GO2-19-082, Energy Northwests Final Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Phase 2 Only
| ML19175A271 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/24/2019 |
| From: | Javorik A Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, GO2-19-082 | |
| Download: ML19175A271 (12) | |
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-13-109 10 CFR 50.54(f)
June 24, 2019 GO2-19-082 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWESTS FINAL 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 GO2-18-145, from A. L. Javorik (Energy Northwest) to NRC, "Energy Northwests December 2018 Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC)
Order EA-13-109, Phase 2 Only," dated December 13, 2018 (ADAMS ML18347B495)
- 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 EA-13-109 (Severe Accident Capable Hardened Vents) (CAC NO.
MF4383)," dated September 29, 2016 (ADAMS No. ML15266A233)
ENERGY NORTHWEST
GO2-19-082 Page 2 of 2
Dear Sir or Madam,
By Reference 1 the Nuclear Regulatory Commission (NRC) 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 ofa 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 NRC Order EA-13-109. Reference 4 reported the completion of activities associated with NRC Order EA-12-049 as well as Phase 1 of NRC 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 May 31, 2019 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. This letter will serve as the final 6-month update required by Reference 1 prior to the submittal of the required report of full compliance with Reference 1.
No new commitments are being made by this letter or the attachment. 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 23/thday of Tur1 e
, 2019.
A. L. Javorik Vice President, Engineering
Attachment:
As stated cc:
NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident lnspector/988C CD Sonoda - BPAf1399 (email)
WA Horin - Winston & Strawn
GO2-19-082 Page 1 of 10 Attachment 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 May 31, 2019.
Correspondence and Reports Milestone Target Completion Date Activity Status Comments (Include date changes in this column) 6-month update for Order EA-13-109 Phase 2 Dec. 2017 Complete GO2-17-201 6-month update for Order EA-13-109 Phase 2 June 2018 Complete GO2-18-080 6-month update for Order EA-13-109 Phase 2 Dec. 2018 Complete GO2-18-145 6-month update for Order EA-13-109 Phase 2 June 2019 Complete This Letter Issuance of Energy Northwest's letter of compliance with NRC Order EA-13-109, Phase 2 Aug. 2019 Started The following is the status of the overall integrated plan for reliable hardened containment vents (HCV) under severe accident conditions milestones as of May 31, 2019.
HCV Phase 1 Milestone Schedule:
Reported complete in letter GO2-17-147, dated August 17, 2017 - no longer reported.
GO2-19-082 Page 2 of 10 Attachment HCV Phase 2 Milestone Schedule:
Milestone Target Completion Date Activity Status Comments (Include date changes in this column)
Hold preliminary/conceptual design meeting July 2016 Complete This date was changed to July 2017 in letter GO2-16-171 Design Engineering On-site/Complete July 2018 Complete Nov. 2018 No modifications required Operations Procedure Changes Developed Jan. 2019 Complete May 2019 Site Specific Maintenance Procedure Developed Jan. 2019 Completed1 Training Complete Apr. 2019 Complete Implementation Outage May 2019 June 2019 Procedure Changes Active May 2019 June 2019 Walk Through Demonstration/Functional Test June 2019 1 No new equipment was procured for Phase 2. Therefore, no new maintenance procedures are required.
4.0 Changes/Updates to Overall Integrated Plan Changes have been made to the response sequence used for mitigation of a beyond-design-basis accident to enable the use of a single response to both a non-severe and severe accident scenario. The changes have been revalidated and remain within the original staffing study staffing levels.
Upon completion of the updated validation, an integrated review was conducted to ensure that adequate resources (personnel, equipment, materials) are available to implement the individual strategies to achieve the intended results was conducted. A comparison of the original FLEX Integrated Review and the severe accident response was made. The review of the two responses shows that there are adequate on-shift crew resources, supplemented by returning staff (after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) without any overlap of assignments to complete the required actions in the required time. The integrated reviews are provided at the end of this attachment.
5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation None
GO2-19-082 Page 3 of 10 Attachment 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 May 31, 2019.
