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

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

ML16182A080
Person / Time
Site:	Columbia
Issue date:	06/30/2016
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, GO2-16-098
Download: ML16182A080 (14)

Text

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 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.

June 30, 2016

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 211ay 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 Milestone Target Completion Date Activity Status Comments (Include date changes in this column)

EA-13-109 Overall Integrated Implementation Plan (Phase 1)

June 2014 Complete GO2-14-107 6/30/2014 1st 6-Month Status Report for EA 13-109 Phase 1 Dec. 2014 Complete GO2-14-175 12/17/2014 2nd 6-Month Status Report for EA 13-109 Phase 1 June 2015 Complete GO2-15-093 6/30/2015 Submit EA-13-109 Overall Integrated Plan for Phase 2 and Phase 1 6-month Update Dec 2015 Complete GO2-15-175 12/16/ 2015 4th 6-Month Update Report for EA 13-109 Phases 1 & 2 Jun 2016 Complete This Letter 5th 6-Month Update Report for EA 13-109 Phases 1 & 2 Dec 2016 6th 6-Month Update Report for EA 13-109 Phases 1 & 2 Jun 2017 Issuance of Energy Northwest's letter of compliance with NRC Order EA-12-049 and Order EA-13-109, Phase 1 Aug 2017 7th 6-Month Update Report for EA 13-109 Phase 2 Dec 2017

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 13-109 Phase 2 Jun 2018 9th 6-Month Update Report for EA 13-109 Phase 2 Dec 2018 10th 6-Month Update Report for EA 13-109 Phase 2 Jun 2019 Issuance of Energy Northwest's letter of compliance with NRC Order EA-13-109, Phase 2 Aug 2019 The following tables provide the status of the non-reporting milestones reported in Reference 2.

Order EA-13-109 Phase 1 Milestone Schedule:

Milestone Target Completion Date Activity Status Comments

{Include date changes in this column}

Hold preliminary/conceptual design meeting June 2014 Complete WW Design Engineering Complete May 2016 In Progress Dec 2016 WW Operation Procedure Changes Developed Mar 2017 Site Specific WW Maintenance Procedure Developed June 2017 WW Training Complete Apr. 2017 WW Installation Complete May 2017 WW Procedure Changes Active May 2017 WW Walk Through Demonstration/Functional Test June 2017

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 Completion Date Activity Status Comments

{Include date changes in this column}

Hold preliminary/conceptual design meeting Jul 2016 Design Engineering On-site/Complete Jul 2018 Operations Procedure Changes Developed Jan 2019 Site Specific Maintenance Procedure Developed Jan 2019 Training Complete Apr 2019 Implementation Outage May 2019 Procedure Changes Active May 2019 Walk Through Demonstration/Functional Test Jun 2019 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 Open Item Action Status Comment OI-HCV-01 Provide resolution of the potential secondary containment bypass leakage path in the first 6-month update of the HCVS OIP CLOSED Closed per EN Letter GO2-14-175.

Columbia will use a rupture disk to prevent secondary containment bypass leakage.

OI-HCV-02 Evaluate the location of the ROS for accessibility.

OPEN OI-HCV-03 Determine the location of the portable air compressor and evaluate for accessibility under Severe Accident HCVS use.

Including connection point(s)

Including refueling operations OPEN OI-HCV-04 Evaluate the location of the FLEX DG for accessibility under Severe Accident HCVS use.

Including connection point(s)

Including refueling operations OPEN OI-HCV-05 Confirm suppression pool heat capacity CLOSED Closed per EN Letter GO2-14-175.

Calculation ME 14-02, Revision 0, Appendix C confirms that there is sufficient heat capacity in the 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 Open Item Action Status Comment OI-HCV-06 Determine the method of qualification for each instrument OPEN OI-HCV-07 Complete the evaluation to determine accessibility, habitability, staffing sufficiency, and communication capability of the ROS.

OPEN OI-HCV-08 Identify design codes after design is finalized.

OPEN OI-HCV-09 Equipment qualifications will include temperature, pressure, radiation level, and total integrated dose from the effluent vent pipe at local and remote locations.

OPEN OI-HCV-10 Provide site-specific details of the EOPs when available.

