JAFP-16-0192, Fifth Six-Month Status Report 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 No. EA-13-109)

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Fifth Six-Month Status Report 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 No. EA-13-109)
ML16357A787
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/22/2016
From: Brian Sullivan
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, JAFP-16-0192
Download: ML16357A787 (16)
v • d • e


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-16-0192 December 22, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Entergy - James A. FitzPatrick Fifth Six-Month Status Report 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)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC Order, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, EA-13-109, dated June 6, 2013
2. NRC Interim Staff Guidance, 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, JLD-ISG-2013-02, dated November 2013
3. NRC Interim Staff Guidance, Compliance with Phase 2 of Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, JLD-ISG-2015-01, dated April 2015
4. NEI document, Industry Guidance for Compliance with NRC Order EA-13-109: BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, NEI 13-02, dated April 2015
5. ENOI letter, James A. FitzPatrick Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP-14-0075, dated June 30, 2014
6. ENOI letter, James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP 0149, dated December 29, 2015
7. ENOI letter, Certification of Permanent Cessation of Power Operations, JAFP-16-0045, dated March 16, 2016
8. ENOI letter, Request for Extension to Comply with NRC Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, JAFP-16-0148, dated September 8, 2016.

JAFP-16-0192 Page 2 of 2

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission ("NRG" or "Commission") issued Order EA-13-109 to James A. FitzPatrick Nuclear Power Plant (JAF) [Reference 1]. EA-13-109 directs JAF to install a reliable hardened venting capability in accordance with the requirements detailed in the Order, including:

A Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D.1. Reference 2 endorses industry guidance document NEI 13-02, Revision O with clarifications and exceptions identified in Reference 2. Reference 5 provided the JAF's Phase 1 Overall Integrated Plan.

A Phase 2 Overall Integrated Plan pursuant to Section IV, Condition D.2. Reference 3 endorses industry guidance document NEI 13-02, Revision 1 [Reference 4]. Reference 6 provided the JAF's Phase 2 Overall Integrated Plan.

Submission of a status report at six-month intervals following submittal of the Overall Integrated Plan phase 1 [Reference 5] pursuant to Section IV, Condition D.3. NEI 13-02

[Reference 4] provides direction regarding the content of the status reports.

The purpose of this letter is to provide the fifth six-month status report, which delineates progress made in implementing the requirements of EA-13-109. Attachment 1 provides an update to milestone status, including any changes to the compliance method, schedule, or possible need for relief and the basis.

Entergy Nuclear Operations, Inc. (ENOI) is no longer planning to cease power operation of JAF on January 27, 2017 [Reference 7]. JAF expects to comply with the Order; however, based on ENOl's request for extension [Reference 8], compliance with the Order implementation date will be affected. Future six-month status report submittals will address any requests for exemption from the Order requirements prior to the Order implementation date.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. William C. Drews, Regulatory Assurance Manager, at 315-349-6562.

I declare under penalty of perjury that the foregoing is true and correct; executed on December 22, 2016.

Sincerely,

('

Brian R. Sullivan Site Vice President BRS/WCD/mh : James A. FitzPatrick (JAF) Nuclear Power Plant's Fifth Six-Month Status Report 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) 2: Response to Phase 1 Interim Staff Evaluation Open Items 3: Response to Phase 2 Interim Staff Evaluation Open Items cc: Director, Office of Nuclear Reactor NRG Project Manager Regulation NYSPSC NRG Regional Administrator NYSERDA NRG Resident Inspector

JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (6 Pages)

JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 1 Introduction JAF developed a Phase 1 Overall Integrated Plan (Reference 2) and a Phase 2 Overall Integrated Plan (Reference 3), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability in response to NRC Order Number EA-13-109 (Reference 1). This attachment provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan, Phase 2 Overall Integrated Plan, and the subsequent Six Month Status Reports, including any changes to the compliance method, schedule, or need for relief / relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Phase 1 Overall Integrated Plan (Reference 2) and Phase 2 Overall Integrated Plan (Reference 3),

and are current as of December 22, 2016. (See Section 3)

