GO2-25-091, License Amendment Request to Revise Technical Specification to Adopt TSTF-599, Eliminate Periodic Surveillance Test of Simultaneous Start of Redundant Diesel Generators
| ML25245A260 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/02/2025 |
| From: | David Brown Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-25-091 | |
| Download: ML25245A260 (1) | |
Text
David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.8385 dpbrown@energy-northwest.com GO2-25-091 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 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION TO ADOPT TSTF-599 ELIMINATE PERIODIC SURVEILLANCE TEST OF SIMULTANEOUS START OF REDUNDANT DIESEL GENERATORS
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 requestV adoption of TSTF-599, Eliminate Periodic Surveillance Test of Simultaneous Start of Redundant Diesel Generators, which is an approved change to the Standard Technical Specifications, into Columbias TS. The proposed change eliminates the periodic Surveillance Requirement to verify that all required diesel generators achieve rated frequency and voltage within the specified time period when started simultaneously.
The enclosure provides a description and assessment of the proposed changes. provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.
Energy Northwest requests that the amendment be reviewed under the Consolidated Line Item Improvement Process. Approval of the proposed amendment is requested within 6 months of completion of the Nuclear Regulatory Commissions acceptance review. Once approved, the amendment shall be implemented within 60 days.
There are no regulatory commitments in this letter, enclosure, or attachments.
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 letter, enclosure, and attachments to the designated State Official.
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September 2, 2025 ENERGY
___ NORTHWEST
GO2-25-091 Page 2 of 2 If there are any questions or if additional information is needed, please contact Ms. T. M. Collis, Licensing Supervisor, at 509-377-8395.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this ______ day of ___________, 2025.
Respectfully, David P. Brown Site Vice President
Enclosure:
Evaluation of Proposed Technical Specification Change Attachments: 1. Proposed Columbia Technical Specification Changes (Mark-Up)
- 2. Proposed Columbia Technical Specification Changes (Clean Pages)
- 3. Proposed Technical Specification Bases Mark-Up Pages (For Information Only) cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector
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CD Sonoda - BPA EFSEC@efsec.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
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GO2-25-091 Enclosure Page 1 of 3 Evaluation of Proposed Technical Specification Change
1.0 DESCRIPTION
Energy Northwest requests adoption of TSTF-599, "Eliminate Periodic Surveillance Test of Simultaneous Start of Redundant Diesel Generators," which is an approved change to the Standard Technical Specifications (STS), into the Columbia Generating Station (Columbia) Technical Specifications (TS). The proposed change eliminates the periodic Surveillance Requirement (SR) to verify that all required diesel generators (DG) achieve rated frequency and voltage within the specified time period when started simultaneously.
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation Energy Northwest has reviewed the safety evaluation for TSTF-599 provided to the Technical Specifications Task Force in a letter dated May 5, 2025. This review included the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-599. Energy Northwest has concluded that the justifications presented in TSTF-599 and the safety evaluation prepared by the NRC staff are applicable to Columbia and justify this amendment for the incorporation of the changes to Columbias TS.
2.2 Variations Energy Northwest is proposing the following variations from the TS changes described in TSTF-599, or the applicable parts of the NRC staffs safety evaluation:
Columbias TS contain requirements that differ from the STS on which TST-599 was based but are encompassed in the TSTF-599 justification. Columbias TS for SR 3.8.1.20 does not have requirements for steady state voltage and frequency. This does not affect the justification of the change.
Columbias TS do not reference SR 3.8.1.20 in SR 3.8.2.1. Therefore, no change to SR 3.8.2.1 is necessary. This does not affect the justification of the change.
3.0 REGULATORY EVALUATION
3.1 No Significant Hazards Consideration Analysis Energy Northwest requests adoption of TSTF-599, "Eliminate Periodic Surveillance Test of Simultaneous Start of Redundant Diesel Generators," which is an approved change to the STS, into Columbias TS. The proposed change eliminates the periodic SR to
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GO2-25-091 Enclosure Page 2 of 3 verify that all required DGs achieve rated frequency and voltage within the specified time period when started simultaneously.
Energy Northwest has evaluated if 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 eliminates a periodic surveillance test which verifies that all required DGs achieve rated frequency and voltage within the specified time period when started simultaneously. Simultaneous start of the redundant DGs is not an initiator of any accident previously evaluated. The fast start of the DGs is verified by other surveillance tests and historical performance of the simultaneous test has not resulted in any failures to maintain DG independence at Columbia. As a result, the DG reliability and the attendant effect on the consequences of any accident previously evaluated are not affected.
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 eliminates a periodic surveillance test which verifies that all required DGs achieve rated frequency and voltage within the specified time period when started simultaneously. No new or different accidents result from the proposed change. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
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GO2-25-091 Enclosure Page 3 of 3
- 3)
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change eliminates a periodic surveillance test which verifies that all required DGs achieve rated frequency and voltage within the specified time period when started simultaneously. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.
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.
3.2 Conclusion In conclusion, 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.
4.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment 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, or would change an inspection or surveillance requirement. However, the proposed amendment 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 amendment meets the eligibility criterion for categorical exclusion set forth in 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.
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GO2-25-091 Proposed Columbia Technical Specification Changes (Mark-Up)
(2 Pages Follow)
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AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-15 Amendment No. 203,204 225 238 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.19
NOTES-----------------------------
1.
