GO2-17-118, Second Combined Six-Month Status Update Report for the Implementation of NRC Orders EA-12-049 and EA-13-109
| ML17178A276 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/27/2017 |
| From: | Javorik A Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, EA-13-109, GO2-17-118 | |
| Download: ML17178A276 (14) | |
Text
Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-8555 l F. 509-377-4150 aljavorik@energy-northwest.com EA-12-049 EA-13-109 10 CFR 50.54(f)
June 27, 2017 GO2-17-118 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWESTS SECOND COMBINED SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NUCLEAR REGULATORY COMMISSION (NRC) ORDERS EA-12-049 AND EA 109
References:
- 1. NRC Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to Energy Northwest et.al, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
- 2. NRC Letter from E. J. Leeds (NRC) to Licensees with Mark I and Mark II Containments, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013
- 3. Letter GO2-16-171, from A. L. Javoik (Energy Northwest) to NRC, "Energy Northwests Combined Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Orders EA-12-049 AND EA-13-109", dated December 29, 2016
Dear Sir or Madam,
This letter and its enclosure transmits the combined 6-month update report on the status of implementing Nuclear Regulatory Commission (NRC) issued Orders EA 049 and EA-13-109 as required by References 1 and 2 as of May 31, 2017. Reference 3 provided the previous combined 6-month update report.
G02*17*118 Page 2 of 2 This letter also provides the notification requested by the NRG staff in its February 5, 2015, letter endorsing NEI whitepaper "HCVS-WP-02: Sequences for HCVS Design and Method for Determining Radiological Dose from HCVS Piping".
No new commitments are being made by this letter or the enclosure. 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 this 271'day of {q&. , 2017.
A. L. Javorik Vice President, Engineering
Enclosure:
As stated cc: NRC RIV Regional Administrator CD Sonoda - BPA/1399 (email)
NRC NRA Project Manager WA Horin - Winston & Strawn NRC Senior Resident lnspector/988C
GO2-17-118 Enclosure Page 1 of 12 1.0 Introduction By References 1 and 2 to this enclosure, the Nuclear Regulatory Commission (NRC) issued Orders EA-12-049 and EA-13-109 to Columbia Generating Station (Columbia).
The Orders contained requirements for mitigation strategies for beyond-design-basis external events and the installation of a reliable containment hardened vent capable of operation under severe accident conditions. References 1 and 2 also required submittal of an Overall Integrated Plan (OIP) describing how compliance with the requirements described in the Orders will be achieved and required the submittal of status reports at six month intervals. This enclosure provides Energy Northwests combined six-month status report for these NRC Orders.
2.0 Milestone Accomplishments All the Mitigation Milestones supporting restart from Refueling Outage 22 (mitigation implementation outage) with the exception of plant changes directly associated with the implementation of a reliable hardened containment vent (HCV) capable of operation under severe accident conditions were reported complete in Reference 4 of this enclosure. During the current refueling outage (Refueling Outage 23), Energy Northwest completed installation of the HCV system in accordance with Phase 1 of Reference 2. Reference 1 Section IV.C.3 requires notification of full compliance with NRC Order EA-12-049. Energy Northwest will submit this notification by August 18, 2017, 60-days from the completion of Refueling Outage 23.
3.0 Milestone Schedule Status The following table provides a listing of the remaining reports associated with NRC Orders EA-12-049 and EA-13-109 as of May 31, 2017.
Correspondence and Reports Target Comments Activity (Include date Milestone Completion Status changes in this Date column)
Submit Overall Integrated GO2-14-107 June 2014 Complete Implementation Plan (Phase 1) 6/30/2014 Submit Overall Integrated Implementation Plan (Phase 2) which GO2-15-175 Dec. 2015 Complete included a Phase 1 6-month status 12/16/2015 update.