Submitted Fifth 6 Month Status Report by letter JAFP-16-0192 3 Milestone Schedule Status The following provides an update to Part 5 of the Phase 1 Overall Integrated Plan (Reference 2) and Part 5 of the Phase 2 Overall Integrated Plan (Reference 2). It provides the status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Target Milestone Completion Activity Status Comments Date Phase 1 Hold preliminary / conceptual design Jan. 2014 Complete meeting Submit Overall Integrated Jun. 2014 Complete Implementation Plan Submit 6 Month Status Report Dec. 2014 Complete Submit 6 Month Status Report Jun. 2015 Complete Design Engineering On-site/Complete Dec. 2015 Complete Submit 6 Month Status Report Dec. 2015 Complete Submit 6 Month Status Report Jun. 2016 Complete Submit 6 Month Status Report Dec. 2016 Complete Submit 6 Month Status Report Jun. 2017 Not Started Submit 6 Month Status Report Dec. 2017 Not Started New item Operations Procedure Changes April 2018* Not Started Developed Page 1 of 6

JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Target Milestone Completion Activity Status Comments Date Site Specific Maintenance Procedure April 2018* Not Started Developed See Section 5.0 (Jan. 2017 HCVS Implementation Complete May 2018* In Progress Outage); Milestone Desc. Changed Procedure Changes Active Jun. 2018* Not Started Walk Through Jun. 2018* Not Started Demonstration/Functional Test Training Complete Jun. 2018* Not Started Submit Completion Report Jun. 2018* Not Started Phase 2 Hold preliminary/conceptual design Oct 2015 Complete meeting Submit Overall Integrated Dec 2015 Complete Implementation Plan Submit 6 Month Status Report Jun 2016 Complete Submit 6 Month Status Report Dec 2016 Complete Submit 6 Month Status Report Jun 2017 Not Started Design Engineering On-site/Complete Jun 2017 Not Started Submit 6 Month Status Report Dec 2017 Not Started Operations Procedure Changes Jun 2018 Not Started Developed Site Specific Maintenance Procedure Jun 2018 Not Started Developed Training Complete Jun 2018 Not Started Submit 6 Month Status Report Jun 2018 Not Started Implementation Outage Sep 2018 Not Started Walk Through Sep 2018 Not Started Demonstration/Functional Test Procedure Changes Active Sep 2018 Not Started Submit Completion Report Nov 2018 Not Started

  • Date changed for this six month update Page 2 of 6

JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 4 Changes to Compliance Method There is no change to the compliance method that meets NEI 13-02 (Reference 4). The JAF design changes to the HCVS will continue to meet the requirements of Order EA 109 (Reference 1). There are several clarifications to the information presented in the JAF HCVS Overall Inspection Plans (OIP) based on the final detailed design. The following clarifications are described based on the applicable Order section items as well as the applicable sections in the OIP.

Phase 1 Overall Integrated Plan (Reference 2): Part 2 [Discussion of BDBEE Venting];

Order EA-13-109 (Reference 1) Item 1.2.1, 1.2.8, 1.2.9 The instrumentation credited for initial operation and monitoring of the HCVS venting within the Phase 1 OIP requires updating to include the component identifiers and remove the system pressure indication from the JAF HCVS design. In addition, the existing MCR /

Relay Room key parameters and indicators are refined to a more specific list of instrumentation. This refined list is consistent with the Phase 2 MCR / Relay Room instrumentation.

The Phase 1 OIP instrumentation tables are updated below:

Key Parameter Component Identifier Indication Location HCVS Effluent Temperature 27TI-115 Admin Building Hallway (27CAD-PNL-1) 27PI-149 27PI-150 HCVS Pneumatic Supply 27PI-151 Admin Building Hallway Pressure 27PI-152 27PI-153 27DC-117A, B HCVS Valve Position 27DC-118A, B Admin Building Hallway (27CAD-PNL-1)

Indication 27DC-142A, B HCVS Radiation Monitor 27RM-106 Admin Building Hallway (27CAD-PNL-2)

HCVS Electrical Power 27AM-1, 27VM-1 Admin Building Hallway (27CAD-PNL-1);

