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 Cooling
| ML23241B044 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/29/2023 |
| From: | David Brown Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-23-056 | |
| Download: ML23241B044 (1) | |
Text
David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 509.377.8385 dpbrown@energy-northwest.com GO2-23-056 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 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-230, ADD NEW CONDITION B TO LCO 3.6.2.3, RHR SUPPRESSION POOL COOLING
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).
Energy Northwest requests adoption of TSTF-230 Rev. 1, Add New Condition B to LCO 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling, which is an approved change to the Standard Technical Specifications, into the Columbia TS. The proposed amendment modifies TS 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling, to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours.
The enclosure to this letter provides an evaluation of the proposed TS change. provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides existing TS Bases pages marked up to show the proposed changes and is provided for information only.
Approval of the proposed amendment is requested within one year of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 120 days.
There are no regulatory commitments made in this submittal.
In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this application, with attachments to the designated State Official.
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August 29, 2023 ENERGY NORTHWEST
GO2-23-056 Page 2 of 2 If you should have any questions regarding this submittal, please contact Mr. R. M.
Garcia, Licensing Supervisor, at 509-377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this ______ day of ___________, 2023.
Respectfully, David P Brown Site Vice President
Enclosures:
- 1. Evaluation of Proposed Technical Specification Change Attachments:
- 1. Proposed Technical Specification Changes (Mark-up)
- 2. Proposed Technical Specification Changes (Clean Pages)
- 3. Proposed Technical Specification Bases Markup Pages (For Information Only) cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSEC@efsec.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
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GO2-23-056 Page 1 of 7 Evaluation of Proposed Technical Specification Change 1.0
SUMMARY
DESCRIPTION This evaluation supports a License Amendment Request (LAR) to Columbia Generating Station (Columbia) Technical Specification (TS) 3.6.2.3, Residual Heat Removal (RHR)
Suppression Pool Cooling. This TS change will allow two RHR suppression pool cooling subsystems to be inoperable for eight hours. The proposed change is consistent with NRC approved Technical Specification Task Force (TSTF) Traveler 230-A, Rev. 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling.
Implementation of this LAR will result in no physical modification to the plant. This proposed change has no adverse effect on the plant or plant safety.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation There are two RHR suppression pool cooling subsystems, each containing a pump and a heat exchanger and is manually initiated and independently controlled. The two RHR suppression pool cooling subsystems perform the suppression pool cooling function by circulating water from the suppression pool through the RHR heat exchangers and returning it to the suppression pool. Standby service water, circulating through the tube side of the heat exchangers, exchanges heat with the suppression pool water and discharges this heat to the ultimate heat sink.
2.2 Current Technical Specifications Requirements TS Limiting Condition for Operation (LCO) 3.6.2.3 requires that two RHR suppression pool cooling subsystems be OPERABLE. This LCO is applicable with the plant in MODES 1, 2, and 3. The current TS require a unit shutdown if both RHR suppression pool cooling subsystems were to become inoperable. With two RHR suppression pool cooling subsystems inoperable the Plant is required to be brought to a MODE in which this LCO does not apply. The Required Action for this condition is for the plant to brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Since the approval of TSTF-230 Rev. 1 Columbia has implemented TSTF-423 Rev. 1, which modified several TS based on Topical Report NEDC-32988-A, Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants, Rev. 2. As part of TSTF-423, TS 3.6.2.3 was changed from what is shown in TSTF-230 Rev. 1. As a result, this LAR requests to add a new Condition C to TS 3.6.2.3 instead of a new Condition B. The purpose of TSTF-230 Rev.
1 is unchanged though, to allow eight hours to restore at least one RHR suppression pool cooling subsystem to OPERABLE status when both subsystems are inoperable.
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GO2-23-056 Page 2 of 7 2.3 Reason for the Proposed Change With two RHR suppression pool cooling subsystems inoperable an eight hour completion time provides the plant time to restore one of the subsystems to OPERABLE status prior to requiring a unit shutdown. This additional eight hours is considered appropriate since an immediate unit shutdown, which is currently required by TS, has the potential to result in a unit scram and discharge of steam to the suppression pool, when both suppression pool cooling subsystems are inoperable and incapable of removing the generated heat.
In addition, this proposed change provides consistency with TS 3.6.1.5, Residual Heat Removal (RHR) Drywell Spray. With both RHR drywell spray subsystems inoperable, LCO 3.6.1.5 has an eight hour Completion Time for restoring one RHR drywell spray subsystem to OPERABLE status.
