GO2-17-181, License Amendment Request to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements

License Amendment Request to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements

ML17346B280
Person / Time
Site:	Columbia
Issue date:	12/12/2017
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-17-181, TSTF-551
Download: ML17346B280 (13)

Text

Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.2354 aljavorik@energy-northwest.com December 12, 2017 GO2-17-181 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-551, "REVISE SECONDARY CONTAINMENT SURVEILLANCE REQUIREMENTS"

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station.

The proposed change revises TS 3.6.4.1, "Secondary Containment," Surveillance Requirement (SR) 3.6.4.1.1. The SR is revised to address conditions during which the secondary containment pressure may not meet the SR pressure requirements. In addition, SR 3.6.4.1.3 is modified to acknowledge that secondary containment access openings may be open for entry and exit. provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only.

Approval of the proposed amendment is requested one year from the date of this letter.

Once approved, the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington Official.

If you should have any questions regarding this submittal, please contact Ms. L. L.

Williams, Licensing Supervisor, at 509-377-8148.

G02-17-181 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed this 12 "('It, day of December, 2017.

A L. Javorik Vice President, Engineering Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases Changes (Mark-Up) -

Information Only cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident lnspector/988C CD Sonoda - BPA/1399 (email)

EFSECutc.wa.gov - EFSEC (email)

RR Cowley - WDOH (email)

WA Horin - Winston & Strawn

GO2-17-181 Page 1 of 4 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises Technical Specification (TS) 3.6.4.1, "Secondary Containment," Surveillance Requirement (SR) 3.6.4.1.1. The SR is revised to allow conditions during which the secondary containment pressure may not meet the SR pressure requirements. In addition, SR 3.6.4.1.3 is modified to acknowledge that secondary containment access openings may be open for entry and exit.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Energy Northwest has reviewed the safety evaluation for TSTF-551 provided to the Technical Specifications Task Force in a letter dated September 21, 2017. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-551. Energy Northwest has concluded that the justifications presented in TSTF-551 and the safety evaluation prepared by the NRC staff are applicable to Columbia Generating Station (Columbia) and justify this amendment for the incorporation of the changes to the Columbia TS.

The radiological consequence analysis for Columbia was approved by the NRC on November 27, 2006 (Accession No. ML062610440), and is documented in FSAR Section 15.6.5. Energy Northwest has confirmed that the brief, inadvertent, simultaneous opening of both an inner and outer personnel access door during normal entry and exit conditions, and their prompt closure by normal means, is bounded by the radiological dose consequence analysis. In the unlikely event that an accident would occur when both personnel access doors are open for entry or exit, the brief time required to close one of the doors is small compared to the 1200 seconds assumed in the accident analysis for reducing the post-accident secondary containment pressure to 0.25 inch of vacuum water gauge, and will not result in an increase in any onsite or offsite dose. Although, the Standby Gas Treatment (SGT) System is not required to draw down secondary containment until the time stated in SR 3.6.4.1.4, the average time it takes SGT System to draw down secondary containment at Columbia when tested for SR 3.6.4.1.4 is 44.9 seconds.

2.2 Variations Energy Northwest is proposing the following variations from the TS changes described in the TSTF-551 or the applicable parts of the NRC staffs safety evaluation. These variations do not affect the applicability of TSTF-551 or the NRC staff's safety evaluation to the proposed license amendment.

GO2-17-181 Page 2 of 4 The Columbia TS wording for SR 3.6.4.1.3 is different than NUREG-1433. The Columbia SR 3.6.4.1.3 states: Verify each secondary containment access inner door or each secondary containment access outer door in each access opening is closed compared with the NUREG-1433 wording: Verify one [secondary] containment access door in each access opening is closed. Both wordings are functionally equivalent, so applying the TSTF-551 exception is an administrative variation.

The Columbia TS wording for SR 3.6.4.1.4 is different than NUREG-1433. The Columbia SR 3.6.4.1.4 states: Verify each standby gas treatment (SGT) subsystem will draw down the secondary containment to 0.25 inch of vacuum water gauge in 120 seconds compared with the NUREG-1433 wording: [Verify [secondary]

containment can be drawn down to [0.25] inch of vacuum water gauge in [120]

seconds using one standby gas treatment (SGT)subsystem. Both wordings are functionally equivalent, so applying the TSTF-551 exception is an administrative variation.

