ML053420181
| ML053420181 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/30/2005 |
| From: | Oxenford W Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-05-186, TQC MC8241 | |
| Download: ML053420181 (9) | |
Text
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- --.k., -e XENERGY (ONORTHWEST People *Vision* Solutions P.O. Box 968
- Richland, WA
- 99352-0968 November 30, 2005 G02-05-186 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS
Reference:
Letter G02-05-145, dated August 17, 2005, from WS Oxenford (Energy Northwest) to NRC, "License Amendment Request for One-time Extension of the Completion Time for Condition B of Technical Specification 3.7.1 and Exemption from Note 1 of Required Action B.1"
Dear Sir or Madam:
Transmitted herewith in Attachment 1 is supplemental information regarding the referenced License Amendment Request (LAR). A telecom between the NRC and Energy Northwest discussing this supplement was conducted on November 29, 2005.
This supplemental information clarifies issues involving the "cascading" of the Service Water subsystem outage into the Diesel Generator Technical Specification (TS).
A revised mark-up of the proposed TS note and the associated TS Bases are provided in Attachment 2 and 3, respectively.
No new commitments are made in this submittal.
This supplemental information does not impact the original no significant hazards determination or the risk assessment used to justify the requested amendment. If you have any questions or require additional information, please contact Michael Brandon (509) 377-4758.
Energy Northwest requests the approval of this LAR on or before December 8, 2005.
SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfully, Oxenfr Vice Presid ntnical Services Mail Drop 4
Attachments:
- 1. Supplemental Information
- 2. Revised mark-up of TS 3.7.1 and 3.8.1
- 3. Revised mark-up of TS Bases 3.7.1 and 3.8.1 cc:
BS Mallett - NRC RIV BJ Benney-NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn
SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Attachment I Page 1 of 1 SUPPLEMENTAL INFORMATION
Background
The referenced submittal requested an amendment to Operating License NPF-21 for Columbia Generating Station (Columbia). The requested amendment revised the Completion Time (CT) for the Required Action of Condition B of Technical Specification (TS) 3.7.1, "Standby Service Water (SW) System and Ultimate Heat Sink (UHS)," from 72 to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />, on a one-time basis and allowed a one-time exemption from Note 1 of the Required Action 3.7.1.B.1.
As discussed in the referenced submittal, the exemption from Note 1 of Required Action B.1 of TS 3.7.1 was requested to avoid entering the Required Action B of TS 3.8.1 "AC Sources Operating" for the diesel generator (DG) supported by the inoperable SW B subsystem. Based on further discussions with the NRC Staff, Energy Northwest has reconsidered this path and is proposing a revision to the CT of both TS 3.7.1 and 3.8.1 on a one-time basis.
A revised marked-up copy of proposed change to the TS is provided in Attachment 2.
Upon approval of the proposed license amendment, Energy Northwest will implement a change to the applicable TS Bases.
A revised marked-up copy of proposed change to the TS Bases is provided in.
SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 1 of 1 Revised Mark-up of TS 3.7.1 and 3.8.1 (pages 3.7.1-2 and 3.8.1-3)
SW System and UHS 3.7.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One SW subsystem B.1 NOTES--------
- 1. Enter applicable Conditions and Required Actions of LCO 3.8.1.
"AC Sources-Operating," for diesel generator made inoperable by SW System.
- 2. Enter applicable Conditions and Required Actions of LCO 3.4-9g "Residual Heat Removal (RHR)
Shutdown Cooling System - Hot Shutdown." for RHR shutdown cooling subsystem made inoperable by SW System.
Restore SW subsystem 72 ho to OPERABLE status.
(,'
(continued)
On a one-time basis, during the refurbishment/replacement of the 1 B Service Water Pump during Cycle 18, the Completion Time for an inoperable service water subsystem is extended to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.
A
=
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Columbia Generating Station 3.7. 1-2 Amendment No. +44g 1691
AC Sources-Operating 3.8.1 k
- i-'
ACTIONS CONDITICN REQUIRED ACTION COMPLETION TIME B. (continued) 6.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s), supported discovery of by the inoperable DG.
Condition B inoperable when the concurrent with redundant required inoperability feature(s) are of redundant inoperable.
required feature(s)
AND 8.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG(s) are not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE DG(s).
AND 6.4 Restore required DG 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l to OPERABLE status.
AND 6 days from discovery of failure to meet LCO (continued)
On a one-time basis, during the refurbishment/replacement of the I B Service Water Pump during Cycle I18, the Completion Time for the Division 2 DG is extended to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.)
