R17 MOD - Fukushima Hardened Vent - N/A Online Work

50. EC 423281 1 2R14 MOD: Fukushima Hardened Vent - N/A Outage Tie-In to Wetwell

51. EC 422831 3 UNIT 2 HCVS Safeguards Room I Train Bay N/A Large Bore Piping

52. T-301 Unit 1 4 RPV Injection from Spray Pond N/A T-301 Unit 2 5

53. LM-0721 1 Hardened Containment Vent System Dose N/A Assessment

54. LM-0706 3 Fukushima FLEX Hydraulic Analysis N/A

55. T-300 3 FLEX Pump Setup at Spray Pond N/A

56. LE-0128 0 HCVS Battery and Battery Charger Sizing N/A

57. ECR 14-00019 1 Fukushima-FLEX - Electrical Engineering Modification

58. EC 622482 0 Evaluation of the Spray Pond Water N/A Inventory for SAWA

59. EC 423331 2 2R14 MOD - Fukushima Hardened Vent - N/A Online Elect/l&C Work

60. T-360 3 Diesel Fuel Transfer from EOG Day Tank or N/A DIG Fuel Tank for Flex Equipment.

Revision 0 Page 41 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 1: Phase 2 Freeboard diagram I

Dow, ~comer Spillover 1' - 6" Top of Level Instrumentation

~

t f

~*

II -- . *--;

1- r ,_

-~ r-

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50'-0" l tSS of HCVS Function 39' - o*

Normal Water level 23'-0"

~ -..... ~ .

SAWAln jection Flow Rates 4 hr at 500 gpm 164 hou It 100gpm

. ~

Rate of c .. nge in Wetwell

soogpm :-

1oogpm .. ..

Total 1.104.

.. . . . . ... . . .a SAWMF *

. ,~. . . ..

0oes not .-

steam leaveing containment through wetwell vent path Not To Scale Revision 0 Page 42 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 2: One Line Diagram of HCVS Vent Path (Unit 1 shown, Typical Unit 2) (Reference 44)

~1 W:- .. ~k~~ I ~..-:;

L1 -' *r..,.ui ,...,.,u .J L _J L

., r

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., r ., r ., r ., r

..=...

I Revision 0 Page 43 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 3: One Line Diagram of HCVS Electrical Power Supply {Unit 1 shown, Unit 2 typical) (Reference 48 and 59)

DIESEL GENERAT:J.~ REACTOR c.

--- E.NCLOSURE ___ _ EN-CLOSURE UN IT 1 MCR E- 12 D.

1( MCC R:IQU 311*

EL. 2- r y 269' 0 1?.4 G-1 1 lBACKFD 8Y FLEX DCI C<JmlD:lR £1.. 2't r'-a*

llOD1 lU r---------------------~

I I

I I 125VDC I BATTERY I vnu TYPE I 6-50005 I iO CCI.LS 10-0101

__________ ...III

...°l~:.i'"m t.ICR tlCVS PANEL 1 O-C689 IMstCtt&

ARGO>I VENT DISCltAJIGf.

lEIAPl::flAiURC PllGSSl1'1£ lNOJCATION !NO!ClllON TJ-057Y-1DI PHJSlV-130 II PJJ---------t-----.

2$Vi)(;

O.\TT£RY Clt~R 1a ~ rno2 l'IB OCTB PC!V PCIV PDS PDS

!NOICATIDN INOIClTIDN C R 1z5 voe PURGE 51.FCGUAAO SYSTEM AEA P!JYOI CllHTRO:. COllTRCt.

RIXIN 309 JIS--c5TV-lt!2 r----------*------,

I I

I Ol!T50 PCIV POSITION HV-057V-181 l!r RY--<15"Y-101 HtVS RAD IOllTCR WITH

£/ S-OSTV-<lOS INDICATION INBD PCIV !.11\E flLTER

?OS I TION HV-057V-1BO

£/S-051V-oo6 11 Ov:JC/127YDC COHVERTEft

£tS-057Y*OC4 HCVS 125YDCl24VOC !---+-------------------~ TEMPERATURE CONYEllTER I I Tl:'.-05 7V-101 I

I I

I

'---+-----+--(TT I I

11CYS I HCVS RA I

RDS PANEL IO-C68l I DETECTOR I RE-057V-1 1 I

I I

~-----------------J SOY VAL\!£ 5V-057Y-Ht2

!'OR HCVS ?~~C:

