View source for GO2-16-098, Fourth Six-Month Status Update Report for the Implementation of NRC Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

{{Adams
| number = ML16182A080
| issue date = 06/30/2016
| title = Fourth Six-Month Status Update Report for the Implementation of NRC Order EA-13-109, Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
| author name = Javorik A
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000397
| license number = 
| contact person = 
| case reference number = EA-13-109, GO2-16-098
| document type = Letter type:GO, Status Report
| page count = 14
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Alex L. Javorik Vice President, Engineering P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-2354 aljavorik@energy-northwest.com EA-13-109 June 30, 2016                                                                10 CFR 50.54(f)
GO2-16-098 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWESTS FOURTH SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NUCLEAR REGULATORY COMMISSION (NRC) ORDER EA-13-109, ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS

==References:==
: 1. Letter dated June 6, 2013, from E. J. Leeds (NRC) to 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"
: 2. Letter GO2-15-175 dated December 16, 2015, 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

==Dear Sir or Madam,==

By Reference 1, the NRC issued Order EA-13-109, which required licensees to implement a reliable hardened containment vent capable of operation under severe accident conditions. Reference 1 also requires the submission of 6-month update reports on the status of implementing the overall integrated plan (OIP) for the reliable hardened containment vent. Reference 2 transmitted the OIP for the implementation of Phases 1 and 2 for the reliable hardened containment vent.
The enclosure provides the fourth 6-month update report on the status of implementation of NRC Order EA-13-109.
There are no new or revised regulatory commitments contained in this submittal.

ENERGY NORTHWEST'S FOURTH SIXTH SIX-MONTH STATUS UPDATE REPORT FOR NRC ORDER EA-13-109 Page 2 of 2 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 this 21''1ay of      ~ 4 -e.          , 2016.
Respectfully, Vice President, Engineering

==Enclosures:==
As stated cc:     NRC Region IV Administrator NRC NRA Project Manager NRC Senior Resident lnspector/988C CA Sonoda- BPA/1399

ENCLOSURE COLUMBIA GENERATING STATION, DOCKET NO. 50-397 FOURTH SIX-MONTH STATUS UPDATE REPORT FOR THE IMPLEMENTATION OF NUCLEAR REGULATORY COMMISSION (NRC) EA-13-109, ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS

ENERGY NORTHWESTS FOURTH SIXTH SIX-MONTH STATUS UPDATE REPORT FOR NRC ORDER EA-13-109 Enclosure Page 1 of 4 1.0     Introduction By Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 to Columbia Generating Station (Columbia). Reference 1 also required submittal of an overall integrated plan (OIP) describing how compliance with the hardened containment vent system (HCVS) requirements described in the Order will be achieved and also required the submittal of status reports at six month intervals. This enclosure provides Energy Northwests fourth six-month status report for Phases 1 and 2 of NRC Order EA-13-109 and includes an update of the remaining milestones including any changes to the compliance method or schedule.
2.0     Milestone Accomplishments The completion date of the wetwell (WW) design has been moved to December of 2016 to account for a change in the engineering support firm on the project.
3.0     Milestone Schedule Status The table below provides the status of the remaining reporting requirements from EA-13-109.
Correspondence and Reports Target                          Comments Activity Milestone                 Completion                      (Include date changes in Status             this column)
Date EA-13-109 Overall Integrated                                              GO2-14-107 June 2014         Complete Implementation Plan (Phase 1)                                               6/30/2014 1st 6-Month Status Report for EA                                          GO2-14-175 Dec. 2014         Complete 13-109 Phase 1                                                             12/17/2014 2nd 6-Month Status Report for EA                                          GO2-15-093 June 2015         Complete 13-109 Phase 1                                                              6/30/2015 Submit EA-13-109 Overall GO2-15-175 Integrated Plan for Phase 2 and          Dec 2015         Complete 12/16/ 2015 Phase 1 6-month Update 4th 6-Month Update Report for EA Jun 2016         Complete          This Letter 13-109 Phases 1 & 2 5th 6-Month Update Report for EA Dec 2016 13-109 Phases 1 & 2 6th 6-Month Update Report for EA Jun 2017 13-109 Phases 1 & 2 Issuance of Energy Northwest's letter of compliance with NRC Aug 2017 Order EA-12-049 and Order EA-13-109, Phase 1 7th 6-Month Update Report for EA Dec 2017 13-109 Phase 2

