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

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

ML15245A530
Person / Time
Site:	Columbia
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

Wrilliam G. Hettel

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

-'TNO. 50-397

Subject:

COLUMBIA GENERATING OF REQUIRED STATION, ACTIONDOCK~

BY N UJCLEAR REGULATORY COMPLETION COMMISSION (NRC) ORDER EA-12-051 REt..IABLE SPENT FUEL POOL INSTRUMENTATION

References:

1. NRC Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool lnstrurr entation," dated March 12, 2012 (ADAMS Accession No. ML12056A044)

2. Letter G02-13-036 dated February 28, 201~ ;, from D. A. Swank (Energy Northwest) to the NRC "Energy No rthwest's Response to NRC Order EA-12-051 - Overall Integrated Plan Ior Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. MLi13071 A470)

3. NRC letter "Interim Staff Evaluation and Re :quest for Additional Information Regarding the Overall Integrate i plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pc )oI Instrumentation," dated November 7, 2013 (ADAMS Accession No. ML1 3302C1! 36)

4. Nuclear Energy Institute document NEI 12-( J2, "Industry Guidance for Compliance with NRC Order EA-12-051, "T )Modify Licenses with Regard to Reliable Spent Fuel Pool Instrum *=ntation," Revision 1, dated August 2012 (ADAMS Accession No. ML12240A307)

5. NRC Japan Lessons-Learned Project Direc' :orate JLD-ISG-201 2-03, "Compliance with Order EA-12-05t, Reliabl SSpent Fuel Pool Instrumentation lnterim Staff Guidance," Re 'ision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A33

6. NRC Letter "Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fu. )l Pool Instrumentation Related to Orders EA-12-049 and EA-12-05 1," dated June 16, 2015 (ADAMS Accession No. ML15139A462)

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 installation of two reliable independent level monitors for the spent fuel pool (SFP) in response to the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, "1.Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrume *itation" (Reference 1). This letter provides the notification required by § IV.C.3 of the Oi der that full compliance with the requirements described in Attachment 2 of the Order h* ye been achieved.

Background

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 independent full scale level monitors on the SFP in response to Reference 1.

Energy Northwest submitted the Columbia OIP by the letter dated February 28, 2013 (Reference 2). By the letter dated November 7, 2013, the INRC provided its interim staff evaluation (Reference 3). Reference 3 requested additiona information necessary for completion of the review. The requested information was pc )sted to the E-portal and included the Columbia bridging document and the vendor reports. This information was also provided to the NRC auditors during the February 2015 NRC on-site audit.

Compliance with Order EA-12-05! was achieved using the iuidance in Nuclear Energy Institute (NEI) document NEI 12-02 "lndustry Guidance for ",ompliance with NRC Order EA-12-05 1.1 (Reference 4), and endorsed by the NRC in Re ference 5.

Identification of Levels of Required Monitoring - ComplI to Columbia has identified the three required levels for monitor nlg SFF level in compliance with Order EA-12-051. These levels have been integrated irito the site processes for monitoring level during events and responding to loss of SF1 Sinventory.

Program Features - Complete Training of personnel performing maintenance functions inc iding calibration and surveillance associated with the SFP level instrument chann *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'yUI 'J,4 completed in accordance with an accepted training proces,, as recommended in NEI 12-02, Section 4.1.

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

Site processes have been established to ensu're the instrun ients are maintained at their design accuracy.

Instrument Designed Features - Complete The design of the SFP level measurement instrumentation 3ystem installed at Columbia complies with the requirements specified in Order EA-1 2-0,* ;1 and described in NEI 12-

02. The instrumentation system has been installed in acco*'dance with the station's design control process.

The instruments have been arranged to provide reasonable protection against missiles.

The instruments have been mounted to retain design confi( *uration during and following the maximum expected ground motion. The instruments wiIIbe reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other ar d have separate and diverse power supplies. The instruments will maintain their designE *d accuracy following a power interruption and are designed to allow for routine tes :ing and calibration.

The instrument displays are located in the main control root n and are readily accessible during postulated events and allow for SFP level informatio i to be promptly available to decision makers.

Open Items and Requests for Additional Information (R*d) -. Complete As documented from February 2-5,in Reference 6, during 2015, the NRC theallon-site closed o rthe portion fo 18 requests NRC audit conducted additional information (RAI) identified in Reference 3. However, one new question on tl ie susceptibility to portable radiofrequency (RF) transmitting devices (i.e., radio) was ra ised during the audit.

Columbia was asked to provide an assessment of the poter *tial susceptibilities of electromagnetic interference (EM I) and RF interference (RFI) in the areas where the SFP instrument is located and how to mitigate those suscer *tibilities (Audit Item 11l-E).

This remained an open item from the February 2015 audit.

Columbia has reassessed the RF susceptibility of the new ;FP instrumentation required by NRC Order EA-1 3-109. Columbia reviewed the requiren *ents in the Electric Power Research Industry (EPRI) Test Report (TR) 102323, "Guide lines for Electromagnetic Interference Testing of Power Plants," previously endorsed by the NRC. The new instrumentation is classified as non-safety related and Tablk 1 of TR-102323 indicates that testing of this equipment for RF susceptibility is optiona Iand therefore was not specified to. the vendor. The vendor performance testing w*ts witnessed and the

COMPLETION OF REQUIRED ACTION BY NUCLEAR RE GULATORY COMMISSION (NRC) ORDER EA-12-051 RELIABLE SPENT FUEL P0 OL INSTRUMENTATION Page 4 of 4 documentation reviewed and accepted by Columbia. A demr3nstration of RF interference susceptibility was performed on May 21. 2015. The vendor reports and the demonstration results have been posted on the Columbia e. portal as outlined in the Columbia Audit Plan dated January 16, 2015. Since no EM [,RFI, or RF susceptibilities were identified, no mitigation is required.

No new commitments are identified in this letter.

Ifyou have any questions or require additional information, plh,*ase 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 11 day of *v4 ,2015 W. G. Hettel Vice President, Operations cc: NRC Region lV Administrator NRC Senior Resident lnspector/988C NRC NRR Project Manager CD Sonoda - BPA/1399 (email)