SOY VALY£ sv-os*1v-1a1 FOR OUTDO PC!V SDV Y£LYE SV-OSTV-180 FDR INBO PC IV RfllOTE DPE~111"G SIAllON IR!ISI L------------*--*-----------------------*---------J

~ ~--~~-------~--------------~----------**----~-~----- * - - * -_J Revision 0 Page 44 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 4: One Line Diagram of SAWA Flow Path (Unit 1 shown, typical Unit

2) (Reference 52)

FLEX PUMP SPRAY POND

§ I DISCHARGE 5" HOSE STORZ CONNECTION 2 FLEX pump PUMP HOUSE I

I connection I

I FLEX HOSE I D& B RHRSW PUMPS FLEX DIESEL 12-0173 OPEN PUMPS ET 12-0174 VENT 12-00028 CLOSED

~ i SFP MIU & SPRAY I

-~

RPV INJECTION HV-51-1F017B 3" RISER in U2 STAIRWELL#S 51-2F129 lfBl LfilIBJ 51-2F127B Rt-flSW RETURN I I HV-51-1F075 I RHRSW RETURN I 51-2F124B I HV-51-2F014B CLOSED I HV-51-1F073 I HV-51-1F014B CLOSED UNIT2 I B RHRSW LOOP I UNIT 1 Revision 0 Page 45 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment SA: One Line Diagram of SAWA/FLEX Electrical Power Supply Div 1 (Same as FLEX, Unit 1 Shown, Unit 2 Typical)

FLEX DIESEL GENERATOR ALIGNMENT STRATEGY 011 SAFEGUARD 4KV Bus FLEX Diesel Generator Connections for 011-BUS-05 DKR r ) XFMR HIGH Unit 1 Div 1 Battery Chargers OPEN~ SIDE II FLEX Modified Bucket 0114 SAFEGUARD 480V LOAD CENTER (All breakers OPEN except those shown)

D114-32 0114-33 BKR BKR CLOSED CLOSED 0114-R-G 480V MCC Rx Bldg 21T ELEV 0114~ 480V MCC (All breakers OPEN except for chargers) ________....____________

FLEX Cub1cie 0 114-D-G-Oe EOG Room (All breakers OPEN)

FLEX CubiclJ 0 114-R-~8 l II ,, IPrimary Alignment I I 11\

I II \

I \ '

I I \ \

CHARGER \ \ \ ',,

BREAKERS , , , , F ex enerator CLOSED , ' ' ,

........ ' ...... ' .... ~ Distribution Panel 0114-R-G-36 0114-R-G-37 ' - - ,_ ....,,

1 Alternate Alignment :

~-------- - --'

Flex Div 1 Battery Generator Chargers Revision 0 Page 46 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 58: One Line Diagram of SAWA/FLEX Electrical Power Supply Div 2 (Same as FLEX, Unit 1 Shown, Unit 2 Typical)

FLEX DIESEL GENERATOR ALIGNMENT STRATEGY 012 SAFEGUARD 4KV Bus FLEX Diesel Generator Connections for 012-BUS<lS I) XFMR HIGH Unit 1 Div 2 Battery Chargers BKROP~ SIDE II FLEX Modified Bucket D124 SAFEGUARD 480V LOAD CENTER (All breakers OPEN except those shown) 0124-32 0124-33 BKR CLOSED

) BKR CLOSED D124-R-G 4BOV MCC Rx Bldg 217' ELEV D124-D-G 480V MCC (All breakers OPEN EDG Room FLEX Cubicle FLEX Cubicle 1*

except for chargers) (All breakers OPEN) 0124-R-G-25 0124-D-G-23

"""\

IPrimary Alignment I Ii\

\

I n--,

I \ ',

I I \ \

CHARGER \ I \ \

I \ \

BREAKERS 1 CLOSED \

I ', \ Flex Generator I \ ' ' Distribution Panel 0124-R-G-36 0124-R-G-37 \ '.... ---::.~-=-

