Text

CFR 50.71 Maintenance of Records Licensing Basis Document Update and Biennial Commitment Change Report
	ML15355A480
Person / Time
Site:	Columbia
Issue date:	12/21/2015
From:	Hettel W; Energy Northwest
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15356A148	List: GO2-15-159, Final Safety Analysis Report, Amendment 63, Appendix a - Supplement Aging Management Programs and Activities Credited for Columbia License Renewal; ML15355A480; ML15355A481; ML15355A486; ML15355A487; ML15355A488; ML15355A489; ML15355A490; ML15355A496; ML15355A497; ML15355A498; ML15355A499; ML15355A500; ML15355A507; ML15355A508; ML15355A509; ML15355A510; ML15355A511; ML15355A512; ML15355A515;
References
	GO2-15-159
	Download: ML15355A480 (11)
	v • d • e

William G. Hettel Vice President, Operations P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-8311 F. 509-377-4674 wghettel@energy-northwest.com 10 CFR 50.71(e)

December 21, 2015 GO2-15-159 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397, 10 CFR 50.71 MAINTENANCE OF RECORDS LICENSING BASIS DOCUMENT UPDATE AND BIENNIAL COMMITMENT CHANGE REPORT

Reference:

Letter, GO2-15-165, W.G. Hettel (Energy Northwest) to NRC, 10 CFR 50.71 Maintenance of Records Non Public Version of the Final Safety Analysis Report (FSAR)

Dear Sir or Madam:

In accordance with the requirements of 10 CFR 50.71(e), Energy Northwest hereby submits the following updated Columbia Generating Station (Columbia) Licensing Basis Documents:

Final Safety Analysis Report (FSAR), Amendment 63 (publicly available)

Technical Specification Bases (TSB), Revision 87 Licensee Controlled Specifications (LCS), Revision 87 Operational Quality Assurance Program Description (OQAPD), Revision 48 In addition to other changes, FSAR Amendment 63 removes some redundant information and excessive detail from the FSAR to improve its focus and clarity. In accordance with NEI 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, as endorsed by Regulatory Guide 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e), a brief description of the information removed is provided in Attachment 1.

contains the Columbia Generating Station 2014 - 2015 Commitment Change Report. This report is submitted pursuant to NEI 99-04, Guidelines for Managing NRC Commitment Changes.

G02-15-159 Page 2 The Columbia License Basis Documents are provided in electronic format in Attachments 4 and 5. The files are in the Portable Document Format (PDF). contains a listing of the individual document component filenames comprising Attachments 4 and 5. The files have been sized to meet file size limitations for electronic submittals. Additionally, the PDF files in Attachment 5 contain hyperlinks.

These hyperlinks are not essential to the FSAR content and are disabled.

Consistent with Energy Northwest's past FSAR submittals, Energy Northwest is providing a publicly available version of the FSAR (Attachment 5) in which information previously considered to be "sensitive unclassified (non-safeguards) information" has been removed. Energy Northwest recognizes that a draft Regulatory Issue Summary (RIS) has been issued addressing the public availability of FSAR information and is currently evaluating the impact to future FSAR biennial submittals. A list of information removed from the FSAR submittal is contained in Attachment 6. A complete copy of the FSAR is submitted under separate cover.

There are no commitments being made to the NRC by this letter; however, two existing commitments have been changed as described in Attachment 2.

If you have any questions or desire additional information pertaining to this report, please contact Ms. L.L. Williams, Licensing Supervisor, at (509)377-8148.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 1 z I /11

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Attachment:

1.

Redundant Information and Excessive Detail Removed from the FSAR

2.

Regulatory Commitment Changes (NEI 99-04 Process)

3.

Document Components

4.

Technical Specification Bases, Revision 87 Licensee Controlled Specifications, Revision 87 Operational Quality Assurance Program Description, Revision 48

5.

Columbia Generating Station FSAR, Amendment 63, Publicly Available

6.

Information withheld from Columbia Generating Station FSAR, Amendment 63, Publicly Available (Attachment 5) cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident lnspector/988C CD Sonada-BPA/1399 WA Horin - Winston & Strawn

GO2-15-159 Page 1 of 3 Redundant Information and Excessive Detail Removed from the FSAR CHAPTER 1 Section Description of Change Type 1.2.2.9.3 Remove redundant and obsolete language regarding environmental monitor Redundant and obsolete information 1.4.6.5 Deleted information contained in Section 1.4.3.

Excessive and redundant information Table 1.6-1 Delete table.

Obsolete information CHAPTER 3 Section Description of Change Type 3.5.3.4 Removed excessive detail that does not reflect current plant configuration.

Excessive detail 3.9.2.2 Deleted AREVA ATRIUM-10 information.

