GO2-14-030, Northwest'S Second Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

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Northwest'S Second Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation
ML14069A078
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/27/2014
From: Swank D
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GO2-14-030
Download: ML14069A078 (8)


Text

David A. Swank ENERGY Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-2309 I F. 509-377-2354 daswank @energy-northwest.com February 27, 2014 G02-14-030 EA-12-051 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION

References:

1. NRC Order EA-1 2-051 dated March 12, 2012, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"
2. Letter G02-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-051 - Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation"
3. Letter dated June 20, 2013, from LK Gibson (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Regarding Spent Fuel Pool Instrumentation (TAC No. MF0797)"
4. Letter G02-13-1 00, dated July 19, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to Request for Additional Information Related to the Overall Integrated Plan for Spent Fuel Pool Instrumentation"
5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's First Six Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"
6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station -

Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"

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ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Page 2 of 2

Dear Sir or Madam,

In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable means of remotely monitoring wide range spent fuel pool levels to support effective prioritization of event mitigation and recovery actions for a beyond-design-basis external event. The Order also requires submission of a status update at six-month intervals following the licensee's submittal of the Overall Integrated Plan.

The attachment to this letter provides Energy Northwest's second six-month report of Columbia's status of implementing Order EA-12-051 pursuant to Section IV, Condition C.2 of Reference 1. As stated in the Memorandum dated December 26, 2014, from C.

A. Hunt (NRC) to M. A. Mitchell (NRC), "Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," (ML13347B030) the staff clarified that the staff interim evaluation questions supersede any previous requests for information issued by the staff concerning the spent fuel instrumentation. Therefore, no updates to the RAIs discussed in References 3, 4, or 5 have been provided.

Energy Northwest is currently working with the equipment vendor to develop the responses to the RAIs contained in Reference 6 and will respond by the November 30, 2014, due date identified in Reference 6. If unable to fully respond by the requested date, Energy Northwest will inform the NRC through the NRC project management.

There are no new or revised regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Ms. L. L. Williams at (509) 377-8148.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, D.A. Swank Assistant Vice President, Engineering Attachment Second Six-Month Status Update Report for the Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C AJ Rapacz - BPA/1 399 (email)

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION ATTACHMENT COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE OVERALL INTEGRATED PLAN FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 1 of 5 1.0 Introduction In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable means of remotely monitoring wide range spent fuel pool (SFP) levels to support effective prioritization of event mitigation and recovery actions for a beyond-design-basis external event. Energy Northwest developed an Overall Integrated Plan (Reference 2) documenting the requirements to install reliable SFP level instrumentation in response to NRC Order EA-12-051. The Order also requires submission of a status update at six-month intervals following the licensee's submittal of the Overall Integrated Plan.

This is Energy Northwest's second six-month report of Columbia's status of implementing Order EA-12-051 pursuant to Section IV, Condition C.2 of Reference 1 and provides an update of milestone accomplishments since the previous update of August 23, 2013, (Reference 5). Changes are identified by a revision bar in the right column or margin.

2.0 Milestone Accomplishments The following milestones are current as of February 28, 2014.

1) Commenced Reliable SFP Instrumentation Engineering Detailed Design
a. In March of 2013 the Energy Northwest design groups (mechanical, electrical, instrumentation, and civil) began the detailed procurement specification and design change development for the Reliable SFP Instrumentation. The overall design and the plant modification packages are approximately 50% completed. The instrumentation vendor has been selected and the equipment has been specified.

3.0 Milestone Schedule Status The following provides an updated milestone schedule to support the Reliable SFP Instrumentation Overall Integrated Plan. Some changes to the schedule have been made as shown by the revision bars as the required vendor information was delayed.

This information has been received and is being reviewed by Energy Northwest.

