Letter Sequence Response to RAI |
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TAC:MC7273, Modify Section 3.8 Mode Restriction Notes, DC Electrical Rewrite (Approved, Closed) |
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Category:Letter type:GO
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GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024
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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
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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
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GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023
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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
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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
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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 - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023
Generation Station - Level of Financial Protection - Annual Reporting Requirement
GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023
Plant Decommissioning Fund Status Report
GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023
Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46
GO2-23-035, Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-03-0909 March 2023
Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-012023-02-0808 February 2023
Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01
GO2-22-131, Guarantee of Payment of Deferred Premium2022-12-19019 December 2022
Guarantee of Payment of Deferred Premium
GO2-22-122, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-11-28028 November 2022
Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
GO2-22-076, Status of License Renewal Commitments2022-10-31031 October 2022
Status of License Renewal Commitments
GO2-22-110, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor2022-10-17017 October 2022
Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor
GO2-22-096, Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-10-0404 October 2022
Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
GO2-22-085, Docket No. 50-397, Evacuation Time Estimate Analysis2022-08-30030 August 2022
Docket No. 50-397, Evacuation Time Estimate Analysis
GO2-22-075, Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves2022-07-11011 July 2022
Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves
GO2-22-072, Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing2022-07-11011 July 2022
Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing
GO2-22-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process2022-05-25025 May 2022
Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process
GO2-22-062, Registration of Spent Fuel Cask Use2022-05-19019 May 2022
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GO2-22-049, Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors2022-05-10010 May 2022
Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors
GO2-22-054, Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report2022-05-0909 May 2022
Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report
GO2-22-056, Registration of Spent Fuel Cask Use2022-04-21021 April 2022
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GO2-22-055, 2021 Annual Environmental Operating Report2022-04-20020 April 2022
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GO2-22-048, 2021 Annual Radioactive Effluent Release Report2022-04-15015 April 2022
2021 Annual Radioactive Effluent Release Report
GO2-22-045, Registration of Spent Fuel Cask Use2022-04-0606 April 2022
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GO2-22-044, Level of Financial Protection - 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
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GO2-22-011, Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report2022-02-0808 February 2022
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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
[Table view] |
Text
- ý Ml'YNORTHWEST ENERGY Paeople
- Vision - Solutions PO. Box 968 Richiand, WA 99352-0968 February 22, 2007 G02-07-036 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER
References:
- 1) Letter dated, May 31, 2005 G02-05-099, WS Oxenford (Energy Northwest) to NRC, "License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"
- 2) Letter dated, February 8, 2006 G02-06-019, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"
- 3) Letter dated, January 5, 2007 G02-07-008, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"
- 4) Letter dated, February 13, 2007 G02-07-027, WS Oxenford (Energy Northwest) to NRC, "Supplemental Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"
Dear Sir or Madam:
Transmitted herewith in the Attachment is the Energy Northwest summary of and response to a Request for Additional Information. This response provides additional clarifying information as discussed with the Staff in a February 21, 2007 teleconference.
No new commitments are provided in this response. The responses provided herein do not result in any changes to the proposed license amendment request as amended by the references.
,,4oo
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 2 If you have any questions or require additional information, please contact Greg Cullen at (509) 377-6105.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfully, WS Oxen rd Vice Pr ide , Technical Services Mail Drop PE04
Attachment:
Response to Request for Additional Information Regarding Technical Specification Change Request.
cc: BS Mallett - NRC RIV CF Lyon - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Attachment Page 1 of 2 Response to Request for Additional Information Regarding Technical Specification Change Request NRC Question 1 Given that the submittal indicates that for some grid conditions the testing performed to meet the Surveillance Requirement (SR), "...shall be performed at a power factor as close to the single largest post-accident load as possible," why are the power factors in The Technical Specifications Bases and previous RAI question 3 (of Reference 2), not the same post-accident load value for a given EDG as specified in Technical Specifications SRs? Explain and quantify the margin mentioned in the Bases and whether it is included in the SR value (would expect that it be in the SR value).
Energy Northwest Response The power factor values for SR 3.8.1.9 specified in the Technical Specifications Bases represent the reactive loading expected to support the single largest post-accident load for the respective EDGs. These values would be used for meeting SR 3.8.1.9. The power factor values for SRs 3.8.1.10 and 3.8.1.14 specified in the Technical Specifications Bases represent the reactive loading expected to support the full post-accident load for the respective EDGs.
The power factor values in the proposed Technical Specifications for SR 3.8.1.10 and SR 3.8.1.14 and in RAI question 3 (of Reference 2), provide a test value parameter for performing these SRs while synchronized to the electrical grid. These power factor parameters include exciter capacity to carry the reactive load as well as the exciter capacity needed to match the electrical grid voltage for synchronizing. For example, during the surveillance test for SR 3.8.1.14, EDG-1 is loaded to 4400 kW and 2200 kVAR which is a power factor of 0.894. The indicated reactive output during the test approximates the accident load power factor for this divisional load group as noted in the Technical Specifications Bases. However, the exciter field current is running at nearly 98.3% of its full load rating (i.e., the generator is rated 5812.5 kVA at 0.8 power factor or 4650 kW and the exciter rated output is 142.4 amps). The EDG exciter must provide the capacity both to reach desired reactive output and match electrical grid voltage while the EDG is synchronized to the electrical grid. Therefore, as illustrated in this example, using a value of 0.9 power factor for SR 3.8.1.14 is simple, inclusive, and can be implemented without undue reliance on the exception note in the SR.
The margin referred to in the proposed TS Bases insert... "In such cases, the power factor shall be maintained as close as practicable to these levels, allowing margin for changing grid conditions, without exceeding the EDG excitation limits," is operational margin to avoid routine overloading of the EDG exciter during SR testing. The testing procedures require the reactive load during testing to be as close as possible to the reactive load associated with the approximate analyzed power factor without exceeding
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Attachment Page 2 of 2 the rated limit for exciter current. In all cases the field current is required to be greater than or equal to 90% of the rated limit for exciter current.
NRC Question 2 Explain how SR testing at other than the post-accident load power factor demonstrates the capacity and capability of the EDG excitation system/AVR/generator field current.
Energy Northwest Response At rated voltage, load, and power factor the design excitation current is 142.4 amps (for EDG-1 and EDG-2). Performing EDG testing against the electrical grid involves increasing generator terminal voltage to match electrical grid voltage in order to parallel to the offsite electrical grid. Increasing field current to achieve the higher voltage needed to parallel requires field current that would be used for increased reactive loading during accident conditions (when isolated from the grid). During testing, when the EDG is paralleled to the electrical grid, the reactive loading is limited by field current to within the manufacturer's rating. Maintaining the reactive loading to achieve a power factor as close as practicable to the SR limit with field current approaching rated current demonstrates the EDG's capability to power its accident loads when operating in the isochronous mode, even if the exact power factor value (derived from indicated reactive load while synchronized) is not achieved. Therefore, demonstration of the EDG's capability to power design accident loads when operating isolated from offsite power is demonstrated 100% of the time. This basic principal is also true for EDG-3.
As discussed above, the testing procedures require the reactive load during testing to be as close as possible to the reactive load associated with the approximate analyzed power factor without exceeding the rated limit for exciter current. In all cases the field current is required to be greater than or equal to 90% of the rated limit for exciter current and is allowed to approach the limit without exceeding it. This ensures the power factor limit specified in the TS will be met except when precluded by existing grid (i.e., higher voltage) conditions.
