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 L 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 NORTHWEST'S COMBIN ED 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 Vent s Capable of Operation under Severe Accident Conditions," dated June 6, 2013 3. Letter GO2-13-034 from A. L. Ja vorik (Energy Northwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-049 - Overall

Integrated Plan for Mitigating St rategies," dated February 28, 2013 4. Letter GO2-15-175 from A. L. Ja vorik (Energy Northwest) to NRC, "Energy Northwest's 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. Sw ank (Energy Northwest) to NRC, "Energy Northwest's Second Six M onth 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 Ev ents," dated February 27, 2014 6. Letter GO2-16-125 from A. L. Ja vorik (Energy Northwest), "Energy Northwest's Seventh Six-Month Status Update Report for the Implementation of Nuclear Regula tory 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. Javo ik (Energy Northwest), "Energy Northwest's Fourth Six-Month Status Update Report for the Implementation of Nuclear Regula tory 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, "Req uest for Relaxation from NRC Order EA-12-049, 'Order Modifying Licens es 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), "C olumbia Generating Station - Relaxation of Certain Schedule Requirements fo r Order EA-12-049

'Issuance of Order to Modify Licens es 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-mont h update reports. Referenc es 3 and 4 transmitted the OIPs for the Orders.

Reference 5 provided a revis ed OIP for Order EA-12-049. References 6 and 7 transmitted the previ ous 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 Ph ase 1 of NRC Order EA-13-109. Therefore, Energy Northwest is combining the rema ining 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 r eported complete and the implementation requirements of Order EA-12-049 have been met. The enclosure to this letter and its atta chment 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. Theref ore, no update for Order EA-12-049 will be issued in February. The next combi ned 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 in formation, 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 of Jl e 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 Columb ia Generating Station (Columbia).

The Orders contained requirements for mitiga tion strategies for beyond-design-basis external events and the installation of a re liable containment hardened vent capable of operation under severe accident conditions. References 1 and 2 also required submittal of an Overall Integrated Plan (OIP) describ ing how compliance with the requirements described in the Orders will be achieved and requi red the submittal of status reports at six month intervals. This enclosure prov ides Energy Northwest's combined six-month status report for these NRC Orders a combined update of the remaining milestones including any changes to the co mpliance method or schedule. 2.0 Milestone Accomplishments All the Mitigation Milestones required to support restart from Refueling Outage 22 (mitigation implementation out age) with the exception of plant changes directly associated with the implement ation of the reliable hard ened containment vent were reported complete in Reference 3 of this enclosure. 3.0 Milestone Sc hedule 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 Milestone Target Completion Date Activity Status Comments (Include date changes in this column)Submit Overall Integrated Implementation Plan (Phase 1) June 2014 Complete GO2-14-107 6/30/2014 Submit Overall Integrated Implementation Plan (Phase 2) which included a Phase 1 6-month status

update. Dec. 2015 Complete GO2-15-175 12/16/2015 Next Combined Status Update Report for the Mitigation Strategies and Reliable Hardened Containment Vent June 2017 Not Started Issuance of Energy Northwest's letter of compliance with NRC Order EA-

12-049,Section IV.C.3 Aug. 2017 Not Started Issuance of Energy Northwest's letter of compliance with NRC Order EA-

13-109, Phase 1 Aug. 2017 Not Started Submittal of Final Integrated Program Document Order EA 049. Aug. 2017 Not Started GO2-16-171 Enclosure Page 2 of 6 6 th 6-month update for Order EA 109 June 2017 Not Started 7 th 6-month update for Order EA 109 Dec. 2017 Not Started 8 th 6-month update for Order EA 109 June 2018 Not Started 9 th 6-month update for Order EA 109 Dec. 2018 Not Started 10 th 6-month update for Order EA-13-109 June 2019 Not Started Issuance of Energy Northwest's letter of compliance with NRC Order EA-

13-109, Phase 2 Aug. 2019 Not Started The tables below provide the status of t he 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:

Milestone Target Completion Date Activity Status Comments (Include date changes in this column)Hold preliminary/conceptual design meeting June 2014 Complete WW Design Engineering Complete May 2016 This date is changed to Feb 2017 WW Operation Procedure Changes Developed Mar 2017 WW Training Complete Apr. 2017 WW Installation Complete May 2017 WW Procedure Changes Active May 2017 Site Specific WW Maintenance Procedure Developed June 2017 WW Walk Through Demonstration/Functional Test June 2017 Submit WW Completion Report Aug. 2017

