GO2-14-175, First Six-Month Status Update Report for Implementation of NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Events Under Severe Accident Conditions

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First Six-Month Status Update Report for Implementation of NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Events Under Severe Accident Conditions
ML14357A069
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/17/2014
From: Swank D
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-050, EA-13-109, GO2-14-175
Download: ML14357A069 (10)
v • d • e


Text

ENERGYDavid A.

Generating ColumbiaP.O. Swank Station Box 968, PE04

) NORTHW EST Richland, WA 99352-0968 Ph. 509-377-2309 1F. 509-377-2354 daswank@energy-northwest.com DEC 1 7 2014 G02-14-175 EA-13-109 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 -

OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS

References:

1. NRC Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 12, 2012
2. NRC Order EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," June 6, 2013
3. Letter G02-14-107, dated June 30, 2014, from DA Swank, Energy Northwest, to the NRC, "Energy Northwest's Phase 1 Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Vents under Severe Accident Condition"

Dear Sir or Madam,

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-050, (Reference 1) which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable hardened vent to remove decay heat and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability or prolonged Station Blackout.

On June 6, 2013, the NRC issued Order EA-13-109; (Reference 2) which rescinded the requirements imposed in Section IV and Attachment 2 of Order EA-12-050 and replaced them with the requirements contained in Section IV and Attachment 2 of Order EA-13-109. Order EA-13-109,Section IV, D.1 requires all licensees to submit an overall integrated plan (OIP) including a description of how compliance with the Phase 1 requirements described in Attachment 1 of the Order will be achieved.

In Reference 3, Energy Northwest submitted Columbia's Overall Integrated Plan for the installation of a reliable hardened severe accident capable wetwell vent.

uS

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Page 2 of 2 The attachment to this letter provides Energy Northwest's first six-month update report of Columbia's status of implementing Order EA-1 3-109 pursuant to Section IV, Condition C.2 of Reference 2.

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 _.*day of 2014 Respectfully, D.A. Swank Assistant Vice President, Engineering Attachment First Six-Month Status Update Report for the Implementation of NRC Order EA-13-109 cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C MA Jones - BPA/1 399 (email)

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS ATTACHMENT COLUMBIA GENERATING STATION, DOCKET NO. 50-397 FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 2 of 8 1.0 Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-050, (Reference 1) which directed Energy Northwest's Columbia Generating Station (Columbia), to have a reliable hardened vent to remove decay heat and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability or prolonged Station Blackout.

On June 6, 2013, the NRC issued Order EA-1 3-109; (Reference 2) which rescinded the requirements imposed in Section IV and Attachment 2 of Order EA-12-050 and replaced them with the requirements contained in Section IV and Attachment 2 of Order EA-13-109. Order EA-1 3-109,Section IV, D.1 required all licensees with Mark I and Mark II containments to submit an overall integrated plan (OIP) including a description of how compliance with the Phase 1 requirements described in Attachment 2 of the Order will be achieved. In Reference 3, Energy Northwest submitted Columbia's OIP for the installation of a reliable, severe accident capable, hardened containment venting system.

Section IV, Condition D.3, of Reference 2 also required status reports at 6-month intervals following the submittal of the Phase 1 OIP. This report is Energy Northwest's first six-month status report of Columbia's implementation of Phase 1 for Order EA-13-109.

2.0 Milestone Accomplishments The following milestones have been completed since the initial submittal on June 30, 2014.

9 Submittal of first 6-month update 3.0 Milestone Schedule Status The following provides an updated milestone schedule to support reliable hardened vent OIP.

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 3 of 8 Target Revised Milestones Completion Activity Status Target Date Completion Date Correspondence & Reports:

Submit the Reliable Hardened Containment Vents under Severe Accident Conditions Jun 30, 2014 Completed N/A Overall Integrated Plan for Phase 1 First Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2014 N/A Severe Accident Conditions Integrated Plan for Phase 1 Second Status Update Report for the Overall Reliable Hardened Containment Vents Jun 30, 2015 N/A under Severe Accident Conditions Integrated Plan for Phase 1 Third Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2015 N/A Severe Accident Conditions Integrated Plan for Phase 1 Fourth Status Update Report for the Overall Reliable Hardened Containment Vents under Jun 30, 2016 N/A Severe Accident Conditions Integrated Plan for Phase 1 Fifth Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2016 N/A Severe Accident Conditions Integrated Plan for Phase 1 Final Completion Report for the Overall Reliable Hardened Containment Vents under June 2017 N/A Severe Accident Conditions Integrated Plan for Phase 1

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 4 of 8 Target Revised Milestones Completion Activity Status Target Date Completion Date Engineering & Modifications:

