ML14069A078

Columbia, Energy Northwest'S Second Six-Month Status Update Report for the Implementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

ML14069A078
Person / Time
Site:	Columbia
Issue date:	02/27/2014
From:	Swank D A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GO2-14-030
Download: ML14069A078 (8)

Text

David A. SwankENERGY Columbia Generating StationP.O. Box 968, PE04Richland, WA 99352-0968 Ph. 509-377-2309 I F. 509-377-2354 daswank @ energy-northwest.com February 27, 2014G02-14-030 EA-12-051 U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

COLUMBIA GENERATING

STATION, DOCKET NO. 50-397ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATEREPORT 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 G02-13-036, dated February 28, 2013, from DA Swank (EnergyNorthwest) to NRC, "Energy Northwest's Response to NRC Order EA-12-051 -Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation"

3. Letter dated June 20, 2013, from LK Gibson (NRC) to ME Reddemann (Energy Northwest),

"Columbia Generating Station -Request forAdditional Information Regarding Spent Fuel Pool Instrumentation (TAC No. MF0797)"4. Letter G02-13-1 00, dated July 19, 2013, from DA Swank (EnergyNorthwest) to NRC, "Energy Northwest's Response to Request forAdditional Information Related to the Overall Integrated Plan for SpentFuel Pool Instrumentation"

5. Letter G02-13-121, dated August 23, 2013, from DA Swank (EnergyNorthwest) to NRC, "Energy Northwest's First Six Month StatusUpdate 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 MEReddemann (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)"VALzQ ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL 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 areliable means of remotely monitoring wide range spent fuel pool levels to supporteffective 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.The attachment to this letter provides Energy Northwest's second six-month report ofColumbia'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, PublicMeeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel PoolInstrumentation,"

(ML13347B030) the staff clarified that the staff interim evaluation questions supersede any previous requests for information issued by the staffconcerning 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 theresponses to the RAIs contained in Reference 6 and will respond by the November 30,2014, due date identified in Reference

6. If unable 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. If youhave 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 onthe date of this letter.Respectfully, D.A. SwankAssistant Vice President, Engineering Attachment Second Six-Month Status Update Report for the Overall Integrated Plan forReliable Spent Fuel Pool Instrumentation cc: NRC Region IV Administrator NRC NRR Project ManagerNRC Senior Resident Inspector/988C AJ Rapacz -BPA/1 399 (email)

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION ATTACHMENT COLUMBIA GENERATING

STATION, DOCKET NO.50-397SECOND SIX-MONTH STATUS UPDATE REPORT FOR THEOVERALL INTEGRATED PLAN FOR RELIABLE SPENT FUEL POOLINSTRUMENTATION ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION Attachment Page 1 of 51.0 Introduction In Reference 1, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 which directed Energy Northwest's Columbia Generating Station (Columbia) to have areliable means of remotely monitoring wide range spent fuel pool (SFP) levels tosupport 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 levelinstrumentation in response to NRC Order EA-12-051.

The Order also requiressubmission of a status update at six-month intervals following the licensee's submittal ofthe Overall Integrated Plan.This is Energy Northwest's second six-month report of Columbia's status ofimplementing Order EA-12-051 pursuant to Section IV, Condition C.2 of Reference 1and provides an update of milestone accomplishments since the previous update ofAugust 23, 2013, (Reference 5). Changes are identified by a revision bar in the rightcolumn or margin.2.0 Milestone Accomplishments The following milestones are current as of February 28, 2014.1) Commenced Reliable SFP Instrumentation Engineering Detailed Designa. In March of 2013 the Energy Northwest design groups (mechanical, electrical, instrumentation, and civil) began the detailed procurement specification and design change development for the Reliable SFPInstrumentation.

The overall design and the plant modification packagesare approximately 50% completed.

The instrumentation vendor has beenselected and the equipment has been specified.

3.0 Milestone Schedule StatusThe following provides an updated milestone schedule to support the Reliable SFPInstrumentation Overall Integrated Plan. Some changes to the schedule have beenmade as shown by the revision bars as the required vendor information was delayed.This information has been received and is being reviewed by Energy Northwest.