1- - - - - - - - - - - - - -1

Alternate Alignment : Flex Div 2 Battery L _ _ ______ _____ I Chargers Generator Revision 0 Page 47 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6A: Plant Layout Showing Operator Action Locations General plant layout

-- -- - - - -- FLEX/SAWA PUMP

{ CONNECTION TO RHRSW FLEX/SA WA POINT OF USE CONTROL ENCLOSURE Revision 0 Page 48 November 14, 2018

Final Integrated Plan HCVS Order EA-13-1 09 Attachment 68: Plant Layout Showing Operator Action Locations RB and DG El. 217' MCC 0124 MCC 0214 UNIT 2 ROS RM 317 UNIT 1 ROS RM 313 MCC D114RG

= l c:i c:J FLEX FLEX GENERNATOR GENERNATOR CONNECTIONS LGS UNIT 1 AND 2 CONNECTIONS RM 315 ELEVATION 217' RM 311 Revision 0 Page 49 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6C: Plant Layout Showing Operator Action Locations RB and Control Enclosure El. 239' l'

f I

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-~

~:-t~ I&\. 1'7Z'-*"

ILAD. N*14'1

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\1; Revision 0 Page 50 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 60: Plant Layout Showing Operator Action Locations RE El. 201' I

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EL 201 RE Revision 0 Page 51 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6E: Plant Layout Showing Operator Action Locations RE El. 283' Pt

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Revision 0 Page 52 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6E: Plant Layout Showing Operator Action Locations RE El. 313' D124 LOAD D214 LOAD CENTER CENTER

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Revision 0 Page 53 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Attachment 6F: Plant Layout Showing Operator Action Locations RE El. 269' MCR -Main Control Revision O Page 54 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Component Equipment

-Range -* . *- -- Local

...*- .. -*-*Location --***--**-**** -----* -- ---- ------

Local Local Qualification Qualification Qualification Qualification Power Name ID Accident Accident Radiation Temp Humidity Radiation Supply Temo Humiditv Level SAWA flow NIA 37- 1246 Outside. 106 °F 100% Outside. Commercial +32 to 140°F 100% NIA FLEX instrument GPM mounted on More than instrument Pump and readout the FLEX 1900 feet qualified for Batteries (on pump away from over the road the pump) the HCVS use, therefore pipe. qualified per Radiation NEI 12-06 not a concern Drywell PT-042-170 0-150 PSI Reactor 120 °F 90% 2.89E+04 IEEE Std 200°F 0 to 100% 6.5E+6 Rads Division I Pressure Enclosure Rads 32JIK battery via Transmitter Room402, (Note 3) 1974/198312003 FLEX El 253'-00" IEEE Std generator 344TM_ and battery 1975/198712004 charn:er Drywell Pl-042-170- 0-150 PSIG Main <I I0°F 50-90% MCR These PI's are NIA NIA NIA Division 1 Pressure 1 Control Per AR (Note 4) not RG 1.97 (Note 4) (Note4) (Note 4) battery via Indicator Room. 1550669- qualified. FLEX Room 533. 04 However, they generator El 269'-00" are safety and battery related charger indicators which are located in the control room.

Drywell PT-042-270 0-150 PSIG Reactor 120 °F 90% 2.89E+04 By comparison NIA NIA NIA Division 1 Pressure Enclosure, Rads to the same (Note 1) (Note I) (Note 1) battery via Transmitter Room 475, (Note 3) model FLEX El. 253'-00" (I 153GB7PJ) generator RG 1.97 and battery qualification charger Drywell Pl-042-270- 0-150 PSIG Main <l I0°F 50-90% MCR These PI' s are NIA NIA NIA Division 1 Pressure 1 Control Per AR (Note 4) not RG 1.97 (Note 4) (Note 4) (Note 4) battery via Indicator Room, 1550669- qualified. FLEX Room 533. 04 However, they generator El 269'-00" are safety and battery related charger indicators which are located in Revision 0 Page 55 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Component Equipment Range Location Local Local Local Qualification Qualification Qualification Qualification Power Name ID Accident Accident Radiation Temp Humidity Radiation Supply Temp Humiditv Level the control room.

