GO2-16-171, Combined Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Orders EA-12-049 and EA-13-109

Combined Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Orders EA-12-049 and EA-13-109

ML16364A245
Person / Time
Site:	Columbia
Issue date:	12/29/2016
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, EA-13-109, GO2-16-171
Download: ML16364A245 (16)

Text

Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-8555 l F. 509-377-4150 aljavorik@energy-northwest.com EA-12-049 EA-13-109 10 CFR 50.54(f)

December 29, 2016 GO2-16-171 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWESTS COMBINED SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NUCLEAR REGULATORY COMMISSION (NRC) ORDERS EA-12-049 AND EA-13-109

References:

1. NRC Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to Energy Northwest et.al, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

2. NRC Letter from E. J. Leeds (NRC) to Licensees with Mark I and Mark II Containments, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013

3. Letter GO2-13-034 from A. L. Javorik (Energy Northwest) to NRC, "Energy Northwests Response to NRC Order EA-12-049 - Overall Integrated Plan for Mitigating Strategies," dated February 28, 2013

4. Letter GO2-15-175 from A. L. Javorik (Energy Northwest) to NRC, "Energy Northwests Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Vents under Severe Accident Conditions Phases 1 and 2, Revision 1," dated December 15, 2015

5. Letter GO2-14-031 from D. A. Swank (Energy Northwest) to NRC, "Energy Northwests Second Six Month Status Update Report for the

GO2-16-171 Page 2 of 3 Implementation of NRC Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated February 27, 2014

6. Letter GO2-16-125 from A. L. Javorik (Energy Northwest), "Energy Northwests Seventh Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated August 30, 2016

7. Letter GO2-16-098 from A.L. Javoik (Energy Northwest), "Energy Northwests Fourth Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Order to Modify Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 30, 2016

8. Letter GO2-14-026 dated February 21, 2014, from D. A. Swank (Energy Northwest) to NRC, "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events'"

9. NRC Letter dated April 15, 2014, from E. J. Leeds (NRC) to M. E.

Reddemann (Energy Northwest), "Columbia Generating Station -

Relaxation of Certain Schedule Requirements for Order EA-12-049

'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events'"

Dear Sir or Madam,

By References 1 and 2, the Nuclear Regulatory Commission (NRC) issued Orders EA-12-049 and EA-13-109. Both Orders required licensees to develop an overall integrated plan (OIP) and submit 6-month update reports. References 3 and 4 transmitted the OIPs for the Orders. Reference 5 provided a revised OIP for Order EA-12-049.

References 6 and 7 transmitted the previous 6-month update reports required by the Orders. By Reference 8 and 9, Energy Northwest requested and received a relaxation of the final implementation date of NRC Order EA-12-049 which tied certain requirements of Order EA-12-049 to the implementation date of Phase 1 of NRC Order EA-13-109. Therefore, Energy Northwest is combining the remaining 6-month update reports for NRC Order EA-12-049 with the 6-month update reports for NRC Order EA-13-109 until Phase 1 of Order EA-13-109 is reported complete and the implementation requirements of Order EA-12-049 have been met.

The enclosure to this letter and its attachment provide a combined 6-month update report and the status of the remaining open items for implementation of NRC Orders EA-12-049 and EA-13-109. Therefore, no update for Order EA-12-049 will be issued in February. The next combined update will be June of 2017.

No new commitments are being made by this letter or the enclosure. If you have any questions or require additional information, please contact Mr. R. M. Garcia at (509) 377-8463.

G02-16-171 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on this ~ 9 t~ay of Jlec,~ m /tt V> , 2016.

Respectfully, Vice President, Engineering

Enclosures:

As stated cc: NRC RIV Regional Administrator CD Sonoda - BPA/1399 (email)

NRC NRA Project Manager WA Horin -Winston & Strawn NRC Senior Resident lnspector/988C

GO2-16-171 Enclosure Page 1 of 6 1.0 Introduction By References 1 and 2 to this enclosure, the Nuclear Regulatory Commission (NRC) issued Orders EA-12-049 and EA-13-109 to Columbia Generating Station (Columbia).