Supply 27AM-2, 27VM-2 DC A Equipment Room Key Parameter Component Identifier Indication Location 27PI-115A1, 2 Drywell Pressure MCR 27PI-115B1, 2 Torus Water Level 23LI-202A, B MCR Phase 2 Overall Integrated Plan (Reference 3): Sketch 3 FLEX / SAWA Equipment Location; Order EA-13-109 (Reference 1) Item 1.2.8, 2.1, 2.2, 2.3 The primary and alternate locations of the FLEX / Severe Accident Water Addition (SAWA) diesel generators have been switched. Sketch 3 has been updated to reflect this change.

Page 3 of 6

JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 5 Need for Relief / Relaxation and Basis for the Relief / Relaxation On September 8, 2016, Entergy Nuclear Operations, Inc. (ENOI) submitted a request for extension until June 30, 2018 to comply with requirements for implementation of Phase 1 (wetwell) vent at JAF (Reference 9). No extension for Phase 2 has been submitted.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following table provides a summary of the open items documented in the Phase 1 and Phase 2 Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Open Items Status Phase 1 None Phase 2 Complete hydraulic analysis of diesel fire pump for SAWA / SAWM In-Progress - Complete flowrates hydraulic analysis of diesel fire pump for Severe Accident Water Addition (SAWA) / Severe Accident Water Management (SAWM) flowrates Identify and evaluate severe accident conditions for Phase 2 manual In-Progress actions.

The FLEX Engineering Change (EC 52736) has not been completed; Complete; Approved therefore, any reference to this information is considered unverified. December 2016 Open items from Phase 1 Interim Staff Evaluation (Reference 7) are provided in Attachment 2 to this letter.

Open items from Phase 2 Interim Staff Evaluation (Reference 8) are provided in Attachment 3 to this letter.

7 Interim Staff Evaluation Impacts There are no potential impacts to the Phase 1 Interim Staff Evaluation (Reference 7) identified at this time.

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JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 8 References The following references support the updates to the Phase 1 & 2 Overall Integrated Plan described in this attachment.

1. NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions dated June 6, 2013 (ML13143A321).
2. Letter JAFP-14-0075, James A. FitzPatrick 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 (ML14181B117).
3. Letter JAFP-15-0149, James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015 (ML15365A593).
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 (ML15113B318).
5. NRC Interim Staff Guidance, JLD-ISG-2013-02, Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 0, dated November 2013 (ML13304B836).
6. NRC Interim Staff Guidance, JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated April 2015 (ML15104A118)
7. James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated February 12, 2015, (ML15007A090).
8. James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents), dated December 16, 2016, (ML16343B030).
9. Letter JAFP-16-0148, Request for Extension to Comply with NRC Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated September 8, 2016 (ML16252A482).

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JAFP-16-0192 Attachment 1 James A. FitzPatrick (JAF) Nuclear Power Plants Fifth Six Month Status Report for the Implementation of Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Sketch 3: FLEX / SAWA Equipment Location Page 6 of 6

JAFP-16-0192 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items (4 Pages)

JAFP-16-0192 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response COMPLETE Make available for NRC staff audit analyses JAF is capable of (a) venting the equivalent of one (1) percent of demonstrating that HCVS has the capacity to licensed/rated thermal power and (b) the Torus is capable of vent the steam/energy equivalent of one (1) absorbing the decay heat from full power to one (1) percent percent of licensed/rated thermal power (unless licensed/rated thermal power to maintain the integrity of primary a lower value is justified), and that the containment.

suppression pool and the HCVS together are Section 3.2.2.1 1

able to absorb and reject decay heat, such that Section 3.2.2.2 Auditable analyses to justify the capability of the Torus, as described following a reactor shutdown from full power in this action, have been issued as calculation JAF-CALC-14-00015 containment pressure is restored and then (part of the approved design change package EC 52721) and maintained below the primary containment calculation JAF-CALC-15-00026 (part of the approved design design pressure and the primary containment change package EC 58158). For additional discussion, see EC pressure limit.