GO2-16-171 Enclosure Page 3 of 6 HCV Phase 2 Milestone Schedule Milestone Target Completion Date Activity Status Comments (Include date changes in this column)Hold preliminary/conceptual design meeting July 2016 This date has been changed to Jul 2017 Design Engineering On-site/Complete July 2018 Operations Procedure Changes Developed Jan. 2019 Site Specific Maintenance Procedure Developed Jan. 2019 Training Complete Apr. 2019 Implementation Outage May 2019 Procedure Changes Active May 2019 Walk Through Demonstration/Functional Test June 2019

4.0 Changes

to the Compliance Methods Changes to the OIP for Reliable HCV V ents 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-sit e 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 offsit e communication to be used during an extended loss of alternating current (ac) power (ELAP) event at Columbia are the installed sound powered telepho ne and radio systems. It has been determined that the indoor and outdoor locations where plan t equipment or on-si te FLEX equipment may be used, can be communicated with by using sound-pow ered 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 pow ered phone system, five portable sound powered phone kits are available in each FLEX building. The kits are available to provide point-to-point communi cation to areas that have lost the other forms of communication. They can also be us ed 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 ar e 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 contro l room, technical support center (TSC), emergency operations facility (EOF), alte rnate 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 batteri es are powered by normal site power with the respective facility's 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 In tegrated Plan for Mitigati ng Strategies (EA-12-049):

Reference 6 of this enclosure revised the orig inal overall integrated plan and provided the following Phase 3 discussion for maintain ing 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 di esel 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 r oom 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 Divisi on 2 EDG, thereby prov iding 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 Co ntrol 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 coo ling or suppression pool cooling modes of RHR. This strategy for shutdown cooling can be accomplished utilizing a single large FLEX pump or multip le 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 pr oper fill and vent of the RHR system prior to shutdown cooling operation." Consequently, Columbia's Phas e 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 supplem ent 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 deliv ery. Other NSRC equipment that is not ba ckup or redundant to Phas e 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 fu nction and use the same connection points as the on-site Phase 2 FLEX equipment: NSRC Component Performance Description 480 VAC Diesel-powered Generator 480 Volts AC 1100 kW SG/RPV Water

Makeup Pump 500 PSI 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 relaxati on 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 C apable of Operation under Severe Accident Conditions," dated June 6, 2013 3. Letter GO2-15-124, from D. A. Swank (Energy Northwest) to NRC "Energy Northwest's Fifth Six-Month Status U pdate Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-12-049 Mitigation Strategies for Beyond Design Basis Ex ternal Events," dated August 25, 2015 4. Letter GO2-16-098 from A.L. Javo ik (Energy Northwest), "Energy Northwest's 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. Ja vorik (Energy Northwest), "Energy Northwest's 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 Northwest's Second Six Month Status Update Report for t he 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 - Re laxation of Certain Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigat ion 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 Open Item Action Status Comment OI-HCV-01 Provide resolution of the potential secondary containment bypass leakage path in the first 6-month update of the HCVS OIP CLOSED Closed in Letter GO2-15-175.

Columbia will use a rupture disk to prevent secondary containment bypass leakage. OI-HCV-02 Evaluate the location of the ROS for accessibility.

OPEN OI-HCV-03 Determine the location of the portable air compressor and evaluate for accessibility under Severe Accident HCVS use. Including connection point(s) Including refueling operations OPEN OI-HCV-04 Evaluate the location of the FLEX DG for accessibility under Severe

Accident HCVS use. Including connection point(s) Including refueling operations OPEN OI-HCV-05 Confirm suppression pool heat capacity CLOSED Closed in Letter GO2-15-175.

Calculation ME 14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the suppression pool water when at a minimum Technical Specification level to

control pressure in

containment before venting commences.

OI-HCV-06 Determine the method of qualification for each instrument OPEN OI-HCV-07 Complete the evaluation to determine accessibility, habitability, staffing sufficiency, and communication capability of the ROS. OPEN OI-HCV-08 Identify design codes after design is finalized. OPEN GO2-16-171 Attachment Page 2 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Open Item Action Status Comment OI-HCV-09 Equipment qualifications will include temperature, pressure, radiation level, and total integrated dose radiation from the effluent vent pipe at local and remote locations. OPEN OI-HCV-10 Provide site-specific details of the EOPs when available. Develop procedures for SAWA and

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

The 300 CFM capacity of the air compressor is sufficient.