The NUREG-1433 TS 3.6.4.1 APPLICABILITY (for which the as-modified SRs are required) includes During the movement of [recently] irradiated fuel assemblies in the

[secondary] containment. Similarly Section 3.2.2 of the TSTF-551 Model Safety Evaluation describes the effects of TSTF-551 on the radiological dose consequences of the Fuel Handling Accident (FHA). However, with License Amendment 199, the requirement for Secondary Containment operability during the movement of irradiated fuel was removed from the Columbia TS. Since this previous license amendment does not invalidate any of the conclusions of the TSTF-551 Safety Evaluation, this is considered to be an administrative variation.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Analysis Energy Northwest requests adoption of TSTF-551, "Revise Secondary Containment Surveillance Requirements," which is an approved change to the standard technical specifications (STS), into the Columbia Generating Station Technical Specifications (TS). The proposed change revises Technical Specification (TS) Surveillance Requirement (SR) 3.6.4.1.1. The SR is revised to permit conditions during which the secondary containment may not meet the SR acceptance criterion for a period of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if an analysis demonstrates that one standby gas treatment (SGT) subsystem remains capable of establishing the required secondary containment vacuum. In addition, SR 3.6.4.1.3 is modified to acknowledge that secondary containment access openings may be open for entry and exit.

Energy Northwest has evaluated the proposed change against the criteria of 10 CFR 50.92(c) to determine if the proposed change results in any significant hazards.

The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

GO2-17-181 Page 3 of 4

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change addresses conditions during which the secondary containment SRs are not met. The secondary containment is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not increased. The consequences of an accident previously evaluated while utilizing the proposed changes are no different than the consequences of an accident while utilizing the existing four hour Completion Time for an inoperable secondary containment. In addition, the proposed Note for SR 3.6.4.1.1 provides an alternative means to ensure the secondary containment safety function is met. As a result, the consequences of an accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change does not alter the protection system design, create new failure modes, or change any modes of operation. The proposed change does not involve a physical alteration of the plant; and no new or different kind of equipment will be installed. Consequently, there are no new initiators that could result in a new or different kind of accident.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change addresses conditions during which the secondary containment SRs are not met. Conditions in which the secondary containment vacuum is less than the required vacuum are acceptable provided the conditions do not affect the ability of the SGT System to establish the required secondary containment vacuum under post-accident conditions within the time assumed in the accident analysis. This condition is incorporated in the proposed change by requiring an analysis of actual environmental and secondary containment pressure conditions to confirm the capability of the SGT System is maintained within the assumptions of the accident analysis. Therefore, the safety function of

GO2-17-181 Page 4 of 4 the secondary containment is not affected. The allowance for both an inner and outer secondary containment door to be open simultaneously for entry and exit does not affect the safety function of the secondary containment as the doors are promptly closed after entry or exit, thereby restoring the secondary containment boundary.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Energy Northwest concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusions In conclusion, based on the considerations discussed above, (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 Commissions 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.

4.0 ENVIRONMENTAL EVALUATION The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

GO2-17-181 Attachment 2 Proposed Technical Specification Changes (Mark-Up)

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 --------------------------NOTE--------------------------------

Not required to be met for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if analysis demonstrates one standby gas treatment (SGT) subsystem is capable of establishing the required secondary containment vacuum.

Verify secondary containment vacuum is 0.25 inch In accordance of vacuum water gauge. with the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify all secondary containment equipment hatches In accordance are closed and sealed. with the Surveillance Frequency Control Program SR 3.6.4.1.3 Verify each secondary containment access inner In accordance door or each secondary containment access outer with the door in each access opening is closed, except when Surveillance the access opening is being used for entry and exit. Frequency Control Program SR 3.6.4.1.4 Verify each standby gas treatment (SGT) subsystem In accordance will draw down the secondary containment to with the 0.25 inch of vacuum water gauge in Surveillance 120 seconds. Frequency Control Program SR 3.6.4.1.5 Verify each SGT subsystem can maintain In accordance 0.25 inch of vacuum water gauge in the secondary with the containment for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate 2240 cfm. Surveillance Frequency Control Program Columbia Generating Station 3.6.4.1-2 Amendment No. 169,199 225 238

GO2-17-181 Attachment 3 Revised Technical Specification Pages

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 --------------------------NOTE--------------------------------

Not required to be met for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if analysis demonstrates one standby gas treatment (SGT) subsystem is capable of establishing the required secondary containment vacuum.