2.4 Description of the Proposed Change The proposed change would add a new Required Action to LCO 3.6.2.3 which would allow eight hours to restore at least one RHR suppression pool cooling subsystem to OPERABLE status, if two RHR suppression pool cooling subsystems were inoperable, before requiring a unit shutdown. If this condition were not to be met by restoring at least one RHR suppression pool cooling subsystem to OPERABLE status the plant would then be required to perform a unit shutdown. The Required Action would be for the plant to be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A markup of TS 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling, is provided in Attachment 1 of this amendment request.
3.0 TECHNICAL EVALUATION
Following a Design Basis Accident (DBA), the RHR suppression pool cooling system removes heat from the suppression pool. The suppression pool is designed to absorb the sudden input of heat from the primary system. In the long term, the pool continues to absorb residual heat generated by fuel in the reactor core. Some means must be provided to remove heat from the suppression pool so that the temperature inside the primary containment remains within design limits. This function is provided by two redundant RHR suppression pool cooling subsystems.
The heat removal capability of one RHR subsystem is sufficient to meet the overall DBA pool cooling requirement to limit peak temperature to 220°F for loss of coolant accidents (LOCAs) and transient events such as a turbine trip or a stuck open safety/relief valve (SRV). SRV leakage and Reactor Core Isolation Cooling (RCIC)
System testing increase suppression pool temperature more slowly. The RHR suppression pool cooling system is also used to lower the suppression pool water bulk temperature following such events.
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GO2-23-056 Page 3 of 7 The proposed eight hour time to restore at least one RHR suppression pool cooling subsystem to OPERABLE status is considered appropriate since an immediate shutdown has the potential for resulting in a unit scram and discharge of steam to the suppression pool, when both suppression pool cooling subsystems are inoperable and incapable of removing the generated heat. The proposed eight hours provides some time to restore one of the RHR suppression pool cooling subsystems to OPERABLE status prior to requiring a unit shutdown, and therefore precluding the potential problem described above. In addition, the proposed eight hours is short enough that it does not significantly increase the probability of an accident to occur during this additional time.
3.1 Impact on Submittals under Review by NRC The NRC is presently reviewing two Energy Northwest LARs, however neither impacts this LAR:
x License Amendment Request to Adopt TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (ML23086C103 dated March 27, 2023) x License Amendment Request to Clean-Up Operating License and Appendix A Technical Specifications (ML23121A294 dated May 1, 2023).
4.0 REGULATORY EVALUATION
The Columbia Final Safety Analysis Report (FSAR) Chapter 3 provides detailed discussion of Columbias compliance with the applicable regulatory requirements and guidance.
The proposed TS amendment:
x Does not result in any change in the qualifications of any component; and x Does not result in the reclassification of any components status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
4.1 Applicable Regulatory Requirements 4.1.1 10 CFR 50 Appendix A General Design Criteria (GDC)
The relevant GDCs are discussed below:
Criterion 34 - Residual Heat Removal:
A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a
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GO2-23-056 Page 4 of 7 rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.
Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.
Criterion 34 continues to be met after implementation of this amendment. The RHR system provides the means to remove decay heat and residual heat from the nuclear system so that refueling and nuclear system servicing can be performed. There is no change being proposed to the design or configuration of the RHR system or how it is operated. The proposed change will allow for eight hours of operation before a plant shutdown is required with two RHR suppression pool cooling subsystems inoperable.
Criterion 38 - Containment Heat Removal:
A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.
Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.
Criterion 38 continues to be met after implementation of this amendment. The containment heat removal function is accomplished by the RHR system.
There is no change to the RHR system or any components that perform the containment heat removal function. There is no change being proposed that affects the ability of the RHR system to perform its safety function. There is no impact by this proposed amendment on the redundancy of the RHR systems containment heat removal function, interconnections, leak detection, isolation and containment capabilities and that the RHR systems safety function can be accomplished even with a single failure.
The proposed change will allow for eight hours of operation before a plant shutdown is required with two RHR suppression pool cooling subsystems inoperable.
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GO2-23-056 Page 5 of 7 4.2 Applicable Regulatory Guidance The following regulatory requirements and criteria were reviewed during development of the proposed license amendment:
x 10 CFR 50, Appendix A, Criterion 34 - Residual Heat Removal x 10 CFR 50, Appendix A, Criterion 38 - Containment Heat Removal x 10 CFR 50.36, Technical Specifications.
5.0 PRECEDENT TSTF-230 Rev. 1 has recently been approved for the following nuclear stations:
x Clinton Power Station, Unit 1, Amendment No. 247, November 10, 2022 o Clinton Power Station had implemented TSTF-423 Rev 1 since TSTF-230 Rev. 1 was approved. As a result, they also added a new LCO Condition C instead of a Condition B as described in Section 2.2 above.
x Perry Nuclear Power Plant, Unit 1, Amendment No. 195, November 5, 2021.
o TSTF-230 Rev. 1 was previously approved for Perry Nuclear plant in November 2021.
