Text

License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revision 0
	ML16067A390
Person / Time
Site:	Columbia
Issue date:	03/03/2016
From:	Hettel W; Energy Northwest
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GO2-16-047
	Download: ML16067A390 (15)
	v • d • e

W. Grover Hettel Vice President, Operations P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8311 F. 509-377-4150 wghettel@energy-northwest.com 10 CFR 50.90 March 3, 2016 GO2-16-047 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia).

The proposed amendment would modify the TS requirements to operate ventilation systems with charcoal filters for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months each month in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per Month." The proposed changes are consistent with the NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-522, Revision 0. The availability of this TS improvement was announced in the Federal Register on September 20, 2012, (77 FR 58412) as part of the consolidated line item improvement process (CLIIP).

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant specification verifications.

Attachment 2 provides the existing TS pages marked up to show the proposed change.

Attachment 3 provides revised (clean) TS pages.

Attachment 4 provides the existing TS Bases pages marked up to show the proposed change. The marked up TS Bases pages are provided for information only and do not require NRC approval.

Energy Northwest requests approval of the proposed License Amendment within one year of the date of this letter with the amendment being implemented within 60 days thereafter.

There are no new regulatory commitments contained in this request.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington State Official.

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 Page 2 of 2 If you should have any questions regarding this submittal, please contact Ms. L. L.

Williams, Licensing Supervisor, at 509-377-8148.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the Q. day of Mc-.r--._'.- , 2016.

Respectfully, W. G. Hettel Vice President, Operations Attachments; As stated.

cc: NRC Region IV Administrator NRC NRA Project Manager NRC Sr. Resident Inspector - 988C CD Sonoda - BPA/1399 (email)

WA Horin - Winston & Strawn (email)

RR Cowley-WDOH (email)

EFSEC @utc.wa.gov (email)

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 Page 1 of 4 Description of Proposed Change and Requested Confirmation of Applicability

1.0 DESCRIPTION

The proposed amendment revises the Technical Specifications Surveillance Requirements which currently require operating ventilation systems with heaters operating for a continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period every 31 days. The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days.

The proposed amendment is consistent with Technical Specification Task Force (TSTF)

Traveler TSTF-522, Revision 0 "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Energy Northwest has reviewed the model safety evaluation dated September 20, 2012, as part of the Federal Register Notice of Availability. This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-522 Revision 0. Energy Northwest has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to Columbia Generating Station (Columbia) and justify this amendment for the incorporation of the changes to the Columbia Technical Specifications.

2.2 Optional Changes and Variations Energy Northwest is not proposing any variations or deviations from the Technical Specifications changes described in TSTF-522, Revision 0, or the applicable parts of the NRC staffs model safety evaluation dated September 20, 2012. There are no changes being made to Technical Specification 5.5.7, Ventilation Filter Testing Program (VFTP). Columbia performs ventilation filter testing at 70 percent humidity which requires that operation of the systems be performed with heaters operating as described in TSTF- 522. Columbia is not proposing to remove the requirement to operate the heaters from the Surveillance Requirements.

Columbia's Technical Specifications utilizes a different nomenclature than the Standard Technical Specification on which TSTF-522 was based. Specifically, Columbia's TS 3.7.3 is titled "Control Room Emergency Filtration (CREF) System" whereas the cited specification in TSTF-522 is titled "Control Room Fresh Air (CRFA) System". This is an administrative difference that does not affect the applicability of TSTF-522.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Energy Northwest requests adoption of Technical Specification Task Force (TSTF)

Traveler TSTF-522 Revision 0, for Columbia's Technical Specification which will revise Technical Specifications 3.6.4.3 "Standby Gas Treatment (SGT) System" and Technical

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 Page 2 of 4 Specifications 3.7.3 "Control Room Emergency Filtration (CREF) System", Surveillance Requirements to operate the SGT and CREF systems with electric heaters for a continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period every 31 days. The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days with heaters operating.

Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment as required by Title 10 of the Federal Code of Regulations (CFR), Paragraph 50.91(a). An analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change replaces an existing Surveillance Requirements to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change replaces an existing Surveillance Requirements to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 Page 3 of 4

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change replaces an existing Surveillance Requirements to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

The design basis for the ventilation systems' heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Energy Northwest concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

3.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 requires Technical Specifications to contain surveillances. It states, "Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The proposed change revises Surveillance Requirements and the revised Surveillance Requirements continue to demonstrate that the necessary quality of the SGT and CREF systems are maintained. Therefore, the proposed change is in compliance with 10 CFR 50.36.

3.2 Precedent The NRC approved a similar change reducing the duration of the system and heater tests for the Shield Building Ventilation System, Auxiliary Building Special Ventilation System, and Spent Fuel Pool Special Ventilation System from 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months to 15 minutes for Prairie Island Nuclear Generating Plant, Units 1 and 2 in a Safety Evaluation dated July 18, 2008 (ADAMS Accession Number ML072010452) (Reference 5.3).

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 Page 4 of 4 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

5.1. TSTF-522, Revision 0 "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month.

5.2. NRC staffs model Safety Evaluation Report (77 FR 58412), dated September 20, 2012 5.3. NRC Safety Evaluation, Prairie Island Nuclear Generating Plant, Units 1 and 2 -

Issuance of Amendments RE: Adopting Provisions of Regulatory Guide (RG) 1.52 Revision 3 (TAC Nos. MD6120 and MD 6121), dated July 18, 2008 (ADAMS Accession No. ML072010452).

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UPS)

Page 3.6.4.3-2 Page 3.7.3-3

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two SGT subsystems E.1 Initiate action to suspend Immediately inoperable during OPDRVs.

OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 1015 31 days continuous hoursminutes with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooling recirculation valve can 24 months be opened and the fan started.

Columbia Generating Station 3.6.4.3-2 Amendment No. 169,199 225

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREF subsystem for 1015 31 days continuous hoursminutes with the heaters operating.

SR 3.7.3.2 Perform required CREF filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.3.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program Columbia Generating Station 3.7.3-3 Amendment No. 199,207 225

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN)

Page 3.6.4.3-2 Page 3.7.3-3

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Two SGT subsystems E.1 Initiate action to suspend Immediately inoperable during OPDRVs.

OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 15 continuous 31 days minutes with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooling recirculation valve can 24 months be opened and the fan started.

Columbia Generating Station 3.6.4.3-2 Amendment No. 169,199 225

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREF subsystem for 15 continuous 31 days minutes with the heaters operating.

SR 3.7.3.2 Perform required CREF filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.3.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air inleakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program Columbia Generating Station 3.7.3-3 Amendment No. 199,207 225

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522 REVISION 0 MARKED UP TECHNICAL SPECIFICATION BASES PAGES (Information Only)

Page B 3.6.4.3-4 Page B 3.7.3-6

SGT System B 3.6.4.3 BASES ACTIONS (continued)

C.1 and C.2 During OPDRVs, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should be immediately placed in operation. This Required Action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation will occur, and that any other failure would be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the unit in a condition that minimizes risk. Action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until OPDRVs are suspended.

D.1 If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactive release control function. Therefore, actions are required to enter LCO 3.0.3 immediately.

E.1 When two SGT subsystems are inoperable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until OPDRVs are suspended.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating (from the control room) each SGT subsystem for 1015 continuous hoursminutes with heaters operating ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

Columbia Generating Station B 3.6.4.3-4 Revision 73

CREF System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.1 REQUIREMENTS Operating (from the control room) each CREF subsystem for 1015 continuous hoursminutes with heaters operating ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain humidity) for 10 continuous hours every 31 days reduces moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.7.3.2 This SR verifies that the required CREF testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREF filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6).

The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test-Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.3.3 This SR verifies that each CREF subsystem starts and operates on an actual or simulated initiation signal. This SR also includes ensuring the control room isolates (i.e., the normal intake dampers close and the exhaust fan trips and associated discharge damper closes). The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.4 overlaps this SR to provide complete testing of the safety function. The Frequency of 24 months is based on industry operating experience and is consistent with the typical refueling cycle. Therefore, the Frequency was found to be acceptable from a reliability standpoint.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

Columbia Generating Station B 3.7.3-6 Revision 73