Verify secondary containment vacuum is 0.25 inch In accordance of vacuum water gauge. with the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify all secondary containment equipment hatches In accordance are closed and sealed. with the Surveillance Frequency Control Program SR 3.6.4.1.3 Verify each secondary containment access inner In accordance door or each secondary containment access outer with the door in each access opening is closed, except when Surveillance the access opening is being used for entry and exit. Frequency Control Program SR 3.6.4.1.4 Verify each SGT subsystem will draw down the In accordance secondary containment to 0.25 inch of vacuum with the water gauge in 120 seconds. Surveillance Frequency Control Program SR 3.6.4.1.5 Verify each SGT subsystem can maintain In accordance 0.25 inch of vacuum water gauge in the secondary with the containment for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate 2240 cfm. Surveillance Frequency Control Program Columbia Generating Station 3.6.4.1-2 Amendment No. 169,199 225 238

GO2-17-181 Attachment 4 Proposed Technical Specification Bases Changes (Mark-Up) - Information Only

Secondary Containment B 3.6.4.1 BASES SURVEILLANCE REQUIREMENTS (continued) area that has open communication with the rest of the secondary containment volume. The use of 0.25 inches of vacuum water gauge includes margin to account for uncertainties.

The SR is modified by a Note which states the SR is not required to be met for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if an analysis demonstrates that one SGT subsystem remains capable of establishing the required secondary containment vacuum. Use of the Note is expected to be infrequent but may be necessitated by situations in which secondary containment vacuum may be less than the required containment vacuum, such as, but not limited to, wind gusts or failure or change of operating normal ventilation subsystems. These conditions do not indicate any change in the leak tightness of the secondary containment boundary. The analysis should consider the actual conditions (equipment configuration, temperature, atmospheric pressure, wind conditions, measured secondary containment vacuum, etc.) to determine whether, if an accident requiring secondary containment to be OPERABLE were to occur, one train of SGT could establish the assumed secondary containment vacuum within the time assumed in the accident analysis. If so, the SR may be considered met for a period up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit is based on the expected short duration of the situations when the Note would be applied.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.1.2 and SR 3.6.4.1.3 Verifying that secondary containment equipment hatches and each inner access door or each outer access door in each access opening are closed at all times when secondary containment is required ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not occur and.

Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur.

SR 3.6.4.1.2 also requires equipment hatches to be sealed. In this application, the term "sealed" has no connotation of leak tightness.

Maintaining secondary containment OPERABILITY requires verifying either all inner doors or all outer doors in the access opening are closed at all times when secondary containment is required. However, each secondary containment access door is normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access. The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

Columbia Generating Station B 3.6.4.1-4 Revision 93

Secondary Containment B 3.6.4.1 SR 3.6.4.1.3 Verifying that each inner access door or each outer access door in each access opening is closed provides adequate assurance that exfiltration from the secondary containment will not occur. An access opening contains at least one inner and one outer door. The intent is to not breach the secondary containment, which is achieved by maintaining the inner or outer portion of the barrier closed except when the access opening is being used for entry and exit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.1.4 and SR 3.6.4.1.5 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment. To ensure that all fission products are treated, SR 3.6.4.1.4 verifies that the SGT System will rapidly establish and maintain a pressure in the secondary containment that is less than the pressure external to the secondary containment boundary. This is accomplished by verifying the secondary containment can be drawn down to an indicated pressure of greater than or equal to 0.25 inches of vacuum water gauge in less than or equal to 120 seconds, following the start of a single SGT fan.

SR 3.6.4.1.5 demonstrates that each SGT subsystem can maintain an indicated secondary containment pressure of 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at an indicated flow rate 2240 cfm. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Columbia Generating Station B 3.6.4.1-5 Revision 93