List of Overall HCV Integrated Plan Open Items HCV OIP Open Item Action Status Comment/Update OI-HCV-10 Provide site-specific details of the EOPs when available.
Develop procedures for SAWA and SAWM OPEN Phase 1: No EOP procedure changes are required.
Phase 2: in review.
OI-HCV-12 SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA-12-049 actions).
Location of these valves and flow elements will need to be considered per HCVS-FAQ-12.
CLOSED The FLEX flow element and control valves have been moved into the reactor building at the 522' level.
OI-HCV-13 Reconcile the out-of-service provisions for HCVS/SAWA with the provisions documented in Columbias PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.
CLOSED OI-HCV-14 Complete the evaluation to determine accessibility, habitability, staffing sufficiency, and communication capability during SAWA/SAWM CLOSED OI-HCV-15 Perform MAPP analysis for NEI 13-02 figures C-2 through C-6 and determine the time sensitive SAWM actions CLOSED OI-HCV-20 Incorporate approved language of OIP.1.D into site SAMG procedure(s)
OPEN Response to the Phase 2 Request for Additional Information RAI Number ISE Report Section Action Status Comment 1
Section 3.2.1 Licensee to determine the location of the FLEX hose installed valves and flow elements, which will be used to control SAWA/SAWM flow.
CLOSED The FLEX flow element and control valves have been moved into the reactor building at the 522' level.
GO2-19-082 Page 4 of 10 Attachment Response to the Phase 2 Request for Additional Information RAI Number ISE Report Section Action Status Comment 2
Section 3.3.2.3 Licensee to evaluate the SAWA equipment and controls, as well as ingress and egress paths for the expected severe accident conditions (temperature, humidity, radiation) for the sustained operating period.
CLOSED 3
Section 3.3.3 Licensee to demonstrate that containment failure as a result of overpressure can be prevented without a drywell vent during severe accident conditions.
CLOSED 4
Section 3.3.3.1 Licensee shall demonstrate how the plant is bounded by the reference plant analysis that shows the SAWM strategy is successful in making it unlikely that a drywell vent is needed.
CLOSED 5
Section 3.3.3.4 Licensee to demonstrate that there is adequate communication between the MCR and the operator at the FLEX pump during severe accident conditions.
CLOSED See discussion below1.
6 Section 3.3.3.4 Licensee to demonstrate the SAWM flow instrumentation qualification for the expected environmental conditions.
CLOSED 1 Procedure ABN-FSG-002 has been revised to include a sound powered phone kit to be deployed with either FLEX pump to allow the pump operator to use the sound powered phone jack in either service water pump house to communicate with the control room or the valve operator in the reactor building if radio communications are not available. Additionally, the sound powered phone system and radio system are routinely tested and inventoried.
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.)
GO2-19-082 Page 5 of 10 Attachment FLEX Integrated Review Action Item Action T0-15 min 15-30 min 30-45 min 45-60 min 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs Event Starts Time when ERO begins to arrive Time when NSRC begins to arrive 1
Reactor Core Isolation Cooling (RCIC) starts 1
Suction swaps from CST to suppression pool 2
Operations crew enters SBO/ELAP procedure PPM 5.6.1 3
Monitor RPV and containment parameters and initiate RPV cool down 4
Complete compensatory measures to promote CR cooling PPM 5.6.2 Att 8.5 STA 15 min 5
Consult with regional load centers on offsite power recovery PPM 5.6.1 Shift Manager - 30 min 6
Determine if AC power will not be restored within the normal SBO coping period (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) (i.e., declare ELAP)
PPM 5.6.1 Shift Manager with input from OPS2 and OPS4 - 35 min 7
Complete 125-V dc load shed PPM 5.6.2 Att. 8.4 RWCR and CRO3 - 20 min 8
Perform 250-V DC load shed
- PPM 5.6.2 Att. 8.4 & 8.9 OPS 3 - 5 min 9