ENERGY NORTHWESTS FOURTH SIXTH SIX-MONTH STATUS UPDATE REPORT FOR NRC ORDER EA-13-109 Enclosure Page 2 of 4 8th 6-Month Update Report for EA Jun 2018 13-109 Phase 2 9th 6-Month Update Report for EA Dec 2018 13-109 Phase 2 10th 6-Month Update Report for Jun 2019 EA 13-109 Phase 2 Issuance of Energy Northwest's letter of compliance with NRC           Aug 2019 Order EA-13-109, Phase 2 The following tables provide the status of the non-reporting milestones reported in Reference 2.
Order EA-13-109 Phase 1 Milestone Schedule:
Target                          Comments Activity Milestone                 Completion Status      {Include date changes in Date                              this column}
Hold preliminary/conceptual design June 2014         Complete meeting WW Design Engineering Complete           May 2016       In Progress          Dec 2016 WW Operation Procedure Mar 2017 Changes Developed Site Specific WW Maintenance June 2017 Procedure Developed WW Training Complete                     Apr. 2017 WW Installation Complete                 May 2017 WW Procedure Changes Active              May 2017 WW Walk Through June 2017 Demonstration/Functional Test

ENERGY NORTHWESTS FOURTH SIXTH SIX-MONTH STATUS UPDATE REPORT FOR NRC ORDER EA-13-109 Enclosure Page 3 of 4 Order EA-13-109 Phase 2 Milestone Schedule Milestone                    Target        Activity           Comments Completion        Status        {Include date changes in Date                               this column}
Hold preliminary/conceptual design Jul 2016 meeting Design Engineering On-Jul 2018 site/Complete Operations Procedure Changes Jan 2019 Developed Site Specific Maintenance Jan 2019 Procedure Developed Training Complete                         Apr 2019 Implementation Outage                     May 2019 Procedure Changes Active                  May 2019 Walk Through Jun 2019 Demonstration/Functional Test 4.0    Changes to the Compliance Method The changes to the Phase 1 actions for the EA-13-109 severe accident capable venting scenario can be summarized by the following:
The HCVS will be made operational by manual action from the remote operating station (ROS) at the appropriate time based on the start of the ELAP. Nitrogen will be manually aligned to allow remote operation of the pneumatically operated primary containment isolation valves (PCIV). Breaching of the rupture disk will use the same nitrogen system used for the HCV primary containment valve operation.
The remote operating station containing the solenoid pilot valves (SPV) will have a locked nitrogen supply valve versus a cabinet with lockable cover/door. The SPVs will have the ability to be manually bypassed verses the ability to be manually operated.
No changes to the Phase 2 actions are planned.
5.0    Need for Relief/Relaxation and Basis for the Relief/Relaxation No new relaxation is being requested.

ENERGY NORTHWESTS FOURTH SIXTH SIX-MONTH STATUS UPDATE REPORT FOR NRC ORDER EA-13-109 Enclosure Page 4 of 4 6.0   Status of HCV Open Items The tables in the attachment to this enclosure provide a summary and status of the remaining open since the initial submittal of the OIP (Reference 2.
7.0   References
: 1. Letter dated June 6, 2013, from E. J. Leeds (NRC) to 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"
: 2. Letter GO2-15-175 dated December 16, 2015, from A. L. Javorik (Energy Northwest) to the 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"
: 3. NRC letter dated March 25, 2015, from M. K. Halter (NRC) to M. E.
Reddemann (Energy Northwest), " Columbia Generating Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents)"
: 4. Letter dated June 16, 2015, from S. Monarque (NRC) to M. E. Reddemann (Energy Northwest), "Columbia Generating Station - Report for the Audit Regarding Implementation of Mitigation Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051"