The Orders contained requirements for mitigation strategies for beyond-design-basis external events and the installation of a reliable containment hardened vent capable of operation under severe accident conditions. References 1 and 2 also required submittal of an Overall Integrated Plan (OIP) describing how compliance with the requirements described in the Orders will be achieved and required the submittal of status reports at six month intervals. This enclosure provides Energy Northwests combined six-month status report for these NRC Orders a combined update of the remaining milestones including any changes to the compliance method or schedule.

2.0 Milestone Accomplishments All the Mitigation Milestones required to support restart from Refueling Outage 22 (mitigation implementation outage) with the exception of plant changes directly associated with the implementation of the reliable hardened containment vent were reported complete in Reference 3 of this enclosure.

3.0 Milestone Schedule Status The following table provides a listing of the remaining reports associated with NRC Orders EA-12-049 and EA-13-109.

Correspondence and Reports Target Comments Activity (Include date Milestone Completion Status changes in this Date column)

Submit Overall Integrated GO2-14-107 June 2014 Complete Implementation Plan (Phase 1) 6/30/2014 Submit Overall Integrated Implementation Plan (Phase 2) which GO2-15-175 Dec. 2015 Complete included a Phase 1 6-month status 12/16/2015 update.

Next Combined Status Update Report for the Mitigation Strategies June 2017 Not Started and Reliable Hardened Containment Vent Issuance of Energy Northwest's letter of compliance with NRC Order EA- Aug. 2017 Not Started 12-049,Section IV.C.3 Issuance of Energy Northwest's letter of compliance with NRC Order EA- Aug. 2017 Not Started 13-109, Phase 1 Submittal of Final Integrated Program Document Order EA Aug. 2017 Not Started 049.

GO2-16-171 Enclosure Page 2 of 6 6th 6-month update for Order EA June 2017 Not Started 109 7th 6-month update for Order EA Dec. 2017 Not Started 109 8th 6-month update for Order EA June 2018 Not Started 109 9th 6-month update for Order EA Dec. 2018 Not Started 109 10th 6-month update for Order EA-June 2019 Not Started 13-109 Issuance of Energy Northwest's letter of compliance with NRC Order EA- Aug. 2019 Not Started 13-109, Phase 2 The tables below provide the status of the overall integrated plan for reliable hardened containment vents (HCV) under severe accident conditions milestones last reported in References 4 and 5 of this enclosure.

HCV Phase 1 Milestone Schedule:

Target Comments Activity (Include date Milestone Completion Status changes in this Date column)

Hold preliminary/conceptual design June 2014 Complete meeting This date is WW Design Engineering Complete May 2016 changed to Feb 2017 WW Operation Procedure Changes Mar 2017 Developed WW Training Complete Apr. 2017 WW Installation Complete May 2017 WW Procedure Changes Active May 2017 Site Specific WW Maintenance June 2017 Procedure Developed WW Walk Through June 2017 Demonstration/Functional Test Submit WW Completion Report Aug. 2017

GO2-16-171 Enclosure Page 3 of 6 HCV Phase 2 Milestone Schedule Target Comments Activity (Include date Milestone Completion Status changes in this Date column)

This date has Hold preliminary/conceptual design July 2016 been changed to meeting Jul 2017 Design Engineering On-site/Complete July 2018 Operations Procedure Changes Jan. 2019 Developed Site Specific Maintenance Procedure Jan. 2019 Developed Training Complete Apr. 2019 Implementation Outage May 2019 Procedure Changes Active May 2019 Walk Through June 2019 Demonstration/Functional Test 4.0 Changes to the Compliance Methods Changes to the OIP for Reliable HCV Vents under Severe Accident Conditions (EA-13-109):

During the September 29, 2016 audit phone call between the NRC staff and Energy Northwest, it was identified by the NRC that the method by which communications between the main control room, on-site FLEX pump operators, and the remote operating station would be accomplished was not explicitly defined in the OIP for Order EA-13-109.