52721 Topic Notes Section 3.1.7 entitled Hydraulic Requirements.

COMPLETE The HCVS piping from the Torus to the discharge above the RB Roof is designed to be seismically rugged as supported by calculations JAF-CALC-14-00017, JAF-CALC-15-00008, JAF-CALC-15-00033, and JAF-CALC-14-00016 (part of the approved Make available for NRC staff audit the seismic design change package EC 52721).

2 and tornado missile final design criteria for the Section 3.2.2.3 HCVS stack.

Protection from tornado missiles is acceptable in accordance with evaluations based on the HCVS-WP-04 guidance. See EC 52721 Topic Notes Section 3.1.6.1 entitled Structural Requirements.

Specifically, see the associated subsection entitled Tornado Missiles.

Page 1 of 4

JAFP-16-0192 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response COMPLETE The HCVS Battery System will support a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of Section 3.2.2.4 operation. Refer to EC 52721 Topic Notes, Section 3.1.4 entitled Section 3.2.3.1 "Electrical Requirements." Specifically, refer to the subsections Make available for NRC staff audit the final Section 3.2.3.2 entitled "Battery Selection and Sizing," "Battery Charger Selection sizing evaluation for HCVS batteries/battery Section 3.2.4.1 3 and Sizing," and the associated EC attachment, P2e Sequence No.

charger including incorporation into FLEX DG Section 3.2.4.2 6.003.

loading calculation. Section 3.2.5.1 Section 3.2.5.2 The HCVS battery load has been incorporated into the FLEX DG via Section 3.2.6 approved EC 52736 (FLEX Strategy) and associated calculation JAF-CALC-15-00031.

COMPLETE Section 3.2.2.4 The HCVS pneumatic system design sizing will be capable of 12 Section 3.2.3.1 cycles in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The sizing of the nitrogen motive force Section 3.2.3.2 Make available for NRC staff audit and purge systems is provided in calculations JAF-CALC-15-00013 Section 3.2.4.1 4 documentation of the HCVS nitrogen pneumatic and JAF-CALC-15-00038, respectively (part of the approved design Section 3.2.4.2 system design including sizing and location. change package EC 52721). For additional discussion, see EC Section 3.2.5.1 52721 Topic Notes Section 3.1.6.3 entitled Cross Flow & Hydrogen Section 3.2.5.2 Detonation. Specifically, see the associated subsection entitled Section 3.2.6 HCVS Pipeline Protection.

COMPLETE The JAF strategy for preventing hydrogen detonation and deflagration beyond the final isolation point (valve) is a nitrogen Provide a description of the final design of the purge system. Concurrent with closing the isolation valve, the purge 5 HCVS to address hydrogen detonation and Section 3.2.2.6 system will be initiated to purge the vented fluid from the HCVS deflagration. pipeline. For additional discussion, see EC 52721 Topic Notes Section 3.1.6.3 entitled Cross Flow & Hydrogen Detonation.

Specifically, see the associated subsection entitled HCVS Pipeline Protection.

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JAFP-16-0192 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response COMPLETE At JAF the interfaces between the RB and the HCVS pipeline are limited to normally closed, small bore drain and instrument valves Provide a description of the strategies for minimizing the hydrogen gas migration and ingress into the Reactor hydrogen control that minimizes the potential for Building. In addition, migration to the Standby Gas Treatment 6 Section 3.2.2.6 hydrogen gas migration and ingress into the System is minimized through the use of existing Class VI MOVs that reactor building or other buildings. will be leak tested in accordance with NEI 13-02. For additional discussion, see EC 52721 Topic Notes Section 3.1.6.3 entitled Cross Flow & Hydrogen Detonation. Specifically, see the associated subsection entitled Interconnecting Systems.

NOT COMPLETE Make available for NRC staff audit descriptions The required instrumentation and controls (existing and new) are of all instrumentation and controls (existing and identified as part of the JAF OIP, Part 2. The qualification of the 7 Section 3.2.2.10 planned) necessary to implement this order equipment has been described within the approved design change including qualification methods. package EC 52721; however, additional documentation must be supplied by vendors before this item is completed.

