ML14070A445
| ML14070A445 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/21/2014 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-029 | |
| Download: ML14070A445 (6) | |
Text
ENERGY.,
NORTHWEST David A: Swank Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-2309 I F. 509-377-2354 daswank @ energy-northwest.com NRC Order EA-12-049 February.21;, 2014 G02-14-026 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" ;
References:
- 1) Letter-dated March 12, 2012, from E. J.Leeds, USNRC, to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Extemal Events" (NRC Order EA-12-049)
- 2) Letter G02-13-034, dated February 28, 2013, frr6m A. L. Javorik (Energy Northwest) to USNRC, "Energy Northwest's Responseto.NRC Order EA-
- 12-049 - Overall Integrated Plan for Mitigating Strategies."
--3) Letter dated March 12, 2012, from E. J. Leeds, USNRC, 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," (NRC Order EA-12-050)
- 4) Letter dated June 6, 2013, from E. J. Leeds, USNRC, 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," (NRC Order EA-13-109)
Dear Sir or Madam:
This letter transmits a request for relaxation of the requirements contained in Nuclear Regulatory Commission Order EA-12-049.
On March 12, 2012, the NRC issued an Order (Reference 1) to Energy Northwest.
Reference 1 was immediately effective and directed Energy Northwest to develop, implement, and maintain guidance and strategies to maintain or restore core cooling,
REQUEST FOR RELAXAION FROM NRC ORDER EA-12049, 'OROE MODIFYING LICENSES WITH REGARD TO REGUiREMENTS FOR MITIGATION STRATEGIES FOR BEXTERNAL EVEN" Page 2 of 2 containment, and spent fuel pool cooling capabilities In the event of a beyond-design-basis external event. As described In the Overall Integrated Plan for Columbia Generating Station (Columbia) (Reference 2), these mitigation strategies are dependent upon Implementation of reliable hardened containment venting capability established in accordance with NRC Order EA-12-050 (Reference 3).
The NRC subsequently Issued NRC Order EA-1 3-109 (Reference 4), which rescinded the requirements of Order EA-12-050 and established revised schedule timelines and implementation dates for reliable hardened containment vents capable of operation under severe accident conditions. The revised containment venting capability schedule and Implementation timeline impacts the ability to achieve full Implementation of the mitigation strategy requirements of NRC Order EA-1 2-049 by the required dates for Columbia.
Section IV of NRC Order EA-12-049 (Reference 1) states that licensees proposing to deviate from requirements contained In NRC Order EA-12-049 may request that the Director, Office of Nuclear Reactor Regulation, relax those requirements. In accordance with Section IV of NRC Order EA-12-049, Energy Northwest is requesting that the Director, Office of Nuclear Reactor Regulation, relax the requirement for completion of full implementation as proscribed in Section IV.A.2 of NRC Order EA-12-049 as described In Attachment I to this letter.
Energy Northwest considers that, upon approval by the NRC, the alternative full implementation dates regarding NRC Order EA-1 2-049 proposed in the enclosure will constitute a condition of the NRC Order EA-1 2-049 for Columbia. Therefore, there are no new regulatory commitments contained in this letter.
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 the date of this letter.
Respectfully, D. A. Swank Assistant Vice President, Engineering
Attachment:
Request for Relaxation of NRC Order EA-12-049 Requirement IV.A.2 for Columbia Generating Station cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C AJ Rapacz - BPA/1 399
REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" Attachment Page 1 of 4 Request for Relaxation of NRC Order EA-12-049 Requirement IV.A.2 for Columbia Generating Station Relaxation Request:
Pursuant to the procedure specified in Section IV of Nuclear Regulatory Commission (NRC) Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1), Columbia Generating Station (Columbia), hereby submits a request for relaxation from the Order requirements for completion of full implementation currently required to be no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a of the Order, or December 31, 2016, whichever occurs first.
Order Requirement from Which Relaxation is Requested:
NRC Order EA-1 2-049,Section IV.A.2 requires completion of full implementation of the Order requirements to be no later than two (2) refueling cycles after submittal of the overall integrated plan, as required by Condition C.1.a or December 31, 2016, whichever comes first. In accordance with the requirements of the Order, Energy Northwest submitted the Columbia Generating Station Mitigation Strategies Overall Integrated Plan (Reference 2) on February 28, 2013. In Reference 5, Columbia identified the completion date for full implementation of NRC Order EA-12-049 as the restart from the spring 2015 refueling outage, in order to satisfy the requirements of NRC Order EA-12-049.
NRC Order EA-12-049 requires the development, implementation, and maintenance of guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling in the event of a beyond-design-basis external event. As described in the Overall Integrated Plan for Columbia (Reference 2), these mitigation strategies are dependent upon implementation of reliable hardened containment venting capability established in accordance with NRC Order EA-12-050 (Reference 3). However, the NRC subsequently issued NRC Order EA-13-109 (Reference 4), which rescinded the requirements of Order EA-1 2-050 and established revised schedule timelines and implementation dates for reliable hardened containment vents capable of operation under severe accident conditions. The revised schedule and implementation timeline contained in NRC Order EA-1 3-109 impacts the ability to achieve full implementation of the mitigation strategy requirements of NRC Order EA-12-049 with respect to the current required date for Columbia specified above.