Next Combined Status Update Report for the Mitigation Strategies June 2017 Complete This Letter and Reliable Hardened Containment Vent
GO2-17-118 Enclosure Page 2 of 12 Issuance of Energy Northwest's letter of full compliance with NRC Order Aug. 2017 Not Started EA-12-049,Section IV.C.3 6-month update for Order EA-13-109 Dec. 2017 Not Started Phase 2 6-month update for Order EA-13-109 June 2018 Not Started Phase 2 6-month update for Order EA-13-109 Dec. 2018 Not Started Phase 2 6-month update for Order EA-13-109 June 2019 Not Started Phase 2 Issuance of Energy Northwest's letter of compliance with NRC Order EA- Aug. 2019 Not Started 13-109, Phase 2 The tables below provide the Milestone status for implementation of Phases 1 and 2 of Reference 2 last reported in Reference 3.
HCV Phase 1 Milestone Schedule:
Target Comments Activity (Include date Milestone Completion Status changes in this Date column)
Hold preliminary/conceptual design June 2014 Complete meeting This date is WW Design Engineering Complete May 2016 In Progress changed to June 2017 This date is WW Operation Procedure Changes Mar 2017 In Progress changed to June Developed 2017 This date is WW Training Complete Apr. 2017 In Progress changed to June 2017 This date is WW Installation Complete May 2017 In Progress changed to June 2017 This date is WW Procedure Changes Active May 2017 In Progress changed to June 2017 Site Specific WW Maintenance June 2017 In Progress Procedure Developed WW Walk Through June 2017 In Progress Demonstration/Functional Test
GO2-17-118 Enclosure Page 3 of 12 HCV Phase 2 Milestone Schedule Target Comments Activity (Include date Milestone Completion Status changes in this Date column)
This date has Hold preliminary/conceptual design July 2016 been changed to meeting Jul 2017 Design Engineering On-site/Complete July 2018 Operations Procedure Changes Jan. 2019 Developed Site Specific Maintenance Procedure Jan. 2019 Developed Training Complete Apr. 2019 Implementation Outage May 2019 Procedure Changes Active May 2019 Walk Through June 2019 Demonstration/Functional Test 4.0 Changes to the Compliance Methods Changes to the OIP for Reliable HCV Vents under Severe Accident Conditions (EA-13-109):
None Changes to the Overall Integrated Plan for Mitigating Strategies (EA-12-049):
None 5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation None 6.0 Open Items from Overall Integrated Plan, Interim Staff Evaluation, and Audits The tables in Section 8 of this enclosure provide an update of the status of the remaining Licensee identified integrated plan open items for NRC Orders EA-12-049 and EA-13-109 as well as the open items identified in the NRC Interim Staff Evaluations dated March 25, 2015, and September 29, 2016, as of May 31, 2017.
As part of the response to provide the locations of the portable air compressor and diesel generator identified as items 02 and 03 in the table titled "Response to the Phase 1 Request for Additional Information," Energy Northwest completed the severe accident dose assessment using the NRC endorsed guidance in NEI whitepaper "HCVS-WP-02:
Sequences for HCVS Design and Method for Determining Radiological Dose from
GO2-17-118 Enclosure Page 4 of 12 HCVS Piping." Although the dose levels identified using this method are elevated, Energy Northwest completed an assessment of the radiological consequences to address elements A.1.1.3, A.1.1.4, and A.1.2.10 of Order EA-13-109. It was determined that Energy Northwest will be able to control the overall dose to station personnel to within the limits of EPA Manual EPA-400-R-92-001, May 1992, "Manual of Protective Action Guidelines and Protective Actions for Nuclear Incidents" by:
identifying lower dose areas to be used in stationing equipment, providing maps of the expected dose fields in the procedures and program document, and designing the HCV to withstand and remain functional during severe accident conditions, Additionally, Energy Northwest has undertaken an optional site specific analysis utilizing NUREG-1465 and site characteristics using the guidance in Appendix A of HCVS-WP-02. When completed, this analysis is expected to produce lower dose levels and allow for more efficient and effective response planning for implementation of Phase 2 of NRC Order EA-13-109. Energy Northwest will provide the results to NRC for review upon completion of the analysis.