6.0 SIGNIFICANT HAZARDS CONSIDERATION Energy Northwest requests adoption of TSTF-230 Rev. 1, Add New Condition B to LCO 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling, which is an approved change to the Standard Technical Specifications, into the Columbia TS. The proposed amendment modifies TS 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling, to allow two RHR suppression pool cooling subsystems to be inoperable for eight hours.
Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below.
- 1)
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change relaxes the Required Actions of LCO 3.6.2.3 by allowing eight hours to restore one RHR suppression pool cooling subsystem to OPERABLE status when both subsystems have been determined to be inoperable.
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GO2-23-056 Page 6 of 7 Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated. The proposed eight hour Completion Time provides some time to restore an RHR suppression pool cooling subsystem to OPERABLE status yet is short enough that operating an additional eight hours is not a significant risk. The Required Actions in the proposed change have been developed to provide assurance that appropriate remedial actions are taken in response to the degraded condition, considering the operability status of the RHR suppression pool cooling subsystem and the capability of minimizing the risk associated with continued operation. As a result, neither the probability nor the consequence of any accident previously evaluated are significantly increased.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2)
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?
Response: No.
The proposed change does not involve a physical modification or alteration of plant equipment (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The Required Actions and associated Completion Times in the proposed change have been evaluated to ensure that no new accident initiators are introduced.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3)
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The relaxed Required Actions do not involve a significant reduction in a margin of safety. The proposed change has been evaluated to minimize the risk of continued operation with both RHR suppression pool cooling subsystems inoperable. The operability status of the RHR suppression pool cooling subsystem, a reasonable time for repairs, and the low probability of a design basis accident occurring during the repair period have been considered in the evaluation.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
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GO2-23-056 Page 7 of 7 Based on the above evaluation, 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.
7.0 CONCLUSION
S Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
8.0 ENVIRONMENTAL CONSIDERATION
Energy Northwest has determined that the proposed amendment would change requirements with respect to installation or use of a facility component located within Columbia's restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. Energy Northwest has evaluated the proposed change and has determined that the change does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or a 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 criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
9.0 REFERENCES
- 1. TSTF-230-A, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling
- 2. Letter from S.P. Wall (U.S. NRC) to R.L. Penfield (Energy Harbor Nuclear Corp.),
Perry Nuclear Power Plant, Unit No. 1 - Issuance of Amendment No. 195 Regarding Adoption of TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling (EPID L-2021-LLA-0019), dated November 5, 2021
- 3. Letter from J.S. Wiebe (U.S. NRC) to D.P. Rhoades (Constellation Nuclear),
Clinton Power Station, Unit No. 1 - Issuance of Amendment No. 247 Re:
Adoption of TSTF-230, Revision 1 (EPID L-2022-LLA-0076), dated November 10, 2022
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Proposed Technical Specification Changes (Mark-Up)
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RHR Suppression Pool Cooling 3.6.2.3 Columbia Generating Station 3.6.2.3-1 Amendment No. 149,169,225,230,236 245 270 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.
A.1 Restore RHR suppression pool cooling subsystem to OPERABLE status.
7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.
B.1
NOTE--------------
LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Two RHR suppression pool cooling subsystems inoperable.
C.1 Be in MODE 3.
AND C.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours
'. 5HTXLUHG$FWLRQDQG DVVRFLDWHG&RPSOHWLRQ 7LPHRI&RQGLWLRQ&QRW PHW
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Be in MODE 3.
AND
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Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours 8
Restore one RHR suppression pool cooling subsystem to OPERABLE status.
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Proposed Technical Specification Changes (Clean Pages)
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RHR Suppression Pool Cooling 3.6.2.3 Columbia Generating Station 3.6.2.3-1 Amendment No. 149,169,225,230,236 245 270 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.
A.1 Restore RHR suppression pool cooling subsystem to OPERABLE status.
7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.
B.1
NOTE--------------
LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Two RHR suppression pool cooling subsystems inoperable.
C.1 Restore one RHR suppression pool cooling subsystem to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D. Required Action and associated Completion Time of Condition C not met.
D.1 Be in MODE 3.
AND D.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours
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Proposed Technical Specification Bases Markup Pages (For Information Only)
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D.1 and D.2 If two RHR suppression pool cooling subsystems are inoperable and are not restored to OPERABLE status within the required Completion Time
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