GO2-15-120, Completion of Required Action by Nuclear Regulatory Commission (NRC) Re Order EA-12-051, Reliable Spent Fuel Pool Instrumentation

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Completion of Required Action by Nuclear Regulatory Commission (NRC) Re Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
ML15245A530
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/12/2015
From: Hettel W
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GO2-15-120
Download: ML15245A530 (4)


Text

UOTWS August 12, 2015 G02-1 5-120 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

References:

COLUMBIA GENERATING STATION, DOCK~

COMPLETION OF REQUIRED ACTION BY N COMMISSION (NRC) ORDER EA-12-051 REt.

POOL INSTRUMENTATION

1. NRC Order EA-12-051, "Issuance of Order Regard to Reliable Spent Fuel Pool lnstrurr 2012 (ADAMS Accession No. ML12056A04
2. Letter G02-13-036 dated February 28, 201~

(Energy Northwest) to the NRC "Energy No Order EA-12-051 - Overall Integrated Plan I Instrumentation" (ADAMS Accession No. M

3. NRC letter "Interim Staff Evaluation and Re Information Regarding the Overall Integrate of Order EA-12-051, Reliable Spent Fuel Pc November 7, 2013 (ADAMS Accession No.
4. Nuclear Energy Institute document NEI 12-(

Compliance with NRC Order EA-12-051, "T Regard to Reliable Spent Fuel Pool Instrum August 2012 (ADAMS Accession No. ML12

5. NRC Japan Lessons-Learned Project Direc' "Compliance with Order EA-12-05t, Reliabl Instrumentation lnterim Staff Guidance," Re 2012 (ADAMS Accession No. ML12221A33
6. NRC Letter "Report for the Audit Regarding Mitigating Strategies and Reliable Spent Fu.

Related to Orders EA-12-049 and EA-12-05 (ADAMS Accession No. ML15139A462)

Wrilliam G. Hettel

.Columbia Generating Station P.O. Box 968, PE23 Richland. WA 99352-0968 Ph. 509,377.8311! F. 509.377.4674 wghettel @energy-no rt~hwest~com EA-1 2-0151

-'T NO. 50-397 UJCLEAR REGULATORY

.IABLE SPENT FUEL to Modify Licenses with entation," dated March 12, 4)

, from D. A. Swank rthwest's Response to NRC or Reliable Spent Fuel Pool Li13071 A470)
quest for Additional i plan for Implementation

)oI Instrumentation," dated ML1 3302C1! 36)

J2, "Industry Guidance for

)Modify Licenses with

  • =ntation," Revision 1, dated 240A307)
orate JLD-ISG-201 2-03, SSpent Fuel Pool

'ision 0, dated August 29, Implementation of

)l Pool Instrumentation 1," dated June 16, 2015

COMPLETION OF REQUIRED ACTION BY NUCLEAR R ;GULATORY COMMISSION (NRC) ORDER EA-12-051 RELIABLE SPENT FUEL P9)OL INSTRUMENTATION Page 2 of 4

Dear Sir or Madam:

Columbia Generating Station (Columbia) has completed thE independent level monitors for the spent fuel pool (SFP) in Regulatory Commission (NRC) issued Order EA-12-051, "1.

Licenses with Regard to Reliable Spent Fuel Pool Instrume letter provides the notification required by § IV.C.3 of the Oi the requirements described in Attachment 2 of the Order h*

Background

installation of two reliable response to the Nuclear Issuance of Order Modifying

  • itation" (Reference 1). This der that full compliance with ye been achieved.

On March 12, 2012, the NRC issued Order EA-12-051 (Ref*=rence 1) to Energy Northwest. This Order was effective immediately and direc':ed installation of a reliable 5FP instrumentation as outlined in Attachment 2 of the Order. The Order required compliance prior to plant startup from the second refueling ~utage following submittal of the Overall integrated Plan (OIP), or by December 31, 201 4, whichever comes first.

Columbia completed Refueling Outage 22 on June 28, 201 5. The NRC staff requested that Licensees report to the Commission when full compliar~ ce with the requirements described in Attachment 2 of Reference 1 is achieved. The~ information provided herein documents full compliance for Columbia Generating Station~ in response to Order EA-12- 05 1.I Compliance Columbia, a single unit with a single SFF, has installed two monitors on the SFP in response to Reference 1.

