ML043090360

Columbia Generating Station - Request for Additional Information to Revise Tech Spec 3.8.1 AC Sources-Operating

ML043090360
Person / Time
Site:	Columbia
Issue date:	11/04/2004
From:	Macon W NRC/NRR/DLPM/LPD4
To:	Parrish J Energy Northwest
Macon W, NRR/DLPM,415-3965
References
TAC MC3203
Download: ML043090360 (7)

Text

November 4, 2004 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MC3203)

Dear Mr. Parrish:

By letter dated May 19, 2004, Energy Northwest submitted a request for an amendment to Facility Operating License No. NPF-21 to revise Technical Specification 3.8.1, "AC Sources-Operating," to permit a longer completion time for the Division 1 and Division 2 diesel generators for the Columbia Generating Station. The staff has performed an initial review of the amendment request and finds that it needs additional information to complete its review.

Therefore, it is requested that you respond to the enclosed request for additional information by November 29, 2004, for the NRC staff to expedite its review. The response date was agreed upon by members of your staff via telephone conference on October 26, 2004. The enclosed questions are unchanged, except for administrative changes, from those sent by e-mail to a member of your staff on October 13, 2004.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

Request for Additional Information cc w/encl: See next page

November 4, 2004 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MC3203)

Dear Mr. Parrish:

By letter dated May 19, 2004, Energy Northwest submitted a request for an amendment to Facility Operating License No. NPF-21 to revise Technical Specification 3.8.1, "AC Sources-Operating," to permit a longer completion time for the Division 1 and Division 2 diesel generators for the Columbia Generating Station. The staff has performed an initial review of the amendment request and finds that it needs additional information to complete its review.

Therefore, it is requested that you respond to the enclosed request for additional information by November 29, 2004, for the NRC staff to expedite its review. The response date was agreed upon by members of your staff via telephone conference on October 26, 2004. The enclosed questions are unchanged, except for administrative corrections, from those sent by e-mail to a member of your staff on October 13, 2004.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397 DISTRIBUTION:

PUBLIC

Enclosure:

Request for Additional Information PDIV-2 Reading RidsNrrDlpmPdiv2 (RGramm) cc w/encl: See next page RidsNrrPMWAMacon RidsNrrLAEPeyton RidsRegion4MailCenter (B. Jones)

EMarinos RDennig RidsNrrDlpmDpr RidsNrrDeDpr RidsNrrDssaDpr ACCESSION NO.: ML043090360 NRR-088 OFFICE PDIV-2/PM PDIV-2/LA PDIV-2/SC NAME WAMacon EPeyton RGramm DATE 10/27/04 10/26/04 10/27/04 DOCUMENT NAME: E:\Filenet\ML043090360.wpd OFFICIAL RECORD COPY

Columbia Generating Station cc:

Mr. Dale Atkinson (Mail Drop PE08) Energy Northwest Vice President, Technical Services P.O. Box 968 Energy Northwest Richland, WA 99352-0968 P.O. Box 968 Richland, WA 99352-0968 Thomas C. Poindexter, Esq.

Winston & Strawn Mr. Albert E. Mouncer (Mail Drop PE01) 1400 L Street, N.W.

Vice President, Corporate Services/ Washington, DC 20005-3502 General Counsel/CFO Energy Northwest Mr. Bob Nichols P.O. Box 968 Executive Policy Division Richland, WA 99352-0968 Office of the Governor P.O. Box 43113 Chairman Olympia, WA 98504-3113 Energy Facility Site Evaluation Council P.O. Box 43172 Ms. Lynn Albin Olympia, WA 98504-3172 Washington State Department of Health P.O. Box 7827 Mr. D. W. Coleman (Mail Drop PE20) Olympia, WA 98504-7827 Manager, Performance Assessment and Regulatory Programs Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Ms. Christina Perino (Mail Drop PE20)

Manager, Licensing Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Chairman Benton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069 Mr. Rodney L. Webring (Mail Drop PE04)

Vice President, Nuclear Generation

REQUEST FOR ADDITIONAL INFORMATION ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 By letter dated May 19, 2004, Energy Northwest submitted a request for an amendment to Facility Operating License No. NPF-21 to revise Technical Specification 3.8.1, "AC Sources-Operating," to permit a longer completion time for the Division 1 and Division 2 diesel generators for the Columbia Generating Station. The following additional information is needed by the staff to complete its review.

1. The 2004 peer review summary results performed in accordance with Regulatory Guide (RG) 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," provide only peer review A and B Facts and Observations (F&O) results. Based on the staff's review of the Columbia Generating Station (CGS) probabilistic risk assessment (PRA), provide the disposition of peer review C F&Os found to be applicable to the proposed diesel generator (DG) completion time (CT) extension to 14 days.

2. Clarify or justify the reactor core isolation cooling (RCIC) system logic used. If the logic is in error, please revise the model and provide updated results for this application (base CDF, LERF, and CDF, LERF, OCCDP, and ICLERP). (Gate GHPS212 identified during the staff review of the CGS PRA).

3. Provide the installation schedule for the permanent alternate AC (AAC) power source and the associated timeframe requested for crediting the temporary AAC power source.

Will the temporary AC power source remain an option after the permanent AC power source is installed? Clarify if the analysis credits the permanent AACSBC [alternate AC source to the Division 1 and Division 2 battery chargers] and for what timeframe the temporary AC power source will be credited for the proposed 14-day CT. The staff considers the schedule for the permanent installation should be identified as a commitment by the licensee.