7.0 References
- 1. NRC Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to Energy Northwest et.al, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
- 2. NRC Letter from E. J. Leeds to Licensees with Mark I and Mark II Containments, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions,"
dated June 6, 2013
- 3. Letter GO2-16-171, from A.L. Javoik (Energy Northwest) to NRC, "Energy Northwests Combined Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Orders EA-12-049 AND EA-13-109",
dated December 29, 2016
- 4. Letter GO2-15-124, from D. A. Swank (Energy Northwest) to NRC "Energy Northwests Fifth Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-12-049 Mitigation Strategies for Beyond Design Basis External Events," dated August 25, 2015
- 5. Letter GO2-15-175, from A. L. Javorik (Energy Northwest) to NRC "Energy Northwests Response to NRC Order EA-13-109 - Overall Integrated Plan for Reliable
GO2-17-118 Enclosure Page 5 of 12 Hardened Containment Vents under Severe Accident Conditions Phases 1 and 2, Revision 1," dated December 16, 2015 8.0 Tables The following tables provide the status as of May 31, 2017. Items associated with NRC Order EA-12-049 or Phase 1 of NRC Order EA-13-109 will be updated as part of the notification of full compliance required by Section IV.C.3 of Reference 1.
List of Remaining FLEX Integrated Plan Open Items FLEX OIP Action Status Open Item GOTHIC analyses will be confirmed, or revised, to bound the design of the hardened containment vent after the OI-FLEX-73 design is finalized. (This OI has been added to assure that CLOSED the subject analyses reflect the design required by EA 109.)
The flooding hazards analysis will provide information about site water level associated with a probable maximum precipitation (PMP) event and a local intense precipitation (LIP) event. These water levels will be compared to CLOSED elevations for the FLEX buildings as well as the deployment The flooding hazard routes for the equipment. A LiDAR survey of the site was reevaluation was completed and the OI-FLEX-43 performed and a topographic plan of the site has been report was provided generated to assist in this evaluation. The flooding analysis to the NRC in letter is currently in progress. The results will be used to provide GO2-16-143, dated a response to this question in a future OIP update. 10/6/16.
(Response to NRC Audit Question 03) (This OI has been changed because the flooding analysis remains in progress and the OI was not closed in the February 2014 update.)
A future update to the OIP will address the applicability to CLOSED Columbia of each of the nine considerations in NEI 12-06 The Flooding Section 6.2.3.2, Deployment of FLEX Equipment. Hazard (Response to NRC Audit Question 04) (This OI has been Reevaluation Report changed because the flooding analysis remains in progress (FHRR) shows the OI-FLEX-44 results are either and the OI will be closed in a future update.)
bounded by the current design basis or available physical margin exists.
The flooding analysis will be used to determine if any of the CLOSED external flooding procedures should be changed. The Flooding (Response to NRC Audit Question 04) Hazard Reevaluation Report (FHRR) shows the OI-FLEX-45 results are either bounded by the current design basis or available physical margin exists.
GO2-17-118 Enclosure Page 6 of 12 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Provide resolution of the potential Closed in Letter secondary containment bypass GO2-15-175.
leakage path in the first 6-month Columbia will use a OI-HCV-01 update of the HCVS OIP CLOSED rupture disk to prevent secondary containment bypass leakage.
Evaluate the location of the ROS for OI-HCV-02 CLOSED accessibility.
Determine the location of the portable air compressor and evaluate for accessibility under Severe Accident OI-HCV-03 OPEN HCVS use.
Including connection point(s)
Including refueling operations Evaluate the location of the FLEX DG for accessibility under Severe OI-HCV-04 Accident HCVS use. OPEN Including connection point(s)
Including refueling operations Confirm suppression pool heat Closed in Letter capacity GO2-15-175.
Calculation ME 14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the OI-HCV-05 CLOSED suppression pool water when at a minimum Technical Specification level to control pressure in containment before venting commences.
