GO2-08-054, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems
| ML081080115 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/10/2008 |
| From: | Gambhir S Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, GO2-08-054 | |
| Download: ML081080115 (4) | |
Text
Sudesh K. Garmbhir Vice President, Technical Services EG iP.O. Box 968, PE04 NO TS Richland, WA 99352-0968 Ph. 509.377.8313 I F. 509.377.2354 sgambhir@energy-northwest.com April 10, 2008 G02-08-054 10 CFR 50.54(f)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS"
Reference:
NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core CoolingD,* ,Day Heat Removal; and-Contaihnm-entS pray Sy-stems" dated 'Januia-ry* 1"1;,,-2008.'
Dear Sir or Madam:
The U. S. Nuclear Regulatory Commission (NRC) issued NRC Generic Letter (GL) 2008-01 (Reference 1) to request that each licensee evaluate its Emergency Core Cooling System (ECCS), Residual Heat Removal (RHR) system, and Containment.
Spray System licensing basis, design, testing, and corrective actions to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.
The NRC, in GL 2008-01, requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within 9 months of the date of the GL to"-provide the following information: -
(a) A description of the results of evaluations that were performed pursuant~to the requested actions of the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appenhdix B to 10 CFR Part 50 and the licensing basis and operating lice-nse'as those requirerhients apply toythe&-ubject;Systemn(o';., A ,
the GL; ' -- .. .- bIB.f.
4'
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Page 2 (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
Additionally, the NRC requested that if a licensee cannot meet the requested response date, the licensee "shall provide a response within 3 months of the date of the GL". In the 3-month response, the licensee was requested to describe the alternative course of action that it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
The attachment to this letter contains the Energy Northwest 3-month response to the requested information in NRC GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11,2008.
Energy Northwest makes the following commitments:
Walkdowns that could not be accomplished prior to October 11, 2008 due to the need to erect scaffolding, the restrictions on removal of insulation from piping, the need for entry into high radiation areas, and the need for containment entries that cannot be accomplished during power operation will be completed prior to the end of the next scheduled refueling outage, currently scheduled for May-June 2009.
Any corrective actions requiring plant piping modifications identified as a result of the deferred walkdowns will be provided to the NRC staff within 90 days following completion of that refueling outage.
If you have any questions, please contact Mr. MC Humphreys, Licensing Supervisor at (509) 377-4025. I declare under penalty of perjury that the foregoing is true and correct.
Executed on the date of this letter.
Resbeltfully, SKambhir Vice President, Technical Services Attachment cc: EE Collins, Jr. - NRC RIV WA Horin - Winston & Strawn CF Lyon - NRC NRR RN Sherman - BPA/1 399 NRC Senior Resident Inspector/988C
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Attachment Page 1 of 2 This response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008, addresses the 3 month response requested in the GL. This response discusses: 1) the required evaluations that will not be complete by October 11, 2008 (9 months from the date of GL 2008-01), 2) the alternative course of action planned, and 3) the basis for the acceptability of the alternative course of action.
The Requested Information in GL 2008-01 includes "A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations;...." The requested description of all corrective actions pertaining to plant modifications would require the completion of a thorough physical walkdown of the system piping to confirm such things as adequate vent capability for system high points and that the design drawings reflect the as-built piping.
The requested information pertaining to plant modification corrective actions will not be complete by October 11, 2008 due to the inability to finish the Emergency Core Cooling, Residual Heat Removal, and Containment Spray System walkdowns. The system walkdowns will not be completed due to the following reasons:
" The need to erect scaffolding,
- The restrictions on removal of insulation from piping,
" The need to enter into high radiation areas during plant operation, and
- The restrictions on entering the primary containment during power operation.
Completion of walkdowns affected by these criteria will be completed prior to the end of the next refueling outage, currently scheduled for May-June of 2009. Any corrective actions requiring plant piping modifications identified as a result of the deferred walkdowns will be provided to the NRC staff within 90 days.following completion of that refueling outage.
Deferring walkdowns and the submission of corrective action information as described above are considered acceptable based on the low risk of gas intrusion issues. This is based on the following;
" Previous system evaluations to determine the adequacy of the current design basis have been completed in response to industry and NRC identified operating experience.
" Columbia surveillance data obtained over the past several years indicate that gas accumulation is not affecting operability of ECCS/RHR pumps. Surveillances of these pumps include monitoring and trending of suction pressure, flow vs. differential pressure, vibration, and motor current.
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Attachment Page 2 of 2
" Inspections of pipe supports in accordance with the Columbia ISI program indicate that there were no unacceptable conditions of pipe supports related to the secondary effects of gas accumulation (i.e., water hammer).
" No anomalies related to gas accumulation were identified during events in which HPCS actuated and injected into the reactor vessel.
" Detailed evaluations of as-built piping drawings are expected to be completed prior to October 11, 2008 including those portions of piping that will not have received in-plant walkdowns by that date. Areas of potential concern will be entered into the corrective action program and treated accordingly.
" Detailed evaluations and, if necessary, revisions of site procedures which ensure the piping systems are sufficiently full of water to perform their functions are expected to be completed prior to October 11, 2008 including those portions of piping that will not have received in-plant walkdowns by that date. Areas of potential concern will be entered into the corrective action program and treated accordingly.
