GO2-22-072, Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing

Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing

ML22192A207
Person / Time
Site:	Columbia
Issue date:	07/11/2022
From:	Wolfgramm D Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-22-072
Download: ML22192A207 (3)

Text

ENERGY Desiree M. Wolfgramm Columbia Generating Station NORTHWEST P.O. Box 968, PE20 Richland, WA 99352-0968 Ph . 509.377.4792 dmwolfgramm@energy-northwest.com July 11, 2022 GO2-22-072 10 CFR 50.54(q)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 205551

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397;

SUMMARY

OF CHANGES AND ANALYSIS FOR REVISION 57 OF PPM 13.14.4 EMERGENCY EQUIPMENT MAINTENANCE AND TESTING

Dear Sir or Madam:

Enclosed is the summary of changes and analysis for Revision 57 of Plant Procedures Manual 13.14.4, Emergency Equipment Maintenance and Testing issued on June 16, 2022. The changes to the Plant Procedures Manual (PPM) have been evaluated in accordance with 10 CFR 50.54(q) and 10 CFR 72.44(f). The PPM, as revised, continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E. The Enclosure contains a summary of changes and evaluations performed. Each change was evaluated in accordance with the station's 10 CFR 50.54(q) evaluation process. These changes do not create a reduction in effectiveness (RIE) of the approved emergency plan.

This submittal contains no new or revised regulatory commitments. Should you have any questions or desire additional information regarding these matters, please contact Jennifer Kuklinski at (509) 377-4133.

Executed on the l r'- u\ ,

day of - ..-..:::-:.~ ....,.......- - - - 2022.

D.M. Wolfgramm Manager, Regulatory

Enclosure:

Summary of Changes and Analysis cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector Director - Division of Fuel Management, NMSS CD Sonoda, BPA

GO2-22-072 Enclosure Page 1 of 2 Summary of Changes and Analysis Revision 57 of PPM 13.14.4, Emergency Equipment Maintenance and Testing incorporates changes associated with Carbon Filter replacement frequency associated with the Technical Support Center (TSC) and the Emergency Operations Facility (EOF).

Additional editorial changes made as necessary. The following summarize the changes.

1. Update frequency of PMID 17351-01, "AMA-CF-52 Replace Carbon, Inspect (Filtr-1 9.3)" from 96 weeks to 24 months.

System performance indicates that carbon filter units are replaced and then the leak by testing is performed. The leakage testing and monitoring of performance is completed in accordance with PPM 10.2.82, HEPA Filter In-Place Testing.

However, for the preventative maintenance performances since 2012 (when carbon filter differential pressure monitoring commenced), the carbon filter was replaced without as found testing performed. Thus, all performance data available for AMA-CF-52 is for a new/clean unit. However, unless the system is operated with significant moisture, fire or volatile vapor in the vicinity of the local intake zone, little filter depletion is expected. Other maintenance activities for comparable ventilation filter units indicate the seals will sustain in excess of two years without significant degradation. For example, WMA-CF-54A/B are on an eight-year PM cycle per PMID 19457 and 22342, respectively.

The filter replacement and testing is consistent with the vendor requirement specified in CVI OMM 216-23,5.

2. Update frequency of PMID 9053-01, "OFMA-HF-1C HEPA Test", from 18 months to 24 months.

System performance indicates that filter performance will not be adversely affected by increasing the periodicity to 2 years. The periodicity is consistent with other Engineered Safety Feature (ESF) filter units.

The leakage testing and monitoring of performance is completed in accordance with PPM 10.2.82, HEPA Filter In-Place Testing. This procedure monitors the prefilter and HEPA filter DP and performs a leak test of the filter assembly for internal leakage.

The maintenance history indicates the HEPA filters have been in place for a considerable period. The testing history indicates leakage is not adversely affected by the increased testing periodicity. The maintenance history indicates the seals will support a two-year periodicity without adversely affecting the potential leakage post-accident.

GO2-22-072 Enclosure Page 2 of 2 OFMA-HF-1C Leakage Year  % Date WO 2012 0.019 12/20/2012 02022202 2014 0.04 6/25/2014 02045513 2016 0.02 2/26/2016 02067030 2017 0.0173 8/16/2017 02104395 2019 Failed *1 7/30/2019 02138368 2021 0.004 3/29/2021 02161207 2021 work performed under WO 02148510

• 1 - Filter failed on visual inspection, not leakage.

3. Update frequency of PMID 9054-01, "OFMA-HF-1 H HEPA Test", from 18 months to 24 months.

See detail in Section 2 above and specific filter data below.

OFMA-HF-1H Leakage Year  % Date WO 2012 0.016 12/20/2012 02022203 2014 0.018 6/25/2014 02045514 2016 0.002 2/26/2016 02067031 2017 0.0133 8/16/2017 02104396 2019 0.0183 8/1/2019 02138369 2021 0.004 3/29/2021 02162481 2021 work performed under WO 02148510 By performance of an evaluation of the NRC approved Emergency Plan and subsequent revisions requirements, the conclusion is this change does not reduce the effectiveness of the Emergency Plan and the plan continues to meet the requirements in §50 Appendix E and the planning standards of§ 50.47(b).

This change does not represent a negative impact to either timeliness or capability, therefore there is no Reduction in Effectiveness to implement the Emergency Plan.