GO2-19-082, Energy Northwest'S Final Six-Month Status Update Report for the Implementation of Nuclear Regulatory Commission (NRC) Order EA-13-109, Phase 2 Only

Energy Northwest'S 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

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)

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)

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 CD Sonoda - BPAf1399 (email)

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

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 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 Complete GO2-18-080 Phase 2 6-month update for Order EA-13-109 Dec. 2018 Complete GO2-18-145 Phase 2 6-month update for Order EA-13-109 June 2019 Complete This Letter Phase 2 Issuance of Energy Northwest's letter of compliance with NRC Order EA- Aug. 2019 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 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:

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 Complete May 2019 Developed Site Specific Maintenance Procedure Jan. 2019 Completed1 Developed Training Complete Apr. 2019 Complete Implementation Outage May 2019 June 2019 Procedure Changes Active May 2019 June 2019 Walk Through June 2019 Demonstration/Functional Test 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 Action Status Comment/Update Open Item Provide site-specific details of the Phase 1: No EOP EOPs when available. procedure changes are OI-HCV-10 OPEN Develop procedures for SAWA and required.

SAWM Phase 2: in review.

SAWA/SAWM flow is controlled using The FLEX flow element hose installed valves and mechanical and control valves have flow elements (EA-12-049 actions). been moved into the OI-HCV-12 CLOSED Location of these valves and flow reactor building at the elements will need to be considered 522' level.

per HCVS-FAQ-12.

Reconcile the out-of-service provisions for HCVS/SAWA with the OI-HCV-13 provisions documented in Columbias CLOSED PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.

Complete the evaluation to determine accessibility, habitability, staffing OI-HCV-14 CLOSED 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 CLOSED 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 The FLEX flow element and 1 of the FLEX hose installed valves control valves have been and flow elements, which will be CLOSED moved into the reactor Section 3.2.1 used to control SAWA/SAWM flow. 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 Action Status Comment Section Licensee to evaluate the SAWA equipment and controls, as well as 2

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

Licensee to demonstrate that containment failure as a result of 3 overpressure can be prevented CLOSED 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 CLOSED strategy is successful in making it 3.3.3.1 unlikely that a drywell vent is needed.

Licensee to demonstrate that there See discussion below1.

5 is adequate communication between Section the MCR and the operator at the CLOSED 3.3.3.4 FLEX pump during severe accident conditions.

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

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 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 Item Event Starts Time when ERO begins to arrive Time when NSRC begins to arrive Reactor Core Isolation 1

Cooling (RCIC) starts Suction swaps from CST to 1

suppression pool Operations crew enters 2 SBO/ELAP procedure PPM 5.6.1 Monitor RPV and 3 containment parameters and initiate RPV cool down Complete compensatory 4 measures to promote CR STA 15 min cooling PPM 5.6.2 Att 8.5 Consult with regional load 5 centers on offsite power Shift Manager - 30 min recovery PPM 5.6.1 Determine if AC power will not be restored within the Shift Manager with input from OPS2 6 normal SBO coping period (4 and OPS4 - 35 min hours) (i.e., declare ELAP)

PPM 5.6.1 Complete 125-V dc load shed RWCR and CRO3 - 20 7

PPM 5.6.2 Att. 8.4 min Perform 250-V DC load shed OPS 3 - 5 8

- PPM 5.6.2 Att. 8.4 & 8.9 min 9 Vent the main generator OPS 3 - 30 min 10 Depressurize RPV CRO1 Remove the pins on piping RWCR 11 support RCIC-967N - PPM 21 min 5.6.2 Att 8.2 OPS 2 Vent containment - PPM and 12 5.5.14 CRO 3 14 min Open additional breakers for RWCR and CRO3 13 Control Room cooling - PPM concurrent with #7 5.6.2 Att. 8.5 above Begin deployment of FLEX 14 ERO Personnel (Facilities personnel if called out) fueling equipment Open designated doors in RWCR 15 vital island and radwaste 16 min bldg. - PPM 5.6.2 Att. 8.12 Connect FLEX equipment for battery charging - ABN-16 OPS2, OPS4, Chem, HP, Laborer ~ 3 hrs ELEC-DG4-CROSS/TIEMC-7A