Suppression LT-052- 0 - 50 ft Reactor 120°F 90% 3.77E+06 RG 1.97 N/A N/A N/A RG 1.97 Pool Level 140A H10 Enclosure Rads (Note (Note I) (Note I) (Note I) Division I Transmitter Room 118, 2) battery via El. 177'-00" FLEX generator and bauery charger Suppression LI-052- 0 - 50 ft Main <I l0°F 50-90% MCR RG 1.97 N/A N/A N/A RG 1.97 Pool Level 140A H10 Control Per AR (Note 4) (Note I) (Note I) (Note I) Division I Indicator Room, 1550669- battery via Room 533. 04 FLEX El 269'-00" generator and battery charger Suppression LT-052- 0 - 50 ft Reactor 120°F 90% 3.77E+06 RG 1.97 NIA N/A N/A RG 1.97 Pool Level 240A H10 Enclosure Rads (Note I) (Note I) (Note I) Division I Transmitter Room 189. (Note 2) battery via Elev. 177'- FLEX 00" generator and bauery char_ger Suppression LI-052- 0 - 50 ft Main <I l0°F 50-90% MCR RG 1.97 NIA NIA NIA RG 1.97 Pool Level 240A H10 Control Per AR (Note 4) (Note I) (Note I) (Note I) Division I Indicator Room, 1550669- battery via Room 533, 04 FLEX El 269'-00" generator and bauery charger HCVS RE-057V- N/A Safeguards 120°F 100% 3.53E+06 Commercial 350 °F 100% 2E+08 Rads 10-DIOI Radiation IOI Room. (LOCA) Rads Grade. maximum battery Detector Room 309. (Note 5) backed up EI 217' -00 by FLEX Diesel Generator HCVS RY-057V- l .OOE-2 to Main <I l0°F 50-90% MCR This Radiation ]3] °F 0% to 95%. NIA 10-DIOI Radiation 101 l .OOE+4 Control Per AR (Note 4) Monitor noncondensing (Note 4) battery Monitor Rad/hr Room. 1550669- Processor is not backed up Processor Room 533. 04 RG 1.97 by FLEX El 269'-00" performed qualified. Diesel Revision 0 Page 56 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Component Equipment Range Location Local Local Local Qualification Qualification Qualification Qualification Power Name ID Accident Accident Radiation Temp Humidity Radiation Supply Temp Humiditv Level for FLEX However, it is Generator actions safety related and located in the control room.

HCVS RE-057V- NIA Safeguards 120°F 100% 3.53E+06 Commercial 350 °F 100% 2E+08 Rads 20-DIOI Radiation 201 Room, (LOCA) Rads Grade. maximum battery Detector Room 376, (Note 5) backed up El 217'-00" by FLEX Diesel Generator HCVS RY-057V- I .OOE-2 to Main <I l0°F 50-90% MCR This Radiation 131 °F 0% to 95%, NIA 20-DIOI Radiation 201 l .OOE+4 Control Per AR (Note 4) Monitor noncondensing (Note 4) bauery Monitor Rad/hr Room. 1550669- Processor is not backed up Processor Room 533, 04 RG 1.97 by FLEX El 269'-00" performed qualified. Diesel for FLEX However, it is Generator actions safety related and located in the control room.