Justification for Relaxation Request:
Columbia's implementation of the NRC Order EA-12-049 mitigation strategy for core cooling and containment credits primary containment wetwell (suppression pool) venting capability to support heat removal from the reactor pressure vessel (RPV) to the water in the suppression pool and from the suppression pool air space to the outside atmosphere.
In addition, containment wetwell venting minimizes the suppression pool heat up which allows crediting the Reactor Core Isolation Cooling (RCIC) System for RPV make-up
REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" Attachment Page 2 of 4 during Mitigating Strategies Phase 1 (reliance only on permanently installed equipment) if RCIC suction is from the suppression pool. Primary containment wetwell venting under Order EA-1 2-050 was initially planned to be implemented concurrently with the Mitigation Strategy Order EA-1 2-049.
As a result of NRC issuance of Order EA-13-109 (Reference 4), modifications to support primary containment wetwell venting (Severe Accident Capable Vent Phase 1 of Order EA-1 3-109) are not required until after 2016. Although, as discussed below, all FLEX equipment supporting the mitigation strategy requirements of NRC Order EA-12-049 will be installed as originally committed, the full mitigating strategy functional capabilities cannot be met until Phase 1 of Order EA-13-109 is implemented. Mitigation strategy procedures and training will need to reflect that the mitigating strategy functional requirements will not be fully met until Phase 1 of Order EA-13-109 is implemented.
In accordance with the requirements of NRC Order EA-13-109,Section IV.B, Columbia is required to complete implementation of the Phase 1 severe accident capable wetwell venting system no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first.
Based on the timelines specified in NRC Order EA-13-109, the severe accident capable wetwell venting system for Columbia will be implemented upon restart from the spring 2017 refueling outage.
Thus, full implementation of the mitigation strategies for Columbia in accordance with NRC Order EA-1 2-049 cannot be fully completed by the Order requirement date, which is no later than two (2) refueling cycles after submittal of the overall integrated plan required by Condition C.1.a or December 31, 2016, whichever comes first, since primary containment wetwell venting capability is an essential element of the mitigation strategies required by NRC Order EA-12-049, as described above.
The FLEX equipment and modifications required to implement the mitigation strategies required by NRC Order EA-12-049 will be completed and available for use in accordance with the implementation schedule requirements specified in NRC Order EA-12-049 except (as per the subject of this request) primary containment wetwell (suppression pool) venting capability. Until full containment wetwell venting capability is installed to meet the requirements of NRC Order EA-13-109, Columbia will maintain primary containment venting strategy in accordance with the Emergency Operating Procedures.
Accordingly, Energy Northwest requests that the NRC Order EA-12-049,Section IV.A.2, full implementation requirement dates for Columbia be relaxed to the following milestone in order to reflect implementation of the primary containment wetwell venting capability required by NRC Order EA-13-109:
Startup from the spring 2017 refueling outage
REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" Attachment Page 3 of 4 The revised containment vent requirements imposed by NRC Order EA-13-109 provide additional defense-in-depth measures for mitigating consequences of a beyond-design-basis external event since severe accident capable vents are required to be implemented by the NRC Order. A sequence of events such as the Fukushima Dai-ichi accident is unlikely to occur in the United States based on current regulatory requirements and existing plant capabilities. Therefore, allowing additional time for full implementation of the modifications required by NRC Order EA-13-109 is not a significant increase in plant risk.
Mitigation strategies not impacted by the delay in the implementation of the containment vent capability described above will be completed and implemented in accordance with the current requirements of NRC Order EA-1 2-049. These strategies described above provide enhanced plant capability to mitigate beyond-design-basis external events.
Therefore, the requested relaxation does not reduce nuclear safety or safe plant operations.
==
Conclusion:==
As described above, compliance with the NRC Order EA-12-049 schedule required for full completion of implementation of mitigation strategies would result in hardship or unusual difficulty without a compensating increase in the level of safety. The detailed requirements and guidelines supporting the design, installation, and operation of the containment wetwell vent will not be finalized by the NRC and industry on a schedule concurrent with full implementation of NRC Order EA-12-049. Accordingly, significant hardship and unusual difficulty exists in proceeding with design and installation of the containment wetwell vent prior to finalization of the detailed implementation requirements and guidelines. Therefore, in accordance with the provisions of Section IV of the Order, Energy Northwest requests relaxation of the requirement described in Section IV.A.2.
References
- 1) Letter dated March 12, 2012, from E. J. Leeds, USNRC, to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (NRC Order EA-12-049)
- 2) Letter G02-13-034, dated February 28, 2013, from A. L. Javorik (Energy Northwest) to USNRC, "Energy Northwest's Response to NRC Order EA-12-049 -
Overall Integrated Plan for Mitigating Strategies"
- 3) Letter dated March 12, 2012, from E. J. Leeds, USNRC, 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," (NRC Order EA-1 2-050)
REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" Attachment Page 4 of 4
- 4) Letter dated June 6, 2013, from E. J. Leeds, USNRC, 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," (NRC Order EA-1 3-109)
- 5) Letter G02-12-149, dated October 25, 2013, from D. A. Swank (Energy Northwest) to USNRC, "Energy Northwest's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"