Energy Northwest intends to use the same communications plan used for the mitigation strategies as provided below.

The primary means of onsite and offsite communication to be used during an extended loss of alternating current (ac) power (ELAP) event at Columbia are the installed sound powered telephone and radio systems. It has been determined that the indoor and outdoor locations where plant equipment or on-site FLEX equipment may be used, can be communicated with by using sound-powered phone headsets, satellite phones, or hand-held radios in radio-to-radio mode. The sound powered phone system can still be used if and when other communication methods become unavailable.

Sound Powered Phones In addition to the installed sound powered phone system, five portable sound powered phone kits are available in each FLEX building. The kits are available to provide point-to-point communication to areas that have lost the other forms of communication. They can also be used to extend the current sound powered

GO2-16-171 Enclosure Page 4 of 6 phone system. Each kit contains 800 feet of cable, two headsets, and junction boxes. The junction boxes allow multiple kits to be attached together to provide longer cable runs or to allow additional headsets to be connected.

Satellite Phone System Each portable satellite phone is battery powered. Three batteries have been allocated to each phone with each battery providing 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of talk time. The battery chargers for the satellite phones are stored in the same locations as the phones. These chargers can be powered by the FLEX building standby generators.

Base stations are located in the control room, technical support center (TSC),

emergency operations facility (EOF), alternate EOF and joint information center (JIC).

The base stations are powered from automobile type batteries located in the FLEX buildings for the control room and TSC, in the telecom room for the EOF and in the APEL/TEC facility for the alternate EOF and JIC. These batteries are good for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on a loss of power.

The chargers for the base station batteries are powered by normal site power with the respective facilitys back-up generators providing the emergency power.

Hand-held Radios It has been determined that the mounting of some radio system components does not meet the seismic requirements necessary to assure radio system availability following an earthquake. However, hand-held portable radio-to-radio capability will be available. Battery chargers can be powered by the FLEX building standby generators.

Changes to the Overall Integrated Plan for Mitigating Strategies (EA-12-049):

Reference 6 of this enclosure revised the original overall integrated plan and provided the following Phase 3 discussion for maintaining core cooling with portable equipment.

The actions discussed in this strategy were later determined to be recovery actions, not Phase 3 actions.

"For Phase 3, core cooling will be accomplished by placing one loop of RHR into the shutdown cooling mode. This will be accomplished by providing power from a pair of synchronized 4160 VAC FLEX portable diesel fueled gas turbine generators (from the RRC [Regional Resource Center]) and supplying the RHR heat exchanger and RHR pump room cooler with SW pumped by a large portable FLEX pump (from the RRC) via connection to either division of SW piping. The flow through the RHR heat exchanger and RHR pump room cooler will be in the opposite direction from that which occurs during normal operation.

The 4160 VAC FLEX turbine generators will be sized to carry the loads necessary to support the Phase 3 FLEX strategies including an RHR pump and its support equipment (e.g., motor-operated valves, keep-fill pumps, room coolers). The turbine generators will be capable of being connected to connection points at the output

GO2-16-171 Enclosure Page 5 of 6 breaker of the Division 1 or the Division 2 EDG, thereby providing power to the Division 1 or Division 2 RHR pump via the associated safety related 4160 VAC bus.

As planned, the 4160 VAC turbine generators will accommodate the approximate 1 MW load from an RHR pump, related valves, and required miscellaneous loads.

The miscellaneous required loads include Control Room, Cable Spreading room, Switchgear Room and RHR Room emergency cooling fans, DC battery chargers and an SFP cooling pump.