Vent the main generator OPS 3 - 30 min 10 Depressurize RPV CRO1 11 Remove the pins on piping support RCIC-967N - PPM 5.6.2 Att 8.2 RWCR 21 min 12 Vent containment - PPM 5.5.14 OPS 2 and CRO 3 14 min 13 Open additional breakers for Control Room cooling - PPM 5.6.2 Att. 8.5 RWCR and CRO3 concurrent with #7 above 14 Begin deployment of FLEX fueling equipment ERO Personnel (Facilities personnel if called out) 15 Open designated doors in vital island and radwaste bldg. - PPM 5.6.2 Att. 8.12 RWCR 16 min 16 Connect FLEX equipment for battery charging - ABN-ELEC-DG4-CROSS/TIEMC-7A OPS2, OPS4, Chem, HP, Laborer ~ 3 hrs
GO2-19-082 Page 6 of 10 Attachment 17 Refuel creditied FLEX equipment - SOP-FLEX-EQUIPMENT-REFUEL ERO Personnel (Facilities personnel if called out) 18 Bypass RCIC trips - PPM 5.6.2 Att. 8.2
- CRO3, RWCR =
15 min 19 Install 6000 cfm fan - PPM 5.6.2 Att. 8.12 RWCR concurr ent w/
- 15 above 20 Perform actions to promote RCIC room and RX bldg.
cooling PPM 5.6.2 Att. 8.11 OPS3 (doors and roof hatch only) 30 min ERO Mechanics (Rigging of hatches) 4 hr 21 Connect FLEX equipment to refill RPV RWCR, OPS3, Chem, HP, Laborer ~ 5 hrs 22 Connect FLEX equipment to provide cooling to SFP 23 Connect large NSRC generator ERO and NSRC Personnel 24 Connect large NSRC pump ERO and NSRC Personnel On-Shift Crew Position T0- 15 m 15-30 m 30-45 m 45-60 m 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs SM Declare SAE, Declare GE, Determine ELAP #1, 2 Time when ERO begins to arrive Time when NSRC begins to arrive CRS Control room Command and Control #4 STA CR Heat Reduction PPM 5.6.2 Assit SM with EP Response Actions CRO1 SCRAM Response RPV Level & Pressure Control CRO2 SCRAM
Response
CRO3 DC Load Shed 5.6.2 B/P RCIC Trips Battery Charging Ops 5.6.2 Vent Cont OPS2 Investigate DGs Battery Charging OPs 5.6.2 Vent Cont OPS3 Vent Main Gen, 250vDC Load Shed RCIC Cooling ABN-FSG-002 Monitor FLEX pump operation OPS4 Investigate Switchyard Battery Charging OPs 5.6.2 RWCR DC Load Shed 5.6.2 Bypass RCIC Trips RCIC Support pins Vital Island Cooling ABN-FSG-002 CHEM Debris Removal ABN-FSG-002 HP1 Debris Removal ABN-FSG-002 HP2 HP3 Laborer Battery Charging OPs 5.6.2 ABN-FSG-002
GO2-19-082 Page 7 of 10 Attachment ERO Arrivals Position 5-6 hr Time when ERO begins to arrive 18-24 hr Time when NSRC begins to arrive ERO Personnel or Facilities call out Refueling Activities ERO Personnel or Facilities call out Refueling Activities ERO Mech RB Cooling 5.6.2 Rigging Activities ERO Mech RB Cooling 5.6.2 Rigging Activities T0-15 min 15-30 min 30-45 min 45-60 min 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs I
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GO2-19-082 Page 8 of 10 Attachment Severe Accident Review Action Item Action T0-15 min 15-30 min 30-45 min 45-60 min 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs Event Starts
< FUEL FAILURE Time when ERO begins to arrive >
< VESSEL FAILURE Time when NSRC begins to arrive 1
Reactor Core Isolation Cooling (RCIC) fails 2
Operations crew enters SBO/ELAP procedure PPM 5.6.1 3
Monitor RPV and containment parameters and initiate RPV cool down CRO1 and CRO2 4
Complete compensatory measures to promote CR cooling - PPM 5.6.2 Att 8.5 STA 15 min 5
Consult with regional load centers on offsite power recovery - PPM 5.6.1 Shift Manager 30 min 6
Determine if AC power will not be restored within the normal SBO coping period (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) (i.e.,
declare ELAP) PPM 5.6.1 Shift Manager with input from OPS2 and OPS4 35 min 7
Complete 125-V dc load shed - PPM 5.6.2 Att. 8.4 RWCR and CRO3 - 20 min 8
Perform 250-V DC load shed - PPM 5.6.2 Att. 8.4
& 8.9 OPS 3 - 5 min 9
Vent the main generator OPS 3 - 30 min 10 Depressurize RPV CRO1 12 Vent containment - PPM 5.5.14 OPS 2 and CRO 3 - 14 min 13 Open additional breakers for Control Room cooling
- PPM 5.6.2 Att. 8.5 RWCR and CRO3 concurrent with #7 above 14 Begin deployment of FLEX fueling equipment ERO Personnel (Facilities personnel if called out) 15 Open designated doors in vital island and radwaste bldg. - PPM 5.6.2 Att.
