ML061880531

Request for Additional Information - Amendment to Facility Operating License No. NPF-21 - Alternate Source Term

ML061880531
Person / Time
Site:	Columbia
Issue date:	07/11/2006
From:	Brian Benney NRC/NRR/ADRO/DORL/LPLIV
To:	Parrish J Energy Northwest
Benney B, NRR/DLPM, 415-3764
References
TAC MC4570
Download: ML061880531 (5)

Text

July 11, 2006 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. MC4570)

Dear Mr. Parrish:

By letter dated September 30, 2004, Energy Northwest submitted a request for a license amendment to Facility Operating License No. NPF-21 to reflect the application of the Alternate Source Term for Columbia Generating Station. The Nuclear Regulatory Commission (NRC) staff has performed a 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 July 30, 2006, for the NRC staff to expedite its review. The enclosed questions are unchanged, except for administrative changes, from those sent by e-mail to a member of your staff on June 29, 2006.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

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

July 11, 2006 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. MC4570)

Dear Mr. Parrish:

By letter dated September 30, 2004, Energy Northwest submitted a request for a license amendment to Facility Operating License No. NPF-21 to reflect the application of the Alternate Source Term for Columbia Generating Station. The Nuclear Regulatory Commission (NRC) staff has performed a 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 July 30, 2006, for the NRC staff to expedite its review. The enclosed questions are unchanged, except for administrative changes, from those sent by e-mail to a member of your staff on June 29, 2006.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

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

PUBLIC RidsNrrDorl (CHaney/CHolden)

LPLIV r/f RidsRgn4MailCenter (CJohnson)

RidsNrrLALFeizollahi RidsNrrDorlDpr RidsNrrPMBBenney RidsOgcRp RidsNrrDorlLpl4 (DTerao)

RidsAcrsAcnwMailCenter ADAMS ACCESSION NO: ML061880531 NRR-106 OFFICE LPL4/PM LPL4/LA LPL4/BC NAME BBenney LFeizollahi DTerao DATE 7/11/06 7/10/06 7/11/06 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION (RAI)

COLUMBIA GENERATING STATION ALTERNATIVE SOURCE TERM (TAC NO. MC4570)

In order to complete its review, the Nuclear Regulatory Commission (NRC) staff needs additional information on the proposed changes to the secondary containment and standby gas treatment system (SGT)

Proposed Changes Technical Specification (TS) 3.6.4.1, "Secondary Containment"

1. Revised Surveillance Requirement (SR) 3.6.4.1.1 to change the minimum required containment vacuum from greater than or equal to 0.25 inch of vacuum water gauge (wg) to greater than 0.0 inch of vacuum wg.

2. Deleted SR 3.6.4.1.4.

3. Revised the existing SR 3.6.4.1.5 to change the maximum allowed standby gas treatment subsystem flow rate from less than or equal to 2240 cubic feet per minute (cfm) to a secondary containment inleakage flow rate of less than or equal to 2430 cfm.

4. Due to the deletion of SR 3.6.4.1.4, SR 3.6.4.1.5 is renumbered as SR 3.6.4.1.4.

TS 3.6.4.3, "Standby Gas Treatment System"

5. Revised SR 3.6.4.3.3 to add the phrase "and reaches greater than or equal to 4800 cfm within 2 minutes."

NRC Staff RAIs

1. The current TSs require the secondary containment to be maintained at negative 0.25 inches wg during normal operation. The daily surveillance on this requirement assures that the building integrity is being monitored and maintained during the 24-month interval between draw down testing. If the TSs were changed to allow less than or equal to 0.0 wg pressure normally (change No. 1 above), the building would potentially breathe as external pressures changed and integrity could degrade and be undetected. What assurance would this test or any other test provide that secondary containment integrity capability is being maintained?

