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)

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
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)

Text

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.

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

Dear Sir or Madam:

JAFP-16-0192 Page 2 of 2 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 Regulation NRG Regional Administrator NRG Resident Inspector NRG Project Manager NYSPSC NYSERDA

JAFP-16-0192 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 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 Page 1 of 6 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.

Milestone Target Completion Date Activity Status Comments Phase 1 Hold preliminary / conceptual design meeting Jan. 2014 Complete Submit Overall Integrated Implementation Plan Jun. 2014 Complete 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 Developed April 2018*

Not Started

JAFP-16-0192 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 Page 2 of 6 Milestone Target Completion Date Activity Status Comments Site Specific Maintenance Procedure Developed April 2018*

Not Started HCVS Implementation Complete May 2018*

In Progress See Section 5.0 (Jan. 2017 Outage); Milestone Desc. Changed Procedure Changes Active Jun. 2018*

Not Started Walk Through Demonstration/Functional Test Jun. 2018*

Not Started Training Complete Jun. 2018*

Not Started Submit Completion Report Jun. 2018*

Not Started Phase 2 Hold preliminary/conceptual design meeting Oct 2015 Complete Submit Overall Integrated Implementation Plan 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 Design Engineering On-site/Complete Jun 2017 Not Started Submit 6 Month Status Report Dec 2017 Not Started Operations Procedure Changes Developed Jun 2018 Not Started Site Specific Maintenance Procedure Developed Jun 2018 Not Started Training Complete Jun 2018 Not Started Submit 6 Month Status Report Jun 2018 Not Started Implementation Outage Sep 2018 Not Started Walk Through Demonstration/Functional Test Sep 2018 Not Started Procedure Changes Active Sep 2018 Not Started Submit Completion Report Nov 2018 Not Started

• Date changed for this six month update

JAFP-16-0192 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 Page 3 of 6 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)

HCVS Pneumatic Supply Pressure 27PI-149 27PI-150 27PI-151 27PI-152 27PI-153 Admin Building Hallway HCVS Valve Position Indication 27DC-117A, B 27DC-118A, B 27DC-142A, B Admin Building Hallway (27CAD-PNL-1)

HCVS Radiation Monitor 27RM-106 Admin Building Hallway (27CAD-PNL-2)

HCVS Electrical Power Supply 27AM-1, 27VM-1 27AM-2, 27VM-2 Admin Building Hallway (27CAD-PNL-1);

DC A Equipment Room Key Parameter Component Identifier Indication Location Drywell Pressure 27PI-115A1, 2 27PI-115B1, 2 MCR 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.

JAFP-16-0192 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 Page 4 of 6 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 flowrates In-Progress - Complete 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 actions.

In-Progress The FLEX Engineering Change (EC 52736) has not been completed; therefore, any reference to this information is considered unverified.

Complete; Approved December 2016 Open items from Phase 1 Interim Staff Evaluation (Reference 7) are provided in to this letter.

Open items from Phase 2 Interim Staff Evaluation (Reference 8) are provided in 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.

JAFP-16-0192 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 Page 5 of 6 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).

JAFP-16-0192 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 Page 6 of 6 Sketch 3: FLEX / SAWA Equipment Location

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

JAFP-16-0192 Response to Phase 1 Interim Staff Evaluation Open Items Page 1 of 4 OI Action Comment

Response

1 Make available for NRC staff audit analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one (1) percent of 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.

Section 3.2.2.1 Section 3.2.2.2 COMPLETE JAF is capable of (a) venting the equivalent of one (1) percent of licensed/rated thermal power and (b) the Torus is capable of absorbing the decay heat from full power to one (1) percent licensed/rated thermal power to maintain the integrity of primary containment.

Auditable analyses to justify the capability of the Torus, as described in this action, have been issued as calculation JAF-CALC-14-00015 (part of the approved design change package EC 52721) and calculation JAF-CALC-15-00026 (part of the approved design change package EC 58158). For additional discussion, see EC 52721 Topic Notes Section 3.1.7 entitled Hydraulic Requirements.

2 Make available for NRC staff audit the seismic and tornado missile final design criteria for the HCVS stack.

Section 3.2.2.3 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 design change package EC 52721).

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.

