GO2-19-124, Response to Request for Additional Information Related to Exigent License Amendment Request for Change to Technical Specification 3.8.7 Distribution Systems - Operating

Response to Request for Additional Information Related to Exigent License Amendment Request for Change to Technical Specification 3.8.7 Distribution Systems - Operating

ML19232A496
Person / Time
Site:	Columbia
Issue date:	08/20/2019
From:	Schuetz R Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID-L-2019-LLA-0174, GO2-19-124
Download: ML19232A496 (4)

Text

R.E. Schuetz ENERGY Columbia Generating Station P.O. Box 968, PE23 NORTHWEST Richland, WA 99352-0968 Ph. 509.377. 2425 l F. 509.377.4150 reschuetz@energy-northwest.com August 20, 2019 GO2-19-124 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXIGENT LICENSE AMENDMENT REQUEST FOR CHANGE TO TECHNICAL SPECIFICATION 3.8.7 DISTRIBUTION SYSTEMS - OPERATING

References:

1. Letter from R.E. Schuetz, Energy Northwest to NRC, Exigent License Amendment Request for Change to Technical Specification 3.8.7 Distribution Systems - Operating, dated August 15, 2019 (ADAMS Accession Number ML19227A370)

2. Letter from R.E. Schuetz, Energy Northwest to NRC, Supplemental Information Related to Exigent License Amendment Request for Change to Technical Specification 3.8.7 Distribution Systems-Operating, dated August 16, 2019 (ADAMS Accession Number ML19228A291)

3. Letter from R. E. Energy Northwest to NRC, Supplemental Information Related to Exigent License Amendment Request for Change to Technical Specification 3.8.7 Distribution Systems-Operating, dated August 19, 2019 (ADAMS Accession Number ML19231A387)

4. Email from J. Klos, NRC to R. M. Garcia, Energy Northwest, dated August 20, 2019, RE: Formal release of RAIs Ref: Columbia exigent amendment - one electrical RAI, (EPID NO. L-2019-LLA-0174)

G02-19-124 Page 2 of 2

Dear Sir or Madam:

By Reference 1 Energy Northwest submitted an exigent License Amendment Request (LAR) for a change to Technical Specification (TS) 3.8.7 Distribution Systems -

Operating. Based on conversations with the NRC staff, Reference 1 was supplemented with References 2 and 3. By Reference 4, the NRC issued a Request for Additional Information. The enclosure to this letter contains the requested information.

The No Significant Hazards Consideration Determination (NSHCD) provided in the original submittal is not altered by this submittal. No new commitments are being made by this letter or the enclosure.

If there are any questions or if additional information is needed, please contact Mr. RM.

Garcia, Licensing Supervisor, at 509-377-8463.

I declare under penalty of perjury that the foregoing is true and correct.

a Executed this  ::Z O day of flv$ vs (- , 2019.

Respectfully, $ - /*,

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& !:, 1~fw e-- .f-z_

RE. Schuetz Site Vice President

Enclosure:

As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident lnspector/988C NRC NRR Plant Licensing Branch Chief (BC) (e-mail)

CD Sonoda - BPA/1399 (email)

EFSECutc.wa.gov - EFSEC (email)

E Fordham - WDOH (email)

R Brice -WDOH (email)

WA Horin - Winston & Strawn

GO2 19-124 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST No. 1:

By application dated August 15, 2019 and its supplements dated August 16, and 19, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession numbers ML19227A370, ML19228A291 and ML19231A387 respectively), Energy Northwest (the licensee) requested a license amendment to revise the Columbia Generating Station (Columbia) Technical Specification (TS) 3.8.7 Distribution Systems -

Operating. This license amendment request (LAR) would add a one-time extension of the Completion Time of TS Action 3.8.7.A, specifically associated with Division 1 Alternating Current (AC) electrical power distribution inoperability.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following additional information is needed to complete its review.

Regulatory Requirement Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, Technical specifications, establishes the requirements related to the content of the TS. Pursuant to 10 CFR 50.36(c) TS are required to include items in five specific categories related to station operation: (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limited conditions of operation (LCOs), (3) Surveillance requirements (SR),

(4) Design features; and (5) Administrative controls. The proposed change in this LAR relates to the LCO category.

Background

In the LAR, Enclosure 1, Page 3, the licensee stated: Power panel E-PP-7AF voltage is monitored weekly through surveillance test procedures. On July 25, 2019 during the weekly surveillance it was first noted that voltage was less than the administrative limit but above the minimum allowable [acceptable]. However, it is not clear what the minimum allowable [acceptable] and the administrative limit voltage values are.

Request for Additional Information (RAI) No. 1 Please provide the minimum acceptable and administrative limit voltage values, and the basis of the minimum acceptable value. Also provide the voltage values observed at Power Panel E-PP-7AF of Division 1 and Power Panel E-PP-8AF of Division 2, during last three surveillances, to determine no common cause effect exists.

GO2 19-124 Page 2 of 2 ENERGY NORTHWEST RESPONSE TO RAI 1:

The minimum allowable voltage for Columbia Generating Station (Columbia) 120 Volt Power Panels is 114.0. This value is based on American National Standards Institute (ANSI) Standard C84.1-1995, Electrical Power Systems and Equipment - Voltage Ratings, 60 Hz. This minimum value ensures appropriate voltage is supplied to the equipment on a specific circuit.

The administrative limit voltage values used for Power Panels E-PP-7AF and E-PP-8AF phase A-G is 119.0 and 117.0 for phase B-G. Table 1 provides the voltage values observed on Power Panels E-PP-7AF and E-PP-8AF. Highlighted values fall below the administrative limit set for the Power Panel voltage.

E-PP-7AF E-PP-7AF E-PP-8AF E-PP-8AF Date Phase A-G* Phase B-G* Phase A-G* Phase B-G*

July 25, 2019 118.9 I 118.7 120.7 120.8 August 2, 2019 118.89I 118.73 120.89 121.25 August 9, 2019 118.6I 118.5 121.0 120.6 August 16, 2019 118.7I 118.6 121.3 120.9 Table 1

• Note: G is ground As shown in Table 1, the voltages observed on E-PP-8AF are all well above the administrative limit. The readings above do not support a common cause effect.