Letter Sequence Request |
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TAC:MC4570, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) |
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Category:Letter type:GO
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - 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Annual Reporting Requirement2022-03-21021 March 2022 Level of Financial Protection - Annual Reporting Requirement GO2-22-038, Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462022-03-0909 March 2022 Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-22-031, Response to Audit Plan and Online Reference Portal Request2022-02-15015 February 2022 Response to Audit Plan and Online Reference Portal Request GO2-22-011, Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report2022-02-0808 February 2022 Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report GO2-22-001, License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-02-0303 February 2022 License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-012, Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report2022-01-24024 January 2022 Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report 2024-01-08
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- _ ,o (ENERGY NORTHWEST People. Vision. Solutions P.O. Box 968 - Richland, WA
- 99352-0968 September 11, 2006 G02-06-116 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REVISION TO PROPOSED CHANGES ASSOCIATED WITH LICENSE AMENDMENT REQUEST - ALTERNATIVE SOURCE TERM
Reference:
Letter dated September 30, 2004, DK Atkinson (Energy Northwest) to NRC, "License Amendment Request - Altemative Source Term"
Dear Sir or Madam:
In the referenced letter Energy Northwest provided a significant number of proposed changes to the 'Columbia TeChnical Specifications associated with the adoption of the Alternative Source Term'. Included in the proposed changes were changes to Surveillance Requirement (SR) 3.6.4.1.1, SR 3.6.4.1.4, SR 3.6.4.1.5, and SR 3.6.4.3.3. The proposed changes to these SRs provided for an alternate means to ensure the quality and functionality of the secondary containment and the standby gas treatment (SGT) system.
Recent telephone discussions between the NRC:and Energy Northwest personnel have resulted in additional clarifications of the existing specifications and, therefore, Energy Northwest is proposing revisions to the changes identified in the reference.
As discussed in the referenced letter, following adoption of the Alternative Source Term credit for the filtration of the secondary containment effluents by the SGT system is not taken in the design basis loss of coolant accident analysis until the secondary containment pressure has been drawn down by the SGT system to a vacuum condition of at least 0.25 inches water gauge on all surfaces. The design basis drawdown time for Columbia is 20 minutes. However, the purpose of the SRs listed above (in conjunction with others) is to provide regular monitoring of the performance of the SGT subsystems and the secondary containment to ensure degradation in the performance of either is detected.
Regarding SR 3.6.4. 1.1, Energy Northwest proposes to delete the change identified in the reference based on the understanding that this SR verifies the secondary containment
'boundaryis being maintained in a sufficiently leak. tight condition to preclude exfiltration
a' °-
REVISION TO PROPOSED CHANGES ASSOCIATED WITH LICENSE AMENDMENT REQUEST - ALTERNATIVE SOURCE TERM Page 2 under normal operating conditions. This is accomplished by verifying the indicated secondary containment pressure is greater than or equal to 0.25 inches of vacuum water gauge (Note: In this context, "greater" means more vacuum and greater pressure differential between the secondary containment and the environment). In addition, it is understood that the value of greater than or equal to 0.25 inches of vacuum water gauge is an indication of pressure at one location in the secondary containment and not a value maintained at every surface within the secondary containment. The instrument used to perform this surveillance measures pressure at reactor building elevation 572' in an area that has open communication with the rest of the secondary containment volume. The use of 0.25 inches of vacuum water gauge includes margin to account for uncertainties. It is also understood that this SR is considered to be met during momentary perturbations of the secondary containment pressure (i.e., a transient that momentarily causes the pressure to be less than the SR acceptance criterion of 0.25 inches of vacuum water gauge) that are anticipated during routine operation of the plant (e.g., realignment of ventilation trains, opening and closing doors and hatches, and extreme wind gusts).
Regarding SR 3.6.4.1.4, Energy Northwest proposes to delete the change identified in the reference based on the understanding that this SR verifies that the SGT system will rapidly establish and maintain a pressure in the secondary containment that is less than the pressure extemal to the secondary containment boundary. This is accomplished by verifying the secondary containment can be drawn down to an indicated pressure of greater than or equal to 0.25 inches of vacuum water gauge in less than or equal to 120 seconds, following the start of a single SGT fan. In addition, it is understood that the value of greater than or equal to 0.25 inches of vacuum water gauge is an indication of pressure at one location in the secondary containment and not a value maintained at every surface within the secondary containment. The instrument used to perform this surveillance measures pressure at reactor building elevation 572' in an area that has open communication with the rest of the secondary containment volume. The use of 0.25 inches of vacuum water gauge includes margin to account for uncertainties.
Regarding SR 3.6.4.1.5, Energy Northwest proposes to delete the change identified in the reference based on the understanding that this SR demonstrates that each SGT subsystem can maintain an indicated secondary containment pressure of greater than or equal to 0.25 inches of vacuum water gauge for one hour at an indicated flow rate of less than or equal to 2240 cfm. In addition, it is understood that the value of greater than or equal to 0.25 inches of vacuum water gauge is an indication of pressure at one location in the secondary containment and not a value maintained at every surface within the secondary containment. The instrument used to perform this surveillance measures pressure at reactor building elevation 572' in an area that has open communication with the rest of the secondary containment volume. The use of 0.25 inches of vacuum water gauge includes margin to account for uncertainties.
These two tests (SR 3.6.4.1.4 and SR 3.6.4.1.5) verify the continuing ability of each SGT subsystem to achieve and maintain a vacuum in the secondary containment and, therefore, are used to assess secondary containment boundary integrity.
,= N REVISION TO PROPOSED CHANGES ASSOCIATED WITH LICENSE AMENDMENT REQUEST - ALTERNATIVE SOURCE TERM Page 3 Regarding SR 3.6.4.3.3, Energy Northwest proposes to delete the change identified in the reference based on the understanding that the existing requirement is adequate.
Upon approval of the Alternative Source Term Amendment Request, Energy Northwest intends to update the TS Bases to reflect these clarifications as part of the implementation process.
The original no significant hazards consideration included in the reference above is not affected by the information contained in this letter. In addition, there are no new commitments contained in this letter.
Ifyou have any questions or require additional information, please contact Greg Cullen at (509) 377-6105.
Respectfully, WS Ox nford Vice President, T c Services Mail Drop PE04 cc: BS Mallelt - NRC RIV BJ Benney - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPN 1399 WA Horin - Winston &Strawn