Limit HV-057V- NIA Safeguards 120°F 100% 3.53E+06 Nuclear 340°F Enclosure 204E+6 Rads 10-DIOI switches 180 Room. (LOCA) Rads Qualified meets NEMA battery Position Room 309, (Note 5) Products. IEEE I, 4 and 13 backed up indicating for El 217'-00" Standards 344- requirements by FLEX PCIV HY- 1975. 323-1974. for Diesel 057V-!80 and dust-tight. Generator 382-1972. water-tight and oil-tight annlications Limit HV-057V- NIA Safeguards 120°F 100% 3.53E+06 Nuclear 340°F Enclosure 204E+6 Rads 10-DIOI switches 181 Room. (LOCA) Rads Qualified meets NEMA ballery Position Room 309. (Note 5) Products. IEEE I. 4 and 13 backed up indicating for El 217'-00" Standards 344- requirements by FLEX PCIV HY- 1975. 323-1974. for Diesel 057V-181 and dust-tight, Generator 382-1972. water-tight and oil-tight applications Revision 0 Page 57 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Component Equipment Range Location Local Local Local Qualification Qualification Qualification Qualification Power Name ID Accident Accident Radiation Temp Humidity Radiation Supply Temp Humidity Level Limit HV-057V- NIA Safeguards 120°F 100% 3.53E+06 Nuclear 340°F Enclosure 204E+6 Rads 20-DIOI switches 280 Room. (LOCA) Rads Qualified meets NEMA battery Position Room 376. (Note 5) Products. IEEE I. 4 and 13 backed up indicating for El 217'-00.. Standards 344- requirements by FLEX PCIV HV- 1975. 323-1974. for Diesel 057V-280 and dust-tight. Generator 382-1972. water-tight and oil-tight aoolications Limit HV-057V- NIA Safeguards 120°F 100% 3.53E+06 Nuclear 340°F Enclosure 204E+6 Rads 20-DIOI switches 281 Room, (LOCA) Rads Qualified meets NEMA battery Position Room 376, (Note 5) Products. IEEE I. 4 and 13 backed up indicating for El 217'-00" Standards 344- requirements by FLEX PCIV HV- 1975. 323-1974. for Diesel 057V-281 and dust-tight, Generator 382-1972. water-tight and oil-tight aoolications HCVS vent TI-057V- 0-400 F DG 121°F 100% l.45E+02 Nuclear -15 to 185 °F NIA NIA 10-DlOl pipe 101 Enclosure. (LOCA) Rads Qualified (Note 6) (Note 7) battery temperature Room 313, Note 8 (Note 5) Products. backed up transmitter El 21 7' -00 by FLEX Diesel Generator HCVS vent TE-057V- 0-400 F Safeguards 120°F 100% 3.53E+06 Nuclear Up to 500 °F NIA 3E+8 Rads 10-DIOI pipe 101 Room, (LOCA) Rads Qualified (Note 6) battery temperature Room 307. (Note 5) Products. IEEE backed up element El 217'-00" 323-1974 & by FLEX 1983.344-1975 Diesel

& 1987, Generator and NUREG 0588 HCVS vent Tl-057V- 0-400 F Main <I 10°F 50-90% MCR This NIA NIA NIA 10-DIOI pipe IOI Control Per AR (Note 4) temperature (Note 4) (Note 4) (Note 4) battery temperature Room. 1550669- indicator is backed up indicator Room 533. 04 compliant to by FLEX El 269'-00" NUREG0700 Diesel and IEEE Generator Standard 344-1987.

Revision 0 Page 58 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Component Equipment Range Location Local Local Local Qualification Qualification Qualification Qualification Power Name ID Accident Accident Radiation Temp Humidity Radiation Supply Temp Humidity Level HCVS vent IT-057V- 0-400 F DG 121°F 100% l.45E+02 Nuclear -15 to 185 °F NIA NIA 20-DJOl pipe 201 Enclosure, (LOCA) Rads Qualified (Note 6) (Note 7) battery temperature Room 317. Note8 (Note 5) Products. backed up transmitter El 217'-00" by FLEX Diesel Generator HCVS vent TE-057V- 0-400 F Safeguards 120°F 100% 3.53E+06 Nuclear Up to 500 °F NIA 3E+8 Rads 20-DlOl pipe 201 Room. (LOCA) Rads Qualified (Note 6) battery temperature Room 376. (Note 5) Products. IEEE backed up clement El 217'-00" 323-1974 & by FLEX 1983. 344-1975 Diesel

& 1987. Generator and NUREG 0588 HCVS vent Tl-057V- 0-400 F Main <l l0°F 50-90% MCR This NIA NIA NIA 20-0101 pipe 201 Control Per AR (Note 4) temperature (Note 4) (Note 4) (Note 4) battery temperature Room, 1550669- indicator is backed up indicator Room 533, 04 compliant to by FLEX El 269'-00" NUREG0700 Diesel and IEEE Generator Standard 344-1987 Battery Unit I 10-DlOl NIA DG 121 °F 50% l.45E+02 Commercial 122 °F 0% to 90%, NIA Dl24-D-G-Enclosure, (LOCA) (LOCA) Rads Grade. IEEE noncondensing (Note 7) 11 Normal Room 313. Note 8 (Note 5) Standards 485 power El 217'-00" and 946. backed up by FLEX Diesel Generator Battery Unit 2 20-DlOI NIA DG 121 °F 50% 1.45E+02 Commercial 122 °F 0% to 90%, NIA D224-D-G-Enclosure, (LOCA) (LOCA) Rads Grade. IEEE noncondensing (Note 7) 11 Normal Room 317, Note 8 (Note 5) Standards 485 power El 217'-00" and 946. backed up by FLEX Diesel Generator Revision 0 Page 59 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 NOTES:

I. Instrument is qualified to RG 1.97 or equivalent is considered qualified for the sustained operating period without further evaluation.