GO2-19-082 Page 6 of 10 Attachment Refuel creditied FLEX 17 equipment - SOP-FLEX- ERO Personnel (Facilities personnel if called out)

EQUIPMENT-REFUEL CRO3, Bypass RCIC trips - PPM 18 RWCR =

5.6.2 Att. 8.2 15 min RWCR concurr Install 6000 cfm fan - PPM 19 ent w/

5.6.2 Att. 8.12

1. 15 above OPS3 (doors Perform actions to promote and ERO Mechanics (Rigging of hatches) 20 RCIC room and RX bldg. roof 4 hr cooling PPM 5.6.2 Att. 8.11 hatch only) 30 min Connect FLEX equipment to 21 refill RPV RWCR, OPS3, Chem, HP, Laborer ~ 5 hrs Connect FLEX equipment to 22 provide cooling to SFP Connect large NSRC 23 ERO and NSRC Personnel generator 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 Declare SAE, Declare GE, Determine SM Time when ERO begins to arrive Time when NSRC begins to arrive ELAP #1, 2 CRS Control room Command and Control #4 CR Heat Reduction STA Assit SM with EP Response Actions PPM 5.6.2 CRO1 SCRAM Response RPV Level & Pressure Control SCRAM CRO2

Response

B/P RCIC Vent CRO3 DC Load Shed 5.6.2 Battery Charging Ops 5.6.2 Trips Cont Vent OPS2 Investigate DGs Battery Charging OPs 5.6.2 Cont Vent Main Gen, 250vDC RCIC OPS3 ABN-FSG-002 Monitor FLEX pump operation Load Shed Cooling OPS4 Investigate Switchyard Battery Charging OPs 5.6.2 Vital Bypass RCIC Island RWCR DC Load Shed 5.6.2 RCIC Support ABN-FSG-002 Cooling Trips pins 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 I I I I Position 5-6 hr Time when ERO begins to arrive 18-24 hr Time when NSRC begins to arrive ERO Personnel or Refueling Activities Facilities call out ERO Personnel or Refueling Activities Facilities call out 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 I I I

GO2-19-082 Page 8 of 10 Attachment Severe Accident Review Action 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 Item Time when ERO i

! < FUEL FAILURE I

Event Starts < VESSEL FAILURE I Time when NSRC begins to arrive begins to arrive > i I Reactor Core Isolation 1

Cooling (RCIC) fails Operations crew enters 2 SBO/ELAP procedure PPM 5.6.1 Monitor RPV and containment parameters 3 CRO1 and CRO2 and initiate RPV cool down I I I I Complete compensatory measures to promote CR 4 STA 15 min cooling - PPM 5.6.2 Att 8.5 I I I I Consult with regional load 5 centers on offsite power Shift Manager 30 min recovery - PPM 5.6.1 Determine if AC power  !  !  !  !

will not be restored within the normal SBO coping Shift Manager with input from OPS2 6

period (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) (i.e., and OPS4 35 min declare ELAP) PPM 5.6.1 I I I Complete 125-V dc load RWCR and CRO3 - 20 II 7 I shed - PPM 5.6.2 Att. 8.4 min I I

Perform 250-V DC load I I I I OPS 3 - 5 8 shed - PPM 5.6.2 Att. 8.4 min

& 8.9 I I I I I 9 Vent the main generator OPS 3 - 30 min I I I I 10 Depressurize RPV CRO1 OPS 2 Vent containment - PPM and CRO 12 5.5.14 3 - 14 min I I I I Open additional breakers RWCR and CRO3 13 for Control Room cooling concurrent with #7