Energy Northwest submitted the Columbia OIP by the letter (Reference 2). By the letter dated November 7, 2013, the IN evaluation (Reference 3). Reference 3 requested additiona completion of the review. The requested information was pc included the Columbia bridging document and the vendor re also provided to the NRC auditors during the February 2015 Compliance with Order EA-12-05! was achieved using the Institute (NEI) document NEI 12-02 "lndustry Guidance for EA-12-05 1.1 (Reference 4), and endorsed by the NRC in Re independent full scale level dated February 28, 2013 RC provided its interim staff information necessary for

)sted to the E-portal and ports. This information was NRC on-site audit.

iuidance in Nuclear Energy

",ompliance with NRC Order ference 5.

Identification of Levels of Required Monitoring - ComplI to Columbia has identified the three required levels for monitor with Order EA-12-051. These levels have been integrated ir monitoring level during events and responding to loss of SF1 Program Features - Complete Training of personnel performing maintenance functions inc surveillance associated with the SFP level instrument chann nlg SFF level in compliance ito the site processes for Sinventory.

iding calibration and

  • ls at Columbia has been

COMPLETION OF REQUIRED ACTION BY NUCLEAR R I :GULATORY COMMISSION (NRC) ORDER EA-12-051 RELIABLE SPENT FUEL P( OL INSTRUMENTATION 3'y UI 'J,4 completed in accordance with an accepted training proces,,

02, Section 4.1.

Operating and maintenance procedures for the Columbia S channels have been developed and integrated with existing procedures have been verified and are available for use in procedure control program.

Site processes have been established to ensu're the instrun design accuracy.

Instrument Designed Features - Complete The design of the SFP level measurement instrumentation complies with the requirements specified in Order EA-1 2-0,*

02. The instrumentation system has been installed in acco*

design control process.

The instruments have been arranged to provide reasonable The instruments have been mounted to retain design confi(

the maximum expected ground motion. The instruments wi environmental and radiological conditions when the SFP is periods. The instruments are independent of each other ar power supplies. The instruments will maintain their designE power interruption and are designed to allow for routine tes The instrument displays are located in the main control root during postulated events and allow for SFP level informatio decision makers.

as recommended in NEI 12-FP level instrument procedures. These accordance with the site ients are maintained at their 3ystem installed at Columbia

1 and described in NEI 12-

'dance with the station's protection against missiles.

  • uration during and following II be reliable during expected at saturation for extended d have separate and diverse
  • d accuracy following a
ing and calibration.

n and are readily accessible i to be promptly available to Open Items and Requests for Additional Information (R *d) -.Complete As documented in Reference 6, during the on-site portion o from February 2-5, 2015, the NRC closed all 18 requests fo identified in Reference 3. However, one new question on tl radiofrequency (RF) transmitting devices (i.e., radio) was ra Columbia was asked to provide an assessment of the poter electromagnetic interference (EM I) and RF interference (RF SFP instrument is located and how to mitigate those suscer This remained an open item from the February 2015 audit.

Columbia has reassessed the RF susceptibility of the new by NRC Order EA-1 3-109. Columbia reviewed the requiren Research Industry (EPRI) Test Report (TR) 102323, "Guide Interference Testing of Power Plants," previously endorsed instrumentation is classified as non-safety related and Tablk that testing of this equipment for RF susceptibility is optiona specified to. the vendor. The vendor performance testing w*

the NRC audit conducted r additional information (RAI) ie susceptibility to portable ised during the audit.

  • tial susceptibilities of I) in the areas where the
  • tibilities (Audit Item 11 l-E).
FP instrumentation required
  • ents in the Electric Power lines for Electromagnetic by the NRC. The new 1 of TR-102323 indicates Iand therefore was not ts witnessed and the

COMPLETION OF REQUIRED ACTION BY NUCLEAR RE (NRC) ORDER EA-12-051 RELIABLE SPENT FUEL P0 Page 4 of 4 documentation reviewed and accepted by Columbia. A demr interference susceptibility was performed on May 21. 2015.

demonstration results have been posted on the Columbia e.

Columbia Audit Plan dated January 16, 2015. Since no EM were identified, no mitigation is required.

No new commitments are identified in this letter.

If you have any questions or require additional information, plh Williams at (509) 377-8148.

GULATORY COMMISSION OL INSTRUMENTATION 3nstration of RF The vendor reports and the portal as outlined in the

[, RFI, or RF susceptibilities

,*ase contact Ms. L. L.

i declare under penalty of perjury that the foregoing is true and correct.

Executed on the 11 day of

  • v4

,2015 W. G. Hettel Vice President, Operations cc: NRC Region lV Administrator NRC Senior Resident l nspector/988C NRC NRR Project Manager CD Sonoda - BPA/1399 (email)