ML120800078

Issuance of Amendment No. 223, Administrative Changes to Facility Operating License to Modify Existing License Conditions or Delete Obsolete License Conditions

ML120800078
Person / Time
Site:	Columbia
Issue date:	03/30/2012
From:	Thadani M Plant Licensing Branch IV
To:	Reddemann M Energy Northwest
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME5903
Download: ML120800078 (45)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2012 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION -ISSUANCE OF AMENDMENT RE:

DELETION OR MODIFICATIONS OF LICENSE CONDITIONS THAT HAVE BEEN COMPLETED OR ARE NO LONGER IN EFFECT (TAC NO. ME5903)

Dear Mr. Reddemann:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 223 to Facility Operating License No. NPF-21 for the Columbia Generating Station (CGS).

The amendment consists of changes to the operating license in response to your application dated March 3, 2011.

The amendment revises the Facility Operating License No. NPF-21 for CGS. The changes either delete or modify existing license conditions which have been completed, modified, or are otherwise no longer in effect. The licensee stated that approval of the proposed changes to the operating license has been requested in order to support the CGS license renewal effort.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosures:

1. Amendment No. 223 to NPF-21

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 223 License No. NPF-21

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Energy Northwest (licensee), dated March 3, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amer:Jdment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

-2

2. Accordingly, the license is amended by changes as indicated in the attachment to this license amendment. Paragraphs 2.C.(1) through (10),

Paragraph 2.C.(12), Paragraphs 2.C.(15) through (28), and Paragraph 2.C.(30) of Facility Operating License No. NPF-21 are hereby amended to read as follows:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3486 megawatts thermal).

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

a. For Surveillance Requirements (SRs) not previously performed by existing SRs or other plant tests, the requirement will be considered met on the implementation date and the next required test will be at the interval specified in the Technical Specifications as revised in Amendment No. 149.

(3) Deleted.

(4) Deleted.

(5) Deleted.

(6) Deleted.

(7) Deleted.

(8) Deleted.

(9) Deleted.

(10) Deleted.

(12) Deleted.

(15) Deleted.

- 3 (16) Deleted.

(17) Deleted.

(18) Deleted.

(19) Deleted.

(20) Deleted.

(21 ) Deleted.

(22) Deleted.

(23) Deleted.

(24) Deleted.

(25) Deleted.

(26) Deleted.

(27) Deleted.

(28) Deleted.

(30) Deleted.

In addition, as indicated in the attachment to this license amendment, Attachments 1 and 2 to Facility Operating License No. NPF-21 have been modified to delete the contents; Attachment 3 to Facility Operating License No. NPF-21 has been modified to delete items (1) through (4) and the associated footnote and to modify items (5) through (9); Appendix B to Facility Operating License No. NPF-21 has been modified to remove an outdated reference; and Appendix C to Facility Operating License No. NPF-21 has been modified to delete the contents.

-4

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

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Michael T. Markley; Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-21 and Technical Specifications Date of Issuance: March 30, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 223 FACILITY OPERATING LICENSE NO. NPF-21 DOCKET NO. 50-397 Replace the following pages of the Facility Operating License No. NPF-21 and Appendices B and C with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Facility Operating License REMOVE INSERT throug h -6 through -6

-6a through -9 through -9 Attachment 1, page 1 Attachment 1, page 1 Attachment 2, pages 1-2 Attachment 2, page 1 Attachment 3, page 1 Attachment 3, page 1 Appendix B, page 3-2 Appendix B, page 3-2 Appendix C, pages 1-2 Appendix C, page 1

-3 (3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

(6) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to store byproduct, source and special nuclear materials not intended for use at Columbia Generating Station. The materials shall be no more than 9 sealed neutron radiation sources designed for insertion into pressurized water reactors and no more than 40 sealed beta radiation sources designed for use in area radiation monitors. The total inventory shall not exceed 24 microcuries of strontium-90, 20 microcuries of uranium-235, 30 curies of plutonium-238, and 3 curies of americium-241.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3486 megawatts thermal).

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223 and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

a. For Surveillance Requirements (SRs) not previously performed by existing SRs or other plant tests, the requirement will be considered met on the implementation date and the next required test will be at the interval specified in the Technical Specifications as revised in Amendment No. 149.

Amendment No. 223

-4 (3) Deleted.

(4) Deleted.

(5) Deleted.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 223

- 5 (6) Deleted.

(7) Deleted.

(8) Deleted.

(9) Deleted.

Amendment No. 223

- 6 (10) Deleted.

(11) Shield Wall Deferral (Section 12.3.2, SSER #4, Licensee Amendment #7)

The licensee shall complete construction of the deferred shield walls and window as identified in Attachment 3, as amended by this license amendment.

(12) Deleted.

(13) Deleted.

(14) Fire Protection Program (Generic Letter 86-10)

The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the Final Safety Analysis Report (FSAR) for the facility thru Amendment #39 and as described in subsequent letters to the staff through November 30, 1988, referenced in the May 22, 1989 safety evaluation and in other pertinent sections of the FSAR referenced in either Section 9.5.1 or Appendix F and as approved in the Safety Evaluation Report issued in March 1982 (NUREG 0892) and in Supplements 3, issued in May 1983, and 4, issued in December 1983, and in safety evaluations issued with letters dated November 11, 1987 and May 22, 1989 subject to the following provision:

The license may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(15) Deleted.

(16) Deleted.

Amendment 1, 7, 67,184223

-7 (17) Deleted.

(18) Deleted.

(19) Deleted.

(20) Deleted.

(21) Deleted.

Amendment No. 449 223

- 8 (22) Deleted.

(23) Deleted.

(24) Deleted.

(25) Deleted.

Amendment No. 223

- 9 (26) Deleted.

(27) Deleted.

(28) Deleted.

(29) Protection of the Environment (FES)

Before engaging in additional construction or operational activities which may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than the evaluation in the Final Environmental Statement the licensee shall provide a written notification to the Director of the Office of Nuclear Reactor Regulation and receive written approval from that office before proceeding with such activities.

(30) Deleted.

Amendment No. 149, 151, 153, 157 223

ATTACHMENT 1 TO OPERATING LICENSE NPF-21 Deleted Amendment No. 4&7 223

ATTACHMENT 2 Deleted Amendment No. 25, 60, 162223

ATTACHMENT 3 LIST OF SHIELD WALLS

1. Deleted.

2. Deleted.

3. Deleted.

4. Deleted.

• • 5. FSAR Figure 12.3"12, Zone G The access blockout to the duplicate centrifuge room.

• • 6. FSAR Figure 12.3-12. Zone F Same as above for the duplicate centrifuge.

• • 7. FSAR Figure 12.3-13, Zone J The blockout for one of the two decon concentrators.

• • 8. FSAR Figure 12.3-11. Zone 0"8 - The two block walls at the north end of the truck loading bay.

• • 9. FSAR Figure 12.3-11. Zone E The leaded glass viewing window in the radwaste area.

• • Shield walls and window identified in items 5, 6, 7, 8, and 9 will be installed if the associated radiation levels at these locations exceed 2.5mRlhr as dictated by the ongoing ALARA reviews.

Amendment No. +- 223

significant increase in any adverse environmental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.