Text
Sudesh K. Garmbhir Vice President, Technical Services EG iP.O. Box 968, PE04 NO TS Richland, WA 99352-0968 Ph. 509.377.8313 I F. 509.377.2354 sgambhir@energy-northwest.com April 10, 2008 G02-08-054 10 CFR 50.54(f)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS"
Reference:
NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core CoolingD,* ,Day Heat Removal; and-Contaihnm-entS pray Sy-stems" dated 'Januia-ry* 1"1;,,-2008.'
Dear Sir or Madam:
The U. S. Nuclear Regulatory Commission (NRC) issued NRC Generic Letter (GL) 2008-01 (Reference 1) to request that each licensee evaluate its Emergency Core Cooling System (ECCS), Residual Heat Removal (RHR) system, and Containment.
Spray System licensing basis, design, testing, and corrective actions to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.
The NRC, in GL 2008-01, requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within 9 months of the date of the GL to"-provide the following information: -
(a) A description of the results of evaluations that were performed pursuant~to the requested actions of the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appenhdix B to 10 CFR Part 50 and the licensing basis and operating lice-nse'as those requirerhients apply toythe&-ubject;Systemn(o';., A ,
the GL; ' -- .. .- bIB.f.
4'
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Page 2 (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
Additionally, the NRC requested that if a licensee cannot meet the requested response date, the licensee "shall provide a response within 3 months of the date of the GL". In the 3-month response, the licensee was requested to describe the alternative course of action that it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
The attachment to this letter contains the Energy Northwest 3-month response to the requested information in NRC GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11,2008.
Energy Northwest makes the following commitments:
Walkdowns that could not be accomplished prior to October 11, 2008 due to the need to erect scaffolding, the restrictions on removal of insulation from piping, the need for entry into high radiation areas, and the need for containment entries that cannot be accomplished during power operation will be completed prior to the end of the next scheduled refueling outage, currently scheduled for May-June 2009.
Any corrective actions requiring plant piping modifications identified as a result of the deferred walkdowns will be provided to the NRC staff within 90 days following completion of that refueling outage.
If you have any questions, please contact Mr. MC Humphreys, Licensing Supervisor at (509) 377-4025. I declare under penalty of perjury that the foregoing is true and correct.
Executed on the date of this letter.
Resbeltfully, SKambhir Vice President, Technical Services Attachment cc: EE Collins, Jr. - NRC RIV WA Horin - Winston & Strawn CF Lyon - NRC NRR RN Sherman - BPA/1 399 NRC Senior Resident Inspector/988C
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Attachment Page 1 of 2 This response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008, addresses the 3 month response requested in the GL. This response discusses: 1) the required evaluations that will not be complete by October 11, 2008 (9 months from the date of GL 2008-01), 2) the alternative course of action planned, and 3) the basis for the acceptability of the alternative course of action.
The Requested Information in GL 2008-01 includes "A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations;...." The requested description of all corrective actions pertaining to plant modifications would require the completion of a thorough physical walkdown of the system piping to confirm such things as adequate vent capability for system high points and that the design drawings reflect the as-built piping.
The requested information pertaining to plant modification corrective actions will not be complete by October 11, 2008 due to the inability to finish the Emergency Core Cooling, Residual Heat Removal, and Containment Spray System walkdowns. The system walkdowns will not be completed due to the following reasons:
" The need to erect scaffolding,
- The restrictions on removal of insulation from piping,
" The need to enter into high radiation areas during plant operation, and
- The restrictions on entering the primary containment during power operation.
Completion of walkdowns affected by these criteria will be completed prior to the end of the next refueling outage, currently scheduled for May-June of 2009. Any corrective actions requiring plant piping modifications identified as a result of the deferred walkdowns will be provided to the NRC staff within 90 days.following completion of that refueling outage.
Deferring walkdowns and the submission of corrective action information as described above are considered acceptable based on the low risk of gas intrusion issues. This is based on the following;
" Previous system evaluations to determine the adequacy of the current design basis have been completed in response to industry and NRC identified operating experience.
" Columbia surveillance data obtained over the past several years indicate that gas accumulation is not affecting operability of ECCS/RHR pumps. Surveillances of these pumps include monitoring and trending of suction pressure, flow vs. differential pressure, vibration, and motor current.
THREE MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Attachment Page 2 of 2
" Inspections of pipe supports in accordance with the Columbia ISI program indicate that there were no unacceptable conditions of pipe supports related to the secondary effects of gas accumulation (i.e., water hammer).
" No anomalies related to gas accumulation were identified during events in which HPCS actuated and injected into the reactor vessel.
" Detailed evaluations of as-built piping drawings are expected to be completed prior to October 11, 2008 including those portions of piping that will not have received in-plant walkdowns by that date. Areas of potential concern will be entered into the corrective action program and treated accordingly.
" Detailed evaluations and, if necessary, revisions of site procedures which ensure the piping systems are sufficiently full of water to perform their functions are expected to be completed prior to October 11, 2008 including those portions of piping that will not have received in-plant walkdowns by that date. Areas of potential concern will be entered into the corrective action program and treated accordingly.