GO2-15-032, Fourth Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

Fourth Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

ML15084A106
Person / Time
Site:	Columbia
Issue date:	02/27/2015
From:	Swank D Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GO2-15-032, TAC MF0797
Download: ML15084A106 (8)

Text

Davi A.Swu*

4 ~PA.0BW Of PE04

.f- hkoL WA 0.524M Ptl, 5977-230S I F. 50,77-23M4 d _W0ew4gm February 27, 2015 G02-15-32" EA-12-051 U.S. Nuclear Reo ssl, "4" Commission ATTN: Document Control Desk -

washington, DC 20566-00

Subject:

. Co UA GNAT

• KuG TAO# OCKET 1O. W ENRa NWWHWR1'S FOURTH S4I~NIMT STATUS UPDATE, REUAWSL SPN OPIL ~OWL t4TUST1 RfeOen!e: 1. NRC Order EA-'12-0l diWM&aroh 12,2012, "Order ModifyIng Lenses wi Regard t* Rel*ilebSpent Fuel Pool Instr

2. Letter GO2-1 36.0, dated February 28, 2013, from DA Swank (Energy Northwe) to NRC, -Energy Northwets Response to NRC Order EA-Ovr~i nt10afd 12-51 tanttRelialeSpentOFe Pool

3. Letter dated June 0, 2013, frbi LK Glbion,(NRC) to ME Reddemann (Energy aStasio Re"uest for Additional Information Regarding Spent Fuel Pool Instrumentation (TAG No. MF0O797

4. Letter G02-13.1 00, dated July 19,2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwes 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 Updat Report for the Implementation of NRC Order EA-12-051 Reli Spent Fuel Pool Instrumentation"

6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Redde.aann (Energy No ), olumbia Geneati Station-Interim Staff Evaluatiuonand Requestefor Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"

ENERGY NORTHWEST'S FOURTH SIX-MONTH STATUS UPDATE REPORT FOR THE NPLEMENTATIONOF AC OOER A12451' fEUABLE SPENT IUEL'-

IPOOL 101U11TAIO Page 2aof

Dear Sir or Madam,

In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-1 2-051 which directed Energy Northwost Columbia Generatng Station (Columbia) to have a reliable means of remotely monitoring wide range spent fuel pool levels to support effective prioritization 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 fourth six-month report of Columbia's tatus o(I pmentlhV'Oe 9M"51 pvhuent to Section IV,Condition C.2 of Reference I. As stated In the Memorandum dated December 26,2014, from C.

A. Hunt (NRC) to M. A.AikWe(NRC), %r4.irV of te Noý1 r8, 2013, Public Meeting tfllscuss lnd srt Reeoiipsto SMfA'dft Evaluations frSjpnFuel Pool Instrumentation," (ML133478030)'the. W061 la dlhat 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 RAIs discussed In eferences 3, 4, or 5 were provided.

Energy Northwest has completed the development of the responses to the RAIs contained InReference 6 and has posted the responses to the E-portal as requested.

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.

4-fk Executed on the o dayof r'etua.t. ,2015 Respectfully, D.A. Swank Assistant Vice President, Engineering

Attachment:

Fourth 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/88C MA Jones - BPA/1 399 (email)

ENERGY NORTHWEST'S FOURTH S1KMONTI GTUTUS UPPAIW REPORT FOR THE IMPLEMENTATlON OF NRC ORDEWIWAHI* REUAN.EWIW FUEL POOL IMOTUMENATIO -. '

-V ~

. t ATTACHMENT,

- OWUSIEA ENER~A~TI STATION DOCKET NO. W0-W7 FOURTMSMONTH STATUS UPDATE REPORT FOR THE OVERALL NTEGRATED PLAN FORMAUASE WENT FUELPOOL INSTRUKUEWIATION

FOURTH SIX.MOtTH STATUS UPDATE REPORT FOR ThE ALL INTEGRATED PLAN FOR RELIABLE SPENT FUEL POOL INSIRUIENATION Attachment Page 1of 5 1.0 kItodution In Reference i!the Nuclear Regulatory Commi*lon (NRC) iiuedsOrder EA-1*2-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have a rellable menwaneot Ieely 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- 12-081. The Order also requires submission of a statu update at six-month intervals following the licensee's submittal of the Overall Integrated Plan.

This is Energy Northwest~ fourth 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 August 2014, (Reference 8). Changes are identified by a revision bar in the right column or margin.

