ML18215A204

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Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRC Order EA-13-109 to Modify Licenses with Re. to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML18215A204
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/06/2018
From: Rajender Auluck
Beyond-Design-Basis Engineering Branch
To: Sawatzke B
Energy Northwest
Lee B
References
CAC MF4383, EA-13-009, EPID L-2014-JLD-0045
Download: ML18215A204 (18)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 6, 2018 Mr. Bradley J. Sawatzke Chief Executive Officer Energy Northwest MD 1023 76 North Power Plant Loop P.O. Box 968 Richland, WA 99352

SUBJECT:

COLUMBIA GENERATING STATION - REPORT FOR THE AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO NRC ORDER EA-13-109 TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS (CAC NO. MF4383; EPID L-2014-JLD-0045)

Dear Mr. Sawatzke:

On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," to all Boiling-Water Reactor licensees with Mark I and Mark II primary containments. The order requirements are provided in Attachment 2 to the order and are divided into two parts to allow for a phased approach to implementation. The order required licensees to submit for review overall integrated plans (OIPs) that describe how compliance with the requirements for both phases of Order EA-13-109 will be achieved.

By letter dated June 30, 2014 (ADAMS Accession No. ML14191A688), Energy Northwest (the licensee) submitted its Phase 1 OIP for Columbia Generating Station (Columbia). By letters dated December 17, 2014, June 30, 2015, December 16, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 29, 2016, June 27, 2017, December 28, 2017, and June 21, 2018 (ADAMS Accession Nos. ML14357A069, ML15181A436, ML15351A363, ML16182A080, ML16364A245, ML17178A276, ML18002A438, and ML18176A186 respectively), the licensee submitted its 6-month updates to the OIP. The NRC staff reviewed the information provided by the licensee and issued interim staff evaluations (ISEs) for Phase 1 and Phase 2 of Order EA-13-109 for Columbia by letters dated March 25, 2015 (ADAMS Accession No. ML14335A158), and September 29, 2016 (ADAMS Accession No. ML16266A233), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.

The NRC staff is using the audit process described in letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328),

to gain a better understanding of licensee activities being performed for compliance with the order. As part of the audit process, the staff reviewed the licensee's closeout of the ISE open

B. Sawatzke items. The NRC staff conducted a teleconference with the licensee on July 19, 2018. The enclosed audit report provides a summary of that aspect of the audit.

If you have any questions, please contact me at (301) 415-1025 or by e-mail at Rajender.Auluck@nrc.gov.

Sincerely, Rajender Auluck, Senior Project Manager Beyond-Design-Basis Engineering Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

Audit report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO ORDER EA-13-109 MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 BACKGROUND On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condition," to all Boiling-Water Reactor (BWR) licensees with Mark I and Mark II primary containments. The order requirements are divided into two parts to allow for a phased approach to implementation.

Phase 1 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a Hardened Containment Vent System (HCVS), using a vent path from the containment wetwell to remove decay heat, vent the containment atmosphere (including steam, hydrogen, carbon monoxide, non-condensable gases, aerosols, and fission products}, and control containment pressure within acceptable limits. The HCVS shall be designed for those accident conditions (before and after core damage) 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 or extended loss of alternating current (ac) power {ELAP). The order required all applicable licensees, by June 30, 2014, to submit to the Commission for review an overall integrated plan (OIP) that describes how compliance with the Phase 1 requirements described in Order EA-13-109 will be achieved.

Phase 2 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a system that provides venting capability from the containment drywell under severe accident conditions, or, alternatively, to develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. The order required all applicable licensees, by December 31, 2015, to submit to the Commission for Enclosure

review an OIP that describes how compliance with the Phase 2 requirements described in Order EA-13-109 Attachment 2 will be achieved.

By letter dated June 30, 2014 (ADAMS Accession No. ML14191A688), Energy Northwest (the licensee) submitted its Phase 1 OIP for Columbia Generating Station (Columbia). By letters dated December 17, 2014, June 30, 2015, December 16, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, December 29, 2016, June 27, 2017, December 28, 2017, and June 21, 2018 (ADAMS Accession Nos. ML14357A069, ML15181A436, ML15351A363, ML16182A080, ML16364A245, ML17178A276, ML18002A438, and ML18176A186 respectively), the licensee submitted its 6-month updates to the OIP, as required by the order.