Also, with the secondary containment being maintained at a negative pressure, the release to the environment is from a single point that is monitored for release. If the secondary containment is allowed to breathe with external pressure changes, how would Columbia meet General Design Criteria (GDC) 64 or its equivalent for monitoring releases?

2. Deleting SR 3.6.4.1.4 (change No. 2) deletes the requirement to measure the time it takes to achieve a secondary containment negative pressure of negative 0.25 inches wg. Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR),

Criterion 2, requires a limiting condition for operation (LCO) for a process variable, design feature, or operating restriction that is an initial condition of a deign-basis accident. The time at which secondary containment is established is directly input into the loss-of-coolant accident design-basis analysis as the point at which secondary containment and the SGT can be credited. The LCO is relieved by meeting the SR that measures the time at which draw down is achieved as stated in the TS. Please clarify how the requirements of 10 CFR 50.36 are satisfied with respect to removing this SR.

3. SR 3.6.4.1.5 verifies the SGT ability to maintain the negative 0.25 inch wg pressure in the secondary containment for a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The change increases the flow rate from a maximum of 2240 cfm to a maximum of 2430 cfm, and labels this flow as an "inleakage" flow. Please clarify how inleakage flow is measured or provide a basis for labeling it inleakage flow in lieu of the measured quantity which appears to be SGT subsystem flow. Please clarify if the reason to increase this maximum flow results from greater secondary containment inleakage, and identify any steps being taken to control the degradation of secondary containment integrity.

4. No question on change No. 4. It is editorial.

5. SR 3.6.4.3.3 verifies the ability of each subsystem to start. The proposed additional requirement of achieving 4800 cfm in 2 minutes is more restrictive and conservative.

The NRC staff is concerned that Columbia is trying to relate the initial subsystem flow rate (4800 cfm in 2 minutes) to the time it takes to achieve draw down of the secondary containment to the negative 0.25 inches wg. Subsystem flow rate is not related to secondary containment integrity except in the sense that if there was more inleakage such as a door being open, there would be less pressure drop on the subsystem and a corresponding increase in flow. Please clarify if Columbia is requesting that an SR on SGT subsystem flow combined with a Gothic analysis be substituted for measuring the draw down time directly, and explain how this would identify changes in building leakage and other parameters used in the analysis over the time interval between tests (24 months).

Columbia Generating Station cc:

Mr. W. Scott Oxenford (Mail Drop PE04) Mr. Dale K. Atkinson (Mail Drop PE08)

Vice President, Technical Services Vice President, Nuclear Generation Energy Northwest Energy Northwest P. O. Box 968 P.O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Albert E. Mouncer (Mail Drop PE01) Mr. William A. Horin, Esq.

Vice President, Corporate Services/ Winston & Strawn General Counsel/CFO 1700 K Street, N.W.

Energy Northwest Washington, DC 20006-3817 P.O. Box 968 Richland, WA 99352-0968 Mr. Matt Steuerwalt Executive Policy Division Chairman Office of the Governor Energy Facility Site Evaluation Council P.O. Box 43113 P.O. Box 43172 Olympia, WA 98504-3113 Olympia, WA 98504-3172 Ms. Lynn Albin Mr. Douglas W. Coleman (Mail Drop PE20) Washington State Department of Health Manager, Regulatory Programs P.O. Box 7827 Energy Northwest Olympia, WA 98504-7827 P.O. Box 968 Richland, WA 99352-0968 Technical Services Branch Chief FEMA Region X Mr. Gregory V. Cullen (Mail Drop PE20) 130 228th Street S.W.

Supervisor, Licensing Bothell, WA 98201-9796 Energy Northwest P.O. Box 968 Cheryl M. Whitcomb (Mail Drop PE03)

Richland, WA 99352-0968 Vice President, Organizational Performance & Staffing/CKO Regional Administrator, Region IV Energy Northwest U.S. Nuclear Regulatory Commission P.O. Box 968 611 Ryan Plaza Drive, Suite 400 Richland, WA 99352-0968 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 November 2005