The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall include written evaluations which provide bases for the determination that the change, test, or experiment does not involve an un reviewed environmental question or constitute a decrease in the effectiveness of this EPP to meet the objectives specified in Section 1.0. The licensee shall include as part of its Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reporting Related to the NPDES Permit and State Certification Changes to, or renewals of, the NPDES Permit or the State certification shall be reported to the NRC within 30 days following the date the change or renewal is approved. If a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days following the date the stay is granted.

3-2 Amendment No. 223

APPENDIX C Deleted Amendment No. 149, 151, 153, 157223

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 223 TO FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397

1.0 INTRODUCTION

By letter dated March 3, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110690023), Energy Northwest (the licensee) submitted a license amendment request to the U.S. Nuclear Regulatory Commission (NRC) requesting approval of changes to Facility Operating License NPF-21 for the Columbia Generating Station (CGS). The proposed changes either delete or modify existing license conditions which have been completed or are otherwise no longer in effect. The licensee stated that approval of the proposed changes to the operating license was requested in order to support the Columbia license renewal effort.

1.1 Background Facility Operating License No. NPF-21 was issued on December 20, 1983, to Washington Public Power Supply System (WPPSS) for the WPPSS Nuclear Project No.2 (WNP-2).

WPPSS subsequently changed its name to Energy Northwest and changed the name of the plant to Columbia Generating Station. Conditional requirements were placed on the operating license for CGS to address outstanding licensing issues and facilitate issuance of the original operating license. The licensee stated that since the original issuance of the CGS operating license, several additional requirements (license conditions) were incorporated into the license via the license amendment process pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). In some cases, subsequent license amendments have allowed removal of certain license conditions when they were no longer applicable.

1.2 Proposed Changes In the current license amendment request, the licensee is proposing changes to the CGS operating license to remove the remaining license conditions that no longer apply, which also includes minor editorial changes for consistency. Revision of the CGS operating license is Enclosure 2

-2 being proposed to retain only those license conditions that remain pertinent to current station operations. The licensee's intent is to provide a license document for license renewal that does not contain unnecessary or obsolete requirements and that is directly applicable to the current plant design and licensing basis. The licensee requests deletion of the following license conditions (LC):

LC 2.C.(1) LC 2.C.(12) LC 2.C.(23)

LC 2.C.(3) LC 2.C.(15) LC 2.C.(24)

LS 2.C.(4) LC 2.C.(16) LC 2.C.(25)

LC 2.C.(6) LC 2.C.(17) LC 2.C.(26)

LC 2.C.(7) LC 2.C.(18) LC 2.C.(27)

LC 2.C.(8) LC 2.C.(19) LC 2.C.(28)

LC 2.C.(9) LC 2.C.(20) LC 2.C.(30)

LC 2.C.(10) LC 2.C.(21)

LC 2.C.(11) LC 2.C.(22)

2.0 REGULATORY EVALUATION

Pursuant to Section 50.54, "Conditions of licenses," of 10 CFR, the operation of a nuclear power plants is authorized by the Commission subject to conditions of operation identified as a result of Commission's evaluation of applications for operating licenses.

Operation of a nuclear power plants is authorized by the Commission subject to conditions of operation identified as a result of the Commission's evaluation applications for operating licenses. Such conditions were placed on the operating license for CGS requiring the licensee to address outstanding licensing issues and facilitate issuance of the original operating license.

The original issuance of the CGS operating license was subject to several additional requirements (license conditions). Additional requirements were incorporated in the license as required as a result of ongoing reviews via the license amendment process pursuant to 10 CFR 50.90. In some cases, subsequent license amendments removed certain license conditions, when they were no longer applicable. However, the majority of the license conditions have been left intact even though they are no longer required.

The licensee is proposing an administrative change to the CGS operating license to remove or revise those license conditions that no longer apply or have been modified. This proposed operating license "clean-up" activity also includes minor editorial changes for consistency.

Revision of the CGS's operating license is being proposed to retain only those license conditions that remain pertinent to current CGS operations. The licensee's intent is to provide a license document for license renewal that does not contain unnecessary or obsolete requirements and that is directly applicable to the current plant design and licensing basis.

-3 The NRC staff reviewed the licensee's application for changes to the license conditions. The staff's evaluations and conclusions are summarized below.

3.0 TECHNICAL EVALUATION

Proposed Change to Revise License Condition 2.C.(1)

Current license condition 2. C. (1) states:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3486 megawatts thermal). Items in Attachment 1 shall be completed as specified. Attachment 1 is hereby incorporated into this license.

Revised license condition 2.C.(1) would state:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3486 megawatts thermal).

License condition 2.C.(1) required completion of items in Attachment 1 to the operating license.

This attachment contains three types of items: 1) completion of preoperational/acceptance tests, 2) installation of hangers, supports, and restraints, and 3) construction completion (master completion list schedule).

Item 1a requires completion of the System 36 preoperational testing prior to fuel load ..

System 36 (process radiation monitoring) testing was completed as required. NRC Inspection Report 50-397-84-07 discussed the completion of the required testing of System 36 prior to fuel load and identified this item as "Closed." Thus, this item has been satisfied and its deletion is acceptable.

Item 1(b) requires completion of 16 preoperational/acceptance tests prior to exceeding 5 percent rated power. 8y letter dated April 12, 1984 (ADAMS Legacy Accession No. 8405140241), the licensee confirmed that all but two of the tests listed for Item 1(b) have been completed. The other two tests (PT 33.0-8 and PT 92.0-A) were not required to be completed and are addressed in the CGS Final Safety Analysis Report (FSAR).

The PT 33.0-8 test, which tests portions of the chemical waste system, was initially suspended by the licensee as described in a letter to the NRC dated January 17, 1984 (ADAMS Legacy Accession No. 840300066). The request was accepted by the NRC by letter dated April 13, 1984 (ADAMS Legacy Accession No. 8405020375), with the condition that if the permanent system was placed into operation, the PT 33.0-8 test must be completed prior to operation of the permanent chemical waste system.

- 4 The PT 92.0-A test was described by the licensee in its letter dated April 12, 1984, as being completed for the off-gas charcoal adsorber vault refrigeration system utilizing one of two redundant chillers. Subsequently, the licensee permanently deactivated the off-gas charcoal adsorber vault refrigeration system, which is documented in FSAR Section 9.4.5, "Offgas Charcoal Adsorber Vault Refrigeration System."

The NRC staff has reviewed applicable documentation as described above for Item 1(b) and has verified the completion of Item 1(b). The staff also verified that the two incomplete tests were described in the CGS FSAR with administrative measures to conduct the two tests prior to the respective systems operating. The staff concludes that the proposed deletion of item 1(b) of license condition 2.C.(1) is acceptable.

Item 1(c) required completion of PT 22.0-B, Nitrogen Inerting System, prior to 6 months after initial criticality. By letter dated July 18, 1984 (ADAMS Legacy Accession No. 8407250342), the licensee confirmed completion of the required testing. The NRC staff reviewed referenced documentation and has verified the completion of Item 1(c). The staff concludes that the proposed deletion of Item 1(c) for license condition 2.C.(1) is acceptable.

Proposed Change to Delete License Condition 2.C.(3)

Current license condition 2.C.(3) states:

(3) Initial Test Program (Section 14, SER)*

The licensee shall conduct the initial test program (set forth in Section 14 of the licensee's Final Safety Analysis Report, as amended) without making any modifications of this program unless such modifications are in accordance with the provisions of 10 CFR Section 50.59. In addition, the licensee shall not make any major modifications to this program unless modifications have been identified and have received prior NRC approval.