The NRC staff reviewed the information provided by the licensee and issued interim staff evaluations (ISEs) for Phase 1 and Phase 2 of Order EA-13-109 for Columbia by letters dated March 25, 2015 (ADAMS Accession No. ML14335A158), and September 29, 2016 (ADAMS Accession No. ML16266A233), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.

The NRC staff is using the audit process in accordance with the letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328), to gain a better understanding of licensee activities as they come into compliance with the order. The staff reviews submitted information, licensee documents (via ePortals}, and preliminary Overall Program Documents (OPDs)/OIPs, while identifying areas where additional information is needed. As part of this process, the staff reviewed the licensee closeout of the ISE open items.

AUDIT

SUMMARY

As part of the audit, the NRC staff conducted a teleconference with the licensee on July 19, 2018. The purpose of this audit teleconference was to continue the audit review and provide the NRC staff the opportunity to engage with the licensee regarding the closure of open items from the ISEs. As part of the preparation for the audit call, the staff reviewed the information and/or references noted in the OIP updates to ensure that closure of ISE open items and the HCVS design are consistent with the guidance provided in Nuclear Energy Institute (NEI) 13-02, Revision 1, other related documents (e.g. white papers (ADAMS Accession Nos.

ML14126A374, ML14358A040, ML15040A038 and ML15240A072, respectively) and frequently asked questions (FAQs), (ADAMS Accession No. ML15271A148)) that were developed and reviewed as part of overall guidance development. The NRC staff audit members are listed in Table 1. Table 2 is a list of documents reviewed by the staff. Table 3 provides the status of the ISE open item closeout for Columbia. The open items are taken from the Phase 1 and Phase 2 ISEs issued on March 25, 2015, and September 29, 2016, respectively.

FOLLOW UP ACTIVITY The staff continues to audit the licensee's information as it becomes available. During the teleconference on July 19, 2018, the licensee stated that the responses to the Phase 2 ISE open items are still under development and will be included in the December 2018, six-month status update. In response, the NRC staff stated that the staff will review the information once it is available on the ePortal and will arrange for another teleconference call, if needed. The staff will issue further audit reports for Columbia, as appropriate.

Following the licensee's declarations of order compliance, the licensee will provide a final integrated plan (FIP) that describes how the order requirements are met. The NRC staff will evaluate the FIP, the resulting site-specific OPDs, as appropriate, and other licensee documents, prior to making a safety determination regarding order compliance.

CONCLUSION This audit report documents the staff's understanding of the licensee's closeout of the ISE open items, based on the documents discussed above. The staff notes that several of these documents are still preliminary, and all documents are subject to change in accordance with the licensee's design process. In summary, the staff has no further questions on how the licensee has addressed the ISE open items, based on the preliminary information, but notes that some open items are designated by the staff to be open or pending as described in Table 3 below.

The status of the NRC staff's review of these open items may change as additional information is provided to the staff, or if the licensee changes its plans as part of final implementation.

Changes in the NRC staff review will be communicated in the ongoing audit process.

Attachments:

1. Table 1 - NRC Staff Audit and Teleconference Participants
2. Table 2 - Audit Documents Reviewed
3. Table 3 - ISE Open Item Status Table

Table 1 - NRC Staff Audit and Teleconference Participants Title Team Member Organization Team Lead/Sr. Project Manager Raiender Auluck NRR/DLP Project Manager Support/Technical Support - Containment / Ventilation Brian Lee NRR/DLP Technical Support - Containment /

Ventilation Bruce Heida NRR/DLP Technical Support - Electrical Kerby Scales NRR/DLP Technical Support - Balance of Plant Kevin Roche NRR/DLP Technical Support - l&C Steve Wyman NRR/DLP Technical Support - Dose John Parillo NRR/DRA Attachment 1