Obsolete information CHAPTER 4 Section Description of Change Type 4.1.2 Delete AREVA information.

Obsolete information 4.1.4.4 Delete AREVA information.

Obsolete information 4.1.5 Delete AREVA information.

Obsolete information 4.2 Deleted AREVA ATRIUM-10 information.

Obsolete information 4.3 Deleted AREVA ATRIUM-10 information.

Obsolete information 4.4 Deleted AREVA ATRIUM-10 information.

Obsolete information 4.4.2 Remove thermal-hydraulic compatibility report reference. It is redundant to Section 4.4.3.

Redundant information 4.6.1.1.2.4.1 Cooling water pressure reference removed.

Excessive detail

GO2-15-159 Page 2 of 3 CHAPTER 5 Section Description of Change Type 5.2.2 Remove list of reactor kinetics model types Excessive detail Figure 5.2-11 Removed figure not referenced in text. Current reference is Figure 5.2-2.

Obsolete information CHAPTER 6 Section Description of Change Type Reference 6.2-36 Deleted. Not referenced in text.

Obsolete information 6.3 Delete AREVA and other fuel vendor information.

Obsolete information 6.3.3.2 Removed redundant information provided in 6.3.3.6.2 Redundant information 6.3.3.3, 6.3.3.4 Remove redundant single failure discussion previously provided in the same subsection Redundant information Table 6.3.3 Remove excessive detail regarding non-limiting small break Excessive detail CHAPTER 8 Section Description of Change Type Tables 8.3-11, 12, 13, 14; Remove the duty cycles for loads on the batteries.

Not required by Regulatory Guide 1.70. Battery duty cycle totals are still provided on Table 8.3-10.

Excessive detail CHAPTER 11 Section Description of Change Type 11.5.2.2.1.6 Deleted excessive detail and redundant detail concerning initial and continuing radiometric calibration.

Excessive detail and Redundant information Figure 11.5-3 Figure deleted Obsolete information

GO2-15-159 Page 3 of 3 CHAPTER 13 Section Description of Change Type 13.1.1.1 Delete Employee Concerns.

Excessive detail 13.1.1.1 Delete paragraph regarding Training Manager.

Excessive detail 13.1.1.1 13.1.2.2.7 13.1.2.2.7.6 13.1.2.

Redundant to information in 13.2. Delete Construction and Project Management.

Excessive detail and Redundant information 13.1.1.1 Delete information regarding Regulatory Affairs, Organizational Effectiveness, and Training.

Redundant to information in 13.2.

Excessive detail and Redundant information 13.1.1.1 Removed sentence regarding support and refueling operations.

Excessive detail Figure 13.1-1 Delete direct reports to the Chief Executive Officer (CEO) not required by Regulatory Guide 1.70.

Excessive detail Figure 13.1-2 Delete Employee Concerns and Recovery Manager.

Figure 13.1-4 Delete Regulatory Affairs Manager and Organizational Effectiveness Manager.

Figure 13.1-5 Deleted figure depicting Training Organization.

Redundant to information in 13.2.

Figure 13.1-6 Delete Construction and Project Management.

CHAPTER 15 Section Description of Change Type 15.8.7.3.3 Deleted redundant information found in Table 15.8-

3.

Redundant information 15.8.7.4 Deleted redundant information found in Table 15.8-

3.

Redundant information 15.8.9.3.3 Deleted redundant information found in Table 15.8-

3.

Redundant information Figures 15.8-2.4, 15.8-2.5, 15.8-3.1, 15.8-3.2, 15.8-3.3, 15.8-3.4, 15.8-3.5, Deleted figures. Information contained in Figure 15.8-2 series.

Obsolete and redundant information Chapter 15 Deleted definitions of acronyms that were previously defined.

Excessive detail

GO2-15-159 Page 1 of 2 Regulatory Commitment Changes (NEI 99-04 Process)

This section reports changes to regulatory commitments consistent with the information pertaining to Regulatory Commitment Changes (RCC) and is included pursuant to the NEI 99-04 criteria for reporting.

From GO2-90-017 (RCC-110792-01)

The changes proposed are to establish inspection and cleaning as the verification method of appropriate heat transfer capability of all safety related air-to-water heat exchangers cooled by the Service Water system. The intent of the original commitment was to ensure a test program was in place to verify heat transfer capabilities of safety related heat exchangers cooled by the Service Water system. After the response letter for GL 89-13 was submitted, the test program for air-to-water heat exchangers consisted of verifying heat transfer by thermal performance testing of two safety related air-to-water heat exchangers that were determined to be representative samples for each loop of Service Water at Columbia Generating Station. Air side and water side differential pressure testing were also performed for each air-to-water heat exchanger.