Major modifications are defined as:

(a) Elimination of any test identified in Section 14 of the licensee's Final Safety Analysis Report, as amended, as being essential; (b) Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of the licensee's Final Safety Analysis Report, as amended, as being essential; (c) Performance of any test at a power level different from that described in the program; and (d) Failure to complete any tests included in the described program (planned or scheduled) for power levels up to the authorized power level.

- 5 Revised license condition 2.C.(3) would state:

(3) Deleted.

In addition, the NRC staff notes that although the footnote reference symbol (*) for license condition 2.C.(3) will be deleted, the following footnote, which references safety evaluation reports (SERs) and supplements (SSERs), will remain in the license since it also applies to certain license conditions still in effect.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

License condition 2.C.(3) specifies that the Initial Test Program, as described in Section 14 of the CGS FSAR, is to be conducted without making any modifications of this program unless such modifications are in accordance with 10 CFR 50.59. Furthermore, the licensee shall make no major modifications to the test program without prior NRC approval.

Startup testing of CGS was completed in 1985. By letter dated April 17, 1985 (ADAMS Legacy Accession No. 8505030723), the licensee submitted the final startup report. The licensee also referenced NRC Inspection Reports 50-397-84-38 dated January 30, 1985 (ADAMS Legacy Accession No. 8502220074), and 50-397-85-27 dated August 9, 1985 (ADAMS Legacy Accession No. 8508230232), which documented the NRC staff's review of the startup testing program.

The NRC staff has reviewed the referenced documentation and has verified the completion of license condition 2.C.(3). The staff concludes the proposed deletion of license condition 2.C.(3) is acceptable.

Proposed Change to Delete License Condition 2.C.(4)

Current license condition 2.C.(4) states:

(4) Seismic Equipment Qualification (Section 3.10. SSER #4)

Prior to startup following the first refueling outage, the licensee shall complete seismic qualifications for all equipment approved by the NRC staff for interim operation.

Revised license condition 2.C.(4) would state:

(4) Deleted.

This license condition requires completion of seismic qualification for all equipment that was approved by the NRC staff for interim operation. This qualification was required to be completed prior to startup following the first refueling outage.

-6 By letter dated June 3, 1986 (ADAMS Legacy Accession No. 8606090167), the licensee confirmed that the seismic qualification of equipment required by this license condition is complete and this license condition has been satisfied. The NRC staff has reviewed the referenced document and concludes that the deletion of license condition 2.C.(4) is acceptable.

Proposed Change to Delete License Condition 2.C.(5)

Current license condition 2.C.(5) states:

(5) Equipment Qualification (Sections 3.10.1, 3.11.3, SSER #4)

Prior to exceeding five (5) percent of rated power, the licensee shall provide the staff for their review and approval:

(a) assurance that all equipment listed in Appendix 3B is either environmentally qualified or provide justification for interim operation.

(b) for all pipe-mounted safety-related equipment, provide assurance that the "g" values for the as-installed configuration do not exceed the "g" values established in the equipment qualification information documentation (QID) files or provide justification for interim operation.

Revised license condition 2.C.(5) would state:

(5) Deleted.

This license condition requires NRC review and approval of two items relating to equipment qualification: a) assurance that certain equipment is either environmentally qualified or justified for interim operation, and b) assurance that the "g" values for the as-installed configuration of pipe-mounted safety-related equipment do not exceed the "g" values established in the equipment qualification information documentation files or provide justification for continued operation. This qualification was required to be completed prior to exceeding 5 percent rated power.

By letter dated September 16, 1983 (ADAMS Legacy Accession No. 8309210006), the licensee submitted the environmental qualification report for safety-related equipment. By letter dated January 18, 1984 (ADAMS Legacy Accession No. 840300075), the licensee confirmed that the requirements of license condition 2.C.(5)(a) are satisfied.

By letter dated January 23, 1984 (ADAMS Legacy Accession No. 8401300062), the licensee confirmed the completion of the pipeline mounted equipment "g" value comparison program and that all differences are reconciled either by qualification documentation upgrade, piping analysis refinement, or plans for physical plant modifications. By letter dated March 16, 1984 (ADAMS Legacy Accession No. 8403220061), the licensee confirmed the completion of required modifications. In NUREG-0892, "Safety Evaluation Report Related to the Operation of WPPSS

-7 Nuclear Project No.2, Supplement 5," dated April 1984, the NRC staff stated that license condition 2.C.(5) was satisfied. The NRC staff concludes that deletion of license condition 2.C.(5) is acceptable.

Proposed Change to Delete License Condition 2.C.(6)

Current license condition 2.C.(6) states:

(6) Ultimate Heat Sink (Section 2.4.5, SER)

Prior to startup following the first refueling outage, the licensee shall perform operational testing of the ultimate heat sink spray ponds to verify analyzed parameters of drift loss, seepage and operational capacity. The licensee shall inform the NRC staff of scheduled testing at least 30 days in advance of such testing and shall provide the test results and conclusions for NRC review and approval.

Revised license condition 2.C.(6) would state:

(6) Deleted.

License condition 2.C.(6) requires testing of the ultimate heat sink (UHS) spray ponds, along with NRC review and approval of the test results and conclusions. The licensee was required to complete this testing prior to startup following the first refueling outage.

By letter dated September 27, 1985 (ADAMS Legacy Accession No. 8510090163), the licensee submitted the test results and conclusions to the NRC. By letter dated December 11, 1985 (ADAMS Legacy Accession No. 8712100434), the NRC staff approved the test results and stated that the license condition 2.C.(6) was satisfied. The NRC staff has reviewed the referenced documentation and has verified the completion of license condition 2.C.(6). The NRC staff concludes that the deletion of license condition 2.C.(6) is acceptable.

Proposed Change to Delete License Condition 2.C.(7)

Current license condition 2.C.(7) states:

(7) Turbine Missiles (Section 3.5.1.3, SSER #4)

The licensee shall submit for NRC staff approval, within three years of date of issuance of this license, a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities acceptable to the NRC staff or volumetrically inspect all low pressure turbine rotors at the second refueling outage, and at every other refueling outage thereafter until a maintenance program is approved by the NRC staff.

- 8 Revised license condition 2.C.(7) would state:

(7) Deleted.

License condition 2.C.(7) requires the development of a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities or a recurring inspection of the low pressure turbine rotors. The licensee stated that NRC review and approval of the program was required. The license condition also required for the licensee to satisfy this condition 3 years of the date of issuance of the license at CGS.

By letter dated November 20, 1986 (ADAMS Legacy Accession No. 8612010137), the licensee submitted the turbine system inspection schedule to the NRC. The schedule was based upon the Westinghouse Electric Company, LLC's (Westinghouse's) criteria and topical report for estimating the probability of turbine disc rupture from stress-corrosion cracking. By letter dated March 27, 1987 (ADAMS Legacy Accession No. 8704020448), the NRC stated that license condition 2.C.(7) was satisfied by: 1) the licensee's use of the Westinghouse methodology and procedures, and 2) an existing commitment in FSAR Section 3.5.1.3.4.3, "Combined Overall Probability (P4)," in which the licensee commits to reduce the inspection intervals for subsequent inspections if cracks are detected and measured at any inspection. CGS FSAR Section 3.5.1.3.4.3 also describes the current turbine inspection and testing intervals.