Table 2 - Audit Documents Reviewed Calculation NE-02-15-06, "Dose Rates from the Hardened Containment Vent (HCV) Outside the Reactor Building During a Postulated Beyond Design Basis (BOB) Severe Accident Following an Extended Loss of AC Power (ELAP)," Revision 1 Calculation TM-2195, "Remote Operating Station Access and Habitability During HCV Operation," Revision 0 Calculation ME-02-14-02, "General Technical Support for Fukushima Related Licensing Documents," Revision 1 Calculation ME-02-13-03, "Pipe Size and Pressure Drop Calculation for the Hardened Containment Vent System," Revision 2 Calculation ME-02-14-04, "Reactor Building Accessibility and Equipment Operability During an Extended Loss of AC Power (ELAP)," Revision 1 Calculation ME-02-14-17, "Hardened Containment Vent (HCV) Nitrogen Relief Valve Sizing (HCV-RV-101)," Revision 1 Calculation ME-02-15-08, "Evaluation of the Hardened Containment Vent (HCV) Compressed Nitrogen Supply System for HCV-RD-60, HCV-RD-54, HCV-A0-1&2," Revision 1 Calculation TM-2196, "Evaluation of Certain HCV Related Components Under Severe Accident ELAP Environment with HCV Use," Revision O Calculation E/1-02-13-03, "Battery Sizing Calculation for the Hardened Containment Vent (HCV)

System," Revision 1 Calculation E/1-02-91-03, "Calculation for Division 1 and 2 and 3 Diesel Generator Loading,"

Revision 20 Engineering Change (EC) 11763, "New Hardened Containment Vent (HCV) System," Revison 1 OI-HCV-06 AR 25006 Instrument Qualification OI-HCV-09 Spreadsheet - Temperature and Dose for Component/Location CVI 1260-00, 1 - HCV-RIS-RAD/1 Procedure 5.6.1, "Station Blackout (SBO) and Extended Loss of AC Power ELAP," Revision 29 Procedure 5.6.2, "Station Blackout (SBO) and Extended Loss of AC Power ELAP Attachments,"

Revision 11 Procedure 5.2.1, "Primary Containment Control," Revision 27 Attachment 2

Columbia Generating Station Vent Order Interim Staff Evaluation Open Items:

Table 3 - ISE Open Item Status Table ISE Open Item Number Licensee Response - Information NRC Staff Close-out notes Safety Evaluation (SE) provided in 6 month updates and on the status Requested Action ePortal Closed; Pending; Open (need additional information from licensee)

Phase 1 ISE 01 1 Letter G02-15-175. The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff The location of the remote operating month updates and on the [Staff evaluation to be audit the location of the ROS. station is shown on Figure 1-1. ePortal. included in SE Section 3.1.2.4]

Referenced Figure 1-1 indicates the remote operating station (ROS) is located at the west end of the Diesel Generator Building.

No follow-up questions.

Phase 1 ISE 01 2 Due to the dose rates expected during a The NRC staff reviewed the Closed severe accident, the use of the portable information provided in the 6-Make available for NRC staff air compressor has been replaced by month updates and on the [Staff evaluation to be audit the location of the installing a spare nitrogen (N2) bottle in ePortal. included in SE Section portable air compressor. the instrument pneumatics rack. 3.1.2.6]

As indicated in the licensee's revised strategy, a portable air compressor will not be utilized.

Instead a spare N2 bottle in the instrument rack has been installed.

No follow-up auestions.

Phase 1 ISE 01 3 DG5 is stored in FLEX Building 600 which The NRC staff reviewed the Closed is shown on Sketch 1 of letter G02 information provided in the 6-Make available for NRC staff 031. The expected deployment location month updates and on the [Staff evaluation to be audit the location of the of DG5 is shown on Figure 1-1 of letter ePortal. included in SE Section portable diesel generators. G02-15-175. DG4 has not been moved 3.1.2.6]

Attachment 3

and remains in its normal location The location of the portable DGs approximately 69' south of the diesel was confirmed and discussed generator (DG) building. during the closure of the mitigating strategies order EA 049.

No follow-up questions.

