ML020990351
| ML020990351 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/28/2002 |
| From: | Galen Smith Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G02-02-055 | |
| Download: ML020990351 (2) | |
Text
ENERGY NORTH WEST P0. Box 968 m Richland, Washington 99352-0968 March 28, 2002 G02-02-055 Docket No. 50-397 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
COLUMBIA GENERATING STATION, OPERATING LICENSE NPF-21, SUPPLEMENT TO TECHNICAL SPECIFICATION AMENDMENT REQUEST TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.6.1.3.6
Reference:
Letter dated March 22, 2002, GO Smith (Energy Northwest) to NRC, "Columbia Generating Station, Operating License NPF-21, Technical Specification Amendment Request To Technical Specification Surveillance Requirement 3.6.1.3.6" This letter is written to supplement the referenced license amendment request regarding a primary containment isolation valve surveillance requirement.
This supplement provides clarification regarding the exigent nature of the request.
On March 21, 2002 Columbia Generating Station requested enforcement discretion from compliance with Required Action A of Limiting Condition for Operation (LCO) 3.6.1.3 because two inboard main steam isolation valves (MSIVs) were declared inoperable due to failure to meet Surveillance Requirement (SR) 3.6.1.3.6.
Compliance with the LCO action would have required isolation of two main steam lines necessitating a plant shutdown.
Enforcement discretion was granted in order to minimize the potential safety consequences and operational risks associated with an unnecessary plant transient.
The current situation could not be predicted or avoided. The surveillance requirement for MSIVs was previously thought to be met and each MSIV operable. The discovery that circuit response time should not be included in MSIV isolation time, regarding the three-second time limit portion of SR 3.6.1.3.6, resulted in two MSIVs being technically inoperable.
SUPPLEMENT TO TECHNICAL SPECIFICATION AMENDMENT REQUEST TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.6.1.3.6 Page 2 Approval of this exigent Technical Specification amendment request will preclude the need for continued enforcement discretion. The proposed exigent license amendment to SR 3.6.1.3.6 is requested to remain in effect until startup from the R-16 refueling outage, or until startup from a forced outage of sufficient duration (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) to perform surveillance testing to meet the requirements of SR 3.6.1.3.6 as it is currently written.
Should you have any questions or desire additional information regarding this matter, please call Ms. CL Perino at (509) 377-2075.
Respectfully, GOS ih7 ViOceS ident, Generation Mail Drop PE04 cc: EW Merschoff - NRC-RIV JB Hickman - NRC-NRR NRC Sr. Resident Inspector - 988C DL Williams - BPA/MD1399 TC Poindexter - Winston & Strawn JO Luce - ESFEC