The NRC staff has reviewed referenced documentation and has verified the completion of license condition 2.C.(7). The staff concludes that the proposed deletion of license condition 2.C.(7) is acceptable.

Proposed Change to Delete License Condition 2.C.(8)

Current license condition 2.C.(8) states:

(8) Fuel Coolability (Section 4.2.3.3(1), SER)

Prior to startup following the first refueling outage, the licensee shall provide for NRC staff review and approval revised analyses showing the effects of high-burnup fission gas release on loss-of-coolant accident.

Revised license condition 2.C.(8) would state:

(8) Deleted.

This license condition required NRC review and approval of a revised analysis showing the effects of high burnup fission gas release on loss-of-coolant accidents (LOCAs). This condition was required to be satisfied prior to startup following the first refueling outage.

In response to the licensee's letters dated February 4, May 9, and May 16, 1986 (ADAMS Legacy Accession Nos. 8602110062, 8605160207, and 8605270217, respectively), the NRC staff concluded in a letter dated May 23, 1986 (ADAMS Legacy Accession No. 8605300665),

-9 that license condition 2.C.(8) was satisfactorily resolved. Therefore, the NRC staff concludes that the deletion of license condition 2.C.(8) is acceptable.

The current approved LOCA models for CGS are documented in FSAR Section 4.2.1.3, "Fuel Coolability Limits," and Section 4.2.3.3, "Fuel Cool ability Evaluation," and Technical Specification (TS) 5.6.3.b.

Proposed Change to Delete License Condition 2.C.(9)

Current license condition 2.C.(9) states:

(9) Inadeguate Core Cooling (ICC) Instrumentation Analysis (Section 4.4.7, SER)

The licensee shall implement staffs requirements regarding additional instrumentation for detection of inadequate core cooling which may result from the staffs review of the BWR Owner's Group Reports (SU-8211 and SU-8218) and the licensee's plant specific evaluation report addressing the subjects. Any required modifications shall be completed on a schedule acceptable to the NRC staff.

Revised license condition 2.C.(9) would state:

(9) Deleted.

This license condition required implementation of NRC requirements regarding additional instrumentation for detection of inadequate core cooling. Any required modifications were to be completed on a schedule acceptable to the NRC.

The instrument in question is for measurement of reactor vessel water level. By letter dated November 27, 1984 (ADAMS Legacy Accession No. 8412040036), the licensee submitted information supporting closure of license condition 2.C.(9). No modifications were necessary.

The NRC Inspection Report 50-397-84-38 dated February 1, 1985 (ADAMS Legacy Accession No. 8502220070), evaluated the licensee's response to NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980 (ADAMS Accession No. ML102560051) (TMI Items) Item II.F.2, regarding inadequate core cooling and reactor vessel level instrumentation and identified this item as "Closed." This license condition was satisfied and, therefore, the NRC staff concludes that deletion of license condition 2.C.(9) is acceptable.

The instrumentation to measure reactor vessel water level is described in FSAR Section 7.2.1.1.3, "Reactor Vessel Water Level," Section 7 .3.1.1.2.1, "Reactor Vessel Low Water Level," Section 7 .5.1.1.1, "Reactor Water Level," and Section 7.7.1.1.2.2, "Reactor Vessel Water Level."

- 10 Proposed Change to Delete License Condition 2.C.(10)

Current license condition 2.C.(10) states:

(10) Thermal-Hydraulic Stability (Section 4.4.4, SER)

Prior to startup following the first refueling outage, the licensee shall provide for NRC staff review and approval a revised stability analysis.

Revised license condition 2.C.(10) would state:

(10) Deleted.

This license condition required NRC review and approval of a revised stability analysis. This condition was required to be satisfied prior to startup following the first refueling outage.

By letter dated March 21,1986 (ADAMS Legacy Accession No. 8603270155), in response to the licensee's letter dated January 26, 1986 (ADAMS Legacy Accession No. 8602050119), the NRC staff concurred with the licensee's determination that license condition 2.C.(10) was satisfied. The NRC staff noted, The Safety Evaluation for Amendment No. 16 found that operation of WNP-2 in accordance with the Amendment complies with the recommendation made by General Electric in SIL 380 which the staff had previously found to be an acceptable method for meeting the Thermal-Hydraulic Stability requirements.

The NRC staff concludes that this license condition was satisfied, and therefore, the staff concludes that deletion of license condition 2.C.(1 0) is acceptable.

The current approved stability analysis for CGS is documented in FSAR Section 4.1.4.3, "Reactor Systems Dynamics," and Section 4.4.4.2, 'Thermal Hydraulic Stability Analysis," and TS 5.6.3.b.

License Condition 2.C.(11} and Proposed Changes to Portions of Attachment 3 is referenced by license condition 2.C.(11), which requires completion of the construction of shield walls and a shield window. Attachment 3 also describes where the walls are to be located and when they are required to be installed. No changes are proposed to the license condition 2.C.(11) regarding the installation of shield walls and window. The licensee proposes to delete only Items 1 through 4 and the Note (*) of Attachment 3, because these actions have been completed.

By letter dated August 15, 1984 (ADAMS Legacy Accession No. 8408270073), the licensee requested an amendment, and the NRC staff approved the licensee's requests in Amendment No.7, dated December 10, 1984 (ADAMS Legacy Accession No. 8412140243). Those documents provided the basis for deferral of shield walls and window. The installation of shield walls and shield window will remain in the license condition 2.C.(11).

- 11 The walls and window not yet installed are associated with the permanent radwaste solidification system, which is currently not utilized as documented in CGS FSAR Figures 11.2-4 and 11.4-1. The FSAR figure numbers for figures 11.2.4 and 11.4.1 are proposed to be revised to align with current FSAR numbering. In addition, CGS FSAR Section 11.4.2, "System Description," describes the portable solid waste management system, which is used in lieu of the permanent solidification system. Presently, the installation of the shield walls and shield window as a part of permanent radwaste management system is conditional upon local area radiation levels, for which the licensee did not request any changes.

The NRC staff has verified that Items 1 through 4 and the Note (*) as described in Attachment 3 of license condition 2.C.(11) have been satisfied as documented in the FSAR. The renumbering of the FSAR figures 11.2.4 and 11.4.1 is an editorial change. Therefore, the NRC staff concludes that the proposed deletions of the Items 1 through 4 and the Note (*) from of license condition 2.C.(11) and proposed renumbering of figure numbers in the FSAR are acceptable.

Proposed Change to Delete License Condition 2.C.(12)

Current license condition 2.C.(12) states:

(12) Alternate Remote Shutdown System (Section 7.4.2.3, SSER #1)

Prior to startup following the first refueling outage, the licensee shall install, test, and have operable the alternate remote shutdown system.

Revised license condition 2.C.(12) would state:

(12) Deleted.

This license condition required installation of an alternate remote shutdown system. The installation was required to be completed prior to startup following the first refueling outage.