Columbia Generating Station 3.8.1-3 Amendment No. 44.9 1691
SUPPLEMENT TO THE LICENSE AMENDMENT REQUEST FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS Page 1 of 1 Revised Mark-up of TS Bases 3.7.1 and 3.8.1 (pages B 3.7.1-5 and B 3.8.1-12)
SW System and UHS B 3.7.1 BASES (continued)
ACTIONS A.1 With average sediment depth in either or both spray ponds
> 0.5 and < 1.0 ft. water inventory is reduced such that the combined cooling capability of both spray ponds may be less than required for 30 days of operation after a LOCA.
Therefore, action must be taken to restore average sediment depth to < 0.5 ft. The Completion Time of 30 days is based on engineering judgement and plant operating experience and takes into consideration the low probability of a design basis accident occurring in this time period.
On a one-time basis, during a the refurbishment/
replacementofthe 1B If one SW subsystem is inoperable, it must be restored to ServiceWaterPumpduring OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
With the unit in this Cycle 18, the Completion condition, the remaining OPERABLE SW subsystem is adequate Time foran inoperable to perform the heat removal function.
However, the overall service water subsystem is reliability is reduced because a single failure in the OPERABLE SW subsystem could result in loss of SW function.
extended to 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />. The The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into one-timeextensionisbased account the redundant capabilities afforded by the OPERABLE uponariskassessment subsystem and the low probability of a DBA occurring during performed in accordance this period.
with Regulatory Guides 1
1.174and1.177. During The Required Action is modified by two Notes indicating that this extended Completion the applicable Conditions of LCO 3.8.1. 'AC Sources-Time, administrativ controls Operating," and LCO 3.4.9, *Residual Heat Removal (RHR)
Shutdown Cooling System-Hot Shutdown," be entered and the must be implemented to Required Actions taken if the inoperable SW subsystem enhance the reliability of results in an inoperable DG or RHR shutdown cooling required electrical sources subsystem, respectively.
This is in accordance with and to minimize plant LCO 3.0.6 and ensures the proper actions are taken for these activities that might components.
challenge other safety-related equipment. This one-C.2 time extension expires at the C. 1 and
~dof Cycle 18.
If the SW subsystem cannot be restored to OPERABLE status within the associated Completion Time, or both SW subsystems are inoperable, or the UHS is determined inoperable for reasons other tham Condition-A_theunitmust be-Rlaced-in-a MODE in which the LCO does-not apply., To achieve this (continued)
Columbia Generating Station 8 3.7. 1-5 Revision 241l
AC Sources - Operating B 3.8.1 BASES
.k ACTIONS B.4 (continued) the onsite Class 1E distribution system.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.
1?
tm The second Completion Time for Required Action B.4 m b, d
established a limit on the maximum time allowed for any the refurbishment/
combination of required AC power sources to be inoperable replacementoftheIB during any single contiguous occurrence of failing to meet ServiceWaterPumpduring the LCO.
If Condition B is entered while, for instance. an Cycle 18,theCompletion offsite circuit is inoperable and that circuit is Timeforthe Division 2 DG is subsequently restored OPERABLE, the LCO may already have extendedto 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />. The been not met for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
This situation could lead one-timeextensionisbased to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />, since initial failure to meet the uponariskassessment
- LCO, to restore the DG.
At this time, an offsite circuit pfor nacould again become inoperable, the OG restored OPERABLE. and peformed in accordance an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (for a total of 9 days) allowed prior with RegulatoryGuides to complete restoration of the LCO.
The 6 day Completion 1.174and1.177. During Time provides a limit on the time allowed in a specified this extended Completion condition after discovery of failure to meet the LCO.
This Time, administrative controls limit is considered reasonable for situations in which mustbeimplementedto Conditions A and B are entered concurrently. The *AND*
enhance the reliability of connector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 6 day Completion Times required electrcal sources means that both Completion Times apply simultaneously, and andetotminimizeuplant the more restrictive Completion Time must be met.
activitiesthatmight Similar to Required Action B.2, the Completion Time of challengeothersafety-Required Action B.4 allows for an exception to the normal relatedequipment.Thisone-
"time zero" for beginning the allowed outage time 'clock."
timeextensionexpiresatthe his exception results in establishing the 'time zero" at end ofCycle 18.
the time the LCO was initially not met, instead of the time Condition B was entered.
C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of concurrent failure of redundant required features.
Required Action C.1 reduces the vulnerability to a loss of function.
The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed with only one division-without offsite power (Required Action A.2).
The rationale (continued)
Columbia Generating Station B 3.8.1-12
.Revision 38