Determine the method of qualification OI-HCV-06 CLOSED for each instrument Complete the evaluation to determine accessibility, habitability, staffing OI-HCV-07 OPEN sufficiency, and communication capability of the ROS.
Identify design codes after design is OI-HCV-08 CLOSED finalized.
GO2-17-118 Enclosure Page 7 of 12 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Equipment qualifications will include temperature, pressure, radiation level, OI-HCV-09 and total integrated dose radiation OPEN from the effluent vent pipe at local and remote locations.
Provide site-specific details of the Phase 1: No EOP EOPs when available. procedure changes OI-HCV-10 OPEN Develop procedures for SAWA and are required.
SAWM Phase 2: in review.
FLEX air compressors need to be Closed in letter GO2-credited to recharge air lines for 16-171. The HCV HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. strategy will credit for the existing 300 CFM FLEX air compressor FLEX-C-3 staged in FLEX Building 82 and OI-HCV-11 CLOSED FLEX-C-4 in Building 600. The 300 CFM capacity of the air compressor is th sufficient. A 4 bottle (Spare) has been added to the HCV bottle rack.
SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA-12-049 actions).
OI-HCV-12 OPEN Location of these valves and flow elements will need to be considered per HCVS-FAQ-12.
Reconcile the out-of-service provisions for HCVS/SAWA with the OI-HCV-13 provisions documented in Columbias OPEN PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.
Complete the evaluation to determine accessibility, habitability, staffing OI-HCV-14 OPEN sufficiency, and communication capability during SAWA/SAWM Perform MAPP analysis for NEI 13-02 figures C-2 through C-6 and OI-HCV-15 OPEN determine the time sensitive SAWM actions Develop procedure for line-up and use OI-HCV-16 OPEN of HCVS
GO2-17-118 Enclosure Page 8 of 12 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment Open Item Add sound powered phone extension Closed in letter GO2-cable for instrument rack E-IR-85 to 16-171. Additional inventory procedure cable not need as OI-HCV-17 CLOSED each FLEX building has 5 sound powered phone kits Evaluate deployment pathways for OI-HCV-18 OPEN severe accident capable criteria Develop required training and OI-HCV-19 OPEN frequency IAW the SAT process Incorporate approved language of OIP OI-HCV-20 Attachment 2.1.D into site SAMG OPEN procedure(s)
Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit Letter GO2-15-175 the location of the ROSs. The location of the 01 CLOSED remote operating Section 3.2.1 station is shown on Figure 1-1.
Make available for NRC staff audit 02 the location of the portable air OPEN Section 3.2.1 compressor.
Make available for NRC staff audit DG5 is stored in the location of the portable diesel FLEX Building 600 generators. which is shown on Sketch 1 of letter GO2-14-031. The expected deployment location of DG5 is 03 CLOSED shown on Figure 1-1 Section 3.2.1 of letter GO2-15-175.
DG4 has not been moved and remains in its normal location approximately 69 south of the DG building.
GO2-17-118 Enclosure Page 9 of 12 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section 04 Make available for NRC staff audit an Section 3.2.1 evaluation of temperature and Section 3.2.2.4 radiological conditions to ensure that Section 3.2.2.5 operating personnel can safely Section 3.2.2.10 access and operate controls and OPEN Section 3.2.4.1 support equipment.
Section 3.2.4.2 Section 3.2.5.2 Section 3.2.6 Make available for NRC staff audit ME-02-13-03 analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of uprated licensed/rated thermal power (unless a lower value 05 is justified), and that the suppression Section 3.2.2.1 pool and the HCVS together are able CLOSED Section 3.2.2.2 to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe 06 accident for the components (valves, Section 3.2.2.3 instrumentation, sensors, Section 3.2.2.5 transmitters, indicators, electronics, OPEN Section 3.2.2.9 control devices, etc.) required for Section 3.2.2.10 HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
GO2-17-118 Enclosure Page 10 of 12 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for N RC staff audit Calculations ME documentation of the HCVS nitrogen 15-08 and ME-02 pneumatic system design including 17 were approved on sizing and location. 8/10/16. ME-02 08 confirms the adequate sizing and location of the nitrogen piping and 07 ME-02-14-17 sizes Section 3.2.2.4 CLOSED the relief valve HCV-Section 3.2.6 RV-101. This AR may be closed since the calculations are available for NRC audit. Copies of approved cover sheets are included in EDMS.