Develop procedures for Severe Accident Water Addition (SAWA) and Severe Accident Water Management (SAWM)

OPEN OI-HCV-11 FLEX air compressors need to be credited to recharge air lines for HCVS components after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

OPEN OI-HCV-12 SAWA/SAWM flow is controlled using hose installed valves and mechanical flow elements (EA 049 actions). Location of these valves and flow elements will need to be considered per HCVS-FAQ-

12.

OPEN OI-HCV-13 Reconcile the out-of-service provisions for HCVS/SAWA with the provisions documented in Columbias PPM 1.5.18, Managing B.5.b and FLEX Equipment Unavailability.

OPEN

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 Open Item Action Status Comment OI-HCV-14 Complete the evaluation to determine accessibility, habitability, staffing sufficiency, and communication capability during SAWA/SAWM OPEN OI-HCV-15 Perform MAAP analysis for NEI 13-02 figures C-2 through C-6 and determine the time sensitive SAWM actions OPEN OI-HCV-16 Develop procedure for line-up and use of HCVS OPEN OI-HCV-17 Add sound powered phone extension cable for instrument rack E-IR-85 to inventory procedure SOP-FLEX-EQUIPMENT-STORAGE OPEN OI-HCV-18 Evaluate deployment pathways for severe accident capable criteria OPEN OI-HCV-19 Develop required training and frequency IAW the SAT process OPEN OI-HCV-20 Incorporate approved language of OIP Attachment 2.1.D into site SAMG procedure(s)

OPEN Interim Staff Evaluation of Phase 1 Request for Additional Information RAI Number ISE Report Section Action Status Comment 01 Section 3.2.1 Make available for NRC staff audit the location of the ROS.

OPEN 02 Section 3.2.1 Make available for NRC staff audit the location of the portable air compressor.

OPEN

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 Section Action Status Comment 03 Section 3.2.1 Make available for NRC staff audit the location of the portable diesel generators.

OPEN 04 Section 3.2.1 Section 3.2.2.4 Section 3.2.2.5 Section 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 an evaluation of temperature and radiological conditions to ensure that operating personnel can safely access and operate controls and support equipment.

OPEN 05 Section 3.2.2.1 Section 3.2.2.2 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),

and that the suppression pool and the HCVS together are able 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.

OPEN

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 Section Action Status Comment 06 Section 3.2.2.3 Section 3.2.2.5 Section 3.2.2.9 Section 3.2.2.10 Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.)

required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

OPEN 07 Section 3.2.2.4 Section 3.2.6 Make available for NRC staff audit documentation of the HCVS nitrogen pneumatic system design including sizing and location.

OPEN 08 Section 3.2.2.4 Section 3.2.6 Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger including incorporation into FLEX DG loading calculation.

OPEN 09 Section 3.2.2.5 Make available for NRC staff audit documentation that demonstrates adequate communication between the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

OPEN

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 Section Action Status Comment 10 Section 3.2.2.6 Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress into the RB or other buildings.

CLOSED Energy Northwest will use Option number 5 of the NEI White Paper HCV-WP-03, Hydrogen/Carbon Monoxide Control Measures and add a check valve at the discharge end of the vent pipe to address the flammability of combustible gasses.

11 Section 3.2.2.9 Make available for NRC staff audit descriptions of all instrumentation and controls (existing and planned) necessary to implement this order including qualification methods.

OPEN 12 Section 3.2.2.9 Make available for NRC staff audit documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during BDBEE and severe accident wetwell venting.

CLOSED Columbia will be using an unused containment penetration and will be installing new containment isolation valves.

13 Section 3.4.1 Make available for NRC staff audit site specific details of the EOPs when available.

OPEN

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 Section Action Status Comment 14 Section 3.4.4 Provide justification for not leak testing the HCVS every three operating cycles and after restoration of any breach of system boundary within buildings.

CLOSED Columbia has adopted the current NEI guidance on testing and Inspection requirements as shown in Table 4-1 List of Remaining FLEX Integrated Plan Open Items Related to the HCV FLEX OIP Open Item Action Status OI-FLEX-73 GOTHIC analyses will be confirmed, or revised, to bound the design of the hardened containment vent after the design is finalized. (This OI has been added to assure that the subject analyses reflect the design required by EA-13-109.)

OPEN