4. Attachment 1 to the submittal states that procedures for verifying the AACSBC DG is capable of performing its risk management function, including starting and loading, and will be performed prior to declaring the AACSBC available. How is the verification of the temporary/permanent AACSBC availability accomplished? Is this an additional risk management action commitment? Is the temporary/permanent DG only considered available at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />?

5. Maintenance and repair appear to be treated the same. The proposed CT extension does not appear to distinguish between corrective maintenance and preventive maintenance. Are the estimates for CDF, LERF, ICCDP and ICLERP calculated for both preventive maintenance and repair (corrective maintenance)? Is the 72-hour

limiting condition for operation (LCO) assumed to remain intact? Does the evaluation assume only the extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days? Is the 24-hour technical specification (TS) common cause evaluation included in the results?

6. For the equations on page 5 of Attachment 5, please provide a reference for the derivation.

7. Battery mission times assume battery testing complete/successful with elimination of margin for the proposed 14 day CT extension (i.e., battery capacity equal to or greater than 100% capacity - 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> basis for batteries). Is this a risk management action commitment? In addition, is a load shed required for 125 Vdc or 250 Vdc loads to support the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> battery assumption?

8. Provide a discussion on the cumulative risk for the proposed CT extension with respect to previous CGS license amendment requests submitted to the staff for review and approval.

9. The 2004 peer review was not a 100 percent review, but a selective sampling. What systems applicable to the proposed CT extension were reviewed and what systems were not reviewed? Additionally, if the review resulted in a graded capability 1 for the supporting requirement with specific aspects to be upgraded, how are the required upgrades identified?

As stated in RG 1.200, the team qualifications determine the credibility and adequacy of the peer reviewers. To avoid any perception of a technical conflict of interest, the peer reviewers will not have performed any actual work on the PRA. Discuss the independence of the peer review team members with respect to the guidelines given in RG 1.200.

10. In Attachment 6, is the switchgear room cooling confirmed to be met for the proposed 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> mission time?

11. On page 22 of Attachment 5 it is stated that the AACSBC will be pre-staged with required cabling and distribution boards in place for rapid connection. Does this refer to either the temporary or permanent AACSBC?

12. For the permanent installation of the AACSBC, the submittal states that the installation will comply with CGSs separation criteria. Provide an evaluation of the conformance of this installation to the requirements of IEEE 279 (10 CFR 50.55a (h)) and IEEE 308 with respect to channel independence, separation, interaction and single failure.

13. Is the temporary/permament AACSBC to be included in the 10 CFR 50.65(a)(2)

Maintenance Rule? Will the AACSBC have established performance criteria? If so please identify the performance criteria for the AACSBC.

14. Provide the DG unavailability goals and reliability criterion (functional failures) and comparatives to the estimates used in the CGS PRA.

15. For the sensitivity studies performed, were collective effects evaluated (instead of

separate) for individual components/events? Integrated impact? What are the effects resulting from the worst case considerations of all the sensitivity studies?

16. The AAC source described in the submittal is not a qualified AAC source to support the request because it does not have enough capacity to power safe shutdown loads. In the past, the staff has granted extensions in allowed outage time for DGs to those licensees who have installed a qualified AAC credited for station blackout (SBO) events which can be substituted for an inoperable DG in the event of a loss of offsite power (LOOP). Also, some boiling water reactor licensees have taken credit for the Division III DG which can be cross-connected to either Division I or Division II AC buses to provide an alternate source of power for an SBO or in the event of a LOOP when one DG is in the extended outage and the other DG becomes unavailable. This cross-connection can be accomplished within two hours. These licensees have demonstrated that when the Division III DG is cross-connected to the Division I or II bus, it can carry all of the Division I or II automatically connected loads with the exception of certain loads. Some licensees have installed a temporary commercial-grade DG capable of supplying power to, at a minimum, the required safe-shutdown loads on the DG train removed from service for the maintenance outage.

In view of the above, should Energy Northwest elect to utilize the Division III DG as an alternate power source, please provide the following additional information:

a. Is this going to be a permanent cross-connection? How long would it take to accomplish this connection?

b. Demonstrate that the Division III DG has enough capacity to power loads that are needed for an SBO and a LOOP.

17. What type of communication has been established between the control room operator of CGS and the system load dispatcher? Did Energy Northwest obtain current grid conditions information from the dispatcher prior to maintenance on the DG? Is the dispatcher notified in advance that the DG is going to be out for an extended period of time?

18. Clarify if there are any seasonally based or other restrictions on DG maintenance.

Provide clarification as to what is meant by severe weather and the actions to be taken.

19. Attachment 7 to the submittal lists risk management commitment actions for the extended CT. The staff considers the following measures need to be added:

a. The condition of the offsite power supply, switchyard and the grid will be evaluated prior to entering the extended CT for elective maintenance. An extended CT will not be entered to perform elective maintenance when grid stress conditions are high such as during summer temperatures and/or high demand.

b. No maintenance or testing that affects the reliability of the trains associated with the operable DGs will be scheduled during the extended CT. If any testing and maintenance activities must be performed while the extended CT is in effect, a 10 CFR 50.65(a)(4) evaluation will be performed.

c. The system load dispatcher will be contacted once per day and informed of the DG status along with the power needs of the facility.