Additionally, cleanliness inspections of the air side of the heat exchangers were also performed to maintain heat transfer capabilities.

The revised commitment performs inspection and cleaning to ensure heat transfer capabilities of the safety related room coolers supplied by the Service Water system are maintained. Columbia will inspect and clean each room cooler on a periodic frequency.

Columbia is performing a project to replace room coolers susceptible to sacrificial anode degradation with anodeless coolers to eliminate a source of macrofouling. Some coolers cannot be replaced at this time, but are being chemically cleaned to remove any current macrofouling and are having new anodes installed. All room coolers will be inspected on a 4-year frequency and the inspection frequency will be extended or reduced based on cooler inspections.

The original commitment stated:

Columbia will perform thermal performance testing of two air-to-water cooling coils as a representative sample of all other cooling coils.

Commitment description has been revised to say:

In lieu of precise thermal performance testing of safety related air-to-water cooling coils supplied by Service Water, Columbia will perform regularly scheduled preventative maintenance and inspections of the water side of all air-to-water Service Water supplied cooling coils to ensure tube and header fouling is not occurring that could affect heat transfer. Frequency of preventative maintenance inspections will be based on trending history of cooler cleanliness and results of water side differential pressure testing."

GO2-15-159 Page 2 of 2 From GO2-07-025 (RCC-256886-1)

The wording of the commitment was ambiguous. When this commitment was implemented, the procedures were revised such that testing in any operating mode required Division 1 and Division 2 electrical buses to be powered from the main generator through the normal transformer (E-TR-N1). Prior to this commitment testing was restricted to Modes 4 and 5. The electrical lineup in Modes 4 and 5 for Division 1 and 2 electrical buses was determined by the Technical Specification requirements for the Mode. This revision to the commitment clarifies that the commitment is applicable for Modes 1, 2, or 3.

The original commitment stated:

Testing of the HPCS system, to meet SRs 3.8.1.11, 3.8.1.12, 3.8.1.16, and 3.8.1.19 as described in this license amendment request will be performed with the HPCS bus (E-SM-4) aligned to the 230 kV offsite power source via the startup transformer (E-TR-S) and the Division 1 and Division 2 electrical buses will be powered from the main generator through the normal transformer (E-TR-N1).

Commitment description has been revised to say:

Testing of the HPCS system, to meet SRs 3.8.1.11, 3.8.1.12, 3.8.1.16, and 3.8.1.19 in Modes 1, 2, or 3 as described in this license amendment request will be performed with the HPCS bus (E-SM-4) aligned to the 230 kV offsite power source via the startup transformer (E-TR-S) and the Division 1 and Division 2 electrical buses will be powered from the main generator through the normal transformer (E-TR-N 1).

GO2-15-159 Page 1 TSB, LCS, OQAPD File Name Description _1 TSB _2 LCS _3 OQAPD FSAR Amendment 63 Publicly Available _1 of 16.pdf General Table of Contents

& List of Effective Pages _2 of 16.pdf Chapter 1 _3 of 16.pdf Chapter 2 _ 4 of 16.pdf Chapter 3 page 3-i to Table 3.5-6 _5 of 16.pdf Chapter 3 Figure 3.5-48 to Table 3.6-16 _6 of 16.pdf Chapter 3 Figure 3.6-21 to Figure 3.12-4 _7 of 16.pdf Chapter 3a _8 of 16.pdf Chapters 4, 5 & 6 _9 of 16.pdf Chapter 7 _10 of 16.pdf Chapter 8 _11 of 16.pdf Chapter 9 _12 of 16.pdf Chapters 10 & 11 _13 of 16.pdf Chapter 12 p 12-i to Table 12.3-2 _14 of 16.pdf Chapter 12 Figure 12.3-19 to Table 12.5-1 _15 of 16.pdf Chapters 13, 14, 15 16 & 17 _16 of 16.pdf Appendices A, B, F, I & J

GO2-15-159 Page 1 INFORMATION WITHHELD FROM COLUMBIA GENERATING STATION FSAR AMENDMENT 63, PUBLICLY AVAILABLE (ATTACHMENT 5)

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Figure 3.5-34 Figure 3.6-34.1 Figure 3.6-51.3 Figure 3.2-4 Figure 3.5-35 Figure 3.6-34.2 Figure 3.6-52.1

GO2-15-159 Page 2 INFORMATION WITHHELD FROM COLUMBIA GENERATING STATION FSAR AMENDMENT 63, PUBLICLY AVAILABLE (ATTACHMENT 5)

