GO2-25-112, Relief Request for the Columbia Generating Station Fifth Interval Inservice Testing
| ML25324A369 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/20/2025 |
| From: | Kennedy M Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-25-112 | |
| Download: ML25324A369 (1) | |
Text
Michael J Kennedy Columbia Generating Station P.O. Box 968, PE26 Richland, WA 99352-0968 509.377.4452 mjkennedy@energy-northwest.com GO2-25-112 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RELIEF REQUEST FOR THE COLUMBIA GENERATING STATION FIFTH INTERVAL INSERVICE TESTING
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(z)(1), Energy Northwest hereby requests U.S. Nuclear Regulatory Commission approval of the attached relief request for the fifth interval of the Inservice Testing (IST) Program at Columbia Generating Station. The details of the 10 CFR 50.55a request are included as an attachment to this letter.
Energy Northwest requests relief due to alternatives providing an acceptable level of quality and safety.
Approval of the relief request is requested within 12 months of acceptance. Once approved, the relief request shall be implemented within 30 days.
There are no regulatory commitments made in this submittal.
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November 20, 2025 ENERGY NORTHWEST
If you have any questions or require additional information, please contact Ms. T. M. Collis at 509-377-8395.
Executed this ______ day of ___________, 2025.
Respectfully, Michael Kennedy Vice President, Engineering
Attachment:
Relief Request 5IST-08 cc:
NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C JW Hayes - BPA CD Sonoda - BPA EFSEC@efsec.wa.gov - EFSEC R Utley - WDOH R Brice - WDOH L Albin - WDOH
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GO2-25-112 Page 2 of 2
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Signed by:
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GO2-25-112 Attachment Page 1 of 4 Relief Request 5IST-08 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Alternative Provides Acceptable Level of Quality and Safety
Function System CSP-V-93 2
A CONTAINMENT ISOLATION CONTAINMENT SUPPLY PURGE CSP-V-96 2
A CSP-V-97 2
A CSP-V-98 2
A PI-VX-250*
2 A
PROCESS INSTRUMENTATION PI-VX-251*
2 A
PI-VX-253*
2 A
PI-VX-256*
2 A
PI-VX-257*
2 A
PI-VX-259*
2 A
PSR-V-X73/1 2
A PRIMARY SAMPLING RADIOACTIVE PSR-V-X73/2 2
A PSR-V-X77A/1 1
A PSR-V-X77A/2 1
A PSR-V-X77A/3 1
A PSR-V-X77A/4 1
A PSR-V-X80/1 2
A PSR-V-X80/2 2
A PSR-V-X82/1 2
A PSR-V-X82/2 2
A PSR-V-X82/7 2
A PSR-V-X82/8 2
A PSR-V-X83/1 2
A PSR-V-X83/2 2
A PSR-V-X84/1 2
A PSR-V-X84/2 2
A PSR-V-X88/1 2
A PSR-V-X88/2 2
A TIP-V-1*
2 A
TRAVERSING IN-CORE PROBE TIP-V-2*
2 A
TIP-V-3*
2 A
TIP-V-4*
2 A
TIP-V-5*
2 A
TIP-V-15 2
A
- Relief is requested for only the close position verification testing frequency; the open position verification will remain on a two-year testing frequency.
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GO2-25-112 Attachment Page 2 of 4
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2020 Edition, no addenda.
3. Applicable Code Requirements
ASME OM Code Subsection ISTC-3700, Position Verification Testing, states, Valves with remote position indicators shall be observed locally at least once every 2 yr to verify that valve operation is accurately indicated.
4. Reason for Request
Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (a)(3), relief is requested from the requirement of ASME OM Code ISTC-3700 for the valves identified in Section 1 of this submittal. Specifically, Energy Northwest requests relief from performing the verification position indication (VPI) testing at the two-year frequency mandated by ISTC-3700. The basis of the relief is that the proposed alternative would provide an acceptable level of quality and safety.
The valves listed in Section 1 are containment isolation valves classified as Category A per ISTC-1300, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants. The subject valves have a safety function to close to isolate containment during a loss of coolant accident requiring containment isolation. These solenoid-operated valves are designed such that the position of the valve is not locally observable; the coil position is internal to the valve body and is not visible in either the energized or de-energized state.
ISTC-3700 contains an allowance that states, Where local observation is not possible, other indications shall be used for verification of valve operation. The VPI test method used at Columbia Generating Station (Columbia) is a pressure test utilizing local leak rate testing (LLRT) equipment. This method involves pressurizing the containment penetration volume to approximately 38 psi, and verifying the penetration remains pressurized while the valve is indicating closed on the main control room panel. The valve is then opened using the control switch in the main control room. The increase in flowrate is measured, along with the valve position indicating open in the main control room. This method satisfies the requirement for position indication verification and ensures that the indicating system accurately reflects the valve position.
The VPI test at Columbia is performed concurrently with the LLRT since both tests utilize the same testing equipment. To properly complete the testing, each individual valve must have its system thoroughly drained, vented, and aligned correctly, which results in unnecessary radiation exposure, as well as a significant impact to Operations and Maintenance personnel time. It is expected that by decreasing the frequency of the VPI testing, it would result in dose savings and reductions in both staff labor and plant component manipulations.