Develop Engineering Design for Modifications (100% package) Apr 2015 In Process N/A for Phase 1 Plant Modification Installation for June 2017 Awaiting design TBD Phase 1 completion Program & Procedures:

Develop the program and Awaiting design procedures to operate, test, and June 2015 completionTBD maintain the HVCS for Phase 1 Coordinate procedures for HCVS Awaiting design with AOPs, EOPs, SAGs FSGs, Mar 2017 completionTBD and SAMGs for Phase 1 Implement the procedures for June 2017 Awaiting design TBD Phase 1 completion Operations & Training:

Develop the training for all Awaiting design personnel expected to operate Mar 2017 completionTBD the HCVS - Phase_1 completion Complete the training of Mar 2017 Awaiting design TBD personnel - Phase 1 completion 4.0 Changes to Compliance Method PLT-5 Identified three valves, HCV-1, 2, and 7. HCV-V-7 has been replaced by a rupture disc. Energy Northwest is eliminating valve HCV-V-7 and adding a rupture disk HCV-RD-54 to prevent secondary containment bypass leakage. As a result a separate nitrogen supply will be added for use in rupturing the disk if anticipatory venting is to be performed. This will be a manual action in the area of the remote operating station. To prevent inadvertent operation of the WW HCV, instead of the solenoid pilot valves being located in a locked cabinet, the remote operating station will have lockable pneumatic supply valves. A new Sketch 3 is attached.

PLT-7 WW piping will be sized to vent 1% of rated thermal power with a 17%

uprate to a power of 4079 MWt. The piping will also be sized to support anticipatory venting and pass 80,000 Ibm/hr at a maximum pressure of 10 psig in the WW.

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

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 5 of 8 discharge end of the vent pipe to address the flammability of combustible gasses.

The testing and inspection of components identified in Table 4-1 are being changed.

Table 4-1 Testing and Inspection Requirements Description Frequency Reason for Change This testing has been deleted Cylo the HCYS ,.,al'.6 not u..d because HCV-V-7 has been to miAi-ain containment iOnce perF perating cycle replaced by a rupture disc to during

",....... ,,prevent secondary containment bypass leakage.

The frequency of testing is being changed. The accessible components are routinely monitored during operator rounds Perform visual inspections and a Onc

.. per operating cycle and will be visually inspected as walk down of HCVS components Once every other operating part of the validation testing every cycle other operating cycle. The new discharge check valve and outside components will be inspected during the testing identified below.

Testing and calibration have been radiation e monitors. Once per operating cycle separated. Testing will be Test the HCVS rperformed once per operating cycle.

Calibrate the HCVS radiation Once per every other Calibration will be performed every other outage because this monitors operating cycle is a qualitative instrument.

Leak test the HCVS. Prior to first declaring the NO CHANGE system functional Validate the HCVS operating The validation of the HCVS procedures by conducting an operating procedures will be open/close test of the HCVS Once per every other tested as specified. However, control logic from its control panel there are no interfacing valves in a*d eAn urig that all i nter.facing operating cycle this system.

sy..tem valve..move to theirm proper (intended) positions.

Leak test and stroke the discharge Once per every three This testing is added to include check valve, operating cycle the added discharge check valve.

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 6 of 8 5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation 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 Order EA 109.

6.0 Open Items Item Number Open Items Action Status Response Provide resolution of the potential Columbia will use a rupture disk to 1 secondary path in the containment first 6-month bypass update leakage of the Closed prevent secondary containment bypassleakage HCVS OIP Evaluate the location of the ROS for accessibility.

Determine the location of the portable air 3 compressor and evaluate for accessibility under SA HCVS use.

Evaluate the location of the FLEX DGs 4 for accessibility under Severe Accident HCVS use.

Confirm suppression pool heat capacity *Calculation ME-02-14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the 5 Closed* suppression pool water when at a minimum Technical Specification level to control pressure in containment before venting commences.

Determine the method of qualification for each instrument listed Complete the evaluation to determine 7 accessibility, habitability, staffing sufficiency, and communication capability of the ROS.

8 Identify design codes after design is finalized.

Equipment qualifications will include temperature, pressure, radiation level, 9 and total integrated dose radiation from the effluent vent pipe at local and remote locations.

10 Provide site-specific details of the EOPs when available.

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

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 7 of 8 8.0 References

1. NRC Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 12, 2012
2. NRC Order EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," June 6, 2013
3. Letter G02-14-107, dated June 30, 2014, from DA Swank, Energy Northwest, to the NRC, "Energy Northwest's Phase 1 Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Vents under Severe Accident Condition"

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 8 of 8 D3 w H`

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ENERGYDavid A.