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 1 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action                  Status           Comment Open Item Provide resolution of the potential                 Closed per EN secondary containment bypass                        Letter GO2-14-175.
leakage path in the first 6-month                   Columbia will use a OI-HCV-01   update of the HCVS OIP                 CLOSED       rupture disk to prevent secondary containment bypass leakage.
Evaluate the location of the ROS OI-HCV-02                                           OPEN for accessibility.
Determine the location of the portable air compressor and evaluate for accessibility under OI-HCV-03   Severe Accident HCVS use.               OPEN Including connection point(s)
Including refueling operations Evaluate the location of the FLEX DG for accessibility under Severe Accident HCVS use.
OI-HCV-04                                           OPEN Including connection point(s)
Including refueling operations Confirm suppression pool heat                       Closed per EN capacity                                            Letter GO2-14-175.
Calculation ME                                                                 14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the OI-HCV-05                                          CLOSED suppression pool water when at a minimum Technical Specification level to control pressure in containment before venting commences.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 2 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action                   Status          Comment Open Item Determine the method of OI-HCV-06                                            OPEN qualification for each instrument Complete the evaluation to determine accessibility, OI-HCV-07   habitability, staffing sufficiency,      OPEN and communication capability of the ROS.
Identify design codes after design OI-HCV-08                                            OPEN is finalized.
Equipment qualifications will include temperature, pressure, OI-HCV-09   radiation level, and total integrated    OPEN dose from the effluent vent pipe at local and remote locations.
Provide site-specific details of the EOPs when available.
OI-HCV-10      Develop procedures for Severe         OPEN Accident Water Addition (SAWA) and Severe Accident Water Management (SAWM)
FLEX air compressors need to be OI-HCV-11   credited to recharge air lines for       OPEN HCVS components after 24 hours.
SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA OI-HCV-12   049 actions). Location of these          OPEN valves and flow elements will need to be considered per HCVS-FAQ-12.
Reconcile the out-of-service provisions for HCVS/SAWA with the provisions documented in OI-HCV-13                                            OPEN Columbias PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 3 of 7 List of Overall HCV Integrated Plan Open Items HCV OIP Action                   Status         Comment Open Item Complete the evaluation to determine accessibility, OI-HCV-14     habitability, staffing sufficiency,      OPEN and communication capability during SAWA/SAWM Perform MAAP analysis for NEI 13-02 figures C-2 through C-6 and OI-HCV-15                                              OPEN determine the time sensitive SAWM actions Develop procedure for line-up and OI-HCV-16                                              OPEN use of HCVS Add sound powered phone extension cable for instrument rack OI-HCV-17     E-IR-85 to inventory procedure           OPEN SOP-FLEX-EQUIPMENT-STORAGE Evaluate deployment pathways for OI-HCV-18                                              OPEN severe accident capable criteria Develop required training and OI-HCV-19                                              OPEN frequency IAW the SAT process Incorporate approved language of OI-HCV-20     OIP Attachment 2.1.D into site           OPEN SAMG procedure(s)
Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report                         Action              Status       Comment Section 01          Make available for NRC staff audit the location of the ROS.       OPEN Section 3.2.1 02          Make available for NRC staff audit the location of the portable   OPEN Section 3.2.1     air compressor.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 4 of 7 Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report                        Action                Status      Comment Section 03          Make available for NRC staff audit the location of the portable    OPEN Section 3.2.1     diesel generators.
04          Make available for NRC staff audit an evaluation of Section 3.2.1 temperature and radiological Section 3.2.2.4    conditions to ensure that Section 3.2.2.5    operating personnel can safely access and operate controls and Section            support equipment.                    OPEN 3.2.2.10 Section 3.2.4.1 Section 3.2.4.2 Section 3.2.5.2 Section 3.2.6 Make available for NRC staff audit analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of uprated licensed/rated thermal power (unless a lower value is justified),
05          and that the suppression pool Section 3.2.2.1    and the HCVS together are able        OPEN Section 3.2.2.2    to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 5 of 7 Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report                        Action               Status       Comment Section Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during 06          ELAP and severe accident for the Section 3.2.2.3    components (valves, instrumentation, sensors, Section 3.2.2.5 transmitters, indicators,            OPEN Section 3.2.2.9    electronics, control devices, etc.)
Section            required for HCVS venting 3.2.2.10           including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
Make available for NRC staff 07          audit documentation of the HCVS Section 3.2.2.4    nitrogen pneumatic system            OPEN design including sizing and Section 3.2.6 location.
Make available for NRC staff 08          audit the final sizing evaluation for HCVS batteries/battery Section 3.2.2.4                                         OPEN charger including incorporation Section 3.2.6      into FLEX DG loading calculation.
Make available for NRC staff audit documentation that demonstrates adequate 09          communication between the OPEN Section 3.2.2.5    remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 6 of 7 Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report                       Action               Status         Comment Section Provide a description of the                  Energy Northwest strategies for hydrogen control               will use Option that minimizes the potential for              number 5 of the hydrogen gas migration and                    NEI White Paper ingress into the RB or other                  HCV-WP-03, buildings.                                    Hydrogen/Carbon 10                                                        Monoxide Control CLOSED     Measures and add Section 3.2.2.6                                                  a check valve at the discharge end of the vent pipe to address the flammability of combustible gasses.
Make available for NRC staff audit descriptions of all 11          instrumentation and controls OPEN Section 3.2.2.9    (existing and planned) necessary to implement this order including qualification methods.
Make available for NRC staff                  Columbia will be audit documentation of an                     using an unused evaluation verifying the existing             containment 12          containment isolation valves,                 penetration and relied upon for the HCVS, will     CLOSED     will be installing Section 3.2.2.9    open under the maximum                        new containment expected differential pressure                isolation valves.
during BDBEE and severe accident wetwell venting.
13          Make available for NRC staff audit site specific details of the   OPEN Section 3.4.1      EOPs when available.

Request for Relaxation of NRC Order EA-12-049 Requirement IV.C.2 for Columbia Generating Station Attachment Page 7 of 7 Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report                         Action                 Status         Comment Section Provide justification for not leak                Columbia has testing the HCVS every three                      adopted the operating cycles and after                        current NEI 14           restoration of any breach of                      guidance on CLOSED Section 3.4.4       system boundary within                            testing and buildings.                                        Inspection requirements as shown in Table 4-1 List of Remaining FLEX Integrated Plan Open Items Related to the HCV FLEX OIP Action                               Status Open Item GOTHIC analyses will be confirmed, or revised, to bound the design of the hardened containment vent              OPEN OI-FLEX-73 after the design is finalized. (This OI has been added to assure that the subject analyses reflect the design required by EA-13-109.)}}