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GO2-25-112 Attachment Page 3 of 4
5. Proposed Alternative and Basis for Use
As an alternative to the ISTC-3700 test interval of at least once every two years, Energy Northwest proposes that the VPI testing of the valves listed in Section 1 be performed in conjunction with the LLRT at a frequency in accordance with 10 CFR 50, Appendix J, Option B. Energy Northwest was approved to utilize this performance-based option for the Primary Containment Leakage Rate Testing (CLRT) Program in NRC letter dated March 30, 2018 (ADAMS Accession Number ML18052B185).
Option B of 10 CFR 50, Appendix J, permits the extension of the Appendix J seat leakage testing to a frequency corresponding to the specific valve performance.
Valves whose leakage test results indicate good performance may have their testing interval increased based on these test results, not to exceed 75 months.
Columbias CLRT Program, which implements Appendix J, Option B, requires individual containment isolation valves to pass two successful as-found seat leakage tests before it can be placed on extended seat leakage testing frequency. In the event a valve cannot meet test criteria, there is Appendix J leakage, or a VPI test failure, then the surveillance would be reset to the base frequency of 24 months. Only after three consecutive as-found tests in consecutive refueling outages with acceptable results would the frequency be returned to an extended interval. Table 2 below shows successful test results from the most recent refueling outages, demonstrating good performance of the valves. The components not tested in 2025 had previously exhibited as-found leakage results below their administrative limits, which allowed their testing frequency to be expanded to four years per the NRC-approved relief dated March 20, 2025 (ADAMS Accession Number ML25070A151).
Table 2 - Historical Data Affected Valve Leakage Admin.
Limit (sccm) 2021 As-Found leakage (sccm) 2021 VPI Result 2023 As-Found Leakage (sccm) 2023 VPI Result 2025 As-Found Leakage (sccm) 2025 VPI Result CSP-V-93 148 96 Pass 79 Pass No Test No Test CSP-V-96 148 140 Pass 27 Pass No Test No Test CSP-V-97 148 90 Pass 2
Pass No Test No Test CSP-V-98 148 95 Pass 125 Pass No Test No Test PI-VX-250 148 2
Pass 2
Pass No Test No Test PI-VX-251 148 6
Pass 4
Pass No Test No Test PI-VX-253 450 27.5 Pass 30 Pass No Test No Test PI-VX-256 148 1
Pass 2
Pass No Test No Test PI-VX-257 148 2
Pass 2
Pass No Test No Test PI-VX-259 450 1
Pass 2
Pass 3*
Pass PSR-V-X73/1 450 59 Pass 106 Pass 8*
Pass PSR-V-X73/2 450 199 Pass 277 Pass No Test No Test PSR-V-X77A/1 750 0
Pass 2
Pass No Test No Test PSR-V-X77A/2 750 33 Pass 53 Pass No Test No Test
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GO2-25-112 Attachment Page 4 of 4 Table 2 continued Affected Valve Leakage Admin.
Limit (sccm) 2021 As-Found Leakage (sccm) 2021 VPI Result 2023 As-Found Leakage (sccm) 2023 VPI Result 2025 As-Found Leakage (sccm) 2025 VPI Result PSR-V-X77A/3 750 2
Pass 96 Pass No Test No Test PSR-V-X77A/4 750 18 Pass 33 Pass No Test No Test PSR-V-X80/1 450 133 Pass 124 Pass No Test No Test PSR-V-X80/2 450 214 Pass 255 Pass No Test No Test PSR-V-X82/1 148 9
Pass 2
Pass No Test No Test PSR-V-X82/2 148 3
Pass 2
Pass No Test No Test PSR-V-X82/7 450 45 Pass 28 Pass No Test No Test PSR-V-X82/8 450 58 Pass 60 Pass No Test No Test PSR-V-X83/1 450 50 Pass 30 Pass No Test No Test PSR-V-X83/2 450 46 Pass 24 Pass No Test No Test PSR-V-X84/1 450 16 Pass 169 Pass No Test No Test PSR-V-X84/2 450 28 Pass 311 Pass No Test No Test PSR-V-X88/1 148 2
Pass 2
Pass No Test No Test PSR-V-X88/2 148 1
Pass 3
Pass No Test No Test TIP-V-1 110 5
Pass 6
Pass No Test No Test TIP-V-2 110 36 Pass 35 Pass No Test No Test TIP-V-3 110 13 Pass 15 Pass No Test No Test TIP-V-4 110 4
Pass 6
Pass No Test No Test TIP-V-5 110 9
Pass 86 Pass No Test No Test TIP-V-15 110 23 Pass 43 Pass No Test No Test
( * - Components were leak tested due to planned maintenance)
In addition to the VPI and seat leakage testing, each of the valves listed in Section 1 is exercised on a quarterly frequency. The valve stroke times are measured and compared to the ASME OM Code acceptance criteria, providing further data for station personnel to use for assessing the health of the valves. This multi-faceted approach to testing provides the station ample opportunity to assess valve performance. Therefore, the ability to detect valve degradation is not jeopardized by performing the VPI testing at the same frequency as specified by Appendix J, Option B. This frequency of testing provides reasonable assurance of the operational readiness of the valves and provides an acceptable level of quality and safety.
- 6. Duration of Proposed Relief Alternative The proposed alternative will be utilized for the fifth interval of Columbias IST Program, which begins on December 13, 2025.
- 7. Precedent This relief was previously granted for the fourth interval of Columbias IST Program (ADAMS Accession Number ML25070A151).
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