NOT COMPLETE Make available for NRC staff audit The qualification of the equipment has been described within the 8 documentation of a seismic qualification Section 3.2.2.9 approved design change package EC 52721; however, additional evaluation of HCVS components. documentation must be supplied by vendors before this item is completed.

Make available for NRC staff audit the descriptions of local conditions (temperature, NOT COMPLETE radiation and humidity) anticipated during ELAP The approved design change package EC 52721 describes the and severe accident for the components Section 3.2.2.3 conditions and capability of the equipment to function within the (valves, instrumentation, sensors, transmitters, Section 3.2.2.5 9 stated conditions. The qualification of the equipment has been indicators, electronics, control devices, etc.) Section 3.2.2.9 described within the approved design change package EC 52721; required for HCVS venting including Section 3.2.2.10 however, additional documentation must be supplied by vendors confirmation that the components are capable before this item is completed.

of performing their functions during ELAP and severe accident conditions.

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JAFP-16-0192 Attachment 2 Response to Phase 1 Interim Staff Evaluation Open Items OI Action Comment Response COMPLETE At Fitzpatrick, the existing PCIVs (27AOV-117 and -118) that will be Make available for NRC staff audit part of the EA-13-109 HCVS flow path are currently a part of the GL documentation of an evaluation verifying the 89-16 containment hardened pipe flow path. Calculation existing containment isolation valves, relied 10 Section 3.2.2.9 14620.9011-US(N)-004 "Suppression Chamber (20") & Drywell (24")

upon for the HCVS, will open under the Vent & Purge Butterfly Valves based on RELAP 5/MOD2 56 psig maximum expected differential pressure during and 62 psig Results" concludes the valves can be opened against BDBEE and severe accident wetwell ventinq.

the maximum expected differential pressure during an Order EA 109 event, the primary containment pressure limit of 62 psig.

COMPLETE Make available for NRC staff audit The capability for communication between the HCVS operation documentation that demonstrates adequate locations and decision makers will be evaluated as part of EP-11 communication between the remote HCVS Section 3.2.2.5 Communications modifications. The EP-Communications detailed operation locations and HCVS decision makers design (EC 53903) has been approved and will be implemented during ELAP and severe accident conditions.

prior to HCVS compliance is required.

Section 3.2.1 Section 3.2.2.3 COMPLETE Make available for NRC staff audit an Section 3.2.2.4 The approved design change package EC 52721, along with evaluation of temperature and radiological Section 3.2.2.5 supporting calculations, has identified the anticipated conditions 12 conditions to ensure that operating personnel Section 3.2.2.10 during ELAP and a Severe Accident and confirm the capability for can safely access and operate controls and Section 3.2.4.1 operating personnel to safely access and operate controls and support equipment. Section 3.2.4.2 support equipment. For additional discussion, see EC 52721 Topic Section 3.2.5.2 Notes Section 3.1.11.3 entitled HCVS Manual Actions.

Section 3.2.6 Page 4 of 4

JAFP-16-0192 Attachment 3 Response to Phase 2 Interim Staff Evaluation Open Items (1 Page)

JAFP-16-0192 Attachment 3 Response to Phase 2 Interim Staff Evaluation Open Items OI Action Comment Response Licensee to evaluate the SAWA equipment and controls, as well as the ingress and egress 1 paths for the expected severe accident Section 3.3.2.3 In progress conditions (temperature, humidity, radiation) for the sustained operating period.

Licensee to demonstrate how instrumentation and equipment being used for SAWA and supporting equipment is capable to perform for 2 Section 3.3.2.3 In progress the sustained operating period under the expected temperature and radiological conditions.

Licensee to demonstrate that containment failure as a result of overpressure can be 3 Section 3.3.3 In progress prevented without a drywell vent during severe accident conditions.

Licensee to demonstrate that there is adequate communication between the primary HCVS 4 operating station and the operator at the FLEX Section 3.3.3.4 In progress supply hose splitter valve during severe accident conditions.

Licensee to demonstrate the SAWA/SAWM flow 5 instrumentation qualification for the expected Section 3.3.3.4 In progress environmental conditions.

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