Generating ColumbiaP.O. Swank Station Box 968, PE04

) NORTHW EST Richland, WA 99352-0968 Ph. 509-377-2309 1F. 509-377-2354 daswank@energy-northwest.com DEC 1 7 2014 G02-14-175 EA-13-109 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 -

OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS

References:

1. NRC Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 12, 2012
2. NRC Order EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," June 6, 2013
3. Letter G02-14-107, dated June 30, 2014, from DA Swank, Energy Northwest, to the NRC, "Energy Northwest's Phase 1 Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Vents under Severe Accident Condition"

Dear Sir or Madam,

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-050, (Reference 1) which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable hardened vent to remove decay heat and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability or prolonged Station Blackout.

On June 6, 2013, the NRC issued Order EA-13-109; (Reference 2) which rescinded the requirements imposed in Section IV and Attachment 2 of Order EA-12-050 and replaced them with the requirements contained in Section IV and Attachment 2 of Order EA-13-109. Order EA-13-109,Section IV, D.1 requires all licensees to submit an overall integrated plan (OIP) including a description of how compliance with the Phase 1 requirements described in Attachment 1 of the Order will be achieved.

In Reference 3, Energy Northwest submitted Columbia's Overall Integrated Plan for the installation of a reliable hardened severe accident capable wetwell vent.

uS

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Page 2 of 2 The attachment to this letter provides Energy Northwest's first six-month update report of Columbia's status of implementing Order EA-1 3-109 pursuant to Section IV, Condition C.2 of Reference 2.

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 _.*day of 2014 Respectfully, D.A. Swank Assistant Vice President, Engineering Attachment First Six-Month Status Update Report for the Implementation of NRC Order EA-13-109 cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C MA Jones - BPA/1 399 (email)

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS ATTACHMENT COLUMBIA GENERATING STATION, DOCKET NO. 50-397 FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 2 of 8 1.0 Introduction On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-050, (Reference 1) which directed Energy Northwest's Columbia Generating Station (Columbia), to have a reliable hardened vent to remove decay heat and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability or prolonged Station Blackout.

On June 6, 2013, the NRC issued Order EA-1 3-109; (Reference 2) which rescinded the requirements imposed in Section IV and Attachment 2 of Order EA-12-050 and replaced them with the requirements contained in Section IV and Attachment 2 of Order EA-13-109. Order EA-1 3-109,Section IV, D.1 required all licensees with Mark I and Mark II containments to submit an overall integrated plan (OIP) including a description of how compliance with the Phase 1 requirements described in Attachment 2 of the Order will be achieved. In Reference 3, Energy Northwest submitted Columbia's OIP for the installation of a reliable, severe accident capable, hardened containment venting system.

Section IV, Condition D.3, of Reference 2 also required status reports at 6-month intervals following the submittal of the Phase 1 OIP. This report is Energy Northwest's first six-month status report of Columbia's implementation of Phase 1 for Order EA-13-109.

2.0 Milestone Accomplishments The following milestones have been completed since the initial submittal on June 30, 2014.

9 Submittal of first 6-month update 3.0 Milestone Schedule Status The following provides an updated milestone schedule to support reliable hardened vent OIP.

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 3 of 8 Target Revised Milestones Completion Activity Status Target Date Completion Date Correspondence & Reports:

Submit the Reliable Hardened Containment Vents under Severe Accident Conditions Jun 30, 2014 Completed N/A Overall Integrated Plan for Phase 1 First Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2014 N/A Severe Accident Conditions Integrated Plan for Phase 1 Second Status Update Report for the Overall Reliable Hardened Containment Vents Jun 30, 2015 N/A under Severe Accident Conditions Integrated Plan for Phase 1 Third Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2015 N/A Severe Accident Conditions Integrated Plan for Phase 1 Fourth Status Update Report for the Overall Reliable Hardened Containment Vents under Jun 30, 2016 N/A Severe Accident Conditions Integrated Plan for Phase 1 Fifth Status Update Report for the Overall Reliable Hardened Containment Vents under Dec 31,2016 N/A Severe Accident Conditions Integrated Plan for Phase 1 Final Completion Report for the Overall Reliable Hardened Containment Vents under June 2017 N/A Severe Accident Conditions Integrated Plan for Phase 1

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 4 of 8 Target Revised Milestones Completion Activity Status Target Date Completion Date Engineering & Modifications:

Develop Engineering Design for Modifications (100% package) Apr 2015 In Process N/A for Phase 1 Plant Modification Installation for June 2017 Awaiting design TBD Phase 1 completion Program & Procedures:

