GO2-05-186, Supplement to the License Amendment Request for a One-Time Change to Technical Specifications

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Supplement to the License Amendment Request for a One-Time Change to Technical Specifications
ML053480194
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 11/30/2005
From: Oxenford W
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-05-186
Download: ML053480194 (9)
v • d • e


Text

e 0ss

-XENERGY NORTHWEST People *Vision *Solutions P.O. Box 968

  • Richland, WA
  • 99352-0968 November 30, 2005 G02-05-1 86 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS

Reference:

Letter G02-05-145, dated August 17, 2005, from WS Oxenford (Energy Northwest) to NRC, "License Amendment Request for One-time Extension of the Completion Time for Condition B of Technical Specification 3.7.1 and Exemption from Note 1 of Required Action B.1"

Dear Sir or Madam:

Transmitted herewith in Attachment 1 is supplemental information regarding the referenced License Amendment Request (LAR). A telecom between the NRC and Energy Northwest discussing this supplement was conducted on November 29, 2005.

This supplemental information clarifies issues involving the "cascading" of the Service Water subsystem outage into the Diesel Generator Technical Specification (TS).

A revised mark-up of the proposed TS note and the associated TS Bases are provided in Attachment 2 and 3, respectively.

No new commitments are made in this submittal.

This supplemental information does not impact the original no significant hazards determination or the risk assessment used to justify the requested amendment. If you have any questions or require additional information, please contact Michael Brandon (509) 377-4758.

Energy Northwest requests the approval of this LAR on or before December 8, 2005.

SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 2of2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, Vice Presid n

nical Services Mail Drop P 4 Attachments:

1. Supplemental Information
2. Revised mark-up of TS 3.7.1 and 3.8.1
3. Revised mark-up of TS Bases 3.7.1 and 3.8.1 cc:

BS Mallett - NRC RIV BJ Benney - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn

SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Attachment I Page 1 of 1 SUPPLEMENTAL INFORMATION

Background

The referenced submittal requested an amendment to Operating License NPF-21 for Columbia Generating Station (Columbia). The requested amendment revised the Completion Time (CT) for the Required Action of Condition B of Technical Specification (TS) 3.7.1, "Standby Service Water (SW) System and Ultimate Heat Sink (UHS)," from 72 to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />, on a one-time basis and allowed a one-time exemption from Note I of the Required Action 3.7.1.B.1.

As discussed in the referenced submittal, the exemption from Note 1 of Required Action B.1 of TS 3.7.1 was requested to avoid entering the Required Action B of TS 3.8.1 "AC Sources Operating" for the diesel generator (DG) supported by the inoperable SW B subsystem. Based on further discussions with the NRC Staff, Energy Northwest has reconsidered this path and is proposing a revision to the CT of both TS 3.7.1 and 3.8.1 on a one-time basis.

A revised marked-up copy of proposed change to the TS is provided in Attachment 2.

Upon approval of the proposed license amendment, Energy Northwest will implement a change to the applicable TS Bases.

A revised marked-up copy of proposed change to the TS Bases is provided in.

SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 1 of 1 Revised Mark-up of TS 3.7.1 and 3.8.1 (pages 3.7.1-2 and 3.8.1-3)

SW System and UHS 3.7.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One SW subsystem B.1

NOTES--------

inoperable.

1. Enter applicable Conditions and Required Actions of LCO 3.8.1.
  • AC Sources-Operating." for diesel generator made inoperable by SW System.
2. Enter applicable Conditions and Required Actions of LCO 3.4.9.

"Residual Heat Removal (RHR)

Shutdown Cooling System - Hot Shutdown," for RHR shutdown cooling subsystem made inoperable by SW System.

Restore SW subsystem 72 ho0 to OPERABLE status.

(continued)

( On a one-time basis, during the refurbishment/replacement of the I B Service Water Pump during Cycle 18, the Completion Time for an inoperable service water subsystem is extended t144 hours.

A.

Columbia Generating Station 3.7. 1-2 Amendment No. +49 1691

AC Sources - Operating 3.8.1 ACTIONS CONDITICN REQUIRED ACTION COMPLETION TIME B. (continued)

B.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s), supported discovery of by the inoperable DG.

Condition B inoperable when the concurrent with redundant required inoperability feature(s) are of redundant inoperable.

required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG(s) are not inoperable due to common cause failure.

B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE DG(s).

AND B.4 Restore required DG 72 hourf to OPERABLE status.

AND 6 days from discovery of failure to meet SLCO (continued)

On a one-time basis, during the refurbishmenftreplacement of the I B Service Water Pump (

(I during Cycle 18, the Completion Time for the Division 2 DG is extended to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.

)

Columbia Generating Station 3.8.1-3 Amendment No.

