ML14254A408
| ML14254A408 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/28/2014 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, G02-14-130 | |
| Download: ML14254A408 (8) | |
Text
David A.Swank Columbia Generating Staton ENERGYP.O. Box9935-096 Rk~hand, WA 968, PE04 Ph. 509-377-23091 F. 509-377-2364 claswank@ energynorthwesL0om AUG 2 8 2014 G02-14-130 EA-12-051 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION
References:
- 1. NRC Order EA-1 2-051 dated March 12, 2012, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"
- 2. Letter GO2-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-051 - Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation"
- 3. Letter dated June 20, 2013, from LK Gibson (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Regarding Spent Fuel Pool Instrumentation (TAC No. MF0797)"
- 4. Letter G02-13-100, dated July 19, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to Request for Additional Information Related to the Overall Integrated Plan for Spent Fuel Pool Instrumentation"
- 5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's First Six Month Status Update Report for the Implementation of NRC Order EA-1 2-051 Reliable Spent Fuel Pool Instrumentation"
- 6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station -
Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"
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ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL.
INSTRUMENTATION Page 2 of 2
Dear Sir or Madam,
In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable means of remotely monitoring wide range spent fuel pool levels to support effective priortization of event mitigation and recovery actions for a beyond-design-basis external event. The Order also requires submission of a status update at six-month intervals following the licensee's submittal of the Overall Integrated Plan provided in Reference 2.
The attachment to this letter provides Energy Northwest's third six-month report of Columbia's status of implementing Order EA-12-051 pursuant to Section IV,Condition C.2 of Reference 1. As stated in the Memorandum dated December 26, 2014, from C.
A. Hunt (NRC) to M. A. Mitchell (NRC), "Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," (ML13347B030) the staff clarified that the staff interim evaluation questions supersede any previous requests for information issued by the staff concerning the spent fuel instrumentation. Therefore, no updates to the RAts discussed in References 3, 4, or 5 have been provided.
Energy Northwest is continuing to work with the equipment vendor to develop the responses to the RAIs contained in Reference 6 and will respond by the November 30, 2014, due date identified in Reference 6. Ifunable to fully respond by the requested date, Energy Northwest will inform the NRC through the NRC project management.
There are no new or revised regulatory commitments contained in this letter. Ifyou 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 e -edayof i,4 , 2014 Respectfully, D.A. Swank Assistant Vice President, Engineering Attachment Third Six-Month Status Update Report for the Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Senior Resident Inspector/988C MA Jones - BPA/1 399 (email)
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 REUABLE SPENT FUEL POOL INSTRUMENTATION ATTACHMENT COLUMBIA GENERATING STATION, DOCKET NO. 50-397 THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE OVERALL INTEGRATED PLAN FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS. UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 1 of 5 1.0 Introduction In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have a reliable means of remotely monitoring wide range spent fuel pool (SFP) levels to support effective prioritization of event mitigation and recovery actions for a beyond-design-basis external event. Energy Northwest developed an Overall Integrated Plan (Reference 2) documenting the requirements to install reliable SFP level instrumentation in response to NRC Order EA-1 2-051. The Order also requires submission of a status update at six-month intervals following the licensee's submittal of the Overall Integrated Plan.
This is Energy Northwest's third six-month report of Columbia's status of implementing Order EA-12-051 pursuant to Section IV,Condition C.2 of Reference 1 and provides an update of milestone accomplishments since the previous update of February 2014, (Reference 7). Changes are identified by a revision bar in the right column or margin.
2.0 Milestone Accomplishments The following milestones have been completed since the last submittal on February 28, 2014.
- 1. Submittal of the Third Status Update Report for the Reliable SFP Instrumentation Integrated Plan
- 2. Detailed Design for the Reliable SFP Instrumentation 3.0 Milestone Schedule Status The following provides an updated milestone schedule to support the Reliable SFP Instrumentation Overall Integrated Plan. Some changes to the schedule have been made as shown by the revision bars as the required vendor information was delayed.
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 2 of 5 TargetRevised!
maisonsC"'pletio" nTkr ,Avty status Tor"t t0"1.
COM nes Date *
- Correspo*nderch &RePqrts: ...... .