Phase 1 ISE 01 4 The hardened containment vent (HCV) is The NRC staff reviewed the Closed operated from the main control room or information provided in the 6-Make available for NRC staff the remote operating station located in the month updates and on the [Staff evaluation to be audit an evaluation of diesel generator building. TM-2195 ePortal. included in SE Sections temperature and radiological evaluated these locations under severe 3.1.1 .2 and 3.1.1.3]

conditions to ensure that accident conditions and found both Calculation TM-2195, "Remote operating personnel can safely accessible and habitable. Therefore, both Operating Station Access and access and operate controls locations are also accessible and Habitability during HCV and support equipment. habitable to support early (anticipatory) Operation," predicts the Main venting. Additional evaluations of the Control Room (MCR) maximum areas used during severe accident for temperature to be 117.2 degrees water addition and water management Fahrenheit (°F) (implementing are being evaluated under Phase 2 RAls actions in FLEX document TM-1 and 2 which remain Open. 2187) and remains below the Licensee Controlled Specification limit of 120°F. The peak temperature in the ROS is determined to be 104°F. The licensee employs a toolbox approach where mitigating actions are taken within the skill of the craft based on symptoms to address radiological and thermal conditions.

Calculation ME-02-14-04 Revision 1, determined environmental conditions in various rooms and also determined allowable stay times based on Wet Globe Temperature. Appendix Hof this calculation discusses equipment operability under predicted conditions. Appendix I of this calculation provides reactor building instrumentation locations and directions for direct readings with Fluke meter.

Calculation NE-02-15-06, "Dose Rates from the Hardened Containment Vent (HCV) Outside the Reactor Building During a Postulated Beyond Design Basis (BDB) Severe Accident Following an Extended Loss of AC Power (ELAP)," Revision 1 was performed to determine the integrated radiation dose due to HCVS operation. The NRC staff reviewed this calculation and determined that the licensee used conservative assumptions and followed the guidance outlined in NEI 13-02 Revision 1 and HCVS-WP-02 Revision 0. Based on the expected integrated whole body dose equivalent in the MCR and ROS and the expected integrated whole body dose equivalent for expected actions during the sustained operating period, the NRC staff believes that the order requirements are met.

Based on the evaluations, the temperature and radiological conditions should not inhibit operator actions needed to initiate and operate the HCVS during an ELAP with severe accident conditions.

No follow-up questions.

Phase 1 ISE 01 5 ME-02-13-03 The NRC staff reviewed the Closed information provided in the 6-Make available for NRC staff month updates and on the [Staff evaluation to be audit analyses demonstrating ePortal. included in SE Section that HCVS has the capacity to 3.1.2.1]

vent the steam/energy Calculation ME-02-13-03, "Pipe equivalent of one percent of Sizing and Pressure Drop uprated licensed/rated thermal Calculation for the Hardened power (unless a lower value is Containment Vent System justified), and that the (HCVS)," Revision 2 used a suppression pool and the thermal power of 3556 MWt HCVS together are able to [megawatt thermal]. The 1%

absorb and reject decay heat, thermal power flow equivalent at such that following a reactor 45 per square inch gauge (psig) shutdown from full power primary containment pressure is containment pressure is 132,514 lbm/hr. With 25% margin restored and then maintained it is 165,643 lbm/hr. The below the primary containment calculated flow rate through the design pressure and the HCVS with primary containment primary containment pressure pressure of 45 psig is 250,970 limit. lbm/hr. Calculated total system loss at wetwell pressure of 14.5 psig is 3.36 with a 12" diameter stack (11.374" ID).

No follow-up questions.

Phase 1 ISE 01 6 This information is available for NRC The NRC staff reviewed the Closed audit. information provided in the 6-Make available for NRC staff month updates and on the [Staff evaluation to be audit the descriptions of local ePortal. included in SE Section conditions (temperature, 3.1.1.4]

radiation and humidity) OI-HCV-09 Spreadsheet on anticipated during ELAP and eportal provides overview of severe accident for the temperature and dose for each components (valves, com ponenUlocation.

instrumentation, sensors, transmitters, indicators, OI-HCV-06 AR 25006-06 electronics, control devices, Instrument Qualification is a table

etc.) required for HCVS that summarizes methods for venting including confirmation qualification of specific that the components are components.

capable of performing their functions during ELAP and CVI 1260-00, 1 provides data severe accident conditions. sheets and acceptance testing for RM1000 and other equipment.