2. The severe accident dose to wetwell level transmitters LT-052- I 40A and LT-052-240A for Unit 1 in a severe accident condition was considered negligible due to the shielding provided by the containment wall and the water in the wetwell. Therefore, the TID will be less than the TID of3.77E+06 Rads for the design basis accident (i.e., LOCA).

3. The TID (i.e., normal integrated dose plus the integrated dose for the 7-day sustained operation period) for drywell pressure transmitters PT-042-170 for Unit 1 in a severe accident condition is approximately 2.89E+04 Rads. This dose is the normal operating dose since the severe accident dose to the drywell pressure transmitter location is negligible (relative to the normal operating dose). This TID is also considered to be applicable to drywell pressure transmitter PT-042-270, for Unit 2 in a severe accident condition, because the Unit 1 location is bounding for Unit 2 in this scenario, and because the normal integrated dose is the dominant contributor and a slight difference in the 7-day severe accident dose would have a negligible impact.

4. Denotes Main Control Room where local temperature, humidity and radiation levels are not applicable. MCR has no radiation sources and provides adequate shielding. The MCR instrumentation is qualified to operate in the design basis accident temperature and humidity. The design basis accident temperature and humidity does not exceed the temperature and humidity experienced during HCVS and SAW NSA WM .

5 . LM-0721(Reference53), Table 8-1 has been provided as TID (i.e. normal integrated dose plus the 7-day integrated dose.)

6. Weed N9002 Series temperature sensor. This model has previously been environmentally and seismically qualified to use in Class IE applications in nuclear power plants.

7 . There are no acceptance criteria associated with HCVS equipment at the ROS. The equipment in the ROS is located in a low radiation area and, by design, would not be subject to high doses given a severe accident.

8. The minimum temperature is -26 °F. The equipment has been designed for minimum ambient temperature as this is outside of the Reactor Building.

Revision 0 Page 60 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Table 2: Operator Actions Evaluation (Reference 31)

Thermal Radiological Item Operator Actions Evaluation Time Location Evaluation conditions Conditions

-Energize the HCVS power supply to the HCVS components;

-Breach the rupture Disc by opening the Argon Purge Line for the specified Room 533, Main Acceptable amount of time; 1 ::;; 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Control Room, El NIA NIA per HCVS-

-Open Wetwell PCIVs; 269'-00" FAQ-01.

SAWA valve alignment in RB to RPV

- 1 valve (HV-051-1(2)F017(A)B);

-HCVS Valves switch actuation and instrument monitoring

-Enable the motive air for the HCVS Rooms 313 and valves and enable the Argon purge 317, Remote system; Operating Station Negligible 2 -Isolate leak-off connection upstream s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months (ROS) Unit 1 and 121°F Acceptable.

(Note 1) of the rupture disc; Unit 2, DG

-Backup HCVS valve operation (if Enclosure, El 217'-

primary method fails) 00" Cross Path for Unit 1 to Unit 2 Room 202, Pipe Negligible 3 (operator travel path between the unit s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Tunnel, EL. 198'- 123 °F Acceptable.

(Note 1) 1 and unit 2) 00"

-Load shedding/electrical switching at Within the MCC 0114-R-G (0214-R-G) Rooms 304 and range of 9E+03 4 ::;; 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 120 °F Acceptable.