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION Attachment Page 2 of 5Target RevisedMilestones Completion Activity TargetDate Status Completion DateCorrespondence

& Reports:Submit 60 Day Reliable SFPInstrumentation Status ReportSubmit Overall Reliable SFPInstrumentation Integrated PlanFirst Status Update Report for theReliable SFP Instrumentation August 2013 Completed N/AIntegrated PlanSecond Status Update Report forthe Reliable SFP Instrumentation Feb 2014 Completed N/AIntegrated PlanThird Status Update Report for theReliable SFP Instrumentation August 2014 Not Started N/AIntegrated PlanFinal Completion Report for theReliable SFP Instrumentation Feb 2015 Not Started N/AIntegrated PlanEngineering

& Modifications:

Commence Engineering DetailedDesign for the Reliable SFP March 2013 Completed N/AInstrumentation Complete Engineering DetailedDesign for the Reliable SFP Jan 2014 Started June 2014Instrumentation Commence the Reliable SFPInstrumentation Modification May 2014 Not Started July 2014Installation Reliable SFP Instrumentation Dec 2014 Not Started N/AChannels Operational ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION Attachment Page 3 of 5Program & Procedures:

Commence development of theReliable SFP instrumentation

testing, calibration, maintenance, April 2014 Not Started July 2014surveillance, and operational procedures Complete development of theReliable SFP instrumentation

testing, calibration, maintenance, May 2014 Not Started Dec 2014surveillance, and operational procedures Establish programmatic controlson SFP instrumentation related Dec 2014 Not Started N/Aactivities Operations

& Training:

Commence development of theReliable SFP Instrumentation April 2014 Not Started N/Atraining modulesComplete development of theReliable SFP Instrumentation May 2014 Not Started N/Atraining modulesComplete training of station Oct 2014 Not Started N/Apersonnel Functional testing of Reliable SFP Dec 2014 Not Started N/AInstrumentation SSCs completeReliable SFP Instrumentation Program turned over to Dec 2014 Not Started N/AOperations ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION Attachment Page 4 of 54.0 Changes to Compliance MethodThe Overall Integrated Plan (submitted in Reference

2) indicated that there would be analternate display location for viewing level indication in the vendor electronics at theelectronic control cabinet for the guided wave radar. This concept has been revised;the signal processor enclosure will now be located in the main control room. Therefore the reliable SFP instrumentation, primary and backup instrument channel display willonly be located in the main control room. This design modification continues to meetthe 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 itsimplementation date and does not anticipate a request for relief and/or relaxation of theOrder.6.0 Open ItemsIn Reference 3, the NRC requested additional information with regard to the OverallIntegrated Plan and in Reference 4 Energy Northwest responded to that request withthe understanding that the completed responses will be provided to the NRC in a futureupdated status report. In Reference 5, Energy Northwest provided the first 6-monthupdate. 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 SpentFuel Pool Instrumentation,"

the staff clarified that the interim staff evaluation (Reference

6) questions supersede any previous requests for information issued by the staffconcerning 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 theresponses to the RAIs contained in Reference 6 and will respond by the November 30,2014, due date identified in Reference

6. If unable to fully respond by the requested date, Energy Northwest will inform the NRC through the NRC project management.

7.0 Potential Draft Safety Evaluation ImpactsAt this time, Energy Northwest does not believe there are any potential impacts to theDraft Safety Evaluation.

ENERGY NORTHWEST'S SECOND SIX-MONTH STATUS UPDATE REPORT FORTHE IMPLEMENTATION OF NRC ORDER EA-12-051 RELIABLE SPENT FUELPOOL INSTRUMENTATION Attachment Page 5 of 58.0 References

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

2. Letter G02-13-036, dated February 28, 2013, from DA Swank (Energy Northwest) toNRC, "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 (EnergyNorthwest),

"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) toNRC, "Energy Northwest's Response to Request for Additional Information Relatedto the Overall Integrated Plan for Spent Fuel Pool Instrumentation"

5. Letter G02-13-121, dated August 23, 2013, from DA Swank (Energy Northwest) toNRC, "Energy Northwest's First Six Month Status Update Report for theImplementation of NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation"

6. Letter dated November 7, 2013, from CF Lyon (NRC) to ME Reddemann (EnergyNorthwest),

"Columbia Generating Station -Interim Staff Evaluation and Request forAdditional Information Regarding the Overall Integrated Plan for Implementation ofOrder EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0797)"