- PPM 5.6.2 Att. 8.5 above I I Begin deployment of 14 ERO Personnel (Facilities personnel if called out)

FLEX fueling equipment Open designated doors in  !  !  !  !

vital island and radwaste CRO3 - 16 15 bldg. - PPM 5.6.2 Att. min 8.12 I I I Connect FLEX equipment for battery charging 16 OPS2, OPS4, Chem, HP, Laborer ~ 3 hrs ABN-ELEC-DG4-CROSS/TIEMC-7A Refuel credited FLEX  ! I 17 equipment - SOP-FLEX- i ERO Personnel (Facilities personnel if called out)

EQUIPMENT-REFUEL i

GO2-19-082 Page 9 of 10 Attachment CRO3 I II 19 Install 6000 cfm fan - concurrent i I PPM 5.6.2 Att. 8.12 w/ #15 i I I

above  ! I I

CRO3  !

II (doors I Perform actions to and roof ERO Mechanics (Rigging of hatches) - 4 I 20 promote-RX bldg. cooling I hatch hr I

- PPM 5.6.2 Att. 8.11 I only) 30 I

min I 21 Connect FLEX equipment  !  !

II to refill RPV RWCR, OPS3, Chem, HP, - 4 hrs I I I 22 Connect FLEX equipment i i I I

to provide cooling to SFP Connect large NSRC  !  !  ! II ERO and NSRC Personnel 23 generator  ! I i

I i I Connect large NSRC 24 ERO and NSRC Personnel pump On-Shift Crew

1. Position T0- 15 m 15-30 m 30-45 m 45-60 m i 1-2 hr 2-3 hr 3-4 hr 4-5 hr 5-6 hr I 6-7 hr I 7-8 hr 8-9 hr 9-10 hr 10-11 hr 11-12 hr 12-18 hr 18-24 hr II 25 hrs 28 hrs 30 hrs 32 hrs 34 hrs 36 hrs 38 hrs Declare SAE, Declare GE, Determine  ! Time when ERO !  ! II Time when NSRC begins to arrive 1 SM i < VESSEL FAILURE I I ELAP #1, 2 begins to arrive > i i I 2 CRS Control room Command and Control CR Heat Reduction 3 STA Assit SM with EP Response Actions PPM 5.6.2 4 CRO1 SCRAM Response RPV Level & Pressure Control SCRAM  !  ! I 5 CRO2 I I I

Response

!  ! I ABN-  !  ! I I

Vital Island Rx Bldg Battery Charging Vent I I 6 CRO3 DC Load Shed 5.6.2 FSG- I Cooling Cooling Ops 5.6.2 002 Cont i i I i i I ABN-  !  ! I I

Vent I I I 7 OPS2 Investigate DGs Battery Charging OPs 5.6.2 FSG- i i Cont I 002 i i  !

8 OPS3 Vent Main Gen, 250 vDC ABN-FSG-002 Monitor FLEX pump operation II Load Shed I ABN-I I II 9 OPS4 Investigate Switchyard Battery Charging OPs 5.6.2 FSG- I 002 I

10 RWCR DC Load Shed 5.6.2 ABN-FSG-002 I I II 11 CHEM Debris Removal ABN-FSG-002 I I II 12 HP1 Debris Removal ABN-FSG-002 I I II 13 HP2 ABN-FSG-002 II

! I I I I

14 HP3

! I 15 Laborer Battery Charging OPs 5.6.2 i i

GO2-19-082 Page 10 of 10 Attachment ERO Arrivals  !  !

j* I

1. 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 I

I I

ERO Personnel or 1

Facilities i Refueling Activities i

I I ERO Personnel or i 2 Refueling Activities Facilities call out i 3 ERO Mech I

! RB Cooling 5.6.2 Rigging Activities I

! I 4 ERO Mech

!  ! RB Cooling 5.6.2 Rigging Activities II