+4-9 1691

SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 1 of 1 Revised Mark-up of TS Bases 3.7.1 and 3.8.1 (pages B 3.7.1-5 and B 3.8.1-12)

SW System and UHS B 3.7.1 BASES (continued)

ACTIONS AI With average sediment depth in either or both spray ponds

> 0.5 and < 1.0 ft. water inventory is reduced such that the combined cooling capability of both spray ponds may be less than required for 30 days of operation after a LOCA.

Therefore, action must be taken to restore average sediment depth to < 0.5 ft.

The Completion Time of 30 days is based on engineering judgement and plant operating experience and takes into consideration the low probability of a design basis accident occurring in this time period.

pOn a one-time basis, during ithe refurbishmentl La replacementofthe1L If one SW subsystem is inoperable, it must be restored to

-Service Water Pump during OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With the unit in this Cycle 18,theCompletion condition, the remaining OPERABLE SW subsystem is adequate Timeforan inoperable to perform the heat removal function.

However, the overall servicewatersubsystem is reliability is reduced because a single failure in the OPERABLE SW subsystem could result in loss of SW function.

extended to144hours. The The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into one-time extension is based account the redundant capabilities afforded by the OPERABLE uponariskassessment subsystem and the low probability of a DBA occurring during performed in accordance this period.

with Regulatory Guides W

1.174and1.177. During The Required Action is modified by two Notes indicating that thisextended Completion the applicable Conditions of LCO 3.8.1, "AC Sources-Time, administrative controls Operating," and LCO 3.4.9. "Residual Heat Removal (RHR)

Shutdown Cooling System-Hot Shutdown." be entered and the mustbeimplementedto Required Actions taken if the inoperable SW subsystem enhance the reliability of results in an inoperable DG or RHR shutdown cooling required electrical sources subsystem, respectively.

This is in accordance with and to minimize plant LCO 3.0.6 and ensures the proper actions are taken for these activities that might components.

challenge other safety-related equipment. This one-time extension expires at the C 1 and C.2 If the SW subsystem cannot be restored to OPERABLE status id; &64

&6n in

.ee -A P-askrntic4 Time

_r hail, CLIeslUtos W I I'lI f111C O

)ut.

I a bICU L.UIIIJ I a lI 1U.1 I I ilia, Ul UU tlI aK bUUlyb 1tlizi

-are inoperable, or the UHS is determined inoperable for reasmns-o-ther-than Condition-A,-th& unit-musthbe-placed-in a- -

MODE in which the LCO does not apply. To achieve this (continued)

Columbia Generating Station B 3.7.1-5 Revision 241

AC Sources-Operating AC Sources-Ope-rating B 3.8.1 BASES ACTIONS B.4 (continued) the onsite Class 1E distribution system.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

naone-time basis ung The second Completion Time for Required Action B.4 established a limit on the maximum time allowed for any the refurbishment/

combination of required AC power sources to be inoperable replacementoftheIB during any single contiguous occurrence of failing to meet ServiceWaterPumpduring the LCO. If Condition B is entered while, for instance, an Cycle 18,the Completion offsite circuit is inoperable and that circuit is TimefortheDivision2DGis subsequently restored OPERABLE, the LCO may already have extended to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />. The been not met for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This situation could lead one-time extension is based to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />, since initial failure to meet the uponariskassessment

LCO, to restore the DG.

At this time, an offsite circuit pefocould again become inoperable, the DG restored OPERABLE, and performed in accordance an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (for a total of 9 days) allowed prior with Regulatory Guides to complete restoration of the LCO.

The 6 day Completion 1.174and 1.177. During Time provides a limit on the time allowed in a specified thisextendedCompletion condition after discovery of failure to meet the LCO.

This Time,administrativecontrols limit is considered reasonable for situations in which must be implemented to Conditions A and B are entered concurrently. The "AND" enhance the reliabilityof connector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 6 day Completion Times e

.a means that both Completion Times apply simultaneously, and required electrical sourcesthe more restrictive Completion Time must be met.

and to minimize plant activitiesthatmight Similar to Required Action B.2, the Completion Time of challengeothersafety-equired Action B.4 allows for an exception to the normal relatedequipment.Thisone-

'time zero" for beginning the allowed outage time 'clock."

timeextensionexpiresatthe his exception results in establishing the "time zeros at end ofCycle 18.

,the time the LCO was initially not met, instead of the time Condition B was entered.

C-1 and C.2 Required Action C.1 addresses actions to be taken in the event of concurrent failure of redundant required features.

Required Action C.1 reduces the vulnerability to a loss of function.

The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed with only one division without offsite power (Required Action A.2).

The rationale (continued)

Columbia Generating Station B 3.8.1-12 Revision 38

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