The staff's review indicated that the environmental qualifications meet the order requirements.

No follow-up questions.

Phase 1 ISE 01 7 Calculations ME-02-15-08 and ME-02 The NRC staff reviewed the Closed 17 were approved on 8/10/16. ME-02 information provided in the 6-Make available for NRC staff 08 confirms the adequate sizing and month updates and on the [Staff evaluation to be audit documentation of the location of the nitrogen piping and ME ePortal. included in SE Section HCVS nitrogen pneumatic 14-17 sizes the relief valve HCV-RV-101. 3.1.2.6]

system design including sizing Calculations ME-02-15-08, and location The calculations are available for NRC "Evaluation of the Hardened audit. Containment Vent (HCV)

Compressed Nitrogen Supply System for HCV-RD-60, HCV-RD-54, HCV-A0-1&2," Revision 1 and ME-02-14-17, "Hardened Containment Vent (HCV) Nitrogen Relief Valve Sizing (HCV-RV-101 ), " Revision 1, evaluates the HCVS pneumatic system design.

The licensee determined through its evaluation that 3 nitrogen bottles, rated at 2900 psig each, will be sufficient to supply nitrogen for cycling valves of the HCVS system for 7 days.

No follow-up questions.

Phase 1 ISE 01 8 E/1-02-13-03 The NRC staff reviewed the Closed information provided in the 6-

Make available for NRG staff month updates and on the [Staff evaluation to be audit the final sizing evaluation ePortal. included in SE Section for HCVS batteries/battery 3.1.2.6]

charger including incorporation The licensee stated that all into FLEX DG loading electrical power required for calculation. operation of HCVS components is provided by the HGV battery/battery charger.

The battery sizing requirements (in E/1-02-13-03) confirmed that the HGV batteries have a minimum capacity capable of providing power for 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> without recharging, and therefore is adequate.

The licensee provided calculation E/1-02-91-03, "Calculation for Division 1 and 2 and 3 Diesel Generator Loading," Revision 20, which discusses re-powering of the HGV battery charger using a FLEX DG.

No follow-up questions.

Phase 1 ISE 01 9 See Section 4.0 of the Enclosure to this The NRG staff reviewed the Closed letter (December 29, 2016 information provided in the 6-Make available for NRG staff G02-16-171). month updates and on the [Staff evaluation to be audit documentation that ePortal. included in SE Section demonstrates adequate 3.1.1.1]

communication between the The communication methods are remote HCVS operation the same as accepted in Order locations and HCVS decision EA-12-049.

makers during ELAP and severe accident conditions. No follow-up questions.

Phase 1 ISE 0110 Energy Northwest will use Option number The NRG staff reviewed the Closed 5 of the NEI White Paper HCV-WP-03, information provided in the 6-Provide a description of the Hydrogen/Carbon Monoxide Control month updates and on the strategies for hydrogen control Measures and add a check valve at the ePortal.

that minimizes the potential for discharge end of the vent pipe to address [Staff evaluation to be hydrogen gas migration and the flammability of combustible gases. The licensee described that the included in SE Section ingress into the RB or other HCVS design will include a check 3.1.2.12]

buildings. valve to support the HCVS in preventing hydrogen detonation.

The licensee's design is consistent with Option 5 of the NRG-endorsed white paper HCVS-WP-03.

The staff's review of the proposed system indicates that the licensee's design appears to minimize the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

No follow-up questions.

Phase 1 ISE 01 11 Energy Northwest has completed The NRG staff reviewed the Closed compiling the requested information and information provided in the 6-Make available for NRG staff has make it available to the NRG staff. month updates and on the [Staff evaluation to be audit descriptions of all ePortal. included in SE Section instrumentation and controls See OI-HCV-09 Spreadsheet and CVI 3.1.2.8]

(existing and planned) 1260-00, 1. The existing plant instruments necessary to implement this required for HCVS (i.e. wetwell order including qualification level instruments and drywell methods. pressure instruments) meet the requirements of RG 1.97.