2.0 MWtone Aciomplshments The following milestones have been completed since the last submittal on August 28, 2014.

1. Submittal of the Fourth Status Update Report for the Reliable SFP Instrumentation Integrated Plan.

2. Posting to the E-portal the responses to the requests for additional information identified In Reference 6.

3.0 M*lestoe dule 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.

FOURTH UX-4AOW STATUS UPDME REPORT FOR TNE OVERALL iWTEGRATE0 PLAN FOR ReLIABLE SPNT FUEL POOL RUMEINEATAON Attachment Page 2 of 5 Submit 60 Day Relib SFP Oct 2012 Completed N/A lnstiunentatm,Status Report Submit Overall Reliable SFP F 2 C InstWmentatlon Integrated Plan Feb 2013 Completed WA First Status Update Report for the Reli" $FP Instrumetion Aug 2013 Completed N/A Intgated Plan Second Status Update Report for the "elabSFP lnstrum tion Feb 2014 Completed N/A Inegrated Plan

Third Status Update Report for the Reliable SFP instrumentation Aug 2014 Completed N/A lntegratedla Fourth Statut Update Report for the Reliable SFP Instrumentation g at A, n' Feb 2015 Completed N/A I

Final Completion Report for the Reliable SFP Instrumentation Feb 2015 Not Started N/A Integrated Plan Commence Engineering Deae Design for the Reliable SFP Mar 2013 Completed N/A Instrumti Complete Englneri4ng Detailed Degntfcr -theReliable SFP Aug 2014 Completed Jun 2014 Instrumentation Commence the Reliable SFP Instrumentation Modification Jul2014 Started Apr 2015 Installation

FOURTH SIX-MONTH STATUS UPDATIE REPORT FOR THE OVERALL I1TEGRATD PLAN FOR ARUJALE ~ FMEL POOL INSTRUMENTAT1ON Attachment Page 3 of 5 RelaMe SFP In4truMentatlon dec 2014 Jun 2015 Channels Operational instryme t estlorw lqst, . St.

calibration, maintenance, p 2,14 ;Jun 2015 surveillan!ce, and operational

• proceduresw Establish programmatic controls on SFP intumentation related Apr 2015 Not Started N/A activities Reliable SFP Vnsurt meftfioh Apr 2014 Completed. N/A training modules$ *, M,,-,: , .

Completedeveloprnsnt of the Ret ie SFP Instrumentation May .2014 Started May 2015 training modules Complete training of station Oct 2014 Started Jun 2015 personnel Functional testing of Reliable SFP ,

Doc,* Apr 2015 Instruon SSC4complete Instrumentationg~

SS e 04 Not Started Ar21 Rliable SFP Instrumentation Program turned over to Jun 2015 Not Started Jun 2015 operadors_

FOURTH SXUC t4N STATUS UPOATE REPORT FOR THE OVERALL INIEGRATED PLAN FOR RELIABLE SPENT FIEL POOL MINRUMENTATION Attachment Page 4 of 6 4.0 Chltliri to Oimpihn Method '

The Overall Integitted Plan (submitted inRerence 2) Inected that there would be an alternate display location. However, this!concet-wa revised as identifed InReference

5. As a resutth r0e~liable $FP untrurventation, prmary and baclca 'Introument dhanneI displaywKwllony*be located Inthe matiW ctrdolroo. No oO*e chanies have been me to the'- method end the dwsdIg cot usto meet the guidelines of JLD-ISG-2012-13 and NEI 12-09 section 3,9.

&a0 Ned fo -IfI 00xln n oiolo fiw'the7 r7I~fefxto At this time, enrg Northwest eet to fully ponpy with the Ore and its, implementation date and does not anticpate a reque* for relief and/or relaxation of the Order.

6.0 Op"..'S-pe In Reec 3,.the NRC requested additional inormation with egardto the Overall Integrated Plan and n Reference 4 EneryNorthwest mmp to that questwith the understanding that the completed responses will be provided to the NRC in a future updated staue report. In Reference 6, Energy Nthwest oded th first -month.

update. Howevor;ln.the Memorandumoted ,Dceber26, 2014j:frmiC. A.Hunt (NRC) to M.A. Mithet (NRC), *Summary of the November.,26, 2013, (ML13347B();3)

Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool irtrumentt " the staff clarified that the interim staff evualation (Reference

8) questions supersede any previous reiuests for infomton i*sued by the staff concenmingthespent fuel srurmnentation, Therefore, no updates to the RAs discussed in References 3, 4, or 5 were provided.

Energy Northwest has completed the development of the responses to the RAIs contained in Reference 6 and has posted the responses to the E-portal as requested.

7.0 Potential a SAfety Evlati Impacts At this time, Energy Northwest does not believe there are any potential impacts to the Draft Safety Evaluation.

8.0 Refernes

1. NRC Order EA-1 2-051 dated March 12, 2012, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"

FOURTH SX-MONTH STATUS UPDATE REPORT FOR THE OVERALL WITEGRATED PLAN FOR REUASLE SPENT FUEL POOL 4TRUMENTATON Attachment Page 5 of 5

2. Letter G02-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) to NRC, *Energy Northwsrs Response to NRC Order EA-12-051 - Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation"

3. Lettw dated June 20,2013. from LK Gibson (NRC) to ME Reddemann (Energy Northwest), Columbia Generwating 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 Instrumentaton

5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) to NRC, "Energy Northwests First Six Month Status Update Report for the Implementation of NRC Order EA-12-061 Reliable Spent Fuel Pool Instrumentation"

6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia GeneratingStation - 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 Northwe~s Second Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"

8. Letter G02-14-130, dated August 28, 2014, from DA Swank (Energy Northwest) to NRC, "Energy Northwest's Third Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"