8.12 CRO3 - 16 min 16 Connect FLEX equipment for battery charging ABN-ELEC-DG4-CROSS/TIEMC-7A OPS2, OPS4, Chem, HP, Laborer ~ 3 hrs 17 Refuel credited FLEX equipment - SOP-FLEX-EQUIPMENT-REFUEL ERO Personnel (Facilities personnel if called out) i I
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GO2-19-082 Page 9 of 10 Attachment 19 Install 6000 cfm fan -
PPM 5.6.2 Att. 8.12 CRO3 concurrent w/ #15 above 20 Perform actions to promote RX bldg. cooling
- PPM 5.6.2 Att. 8.11 CRO3 (doors and roof hatch only) 30 min ERO Mechanics (Rigging of hatches) - 4 hr 21 Connect FLEX equipment to refill RPV RWCR, OPS3, Chem, HP, - 4 hrs 22 Connect FLEX equipment to provide cooling to SFP 23 Connect large NSRC generator ERO and NSRC Personnel 24 Connect large NSRC pump ERO and NSRC Personnel On-Shift Crew Position T0- 15 m 15-30 m 30-45 m 45-60 m 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs 1
SM Declare SAE, Declare GE, Determine ELAP #1, 2 Time when ERO begins to arrive >
< VESSEL FAILURE Time when NSRC begins to arrive 2
CRS Control room Command and Control 3
STA CR Heat Reduction PPM 5.6.2 Assit SM with EP Response Actions 4
CRO1 SCRAM Response RPV Level & Pressure Control 5
CRO2 SCRAM
Response
6 CRO3 DC Load Shed 5.6.2 Vital Island Cooling Rx Bldg Cooling Battery Charging Ops 5.6.2 ABN-FSG-002 Vent Cont 7
OPS2 Investigate DGs Battery Charging OPs 5.6.2 ABN-FSG-002 Vent Cont 8
OPS3 Vent Main Gen, 250 vDC Load Shed ABN-FSG-002 Monitor FLEX pump operation 9
OPS4 Investigate Switchyard Battery Charging OPs 5.6.2 ABN-FSG-002 10 RWCR DC Load Shed 5.6.2 ABN-FSG-002 11 CHEM Debris Removal ABN-FSG-002 12 HP1 Debris Removal ABN-FSG-002 13 HP2 ABN-FSG-002 14 HP3 15 Laborer Battery Charging OPs 5.6.2 I
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GO2-19-082 Page 10 of 10 Attachment ERO Arrivals Position T0-15 min 15-30 min 30-45 min 45-60 min 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr 6-7 hr 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs 1
ERO Personnel or Facilities Refueling Activities 2
ERO Personnel or Facilities call out Refueling Activities 3
ERO Mech RB Cooling 5.6.2 Rigging Activities 4
ERO Mech RB Cooling 5.6.2 Rigging Activities j*
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