Develop the program and Awaiting design procedures to operate, test, and June 2015 completionTBD maintain the HVCS for Phase 1 Coordinate procedures for HCVS Awaiting design with AOPs, EOPs, SAGs FSGs, Mar 2017 completionTBD and SAMGs for Phase 1 Implement the procedures for June 2017 Awaiting design TBD Phase 1 completion Operations & Training:

Develop the training for all Awaiting design personnel expected to operate Mar 2017 completionTBD the HCVS - Phase_1 completion Complete the training of Mar 2017 Awaiting design TBD personnel - Phase 1 completion 4.0 Changes to Compliance Method PLT-5 Identified three valves, HCV-1, 2, and 7. HCV-V-7 has been replaced by a rupture disc. Energy Northwest is eliminating valve HCV-V-7 and adding a rupture disk HCV-RD-54 to prevent secondary containment bypass leakage. As a result a separate nitrogen supply will be added for use in rupturing the disk if anticipatory venting is to be performed. This will be a manual action in the area of the remote operating station. To prevent inadvertent operation of the WW HCV, instead of the solenoid pilot valves being located in a locked cabinet, the remote operating station will have lockable pneumatic supply valves. A new Sketch 3 is attached.

PLT-7 WW piping will be sized to vent 1% of rated thermal power with a 17%

uprate to a power of 4079 MWt. The piping will also be sized to support anticipatory venting and pass 80,000 Ibm/hr at a maximum pressure of 10 psig in the WW.

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

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 5 of 8 discharge end of the vent pipe to address the flammability of combustible gasses.

The testing and inspection of components identified in Table 4-1 are being changed.

Table 4-1 Testing and Inspection Requirements Description Frequency Reason for Change This testing has been deleted Cylo the HCYS ,.,al'.6 not u..d because HCV-V-7 has been to miAi-ain containment iOnce perF perating cycle replaced by a rupture disc to during

",....... ,,prevent secondary containment bypass leakage.

The frequency of testing is being changed. The accessible components are routinely monitored during operator rounds Perform visual inspections and a Onc

.. per operating cycle and will be visually inspected as walk down of HCVS components Once every other operating part of the validation testing every cycle other operating cycle. The new discharge check valve and outside components will be inspected during the testing identified below.

Testing and calibration have been radiation e monitors. Once per operating cycle separated. Testing will be Test the HCVS rperformed once per operating cycle.

Calibrate the HCVS radiation Once per every other Calibration will be performed every other outage because this monitors operating cycle is a qualitative instrument.

Leak test the HCVS. Prior to first declaring the NO CHANGE system functional Validate the HCVS operating The validation of the HCVS procedures by conducting an operating procedures will be open/close test of the HCVS Once per every other tested as specified. However, control logic from its control panel there are no interfacing valves in a*d eAn urig that all i nter.facing operating cycle this system.

sy..tem valve..move to theirm proper (intended) positions.

Leak test and stroke the discharge Once per every three This testing is added to include check valve, operating cycle the added discharge check valve.

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 6 of 8 5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation 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 Order EA 109.

6.0 Open Items Item Number Open Items Action Status Response Provide resolution of the potential Columbia will use a rupture disk to 1 secondary path in the containment first 6-month bypass update leakage of the Closed prevent secondary containment bypassleakage HCVS OIP Evaluate the location of the ROS for accessibility.

Determine the location of the portable air 3 compressor and evaluate for accessibility under SA HCVS use.

Evaluate the location of the FLEX DGs 4 for accessibility under Severe Accident HCVS use.

Confirm suppression pool heat capacity *Calculation ME-02-14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the 5 Closed* suppression pool water when at a minimum Technical Specification level to control pressure in containment before venting commences.

Determine the method of qualification for each instrument listed Complete the evaluation to determine 7 accessibility, habitability, staffing sufficiency, and communication capability of the ROS.

8 Identify design codes after design is finalized.

Equipment qualifications will include temperature, pressure, radiation level, 9 and total integrated dose radiation from the effluent vent pipe at local and remote locations.

10 Provide site-specific details of the EOPs when available.

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

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 7 of 8 8.0 References

1. NRC Order EA-12-050, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents," March 12, 2012
2. NRC Order EA-1 3-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," June 6, 2013
3. Letter G02-14-107, dated June 30, 2014, from DA Swank, Energy Northwest, to the NRC, "Energy Northwest's Phase 1 Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable Hardened Containment Vents under Severe Accident Condition"

ENERGY NORTHWEST'S FIRST SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109 - OVERALL INTEGRATED PLAN FOR RELIABLE HARDENED CONTAINMENT VENTS UNDER SEVERE ACCIDENT CONDITIONS Attachment Page 8 of 8 D3 w H`

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-J 7) 0 r14

'-4 Cn 3'- cT Ii-)

2i 3,' d Laii New Sketch 3 - Flow Diagram

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