GO2-18-145, Energy Northwest'S December 2018 Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Phase 2 Only

Energy Northwest'S December 2018 Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Phase 2 Only

ML18347B495
Person / Time
Site:	Columbia
Issue date:	12/13/2018
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, GO2-18-145
Download: ML18347B495 (6)

Text

ENERGY Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 NORTHWEST Richland, WA 99352-0968 Ph. 509-377-8555 l F. 509-377-4150 aljavorik@energy-northwest.com EA-13-109 10 CFR 50.54(f)

December 13, 2018 GO2-18-145 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWESTS DECEMBER 2018 SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NUCLEAR REGULATORY COMMISSION (NRC) ORDER EA-13-109, PHASE 2 ONLY

References:

1. EA-13-109 from E. J. Leeds (NRC) to All Operating Boiling Water Reactor 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 (ADAMS ML13143A334 (Pkg.)

2. 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 Hardened Containment Vents under Severe Accident Conditions Phases 1 and 2, Revision 1," dated December 16, 2015 (ADAMS ML15351A363)

3. Letter GO2-18-080, from A. L. Javorik (Energy Northwest) to NRC, "Energy Northwests June 2018 Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Phase 2 Only," dated June 21, 2018 (ADAMS ML18176A186)

4. Letter GO2-17-147 from A. L. Javorik (Energy Northwest) to NRC, "Energy Northwests Notification of Full Compliance with Order EA 049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events'", dated August 17, 2017 (ADAMS ML17229B506)

5. Letter from J. L. Quichocho (NRC) to M. E. Reddemann (Energy Northwest), "Columbia Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order

G02-18-145 Page 2 of 2 EA-13-109 (Severe Accident Capable Hardened Vents) (CAC NO.

MF4383}," dated September 29, 2016 (ADAMS No. ML15266A233)

Dear Sir or Madam,

By Reference 1 the Nuclear Regulatory Commission (NRG) issued Order EA-13-109 which required licensees to develop an overall integrated plan (OIP) and submit 6-month update reports in regards to installation and operation of a reliable hardened containment vent capable of operation under severe accident conditions. Reference 2 provided the Columbia Generating Station's revised OIP for Phase 1 of Order EA 109 and the initial OIP for Phase 2 of the Order. Reference 3 transmitted the previous 6-month update report for Phase 2 of NRG Order EA-13-109. Reference 4 reported the completion of activities associated with NRG Order EA-12-049 as well as Phase 1 of NRG Order EA-13-109.

The attachment to this letter provides the required 6-month update report for the remaining Phase 2 activities and open items of Order EA-13-109 as of November 30, 2018 including the Phase 2 request for additional information identified in Reference 5 relating to Columbia's overall integrated plan for severe accident capable hardened vents.

No new commitments are being made by this letter or the enclosure. If you have any questions or require additional information, please contact Ms. D. M. Wolfgramm at (509) 377-4792.

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

Executed on this f!/t"- day of /lee< ,rz~ ~ f' , 2018.

Respectfully,

tli, A. L. Jav

• Vice Pre ident, Engineering

Attachment:

As stated cc: NRG RIV Regional Administrator CD Sonoda - BPAf1399 (email)

NRG NRR Project Manager WA Horin - Winston & Strawn NRG Senior Resident lnspector/988C

GO2-18-145 Attachment Page 1 of 4 1.0 Introduction By Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 to Columbia Generating Station (Columbia). The Order contained requirements for the installation of a reliable containment hardened vent capable of operation under severe accident conditions. Reference 1 also required submittal of an Overall Integrated Plan (OIP) describing how compliance with the requirements described in the Order will be achieved and required the submittal of status reports at six month intervals. This attachment provides Energy Northwests six-month status report for the remaining Phase 2 milestones, open items, and any changes to the compliance method or schedule.

2.0 Milestone Accomplishments As listed below.

3.0 Milestone Schedule Status The following table provides a listing of the remaining reports associated with NRC Order EA-13-109 as of November 30, 2018.

Correspondence and Reports Target Comments Activity (Include date Milestone Completion Status changes in this Date column) 6-month update for Order EA-13-109 Dec. 2017 Complete GO2-17-201 Phase 2 6-month update for Order EA-13-109 June 2018 Completed GO2-18-080 Phase 2 6-month update for Order EA-13-109 Dec. 2018 Completed This Letter 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 following is the status of the overall integrated plan for reliable hardened containment vents (HCV) under severe accident conditions milestones as of November 30, 2018.

HCV Phase 1 Milestone Schedule:

Reported complete in letter GO2-17-147, dated August 17, 2017 - no longer reported.

GO2-18-145 Attachment Page 2 of 4 HCV Phase 2 Milestone Schedule:

Target Comments Activity (Include date Milestone Completion Status changes in this Date column)

This date was Hold preliminary/conceptual design changed to July July 2016 Complete meeting 2017 in letter GO2-16-171 Nov. 2018 Design Engineering On-site/Complete July 2018 Complete No modifications required Operations Procedure Changes Jan. 2019 May 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/Updates to Overall Integrated Plan 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 following tables provide an update of the status of the remaining open items as of November 30, 2018.

List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment/Update Open Item Provide site-specific details of the EOPs when available.

OI-HCV-10 OPEN Develop procedures for SAWA and SAWM

GO2-18-145 Attachment Page 3 of 4 List of Overall HCV Integrated Plan Open Items HCV OIP Action Status Comment/Update Open Item 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 provisions OI-HCV-13 documented in Columbias PPM OPEN 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 OI-HCV-15 figures C-2 through C-6 and determine OPEN the time sensitive SAWM actions Incorporate approved language of OIP OI-HCV-20 Attachment 2.1.D into site SAMG OPEN procedure(s)

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 flow elements, which will be used to OPEN Section 3.2.1 control SAWA/SAWM flow.

Licensee to evaluate the SAWA equipment and controls, as well as 2

ingress and egress paths for the Section OPEN expected severe accident conditions 3.3.2.3 (temperature, humidity, radiation) for the sustained operating period.

GO2-18-145 Attachment Page 4 of 4 Response to the Phase 2 Request for Additional Information RAI Number ISE Report Action Status Comment Section 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 Section OPEN strategy is successful in making it 3.3.3.1 unlikely that a drywell vent is needed.

Licensee to demonstrate that there is 5 adequate communication between Section the MCR and the operator at the OPEN 3.3.3.4 FLEX pump during severe accident conditions.

Licensee to demonstrate the SAWM 6 flow instrumentation qualification for Section the expected environmental OPEN 3.3.3.4 conditions.

7.0 Reference

1. EA-13-109 from E. J. Leeds (NRC) to All Operating Boiling Water Reactor 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 (ADAMS ML13143A334 (Pkg.)