Submit 60 Day Reliable SFP Instrumentation Status Report Oct 2012 Completed N/A Submit Overall Reliable SFP Instrumentation Integrated Plan First Status Update Report for the Reliable SFP Instrumentation August 2013 Completed N/A Integrated Plan Second Status Update Report for the Reliable SFP Instrumentation Feb 2014 Completed N/A Integrated Plan Third Status Update Report for the Reliable SFP Instrumentation August 2014 Completed N/A Integrated Plan Final Completion Report for the Reliable SFP Instrumentation Feb 2015 Not Started N/A Integrated Plan Engineering & Modifications:
Commence Engineering Detailed Design for the Reliable SFP March 2013 Completed N/A Instrumentation Complete Engineering Detailed Design for the Reliable SFP Aug 2014 Completed June 2014 Instrumentation Commence the Reliable SFP Instrumentation Modification July 2014 Not Started Nov 2014 Installation Reliable SFP Instrumentation Dec 2014 Not Started June 2015 Channels Operational Iec_2014 NotStarted June_2015 I
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 3 of 5 Program & prec dures: _ _. .. .............. .....
Develop the Reliable SFP instrumentation testing, calibration, maintenance, April 2014 Started Jun 2015 surveillance, and operational procedures Establish programmatic controls on SFP instrumentation related Dec 2014 Not Started N/A activities Operations & Tr~iiniing:..
- Commence development of the Reliable SFP Instrumentation April 2014 Completed N/A training modules Complete development of the Reliable SFP Instrumentation May 2014 Started May 2015 training modules Complete training of station Oct 2014 Started Jun 2015 personnel Functional testing of Reliable SFP Dec 2014 Not Started Feb 2015 Instrumentation SSCs complete Reliable SFP Instrumentation Program turned over to Dec 2014 Not Started Jun 2015 Operations
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 4 of 5 4.0 Changes to Compliance Method The Overall Integrated Plan (submitted in Reference 2) indicated that there would be an alternate display location. However, this concept was revised as identified in Reference
- 5. As a result, the reliable SFP instrumentation, primary and backup instrument channel display will only be located in the main control room. No other changes have been made to the compliance method and the design continues to meet the guidelines of JLD-ISG-2012-13 and NEI 12-02 section 3.9.
5.0 Need for Relief/Relaxation and Basis for the Relief/Relaxation At this time, Energy Northwest expects to fully comply with the Order and its implementation date and does not anticipate a request for relief and/or relaxation of the Order.
6.0 Open Items In Reference 3, the NRC requested additional information with regard to the Overall Integrated Plan and in Reference 4 Energy Northwest responded to that request with the understanding that the completed responses will be provided to the NRC in a future updated status report. In Reference 5, Energy Northwest provided the first 6-month update. However, in the Memorandum dated December 26, 2014, from C. A. Hunt (NRC) to M. A. Mitchell (NRC), "Summary of the November 26, 2013, (ML13347B030)
Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," the staff clarified that the interim staff evaluation (Reference
- 6) questions supersede any previous requests for information issued by the staff concerning the spent fuel instrumentation. Therefore, no updates to the RAIs discussed in References 3, 4, or 5 have been provided.
Energy Northwest is currently working with the equipment vendor to develop the responses to the RAIs contained in Reference 6 and will respond by the November 30, 2014, due date identified in Reference 6. Ifunable to fully respond by the requested date, Energy Northwest will inform the NRC through the NRC project management.
7.0 Potential Draft Safety Evaluation Impacts At this time, Energy Northwest does not believe there are any potential impacts to the Draft Safety Evaluation.
8.0 References
- 1. NRC Order EA-12-051 dated March 12, 2012, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"
ENERGY NORTHWEST'S THIRD SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION Attachment Page 5 of 5
- 2. Letter G02-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-051 - Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation"
- 3. Letter dated June 20, 2013, from LK Gibson (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Regarding Spent Fuel Pool Instrumentation (TAC No. MF0797)"
- 4. Letter G02-13-100, dated July 19, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Response to Request for Additional Information Related to the Overall Integrated Plan for Spent Fuel Pool Instrumentation"
- 5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's First Six Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"
- 6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"
- 7. Letter G02-14-030, dated February 27, 2014, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Second Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"