In its letter June 2, 1986 (ADAMS Legacy Accession No. 8606090357), the licensee confirmed completion of the installation of the alternate remote shutdown system and provided a description of the as-installed system. In NRC Inspection Report 50-397-86-18 dated June 20, 1986 (ADAMS Legacy Accession No. 8607070357), the NRC staff documented its observation and review of installation of the alternate remote shutdown system. The NRC staff concluded that this license condition was satisfied. Therefore, the NRC staff concludes that deletion of license condition 2.C.(12) is acceptable.

The alternate remote shutdown system is described in FSAR Section 7.4.1.4, "Remote Shutdown Systems." TS 3.3.3.2, "Remote Shutdown System," and licensee controlled specification (LCS) 1.3.3.3 address the remote shutdown system, which includes the alternate remote shutdown system as documented in the TS Bases and LCS Bases.

- 12 Proposed Change to Delete License Condition 2.C.(15)

Current license condition 2. C.(15) states:

(15) BWR Startup or Operating Experience (Section 13.1.2.1 (1)' SER)

During the startup test program, the licensee shall have on each shift a licensed individual with previous startup or operating experience, on a comparable BWR, or an advisor who meets these experience requirements.

Revised license condition 2.C.(15) would state:

(15) Deleted.

This license condition required that during the startup test program each shift have a licensed individual or advisor with previous startup or operating experience on a comparable boiling water reactor (BWR).

Based on the review of the licensee's submitted resumes of individuals with previous startup or licensed operating experience in Supplement 4 to NUREG-0892, "Safety Evaluation Report Related to the Operation ofWPPSS Nuclear Project No.2," dated December 1983, the NRC staff concluded that this condition was satisfied. The licensee subsequently updated the list of individuals to be utilized to meet this requirement. Startup testing of CGS was completed in 1985.

Accordingly, license condition 2.C.(15) was satisfied and, therefore, the NRC staff concludes that deletion of license condition 2.C.(15) is acceptable.

Proposed Change to Delete License Condition 2.C.(16) and Items 1-5 of Attachment 2 Current license condition 2.C.(16) states:

(16) Emergency Response Capability (Section 18.0, SER. SSER #4, TMI Item 1.0.1 and Section 13.5.2, SER SSER#4)

The licensee shall correct the design deficiencies for the control room and complete the other related emergency response capabilities as required by Attachment 2 to this license.

Revised license condition 2.C.(16) would state:

(16) Deleted.

This license condition requires correction of control room deSign deficiencies and completion of emergency response capabilities as required by Attachment 2 to the license.

- 13 All of the following items in Attachment 2 have been completed as discussed below. In Supplement 5 to NUREG-0892, the NRC stated that license condition 2.C.(16) was satisfied.

• Item 1 requires submittal of a program plan for a detailed control room design review (DCRDR) within 2 months after issuance of the operating license and a summary report not later than 6 months prior to the first refueling outage.

By letter dated February 17, 1984 (ADAMS Legacy Accession No. 8402230225), the licensee submitted the program plan for the DCRDR. By letter dated November 1, 1985 (ADAMS Legacy Accession No. 8511110262), the licensee submitted the DCRDR Summary Report. By letter dated July 9, 1990 (ADAMS Legacy Accession No. 9007120331), the NRC staff issued a Safety Evaluation Report documenting the review of the DCRDR Summary Report.

By letter dated November 13,1991 (ADAMS Legacy Accession No. 9112050140), the NRC staff stated that the status of the DCRDR was considered closed. FSAR Section 7.5.1.22, "Safety Parameter Display," references the DCRDR analysis which is discussed in FSAR Appendix B Item I.D.1

• Item 2 identifies 13 human engineering deficiencies which must be corrected and implemented to the NRC's satisfaction prior to exceeding 5 percent rated power.

By letter dated March 19,1984 (ADAMS Legacy Accession No. 8403260165), the licensee confirmed that the human engineering deficiencies have been corrected.

Item 2 also identifies an additional seven human engineering deficiencies which must be corrected and implemented to the NRC's satisfaction within 4 months after the issuance of the operating license.

By letter dated April 17, 1984 (ADAMS Legacy Accession No. 8404240082), the licensee confirmed that these human engineering deficiencies have been corrected.

NRC Inspection Report 50-397-84-23 dated September 18, 1984 (ADAMS Legacy Accession No. 8410110186), evaluated the licensee's response to TMI Action 1.D.1 regarding control room design reviews and stated that the 20 human engineering deficiencies have been addressed. This item was identified as "Closed."

• Item 3(a) requires implementation of requirements (with the exception of the wide range suppression pool level monitoring system) of Regulatory Guide (RG) 1.97, Revision 2, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," December 1980 (ADAMS Accession No. ML060756525), prior to startup following the first refueling outage. By letter dated June 4, 1986 (ADAMS Legacy Accession No. 8606110326), the licensee confirmed the installation or upgrade of all identified equipment required to meet the recommendations of RG 1.97, Revision 2, with the exception of the wide range suppression pool level monitoring system. FSAR Sections 7.5.1.1, "General," and 7.5.2.1, "Design Basis," describe CGS's compliance with RG 1.97, Revision 2.

Table 7.5-1 lists variables monitored, which have been selected using the methodology

- 14 established in RG 1.97. NUREG-0737. and the Emergency Procedure Guidelines (EPG).

• Item 3(c) requires implementation of a wide range suppression pool level monitoring system prior to startup following the second refueling outage. By letter dated June 15.

1987 (ADAMS Legacy Accession No. 8706230291). the licensee confirmed the installation of this equipment. The wide range suppression pool water level instrumentation is described in FSAR Section 7.5.1.5.7. "Suppression Pool Water Level Monitoring."

• Item 4 requires submittal of an addendum to the Procedures Generation Package describing the function and task analysis as identified in NUREG-0737. Supplement No.1. "Clarification of TMI Action Plan Requirements. Requirements for Emergency Response Capability." January 1983 (ADAMS Accession No. ML102560009). within 3 months after issuance of the license. In a letter dated February 17, 1984 (ADAMS Legacy Accession No. 8402230229). the licensee submitted the addendum to the Procedures Generation Package. FSAR Section 7.5.1.22.1, "Description," discusses the interrelationship between the control room instrumentation and the EPG.

• Item 5 requires fully functional emergency response facilities prior to exceeding 5 percent rated power. By letter dated March 22, 1984 (ADAMS Legacy Accession No. 8403270141). the licensee notified the NRC that the required emergency response facilities were functional. The emergency response facilities are described in the Emergency Plan.

The NRC staff concludes that the proposed deletion of item 5 of license condition 2.C.(16) is acceptable As discussed above, all items in Attachment 2 have been completed. In Supplement 5 to NUREG-0892, the NRC stated that license condition 2.C.(16) was satisfied. Therefore, the NRC staff concludes that deletion of license condition 2.C.(16} is acceptable.

Proposed Change to Delete License Condition 2.C.(17)

Current license condition 2.C.(17) states:

(17) Operation with Partial Feedwater Heating (Section 15.1. SER)

The licensee shall not operate with partial feedwater heating for the purpose of extending the normal fuel cycle unless acceptable justification is provided to and approved by NRC staff.

Revised license condition 2.C.(17} would state:

(17) Deleted.

- 15 License condition 2.C.(17) prohibits operation with partial feedwater heating with the purpose of extending the normal fuel cycle unless the licensee provides justification to the NRC and the NRC staff approves the justification.