The large-capacity FLEX pump will be sized to provide sufficient flow to the RHR heat exchanger to support the shutdown cooling or suppression pool cooling modes of RHR. This strategy for shutdown cooling can be accomplished utilizing a single large FLEX pump or multiple FLEX pumps, depending on pump sizes available from the RRC. In order to prevent pipe damage due to water hammer, a keep-fill pump will be repowered to allow proper fill and vent of the RHR system prior to shutdown cooling operation."

Consequently, Columbia's Phase 3 strategy for reactor core cooling and heat removal has been revised as follows:

The Phase 3 strategy uses equipment from the NSRC [National SAFER Resource Center] to backup or supplement the on-site Phase 2 FLEX equipment to restore or maintain the key safety functions. The Phase 2 mechanical and electrical connection points are compatible with the NSRC equipment. The NSRC equipment is delivered to Columbia within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a request for delivery. Other NSRC equipment that is not backup or redundant to Phase 2 FLEX equipment can be applied towards recovery efforts.

In addition to other equipment, Columbia will receive the following Phase 3 NSRC equipment designed to provide the same function and use the same connection points as the on-site Phase 2 FLEX equipment:

NSRC Component Performance Description 480 VAC Diesel- 480 Volts AC powered Generator 1100 kW SG/RPV Water 500 PSI Makeup Pump 500 GPM 5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation Beyond the relaxation requested in Reference 7 and granted in Reference 8, there has been no additional relaxation needs identified.

GO2-16-171 Enclosure Page 6 of 6 6.0 Open Items from Overall Integrated Plan, Interim Staff Evaluation, and Audits The attached tables provide an update of the status of the remaining open items documented in References 4 and 5.

7.0 References

1. NRC Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to Energy Northwest et.al, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

2. NRC Letter from E. J. Leeds to Licensees with Mark I and Mark II Containments, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013

3. Letter GO2-15-124, from D. A. Swank (Energy Northwest) to NRC "Energy Northwests Fifth Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated August 25, 2015

4. Letter GO2-16-098 from A.L. Javoik (Energy Northwest), "Energy Northwests Fourth Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Order to Modify Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 30, 2016

5. Letter GO2-16-125 from A. L. Javorik (Energy Northwest), "Energy Northwests Seventh Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated August 30, 2016

6. Letter GO2-14-031 from D. A. Swank (Energy Northwest) to NRC, "Energy Northwests Second Six Month Status Update Report for the Implementation of NRC Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated February 27, 2014

7. Letter GO2-14-026, from D. A. Swank (Energy Northwest) to NRC, "Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,'" dated February 21, 2014

8. NRC Letter from E. J. Leeds to M. E. Reddemann (Energy Northwest),

"Columbia Generating Station - Relaxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated April 15, 2014

GO2-16-171 Attachment Page 1 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Provide resolution of the potential Closed in Letter secondary containment bypass GO2-15-175.

leakage path in the first 6-month Columbia will use a OI-HCV-01 update of the HCVS OIP CLOSED rupture disk to prevent secondary containment bypass leakage.

Evaluate the location of the ROS for OI-HCV-02 OPEN accessibility.

Determine the location of the portable air compressor and evaluate for accessibility under Severe Accident OI-HCV-03 OPEN HCVS use.

Including connection point(s)

Including refueling operations Evaluate the location of the FLEX DG for accessibility under Severe OI-HCV-04 Accident HCVS use. OPEN Including connection point(s)

Including refueling operations Confirm suppression pool heat Closed in Letter capacity GO2-15-175.

Calculation ME 14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the OI-HCV-05 CLOSED suppression pool water when at a minimum Technical Specification level to control pressure in containment before venting commences.

Determine the method of qualification OI-HCV-06 OPEN for each instrument Complete the evaluation to determine accessibility, habitability, staffing OI-HCV-07 OPEN sufficiency, and communication capability of the ROS.

Identify design codes after design is OI-HCV-08 OPEN finalized.