JAFP-16-0192 Response to Phase 1 Interim Staff Evaluation Open Items Page 2 of 4 OI Action Comment

Response

3 Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

Section 3.2.2.4 Section 3.2.3.1 Section 3.2.3.2 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6 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 operation. Refer to EC 52721 Topic Notes, Section 3.1.4 entitled "Electrical Requirements." Specifically, refer to the subsections entitled "Battery Selection and Sizing," "Battery Charger Selection and Sizing," and the associated EC attachment, P2e Sequence No.

6.003.

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

4 Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location.

Section 3.2.2.4 Section 3.2.3.1 Section 3.2.3.2 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.1 Section 3.2.5.2 Section 3.2.6 COMPLETE The HCVS pneumatic system design sizing will be capable of 12 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 and purge systems is provided in calculations JAF-CALC-15-00013 and JAF-CALC-15-00038, respectively (part of the approved design change package EC 52721). 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.

5 Provide a description of the final design of the HCVS to address hydrogen detonation and deflagration.

Section 3.2.2.6 COMPLETE The JAF strategy for preventing hydrogen detonation and deflagration beyond the final isolation point (valve) is a nitrogen purge system. Concurrent with closing the isolation valve, the purge system will be initiated to purge the vented fluid from the HCVS 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.

JAFP-16-0192 Response to Phase 1 Interim Staff Evaluation Open Items Page 3 of 4 OI Action Comment

Response

6 Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the reactor building or other buildings.

Section 3.2.2.6 COMPLETE At JAF the interfaces between the RB and the HCVS pipeline are limited to normally closed, small bore drain and instrument valves minimizing the hydrogen gas migration and ingress into the Reactor Building. In addition, migration to the Standby Gas Treatment System is minimized through the use of existing Class VI MOVs that 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.

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

Section 3.2.2.10 NOT COMPLETE The required instrumentation and controls (existing and new) are identified as part of the JAF OIP, Part 2. The qualification of the equipment has been described within the approved design change package EC 52721; however, additional documentation must be supplied by vendors before this item is completed.

8 Make available for NRC staff audit documentation of a seismic qualification evaluation of HCVS components.

Section 3.2.2.9 NOT COMPLETE The qualification of the equipment has been described within the approved design change package EC 52721; however, additional documentation must be supplied by vendors before this item is completed.

9 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.

Section 3.2.2.3 Section 3.2.2.5 Section 3.2.2.9 Section 3.2.2.10 NOT COMPLETE The approved design change package EC 52721 describes the conditions and capability of the equipment to function within the stated conditions. The qualification of the equipment has been described within the approved design change package EC 52721; however, additional documentation must be supplied by vendors before this item is completed.

JAFP-16-0192 Response to Phase 1 Interim Staff Evaluation Open Items Page 4 of 4 OI Action Comment

Response

10 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 ventinq.

Section 3.2.2.9 COMPLETE At Fitzpatrick, the existing PCIVs (27AOV-117 and -118) that will be part of the EA-13-109 HCVS flow path are currently a part of the GL 89-16 containment hardened pipe flow path. Calculation 14620.9011-US(N)-004 "Suppression Chamber (20") & Drywell (24")

Vent & Purge Butterfly Valves based on RELAP 5/MOD2 56 psig and 62 psig Results" concludes the valves can be opened against the maximum expected differential pressure during an Order EA 109 event, the primary containment pressure limit of 62 psig.

11 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.

Section 3.2.2.5 COMPLETE The capability for communication between the HCVS operation locations and decision makers will be evaluated as part of EP-Communications modifications. The EP-Communications detailed design (EC 53903) has been approved and will be implemented prior to HCVS compliance is required.

12 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.

Section 3.2.1 Section 3.2.2.3 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 COMPLETE The approved design change package EC 52721, along with supporting calculations, has identified the anticipated conditions during ELAP and a Severe Accident and confirm the capability for operating personnel to safely access and operate controls and support equipment. For additional discussion, see EC 52721 Topic Notes Section 3.1.11.3 entitled HCVS Manual Actions.

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

JAFP-16-0192 Response to Phase 2 Interim Staff Evaluation Open Items Page 1 of 1 OI Action Comment

Response

1 Licensee to evaluate the SAWA equipment and controls, as well as the ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period.

Section 3.3.2.3 In progress 2

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

Section 3.3.2.3 In progress 3

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

Section 3.3.3 In progress 4

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

Section 3.3.3.4 In progress 5

Licensee to demonstrate the SAWA/SAWM flow instrumentation qualification for the expected environmental conditions.

Section 3.3.3.4 In progress