By letter dated March 1, 1990 (ADAMS Accession No. ML022070491), the NRC issued Amendment No. 77 approving operation with reduced feedwater heating for the purpose of cycle extension. The licensee stated that the NRC's approval of Amendment No. 77 satisfies license condition 2.C.(17). LCS 1.1.6 currently governs operation with feedwater temperature reduction for the purpose of cycle extension.

The NRC staff has reviewed Amendment No. 77 and verified that the requirements of license condition 2.C.(17) are satisfied. The staff concludes that the deletion of license condition 2.C.(17) is acceptable.

Proposed Change to Delete License Condition 2.C.(18)

Current license condition 2.C.(18) states:

(18) Modification of Automatic Depressurization System Logic - Feasibility for Increased Diversity for Some Event Sequences (lI.K.3.18. Section 6.3.5.

SER. SSER #4)

Prior to startup following the first refueling outage, the licensee shall:

(a) Install modifications to the Automatic Depressurization System acceptable to the NRC; and (b) Incorporate into the Plant Emergency Procedures the usage of the inhibit switch.

Revised license condition 2.C.(18) would state:

(18) Deleted.

This license condition required installation of modifications to the automatic depressurization system (ADS) which are acceptable to the NRC, and incorporation of the use of the inhibit switch into emergency procedures. This condition was required to be satisfied prior to startup following the first refueling outage.

The licensee submitted the proposed modification of the ADS to the NRC, and committed to modify the ADS logic to bypass the high drywell pressure trip portion of the existing ADS logic and add a manually operated inhibit switch. In Supplement 4 to NUREG-0892, in which the NRC discussed the acceptability of the proposed modification, the licensee installed the ADS inhibit switches in 1985 and the appropriate emergency procedures were revised. To reflect the installation, NRC Inspection Report 50-397-88-45 dated February 13, 1989 (ADAMS Legacy Accession No. 8902280413), confirmed that the necessary procedures were revised as required. The inspection report stated, "The licensee revised applicable emergency procedures

- 16 to specify the use of the ADS inhibit switch for A TWS events and the ADS 105-second timer reset button as needed for LOCA events." The NRC staff concluded that this item was closed.

Therefore, the NRC staff concludes that deletion of license condition 2.C.(18) is acceptable.

The ADS logic is described in FSAR Section 7.3.1.2.1, "Engineered Safety Feature Systems Instrumentation and Controls," Table 7.3-2, and Figure 7.3-5. The ADS inhibit is described in FSAR Section 7.3.1.1.1.2, "Automatic Depressurization System."

Proposed Change to Delete License Condition 2.C.(19)

Current license condition 2.C.(19) states:

(19) Relocation of Engine-Mounted Controls (Section 9.5.4.1, SER. SSER #4)

Prior to startup following the first refueling outage, the controls and monitoring instrumentation .on the HPCS diesel engine skid shall be installed in a freestanding floor mounted panel separate from the engine skid. The controls and monitoring instrumentation shall be located in a vibration free floor area or shall be qualified for the vibrations that will occur during engine operation.

Revised license condition 2.C.(19) would state:

(19) Deleted.

License condition 2.C.(19) required installation of the controls and monitoring instrumentation for the high pressure core spray (HPCS) diesel engine in a freestanding floor mounted panel separate from the engine skid with a location in a vibration-free floor area or qualification of the instrumentation for vibration that will occur during engine operation. The licensee was required to satisfy this condition prior to startup following the first refueling outage.

By letter dated June 3, 1986 (ADAMS Legacy Accession No. 8606090199), the licensee described the modification that it had completed along with the qualification of the controls and instrumentation for vibration levels that occur during engine operation and stated that license condition 2.C.(19) was satisfied. CGS FSAR Section 8.3.1.1.7.2.10, "Instrumentation and Control System," discusses the qualification of HPCS diesel generator control and monitoring instruments located on the diesel generator skid.

The NRC staff has reviewed the FSAR and verified the completion of the installation required by the license condition 2.C.(19). Therefore, the NRC staff concludes that the proposed deletion of license condition 2.C.(19) is acceptable.

- 17 Proposed Change to Delete License Condition 2.C.(2Q)

Current license condition 2.C.(20) states:

(20) Emergency Diesel Engine Starting System (Section 9.5.6. SER, SSER#4)

Prior to startup following the first refueling outage, air dryers shall be installed in the diesel engine air starting system.

Revised license condition 2.C.(20) would state:

(20) Deleted.

This license condition requires installation of air dryers in the diesel engine air starting system.

This installation was required to be completed prior to startup following the first refueling outage.

By letter dated June 3, 1986 (ADAMS Legacy Accession No. 8606090390), the licensee confirmed completion of the installation of the air dryers. NRC Inspection Report 50-397 11 dated July 25, 1986 (ADAMS Legacy Accession No. 8608220314), documented the NRC review of the design change package for addition of diesel starting air system air dryers. The NRC staff concludes that this license condition has been satisfied. The diesel starting air system air dryers are described in FSAR Section 9.5.6.2, "System Description." Therefore, the NRC staff concludes that deletion of license condition 2.C.(20) is acceptable.

Proposed Change to Delete License Condition 2.C.(21)

Current license condition 2.C.(21) states:

(21) Control Room Chillers Installation (Section 9.4.1. SER, SSER #4)

The licensee shall have operable before May 31, 1984, redundant, seismic Category I environmentally qualified water chillers for control room HVAC.

Revised license condition 2.C.(21) would state:

(21) Deleted.

This license condition requires redundant, seismic Category I, environmentally qualified chillers for the control room HVAC to be operable. This condition was required to be satisfied prior to May 31,1984.

By letter dated May 31! 1984 (ADAMS Legacy Accession No. 8406130150), the licensee confirmed that this license condition has been satisfied. NRC Inspection Report 50-397-90-05 dated August 1! 1989 (ADAMS Legacy Accession No. 9008270010), documented that the chillers had been installed as required. Therefore, this license condition has been satisfied.

- 18 The control room chillers are described in FSAR Sections 9.4.1.2.1, "Main Control Room," and 9.4.1.3.1, "Main Control Room." The NRC staff concludes that deletion of license condition 2.C.(21) is acceptable.

Proposed Change to Delete License Condition 2.C.(22)

Current license condition 2.C.(22) states:

(22) Control Systems Failures (Sections 7.7.2.1.7.7.2.2.7.5.2.3. SER, SSER #4)

Prior to startup following the first refueling outage, the licensee shall provide to NRC staff for review and approval any analysis or modifications needed to resolve the following items.

(a) capability to attain a safe shutdown condition following the loss of any Class 1E instrument bus (b) the impact of control systems failures resulting from high energy line breaks on the transient and accident analyses (c) the impact of control systems failures due to the failure of common power sources, sensors, or instrument sensing lines on the transient analyses.

Revised license condition 2.C.(22) would state:

(22) Deleted.

This license condition requires NRC review and approval of analysis or modifications needed to address the following items related to control system failures: (a) capability to attain a safe shutdown condition following the loss of any Class 1E instrument bus, (b) the impact of control system failures resulting from high energy line breaks (HELB) on the transient and accident analysis, and (c) the impact of control system failures due to the failure of common power sources, sensors, or instrument sensing lines on the transient analysis. This condition was required to be satisfied prior to startup following the first refueling outage.