GO2-16-171 Attachment Page 2 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Equipment qualifications will include temperature, pressure, radiation level, OI-HCV-09 and total integrated dose radiation OPEN from the effluent vent pipe at local and remote locations.

Provide site-specific details of the EOPs when available.

OI-HCV-10 OPEN Develop procedures for SAWA and SAWM FLEX air compressors need to be The HCV strategy will credited to recharge air lines for credit for the existing HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 300 CFM FLEX air compressor FLEX-C-3 staged in FLEX OI-HCV-11 CLOSED Building 82 and FLEX-C-4 in Building 600.

The 300 CFM capacity of the air compressor is sufficient.

SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA-12-049 actions).

OI-HCV-12 OPEN Location of these valves and flow elements will need to be considered per HCVS-FAQ-12.

Reconcile the out-of-service provisions for HCVS/SAWA with the OI-HCV-13 provisions documented in Columbias OPEN PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.

Complete the evaluation to determine accessibility, habitability, staffing OI-HCV-14 OPEN sufficiency, and communication capability during SAWA/SAWM Perform MAPP analysis for NEI 13-02 figures C-2 through C-6 and OI-HCV-15 OPEN determine the time sensitive SAWM actions Develop procedure for line-up and use OI-HCV-16 OPEN of HCVS Add sound powered phone extension Additional cable not cable for instrument rack E-IR-85 to need as each FLEX OI-HCV-17 CLOSED inventory procedure building has 5 sound powered phone kits Evaluate deployment pathways for OI-HCV-18 OPEN severe accident capable criteria

GO2-16-171 Attachment Page 3 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Develop required training and OI-HCV-19 OPEN frequency IAW the SAT process Incorporate approved language of OIP OI-HCV-20 Attachment 2.1.D into site SAMG OPEN procedure(s)

Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit Letter GO2-15-175 the location of the remote operating The location of the 01 station (ROS). CLOSED remote operating Section 3.2.1 station is shown on Figure 1-1.

Make available for NRC staff audit 02 the location of the portable air OPEN Section 3.2.1 compressor.

Make available for NRC staff audit 03 the location of the portable diesel OPEN Section 3.2.1 generators.

04 Make available for NRC staff audit an Section 3.2.1 evaluation of temperature and Section 3.2.2.4 radiological conditions to ensure that Section 3.2.2.5 operating personnel can safely Section 3.2.2.10 access and operate controls and OPEN Section 3.2.4.1 support equipment.

Section 3.2.4.2 Section 3.2.5.2 Section 3.2.6

GO2-16-171 Attachment Page 4 of 7 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit ME-02-13-03 analyses demonstrating that HCVS has the capacity to vent the ME-02-14-13 steam/energy equivalent of one percent of uprated licensed/rated ME-02-12-18 thermal power (unless a lower value 05 is justified), and that the suppression Section 3.2.2.1 pool and the HCVS together are able CLOSED Section 3.2.2.2 to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe 06 accident for the components (valves, Section 3.2.2.3 instrumentation, sensors, Section 3.2.2.5 transmitters, indicators, electronics, OPEN Section 3.2.2.9 control devices, etc.) required for Section 3.2.2.10 HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

Make available for N RC staff audit Calculations ME documentation of the HCVS nitrogen 15-08 and ME-02 pneumatic system design including 17 were approved on sizing and location. 8/10/16. ME-02-15-08 confirms the adequate sizing and location of the nitrogen piping 07 and ME-02-14-17 Section 3.2.2.4 CLOSED sizes the relief valve Section 3.2.6 HCV-RV-101. This AR may be closed since the calculations are available for NRC audit. Copies of approved cover sheets are included in EDMS.

GO2-16-171 Attachment Page 5 of 7 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit E/I-02-13-03 08 the final sizing evaluation for HCVS Section 3.2.2.4 batteries/battery charger including CLOSED Section 3.2.6 incorporation into FLEX DG loading calculation.