Drawing or Section Drawing or Section Drawing or Section Drawing or Section Figure 3.6-52.2 Figure 3.8-11 Figure 3A.2.1-1 Figure 3A.5.1-14b Figure 3.6-53.1 Figure 3.8-12 Figure 3A.2.1-2 Figure 3A.5.1-15a Figure 3.6-53.2 Figure 3.8-13 Figure 3A.2.1-3 Figure 3A.5.1-15b Figure 3.6-54.1 Figure 3.8-17 Figure 3A.2.1-4 Figure 3A.5.1-16a Figure 3.6-54.2 Figure 3.8-18 Figure 3A.2.1-5 Figure 3A.5.1-16b Figure 3.6-55.1 Figure 3.8-20 Figure 3A.2.1-6 Figure 3A.5.1-17a Figure 3.6-55.2 Figure 3.8-21 Figure 3A.2.1-7 Figure 3A.5.1-17b Figure 3.6-56.1 Figure 3.8-22 Figure 3A.2.1-8 Figure 3A.5.1-18a Figure 3.6-56.2 Figure 3.8-23 Figure 3A.2.1-9 Figure 3A.5.1-18b Figure 3.6-57.1 Figure 3.8-24 Figure 3A.4.1-5 Figure 3A.5.1-19a Figure 3.6-57.2 Figure 3.8-25 Figure 3A.4.1-6 Figure 3A.5.1-19b Figure 3.6-57.3 Figure 3.8-26 Figure 3A.4.1-7 Figure 3A.5.1-20a Figure 3.6-58 Figure 3.8-27 Figure 3A.4.2-1 Figure 3A.5.1-20b Figure 3.6-59 Figure 3.8-28 Figure 3A.4.2-3 Figure 3A.5.1-21a Figure 3.6-60.1 Figure 3.8-29 Figure 3A.5.1-1b Figure 3A.5.1-21b Figure 3.6-60.2 Figure 3.8-30 Figure 3A.5.1-2 Figure 3A.5.1-22a Figure 3.6-65 Figure 3.8-31 Figure 3A.5.1-3a Figure 3A.5.1-22b Figure 3.6-66 Figure 3.8-32 Figure 3A.5.1-3b Figure 3A.5.1-23a Figure 3.6-85 Figure 3.8-33 Figure 3A.5.1-4a Figure 3A.5.1-23b Figure 3.6-86 Figure 3.8-34 Figure 3A.5.1-4b Figure 3A.5.1-24a Figure 3.6-87 Figure 3.8-35 Figure 3A.5.1-5a Figure 3A.5.1-24b Figure 3.6-88 Figure 3.8-36 Figure 3A.5.1-5b Figure 3A.5.1-25a Figure 3.6-92.1 Figure 3.8-37 Figure 3A.5.1-6a Figure 3A.5.1-25b Figure 3.6-92.2 Figure 3.8-38 Figure 3A.5.1-6b Figure 3A.5.1-26a Figure 3.6-92.3 Figure 3.8-39 Figure 3A.5.1-7a Figure 3A.5.1-26b Figure 3.6-93 Figure 3.8-40 Figure 3A.5.1-7b Figure 3A.5.2-1 Figure 3.6-94.1 Figure 3.8-41 Figure 3A.5.1-8a Figure 3A.5.2-2 Figure 3.6-94.2 Figure 3.8-42 Figure 3A.5.1-8b Figure 3A.5.2-3 Figure 3.6-95 Figure 3.8-43 Figure 3A.5.1-9a Figure 3A.5.2-4 Section 3.8.4 Figure 3.8-44 Figure 3A.5.1-9b Figure 3A.5.2-5 Figure 3.8-1 Figure 3.8-45 Figure 3A.5.1-10a Figure 3A.5.2-6 Figure 3.8-2 Figure 3.8-46 Figure 3A.5.1-10b Figure 3A.5.2-7 Figure 3.8-3 Figure 3.8-47 Figure 3A.5.1-11a Figure 3A.5.2-8 Figure 3.8-4.1 Figure 3.8-48 Figure 3A.5.1-11b Figure 3A.5.2-9 Figure 3.8-4.2 Figure 3.8-49 Figure 3A.5.1-12a Figure 3A.5.2-10 Figure 3.8-6 Figure 3.8-50 Figure 3A.5.1-12b Figure 3A.D-11 Figure 3.8-7 Figure 3.8-51 Figure 3A.5.1-13a Figure 3A.I-1 Figure 3.8-8 Figure 3.8-52 Figure 3A.5.1-13b Figure 4.6-4 Figure 3.8-10 Figure 3.8-53 Figure 3A.5.1-14a Figure 5.4-15.3

GO2-15-159 Page 3 INFORMATION WITHHELD FROM COLUMBIA GENERATING STATION FSAR AMENDMENT 63, PUBLICLY AVAILABLE (ATTACHMENT 5)

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