By letters dated June 24 and November 10, 1983 (ADAMS Legacy Accession Nos. 8307050004 and 8311210360, respectively), the licensee submitted the required reports. For item (a), the analysis concluded there were no situations where a single bus power failure would prevent plant personnel from achieving a reactor cold shutdown condition. For item (b), the analysis concluded that the consequences of the worst case combination of control system failures due to a HELB were a small fraction of 10 CFR 100 guidelines. For item (c), the analysis concluded there were no new transient category events postulated as a result of common sensor failures.

By letter dated January 6, 1986 (ADAMS Legacy Accession No. 8601130588), the NRC staff documented that the required items were resolved and that the resolution was acceptable.

Therefore, the NRC staff concludes that deletion of license condition 2.C.(22) is acceptable.

- 19 Proposed Change to Delete License Condition 2.C.(23)

Current license condition 2.C.(23) states:

(23) Hydrodynamic Loads (Section 3.9.3.1 SER, SSER#4)

Prior to exceeding five (5) percent of rated thermal power, the licensee shall provide for NRC staff review and approval the results of the reconciliation of the hydrodynamic loads for all the safety-related piping, equipment and their supports.

Revised license condition 2.C.(23) would state:

(23) Deleted.

This license condition requires NRC review and approval of the results of the reconciliation of the hydrodynamic loads for all the safety-related piping, equipment, and their supports. This qualification was required to be completed prior to exceeding 5 percent rated power.

By letters dated March 28, 1983, June 16, 1983, and January 24, 1984 (ADAMS Legacy Accession Nos. 8304060279, 8306280596, and 8401310376, respectively), the licensee provided the results of the reconciliation of the hydrodynamic loads for all affected safety-related piping components and equipment and their supports. In Supplement 5 to NUREG-0892, dated April 1984, the NRC stated that based upon the information submitted the license condition 2.C.(23) was satisfied. FSAR Appendix 3A contains the Plant Design Assessment Report (DAR) which describes the CGS load definition, load application, load combination, and design margins for hydrodynamic loading conditions. The DAR specifies the CGS position for each of the pool dynamic loads. The CGS positions were discussed, reviewed and approved by the NRC in the Supplement 5 to NUREG-0892. Therefore, he NRC staff concludes that deletion of license condition 2.C.(23) is acceptable.

Proposed Change to Delete License Condition 2.C.(24)

Current license condition 2.C.(24) states:

(24) Emergency Planning Program (Section 13.3. SER, SSER #4)

Prior to exceeding five (5) percent of rated thermal power, functionally specific training in emergency response duties must be provided to the remaining members of the emergency organization staff who were not included in previous emergency preparedness training specified in the minimum staffing requirements of Table B-1 of NUREG-0654 (including on-shift and 30 and 60 minute augmentation capability).

- 20 Revised license condition 2.C.(24) would state:

(24) Deleted.

This license condition requires that emergency response duty training be provided to the remaining members of the emergency organization staff who were not included in previous training. This training was required to be completed prior to exceeding 5 percent rated power.

By letter dated March 19, 1984 (ADAMS Legacy Accession No. 8403260006), the licensee confirmed the completion of the required training. In Supplement 5 to NUREG-0892, the NRC staff stated that, based upon the information submitted by the licensee, this license condition was satisfied. Therefore, the NRC staff concludes that deletion of license condition 2.C.(24) is acceptable.

Proposed Change to Delete License Condition 2.C.(25)

Current license condition 2.C.(25) states:

(25) Offsite Emergency Preparedness (Section 13.3, SSER #4)

Prior to exceeding five (5) percent of rated thermal power, the licensee shall certify to the-NRC that:

(1) The distribution of tone alert radios, which are part of the alert and notification system, has been completed to residents within the plume exposure pathway Emergency Planning Zone (EPZ).

(2) The distribution of public information brochures has been completed to the population within the plume exposure pathway EPZ.

Revised license condition 2.C.(25) would state:

(25) Deleted.

This license condition requires certification to the NRC that the distribution of tone alert radios and public information brochures has been completed. This distribution was to be completed prior to exceeding 5 percent rated power.

By letter dated February 3, 1984 (ADAMS Legacy Accession No. 8402130002), the licensee confirmed that the distribution of tone alert radios and brochures was complete. NRC Inspection Report 50-397-84-05 dated March 16, 1984 (ADAMS Legacy Accession No. 8404050251), reviewed the Benton County distribution records and identified this item as "Closed". In Supplement 5 to NUREG-0892, the NRC stated that this license condition was satisfied. Therefore, the NRC staff concludes that deletion of the license condition 2.C.(25) is acceptable.

- 21 Proposed Change to Delete License Condition 2.C.(26)

Current license condition 2.C.(26) states:

(26) Progress of Offsite Emergency Preparedness (Appendix DJ SER)

In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 C.F.R Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of preparedness, the provisions of 10 C.F.R Section 50.54(s)(2) will apply.

Revised license condition 2.C.(26) would state:

(26) Deleted.

The licensee stated that this license condition is historical, claiming that in Supplement 4 to NUREG-0892, the NRC concluded that the state of onsite and offsite emergency preparedness provided reasonable assurance that adequate protective measures could and would be taken in the event of a radiological emergency.

NUREG-0892, "Safety Evaluation Report Related to the Operation of WPPSS Nuclear Project No.2," dated March 1982, states in Section 13.3 that Offsite State and local entities had not yet submitted their plans to NRC because they were still being reviewed by the Federal Emergency Management Agency (FEMA) and that a finding relative to the state of offsite emergency preparedness for the licensee and related emergency planning zones would be made in a future supplement to the document.

The Conclusions section of Appendix D to NUREG-0892 states that:

After receiving the findings and determinations made by FEMA on state and local emergency response plans, a supplement to this report will provide the staff's overall conclusions on the status of emergency preparedness for the WNP-2 plant and related emergency planning zones.

Section 13.3.1 of Supplement 4 to NUREG-0892, dated December 1983, states that:

On August 10, 1983, the Federal Emergency Management Agency (FEMA) provided an overall finding to the NRC on the adequacy of offsite emergency preparedness for WNP-2.

Section 13.3.3 of Supplement 4 to NUREG-0892 states that:

FEMA's overall finding is that the state and local radiological emergency plans and preparedness for WNP-2 are adequate.

- 22 Section 13.3.4 of Supplement 4 to NUREG-0892 states that:

On the basis of its review of the applicant's emergency plan and procedures and on a review of the FEMA evaluation of state and local emergency plans, the staff concludes that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

The licensee also justifies the deletion of license condition 2.C.(26) by pointing out that the provisions of 10 CFR 50.54 are conditions applicable to every nuclear power reactor operating license issued under 10 CFR Part 50.

Based upon this analysis and the licensee's justification, the NRC staff concludes that license condition 2.C.(26) meets the conclusions of Section 13.3.4 of Supplement 4 to NUREG-0892.

Therefore, the NRC staff concludes that deletion of license condition 2.C.(26) is acceptable.

Proposed Change to Delete license Condition 2.C.(27)

Current license condition 2.C.(27) states:

(27) Effluent Radiation Monitors (Section 11.5, SSER #4)

Prior to July 1, 1984, the licensee shall provide the following information to the NRC staff for their review and approval:

1. Sensitivity of the effluent monitors.

2. Evaluation of response times of these instruments.

3. Evaluation of the instruments per criteria set forth in Section 5.4.7 of ANSI 13.10.

4. Compliance with Section 5.4.9 of ANSI 13.10.

5. Evaluation of capability to provide a calibrated electrical Signal to verify circuit alignment and, if used, a commitment, that they be qualified.