Make available for NRC staff audit See Section 4.0 of the documentation that demonstrates Enclosure to this adequate communication between letter.

09 the remote HCVS operation locations CLOSED Section 3.2.2.5 and HCVS decision makers during ELAP and severe accident conditions.

Provide a description of the Energy Northwest will strategies for hydrogen control that use Option number 5 minimizes the potential for hydrogen of the NEI White gas migration and ingress into the RB Paper HCV-WP-03, or other buildings. Hydrogen/Carbon 10 Monoxide Control CLOSED Section 3.2.2.6 Measures and add a check valve at the discharge end of the vent pipe to address the flammability of combustible gasses.

Make available for NRC staff audit descriptions of all instrumentation 11 and controls (existing and planned) OPEN Section 3.2.2.9 necessary to implement this order including qualification methods.

Make available for NRC staff audit Columbia will be using documentation of an evaluation an unused verifying the existing containment containment 12 isolation valves, relied upon for the penetration and will be CLOSED Section 3.2.2.9 HCVS, will open under the maximum installing new expected differential pressure during containment isolation BDBEE and severe accident wetwell valves.

venting.

GO2-16-171 Attachment Page 6 of 7 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit The following EOPs site specific details of the EOPs when provide for containment available. venting during an ELAP event:

13 PPM 5.6.1, CLOSED Section 3.4.1 SBO/ELAP PPM 5.6.2, SBO and ELAP Attachments PPM 5.2.1, Primary Containment Control Provide justification for not leak Columbia has adopted testing the HCVS every three the current NEI operating cycles and after restoration guidance on testing 14 of any breach of system boundary CLOSED and Inspection Section 3.4.4 within buildings. requirements as shown in Table 4-1of Reference 4 Add a discussion on communications Discussed in Section 15 between the CR, FELX pump, and 4.0 of the enclosure to ROS operators to the December 6- CLOSED this letter.

AR Task 36 month HCV update.

List of Remaining FLEX Integrated Plan Open Items FLEX OIP Action Status Open Item GOTHIC analyses will be confirmed, or revised, to bound Open the design of the hardened containment vent after the AR 278368-89 is OI-FLEX-73 design is finalized. (This OI has been added to assure that tracking with a the subject analyses reflect the design required by EA 01/27/2017 due 109.) date (D Myers)

The flooding hazards analysis will provide information about site water level associated with a probable maximum precipitation (PMP) event and a local intense precipitation (LIP) event. These water levels will be compared to Closed elevations for the FLEX buildings as well as the deployment The flooding hazard routes for the equipment. A LiDAR survey of the site was reevaluation was completed and the OI-FLEX-43 performed and a topographic plan of the site has been report was provided generated to assist in this evaluation. The flooding analysis to the NRC in letter is currently in progress. The results will be used to provide GO2-16-143, dated a response to this question in a future OIP update. 10/6/16.

(Response to NRC Audit Question 03) (This OI has been changed because the flooding analysis remains in progress and the OI was not closed in the February 2014 update.)

GO2-16-171 Attachment Page 7 of 7 List of Remaining FLEX Integrated Plan Open Items A future update to the OIP will address the applicability to Closed Columbia of each of the nine considerations in NEI 12-06 The Flooding Section 6.2.3.2, Deployment of FLEX Equipment. Hazard (Response to NRC Audit Question 04) (This OI has been Reevaluation Report changed because the flooding analysis remains in progress (FHRR) shows the OI-FLEX-44 results are either and the OI will be closed in a future update.)

bounded by the current design basis or available physical margin exists.

The flooding analysis will be used to determine if any of the Closed external flooding procedures should be changed. The Flooding (Response to NRC Audit Question 04) Hazard Reevaluation Report (FHRR) shows the OI-FLEX-45 results are either bounded by the current design basis or available physical margin exists.