OI-HCV-12 SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA-12-049 actions). Location of these valves and flow elements will need to be considered per HCVS-FAQ-12. OPEN OI-HCV-13 Reconcile the out-of-service provisions for HCVS/SAWA with the provisions documented in Columbia's PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability. OPEN OI-HCV-14 Complete the evaluation to determine accessibility, habitability, staffing sufficiency, and communication capability during SAWA/SAWM OPEN OI-HCV-15 Perform MAPP analysis for NEI 13-02 figures C-2 through C-6 and determine the time sensitive SAWM

actions OPEN OI-HCV-16 Develop procedure for line-up and use of HCVS OPEN OI-HCV-17 Add sound powered phone extension cable for instrument rack E-IR-85 to inventory procedure CLOSED Additional cable not need as each FLEX building has 5 sound powered phone kits OI-HCV-18 Evaluate deployment pathways for severe accident capable criteria OPEN GO2-16-171 Attachment Page 3 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Open Item Action Status Comment OI-HCV-19 Develop required training and frequency IAW the SAT process OPEN OI-HCV-20 Incorporate approved language of OIP Attachment 2.1.D into site SAMG

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

remote operating station is shown on Figure 1-1.

02 Section 3.2.1 Make available for NRC staff audit the location of the portable air compressor. OPEN 03 Section 3.2.1 Make available for NRC staff audit the location of the portable diesel generators. OPEN 04 Section 3.2.1 Section 3.2.2.4 Section 3.2.2.5 Section 3.2.2.10 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.2 Section 3.2.6 Make available for NRC staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and

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

below the primary containment design pressure and the primary containment pressure limit. CLOSED ME-02-13-03

ME-02-14-13 ME-02-12-18 06 Section 3.2.2.3 Section 3.2.2.5 Section 3.2.2.9 Section 3.2.2.10 Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions. OPEN 07 Section 3.2.2.4 Section 3.2.6 Make available for N RC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location. CLOSED Calculations ME 15-08 and ME-02 17 were approved on

8/10/16. ME-02-15-08 confirms the adequate sizing and location of the nitrogen piping and ME-02-14-17 sizes the relief valve 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 Section Action Status Comment 08 Section 3.2.2.4 Section 3.2.6 Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation. CLOSED E/I-02-13-03 09 Section 3.2.2.5 Make available for NRC staff audit documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions. CLOSED See Section 4.0 of the Enclosure to this letter. 10 Section 3.2.2.6 Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the RB or other buildings. CLOSED Energy Northwest will use Option number 5

of the NEI White

Paper HCV-WP-03, Hydrogen/Carbon Monoxide Control Measures and add a

check valve at the discharge end of the

vent pipe to address

the flammability of combustible gasses.

11 Section 3.2.2.9 Make available for NRC staff audit descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods. OPEN 12 Section 3.2.2.9 Make available for NRC staff audit documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during

BDBEE and severe accident wetwell

venting. CLOSED Columbia will be using an unused

containment penetration and will be installing new containment isolation valves.

GO2-16-171 Attachment Page 6 of 7 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Section Action Status Comment 13 Section 3.4.1 Make available for NRC staff audit site specific details of the EOPs when

available. CLOSED The following EOPs provide for containment

venting during an ELAP event:

PPM 5.6.1, SBO/ELAP PPM 5.6.2, SBO and ELAP Attachments PPM 5.2.1, Primary Containment Control 14 Section 3.4.4 Provide justification for not leak testing the HCVS every three operating cycles and after restoration

of any breach of system boundary within buildings. CLOSED Columbia has adopted the current NEI guidance on testing

and Inspection

requirements as shown in Table 4-1of Reference 4 15 AR Task 36 Add a discussion on communications between the CR, FELX pump, and ROS operators to the December 6-month HCV update. CLOSED Discussed in Section 4.0 of the enclosure to this letter.

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

01/27/2017 due date (D Myers) OI-FLEX-43 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 elevations for the FLEX buildings as well as the deployment routes for the equipment. A LiDAR survey of the site was performed and a topographic plan of the site has been generated to assist in this evaluation. The flooding analysis is currently in progress. The results will be used to provide a response to this question in a future OIP update. (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.)

Closed The flooding hazard reevaluation was completed and the report was provided

to the NRC in letter GO2-16-143, dated 10/6/16.

GO2-16-171 Attachment Page 7 of 7 List of Remaining FLEX Integrated Plan Open Items OI-FLEX-44 A future update to the OIP will address the applicability to Columbia of each of the nine considerations in NEI 12-06 Section 6.2.3.2, Deployment of FLEX Equipment.

(Response to NRC Audit Question 04) (This OI has been changed because the flooding analysis remains in progress and the OI will be closed in a future update.)

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

(Response to NRC Audit Question 04)

Closed The Flooding Hazard Reevaluation Report (FHRR) shows the results are either bounded by the current design basis or available physical margin exists.