All DG starts may be preceded by an engine prelube period.
2.
This Surveillance shall not normally be performed in MODE 1, 2, or 3 (not applicable to DG-3). However, portions of the Surveillance may be performed to re-establish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.
Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
a.
De-energization of emergency buses; b.
Load shedding from emergency buses for DG-1 and DG-2; and c.
DG auto-starts from standby condition and:
1.
energizes permanently connected loads in d 15 seconds, 2.
energizes auto-connected emergency
- loads, 3.
maintains steady state voltage t 3910 V and d 4400 V, 4.
maintains steady state frequency t 58.8 Hz and d 61.2 Hz, and 5.
supplies permanently connected and auto-connected emergency loads for t 5 minutes.
In accordance with the Surveillance Frequency Control Program
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AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-16 Amendment No. 204 225 238 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.20
NOTE------------------------------
All DG starts may be preceded by an engine prelube period.
Verify, when started simultaneously from standby condition, DG-1 and DG-2 achieves, in d 15 seconds, voltage t 3910 V and frequency t 58.8 Hz, and DG-3 achieves, in d 15 seconds, voltage t 3910 V and frequency t 58.8 Hz.
In accordance with the Surveillance Frequency Control Program This page intentionally left blank
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GO2-25-091 Proposed Columbia Technical Specification Changes (Clean Pages)
(2 Pages Follow)
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AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-15 Amendment No. 203,204 225 238 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.19
NOTES-----------------------------
1.
All DG starts may be preceded by an engine prelube period.
2.
This Surveillance shall not normally be performed in MODE 1, 2, or 3 (not applicable to DG-3). However, portions of the Surveillance may be performed to re-establish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.
Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
a.
De-energization of emergency buses; b.
Load shedding from emergency buses for DG-1 and DG-2; and c.
DG auto-starts from standby condition and:
1.
energizes permanently connected loads in d 15 seconds, 2.
energizes auto-connected emergency
- loads, 3.
maintains steady state voltage t 3910 V and d 4400 V, 4.
maintains steady state frequency t 58.8 Hz and d 61.2 Hz, and 5.
supplies permanently connected and auto-connected emergency loads for t 5 minutes.
In accordance with the Surveillance Frequency Control Program
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AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-16 Amendment No. 204 225 238 This page intentionally left blank
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GO2-25-091 Proposed Technical Specification Bases Mark-8p Pages (For Information Only)
(3 Pages Follow)
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AC Sources - Operating B 3.8.1 Columbia Generating Station B 3.8.1-33 Revision 126 BASES SURVEILLANCE REQUIREMENTS (continued) the Surveillance to be performed for the purpose of re-establishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced.
This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.
These shall be measured against the avoided risk of plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1, 2, or 3. Risk insights or deterministic methods may be used for this assessment. If the assessment cannot demonstrate that plant safety is maintained or enhanced (i.e., that the proposed testing will not cause electrical perturbations that would challenge continued steady state operation or challenge plant safety systems), the Note shall not be invoked and the surveillance testing shall not be performed. Usage of the allowance of the Note shall be an invoked and the surveillance testing shall not be performed. Usage of the allowance of the Note shall be an infrequently performed test evolution. Credit may be taken for unplanned events that satisfy this SR.
SR 3.8.1.20 This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.
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AC Sources - Operating B 3.8.1 Columbia Generating Station B 3.8.1-34 Revision 126 BASES REFERENCES 1.
10 CFR 50, Appendix A, GDC 17.
2.
FSAR, Chapter 8.
- 3.
Deleted.
4.
FSAR, Tables 8.3-1, 8.3-2, and 8.3-3.
5.
Safety Guide 9, Revision 0, March 1971.
6.
FSAR, Chapter 6.
7.
FSAR, Chapter 15.
8.
9.
Regulatory Guide 1.93, Revision 0, December 1974.
10.
Generic Letter 84-15, July 2, 1984.
11.
10 CFR 50, Appendix A, GDC 18.
- 12.
Regulatory Guide 1.9, Revision 3, July 1993.
- 13.
Deleted.
14.
Regulatory Guide 1.137, Revision 1, October 1979.
15.
Calculations Nos. E/I-02-87-07 and 2-12-58.
16.
17.
ANSI C84.1, 1982.
18.
Letter, GO2-13-043, Request for Technical Specification Interpretation Regarding the Offsite Power Supplies to the Onsite Class 1E AC Power Distribution System.
19.
NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
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AC Sources - Shutdown B 3.8.2 Columbia Generating Station B 3.8.2-5 Revision 121 BASES ACTIONS (continued)
C.1 When the HPCS is required to be OPERABLE, and the Division 3 DG is inoperable, the required diversity of AC power sources to the HPCS is not available. Since these sources only affect the HPCS, the HPCS is declared inoperable and the Required Actions of LCO 3.5.2, "RPV Water Inventory Control" entered.
In the event all sources of power to Division 3 are lost, Condition A will also be entered and direct that the ACTIONS of LCO 3.8.8 be taken. If only the Division 3 DG is inoperable, and power is still supplied to HPCS, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore the DG to OPERABLE. This is reasonable considering HPCS will still perform its function, absent an additional single failure.
SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 are not required to be met because DG response on an offsite power or ECCS initiation signal is not required. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.
This SR is modified by a Note which precludes requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit are required to be OPERABLE.
REFERENCES 1.
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