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 2 of 5 Target Revised Milestones Completion Activity Target Date Status Completion Date Correspondence & Reports:

Submit 60 Day Reliable SFP Instrumentation Status Report Submit Overall Reliable SFP Instrumentation Integrated Plan First Status Update Report for the Reliable SFP Instrumentation August 2013 Completed N/A Integrated Plan Second Status Update Report for the Reliable SFP Instrumentation Feb 2014 Completed N/A Integrated Plan Third Status Update Report for the Reliable SFP Instrumentation August 2014 Not Started N/A Integrated Plan Final Completion Report for the Reliable SFP Instrumentation Feb 2015 Not Started N/A Integrated Plan Engineering & Modifications:

Commence Engineering Detailed Design for the Reliable SFP March 2013 Completed N/A Instrumentation Complete Engineering Detailed Design for the Reliable SFP Jan 2014 Started June 2014 Instrumentation Commence the Reliable SFP Instrumentation Modification May 2014 Not Started July 2014 Installation Reliable SFP Instrumentation Dec 2014 Not Started N/A Channels Operational

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 3 of 5 Program & Procedures:

Commence development of the Reliable SFP instrumentation testing, calibration, maintenance, April 2014 Not Started July 2014 surveillance, and operational procedures Complete development of the Reliable SFP instrumentation testing, calibration, maintenance, May 2014 Not Started Dec 2014 surveillance, and operational procedures Establish programmatic controls on SFP instrumentation related Dec 2014 Not Started N/A activities Operations & Training:

Commence development of the Reliable SFP Instrumentation April 2014 Not Started N/A training modules Complete development of the Reliable SFP Instrumentation May 2014 Not Started N/A training modules Complete training of station Oct 2014 Not Started N/A personnel Functional testing of Reliable SFP Dec 2014 Not Started N/A Instrumentation SSCs complete Reliable SFP Instrumentation Program turned over to Dec 2014 Not Started N/A Operations

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 4 of 5 4.0 Changes to Compliance Method The Overall Integrated Plan (submitted in Reference 2) indicated that there would be an alternate display location for viewing level indication in the vendor electronics at the electronic control cabinet for the guided wave radar. This concept has been revised; the signal processor enclosure will now be located in the main control room. Therefore the reliable SFP instrumentation, primary and backup instrument channel display will only be located in the main control room. This design modification continues to meet the guidelines of JLD-ISG-2012-13 and NEI 12-02 section 3.9.

5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation At this time, Energy Northwest expects to fully comply with the Order and its implementation date and does not anticipate a request for relief and/or relaxation of the Order.

6.0 Open Items In Reference 3, the NRC requested additional information with regard to the Overall Integrated Plan and in Reference 4 Energy Northwest responded to that request with the understanding that the completed responses will be provided to the NRC in a future updated status report. In Reference 5, Energy Northwest provided the first 6-month update. However, in the Memorandum dated December 26, 2014, from C. A. Hunt (NRC) to M. A. Mitchell (NRC), "Summary of the November 26, 2013, (ML13347B030)

Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," the staff clarified that the interim staff evaluation (Reference

6) questions supersede any previous requests for information issued by the staff concerning the spent fuel instrumentation. Therefore, no updates to the RAIs discussed in References 3, 4, or 5 have been provided.

Energy Northwest is currently working with the equipment vendor to develop the responses to the RAIs contained in Reference 6 and will respond by the November 30, 2014, due date identified in Reference 6. If unable to fully respond by the requested date, Energy Northwest will inform the NRC through the NRC project management.

7.0 Potential Draft Safety Evaluation Impacts At this time, Energy Northwest does not believe there are any potential impacts to the Draft Safety Evaluation.

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 5 of 5 8.0 References

1. NRC Order EA-1 2-051 dated March 12, 2012, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"
2. Letter G02-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-051 - Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation"
3. Letter dated June 20, 2013, from LK Gibson (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Regarding Spent Fuel Pool Instrumentation (TAC No. MF0797)"
4. Letter G02-13-100, dated July 19, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to Request for Additional Information Related to the Overall Integrated Plan for Spent Fuel Pool Instrumentation"
5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's First Six Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"
6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"