OI-HCV-09 Spreadsheet, AR 25006-06, and CVI 1260-00 discusses the qualifications for new HCVS l&C components. The NRG staff's review indicated that the qualification met the order requirements.

No follow-up questions.

Phase 1 ISE 01 12 Columbia will be using an unused The NRC staff reviewed the Closed containment penetration and will be information provided in the 6-Make available for NRC staff installing new containment isolation month updates and on the [Staff evaluation to be audit documentation of an valves. ePortal. included in SE Section evaluation verifying the 3.2.1]

existing containment isolation Since the licensee is installing valves, relied upon for the new containment isolation valves, HCVS, will open under the this item is not applicable, maximum expected differential assuming that the new valves are pressure during BDBEE and sufficient for opening under the severe accident wetwell maximum expected differential venting. pressure during BDBEE and severe accident wetwell venting.

No follow-up questions.

Phase 1 ISE 01 13 The following emergency operating The NRC staff reviewed the Closed procedures (EOPs) provide for information provided in the 6-Make available for NRC staff containment venting during an ELAP month updates and on the [Staff evaluation to be audit site specific details of the event: PPM 5.6.1, SBO/ELAP PPM 5.6.2, ePortal. included in SE Section EOPs when available. SBO and ELAP Attachments PPM 5.2.1, 5.1]

Primary Containment Control. The EOPs for HCVS operation have been developed and are consistent with the guidance in NEI 13-02.

No follow-up questions.

Phase 1 ISE 01 14 Columbia has adopted the current NEI The NRC staff reviewed the Closed guidance on testing and inspection information provided in the 6-Provide justification for not requirements as shown in Table 4-1. month updates and on the [Staff evaluation to be leak testing the HCVS every ePortal. included in SE Section three operating cycles and 3.1.2.13]

after restoration of any breach The licensee has changed its of system boundary within strategy regarding planned testing buildings. and inspection criteria. The licensee has elected to adopt the guidance on testing and inspection requirements as described in Table 4-1 of NEI 13-02.

No follow-up questions.

Phase 2 ISE 01 1 Response to be documented in a future This item will stay open since no Open update. information was provided either Licensee to determine the on the ePortal or in the six-month [Staff evaluation to be location of the FLEX hose- updates. included in SE Sections installed valves and flow 4.1 and 4.4) elements, which will be used to control severe accident water addition/severe accident water management (SAWA/SAWM) flow.

Phase 2 ISE 01 2 Response to be documented in a future This item will stay open since no Open update. information was provided either Licensee to evaluate the on the ePortal or in the six-month [Staff evaluation to be SAWA equipment and updates. included in SE Section controls, as well as ingress 4.5) and egress paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operatinq period.

Phase 2 ISE 01 3 Response to be documented in a future This item will stay open since no Open update. information was provided either Licensee to demonstrate that on the ePortal or in the six-month [Staff evaluation to be containment failure as a result updates. included in SE Sections of overpressure can be 4.1 and 4.2) prevented without a drywell vent during severe accident conditions.

Phase 2 ISE 014 Response to be documented in a future This item will stay open since no Open update. information was provided either Licensee shall demonstrate on the ePortal or in the six-month [Staff evaluation to be how the plant is bounded by updates. included in SE Section the reference plant analysis 4.2) that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed.

Phase 2 ISE 5 Response to be documented in a future This item will stay open since no Open update. information was provided either

Licensee to demonstrate that on the ePortal or in the six-month [Staff evaluation to be there is adequate updates. included in SE Section communication between Main 4.1]

Control Room and the SAWM control location during severe accident conditions.

Phase 2 ISE 01 6 Response to be documented in a future This item will stay open since no Open update. information was provided either Licensee to demonstrate the on the ePortal or in the six-month [Staff evaluation to be SAWM flow instrumentation updates. included in SE Sections qualification for the expected 4.1.1 .3 and 4.2.1.3]

environmental conditions.

ML18215A204 OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA NRR/DLP/PBEB/BC (A) NRR/DLP/PBEB/PM NAME RAuluck SLent BTitus RAuluck DATE 8/6/18 8/3/18 8/6/18 8/6/18