Revised license condition 2.C.(27) would state:

(27) Deleted.

This license condition requires NRC review and approval of information related to the effluent radiation monitors. This condition was required to be satisfied prior to exceeding 5 percent rated power.

- 23 By letter dated June 29,1984 (ADAMS Legacy Accession No. 8407100290), the licensee submitted the required information. NRC Inspection Report 50-397-84-20 dated August 24, 1984 (ADAMS Legacy Accession No. 8409130440), discussed the NRC review of the information and confirmed that there were no items of noncompliance. The NRC staff concludes that deletion of license condition 2.C.(27) is acceptable.

Proposed Change to Delete License Condition 2.C.(28)

Current license condition 2.C.(28) states:

(28) Environmental Qualifications (Section 3.11! SER, SSER #3. SSER #4)

Prior to November 30, 1985, the licensee shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49.

Revised license condition 2.C.(28) would state:

(28) Deleted.

This license condition requires the environmental qualification of all electrical equipment in accordance with 10 CFR 50.49. This qualification was required to be completed prior to November 30,1985.

By letter dated December 30, 1985 (ADAMS Legacy Accession No. 8601060055). the licensee confirmed the environmental qualification of required equipment was completed by November 30, 1985. In Supplement 5 to NUREG-0892, the NRC stated that license condition 2.C.(28) was satisfied. FSAR Section 3.11, "Environmental Design of Mechanical and Electrical Equipment," documents the CGS environmental qualification. The NRC staff concludes that deletion of license condition 2.C.(28) is acceptable.

Proposed Change to Delete License Condition 2.C.{3Q) and Appendix C Current license condition 2.C.(30) states:

(30) Additional Concerns The Additional Concerns contained in Appendix C, as revised through Amendment No. 153, are hereby incorporated into this license. Energy Northwest shall operate the facility in accordance with the Additional Concerns.

Revised license condition 2.C.(30) would state:

(30) Deleted.

License condition 2.C.(30) referenced four additional conditions (or concerns) contained in Appendix C and requires operation of the facility in accordance with the stated conditions.

- 24 The first additional condition is associated with Amendment No. 149 dated March 4, 1997 (ADAMS Accession No. ML022120577), and requires the relocation of certain TS requirements to licensee-controlled documents. This requirement arose for conversion of TS to Improved Technical Specifications (ITS). NRC Inspection Report 50-397-97-05 dated May 6, 1997 (ADAMS Legacy Accession No. 9705120268), documented the completion of these actions, and concludes that this condition has been satisfied. The NRC staff concludes that deletion of this condition is acceptable.

The second additional condition, which is also associated with Amendment No. 149, required implementation of commitment from Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The licensee was required to complete this condition 90 days from issuance of Amendment No. 149, which was issued on March 4, 1997. As part of the change to remove the provisions for accelerated testing of diesel generators from the TS, the licensee committed to implement a maintenance program for monitoring and maintaining diesel generator performance in accordance with the provisions of the maintenance rule and consistent with the guidance of RG 1.160. The NRC Inspection Report 50-397-96-18 dated January 29, 1997 (ADAMS Legacy Accession No. 9702030189), evaluated CGS's implementation of the maintenance rule. The NRC staff concludes that this condition was satisfied. Therefore, the NRC staff concludes that the deletion of this condition is acceptable.

The NRC staff has reviewed applicable documentation and has verified the completion of the second additional condition of Appendix C. The staff concludes the proposed deletion of second Additional Condition of Appendix C is acceptable.

The third license condition is associated with Amendment No. 151 dated June 3, 1997 (ADAMS Accession No. ML022120562). It required that the calculation of delta-CPR include the application of a conservative adder. This action was required to be completed prior to exceeding 25 percent rated power for Cycle 13.

This action was completed as required and is no longer applicable. NRC Inspection Report 50-397-98-01, dated May 8, 1998 (ADAMS Legacy Accession No. 9805140317),

addressed the required conservative adder condition applied to Cycle 13. The NRC inspection report stated, Because of the determination by the NRC inspectors that the OLMCPR and SLMCPR were non conservative, the licensee submitted a technical specification amendment request for Cycle 13 to set the SLMCPR at 1.13 for the SPC fuel in Cycle 13. This represented a significant change from the previous limits of 1.07 for Core Cycles 7-12. The new limit was determined by the application of a conservative multiplier applied to the methodology and the Cycle 13 benchmark calculations. The OLMCPRs were changed accordingly and the amendment was approved, allowing startup of the unit.

The NRC staff reviewed the licensee's submittal, related documentation (e.g., TS, FSAR), and the documentation supporting NRC's acceptance of the licensee's response to the subject license condition, as referenced above. The staff has determined that the licensee has satisfied

- 25 the requirements of these license conditions in an acceptable manner and hence, the subject license conditions are not required. The NRC staff, therefore, concludes that the proposed deletion of this license condition is acceptable.

The fourth additional condition required the incorporation of information into the CGS FSAR resulting from the issuance of Amendment No. 153 dated May 21, 1998 (ADAMS Accession No. ML022130398), regarding suppression pool strainer screen material. The licensee was required to complete this condition 90 days from issuance of Amendment No. 153, which was issued on May 21, 1998. The relevant discussion of this additional condition is contained in CGS FSAR Section 6.1.1.1.3(c), "Controls for Austenitic Stainless SteeL" The NRC staff has reviewed referenced documents and has verified the completion of the fourth additional condition of Appendix C. The staff concludes the proposed deletion of fourth additional condition of Appendix C is acceptable.

Proposed Change to Appendix B The Environmental Protection Plan for CGS contains a reference to 10 CFR 51.5(b)(2) of the National Environmental Policy Act. The licensee proposed to delete the reference from Appendix B.

The regulations in 10 CFR Part 51 were revised effective June 7, 1984 to implement Section 102(2) of the National Environmental Policy Act of 1969, as amended, and 10 CFR 51.5(b)(2) was deleted. The NRC staff concludes that the proposed deletion is acceptable.

NRC Staff Conclusion The NRC staff has reviewed the licensee's application and concludes that, with the implementation of the approved changes, the applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained. The NRC staff concludes that the deletions and modifications of the requested license conditions are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Washington State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumUlative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no

- 26 significant hazards consideration and there has been no public comment on such finding published in the Federal Register on May 31,2011 (76 FR 31372). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22{c){9).

Pursuant to 10 CFR 51.22{b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1)there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: M. Thadani M. Razzaque J. Anderson M. Levine Date: March 30, 2012

' ML120800078 "SE memo dated OFFICE NRR/DORULPL4/PM NRR/LPL4/LA NRRlDSS/SRXB/BC NRR/DSS/SBPB/BC NAME $adani JBurkhardt AUlses* GCasto" 112 3/23/12 10/14/11 10/27/11 IffiEICE NSIRIDPRIORLOB/BC OGC NLO NRR/DORULPL4/BC NRR/DORULPL4/PM II MMarkley (NKalyanam INAME JAnderson" LSubin for) MThadani DATE 10/31/11 3128112 3130112 3/29/12