-Load shedding/electrical switching at 370, EL. 217'-00" mR/hrto MCC 0124-R-G (0224-R-G) 1.3E+04 mR/hr Revision 0 Page 61 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Thermal Radiological Item Operator Actions Evaluation Time Location . Evaluation conditions Conditions

-Load shedding FLEX generator electrical connections Division I MCC D114-D-G (D214-D-G),

Peak dose rate

-Load shedding FLEX generator Rooms 311 and Acceptable 5 $ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 115 °F is 5.9E-01 electrical connections Division II MCC 315, EL. 217'-00", (Note 2).

mR/hr D124-D-G (D224-D-G)

-FLEX Generator connection and alignment Provide backup power for plant Rooms 542 and Rm. 542 - 82 Negligible 6 $ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months OF Acceptable.

paging system Gaitronics SE-12 619, EL. 289'-00", (Note 1)

SAWA manual valve alignment in RB s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Rooms 204 and Negligible 7 to RPV - 2 valves (HV-051-1 (2)F073, (approximate venting 133°F Acceptable.

280, EL. 201 '-00" (Note 1)

HV-051-1 (2)F075) (Note 4) start)

Rooms Battery charger recovery at Battery 436/435/433 and Negligible 8 s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months -106 °F Acceptable.

and Switchgear Room at El. 239' 431/429/427, EL. (Note 1) 239'-00" Load shed in the inverter rooms Per Rooms 452 and Negligible 9 s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 104 °F Acceptable.

E-1 (two locations) 453, EL. 254'-00" (Note 1)

LPCI Injection (if manual action Rooms 599 and Negligible 10 required to open HV-051- s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 120°F Acceptable.

589, EL. 283'-00" (Note 1) 1(2)F017B(A))

Load shed D124-R-C and D224-R-C Rooms 506 and Negligible 11 s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 120°F Acceptable.

Div II MCC 580, EL. 283'-00" (Note 1)

-Electrical switching/load shedding:

Rooms 602 and Negligible 12 -D114 Load Center s 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 120 °F Acceptable.

638, EL. 313'-00" (Note 1)

-D124 Load Center Revision 0 Page 62 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Thermal Radiological Item Operator Actions Evaluation Time Location Evaluation

- - - -- - - - <114 °F conditions Conditions

- - ~

for at least Rooms 700 and Negligible 13 Door Opening on the refuel floor ~ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months the first six Acceptable.

708, EL. 352'-00" (Note 1) hours AR 1550669-13 Outside, South of the Negligible 14 Unit 1 to Unit 2 DG Travel Path ~ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ambient Acceptable.

Reactor Building (Note 1) conditions North west of the Opposite side RB near the spray of the RBs pond. Outdoor from the vent SAWA pump staging, operation, hose 15 ~ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Approximately ambient pipes, well Acceptable.

connection, and refueling 1900 feet away conditions shielded by from the HCVS structure and pipe. distance DG enclosure Outside, (inside and vented Between FLEX generator connection, outside). Acceptable 16 ~ 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months (Continued) enclosure, 0.6043R/hr alignment, operation and refueling Approximately 250 (Note 2).

near ambient and 1.389 R/hr feet away from conditions HCVS pipe.

Rooms 313 and

-Align generator to HCVS battery 317, Remote charger; Operating Station Peak dose rate Acceptable 17 Replace pressurized gas source for > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (ROS) Unit 1 and 121°F is 5.9E-01 (Note 2).

HCVS operation; Unit 2, DG mR/hr

- Replenish Argon bottles Enclosure, El 217'-

00" Revision 0 Page 63 November 14, 2018

Final Integrated Plan HCVS Order EA-13-109 Thermal Radiological Item Operator Actions Evaluation lime Location Evaluation conditions Conditions

- - - ~-

Rm. 542 - 82 Rooms 542, EL. OF Negligible 18 SFP Instrumentation monitoring Continued/intermittent Acceptable.

289'-00" Rm. 619 -104 (Note 3)

OF 1.389E+03 South of the mR/hr Access to FLEX Generator Storage Reactor Building, Outside, (outside)

Building Outside of the Reactor 19 Continued Approximately 250 ambient Approximately Acceptable.

Building (inside and outside of feet away from conditions 2.32E+01 building)

HCVS pipe mR/hr (inside)

(Note 5)

Revision O Page 64 November 14, 2018

RS-18-106, Report of Full Compliance with Phase 1 and Phase 2 of June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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RS-18-106, Report of Full Compliance with Phase 1 and Phase 2 of June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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Subject:

References:

SUMMARY

Enclosure:

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