Make available for NRC staff audit E/I-02-13-03 08 the final sizing evaluation for HCVS Section 3.2.2.4 batteries/battery charger including CLOSED Section 3.2.6 incorporation into FLEX DG loading calculation.
Make available for NRC staff audit See Section 4.0 of documentation that demonstrates the Enclosure to this adequate communication between letter.
09 the remote HCVS operation locations CLOSED Section 3.2.2.5 and HCVS decision makers during ELAP and severe accident conditions.
Provide a description of the Energy Northwest will strategies for hydrogen control that use Option number 5 minimizes the potential for hydrogen of the NEI White gas migration and ingress into the RB Paper HCV-WP-03, or other buildings. Hydrogen/Carbon 10 Monoxide Control CLOSED Section 3.2.2.6 Measures and add a check valve at the discharge end of the vent pipe to address the flammability of combustible gasses.
GO2-17-118 Enclosure Page 11 of 12 Response to the Phase 1 Request for Additional Information RAI Number ISE Report Action Status Comment Section Make available for NRC staff audit Energy Northwest descriptions of all instrumentation has completed and controls (existing and planned) compiling the 11 necessary to implement this order CLOSED requested information Section 3.2.2.9 including qualification methods. and will make it available to the NRC staff.
Make available for NRC staff audit Columbia will be documentation of an evaluation using an unused verifying the existing containment containment 12 isolation valves, relied upon for the penetration and will CLOSED Section 3.2.2.9 HCVS, will open under the maximum be installing new expected differential pressure during containment isolation BDBEE and severe accident wetwell valves.
venting.
Make available for NRC staff audit The following EOPs site specific details of the EOPs when provide for available. containment venting during an ELAP event:
PPM 5.6.1, 13 SBO/ELAP CLOSED Section 3.4.1 PPM 5.6.2, SBO and ELAP Attachments PPM 5.2.1, Primary Containment Control Provide justification for not leak Columbia has testing the HCVS every three adopted the current operating cycles and after restoration NEI guidance on 14 of any breach of system boundary CLOSED testing and Inspection Section 3.4.4 within buildings. requirements as shown in Table 4-1 of Reference 5 Add a discussion on communications Discussed in Section 15 between the CR, FLEX pump, and 4.0 of the enclosure to CLOSED Section 3.2.2.5 ROS operators to the December 6- letter GO2-16-171 month HCV update.
GO2-17-118 Enclosure Page 12 of 12 Response to the Phase 2 Request for Additional Information RAI Number ISE Report Action Status Comment Section Licensee to determine the location of 1 the FLEX hose installed valves and OPEN Section 3.2.1 flow elements, which will be used to control SAWA/SAWM flow.
Licensee to evaluate the SAWA equipment and controls, as well as 2 ingress and egress paths for the OPEN Section 3.3.2.3 expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period.
Licensee to demonstrate that containment failure as a result of 3
overpressure can be prevented OPEN Section 3.3.3 without a drywell vent during severe accident conditions.
Licensee shall demonstrate how the plant is bounded by the reference 4
plant analysis that shows the SAWM OPEN Section 3.3.3.1 strategy is successful in making it unlikely that a drywell vent is needed.
Licensee to demonstrate that there is adequate communication between the 5
MCR and the operator at the FLEX OPEN Section 3.3.3.4 pump during severe accident conditions.
Licensee to demonstrate the SAWM 6 flow instrumentation qualification for OPEN Section 3.3.3.4 the expected environmental conditions.