ML18025A213

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Issuance of Amendment No. 246 Revision of Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation
ML18025A213
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/16/2018
From: Klos L
Plant Licensing Branch IV
To: Reddemann M
Energy Northwest
Klos L, 301-415-5136
References
CAC MF9468, EPID L-2017-LLA-0196, GL-08-001
Download: ML18025A213 (25)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968 February 16, 2018

SUBJECT:

COLUMBIA GENERA TING STATION - ISSUANCE OF AMENDMENT RE:

REVISION OF TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, REVISION 2, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (CAC NO. MF9468; EPID L-2017-LLA-0196)

Dear Mr. Reddemann:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 246 to Renewed Facility Operating License No. NPF-21 for the Columbia Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 27, 2017.

The amendment revises the TS requirements to address NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in Technical Specifications Task Force (TSTF}

Standard Technical Specifications Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

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

Docket No. 50-397

Enclosures:

1. Amendment No. 246 to NPF-21
2. Safety Evaluation cc: Listserv Sincerely, L1~~~nager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERA TING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 246 License No. NPF-21

1.

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

A.

The application for amendment by Energy Northwest (the licensee), dated March 27, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and 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 amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-21 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 246 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

Attachment:

Changes to the Renewed Facility Operating License No. NPF-21 and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 1 6, 2 O 1 8

ATTACHMENT TO LICENSE AMENDMENT NO. 246 COLUMBIA GENERA TING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-21 DOCKET NO. 50-397 Replace the following pages of the Renewed Facility Operating License No. NPF-21 and Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE 3.4.9-2 3.4.10-2 3.5.1-4 3.5.1-5 3.5.2-3 3.5.3-2 3.6.1.5-2 3.6.2.3-2 3.9.8-2 3.9.9-2 INSERT 3.4.9-2 3.4.9-3 3.4.10-2 3.5.1-4 3.5.1-5 3.5.1-6 3.5.2-3 3.5.3-2 3.6.1.5-2 3.6.2.3-2 3.9.8-2 3.9.8-3 3.9.9-2 (2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 246 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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.

( 11)

Shield Wall Deferral (Section 12.3.2, SSER #4, License 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.

  • 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.

Renewed License No. NPF-21 Amendment No. 246

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

8. No RHR shutdown 8.1 Initiate action to restore one Immediately cooling subsystem in RHR shutdown cooling operation.

subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

8.2 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery circulation by an alternate of no reactor coolant method.

circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND 8.3 Monitor reactor coolant Once per hour temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1

NO TE------------------------------

N ot required to be met until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after reactor steam dome pressure is less than 48 psig.

Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.4.9-2 Amendment No. 484,499 ~

~

246

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 SURVEILLANCE REQUIREMENTS SR 3.4.9.2 SURVEILLANCE

NOTE------------------------------

N ot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is < 48 psig.

Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

FREQUENCY In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.4.9-3 Amendment No. 246

RHR Shutdown Cooling System - Cold Shutdown 3.4.10 ACTIONS CONDITION REQUIRED ACTION

8. No RHR shutdown 8.1 Verify reactor coolant cooling subsystem in circulating by an alternate operation.

method.

AND No recirculation pump in operation.

AND 8.2 Monitor reactor coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SR 3.4.10.1 SURVEILLANCE Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.4.10.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.4.10-2 Amendment No. 449,489 ~

~

246

SURVEILLANCE REQUIREMENTS SR 3.5.1.1 SR 3.5.1.2 SR 3.5.1.3 SURVEILLANCE Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

NOTES---------------------------

1.

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than 48 psig in MODE 3, if capable of being manually realigned and not otherwise inoperable.

2.

Not required to be met for system vent flow paths opened under administrative controls.

Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify ADS accumulator backup compressed gas system average pressure in the required bottles is

2200 psig.

ECCS - Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.5.1-4 Amendment No. 169,205,225,229,236 ~

~

246

SURVEILLANCE REQUIREMENTS SR 3.5.1.4 SR 3.5.1.5 SR 3.5.1.6 SURVEILLANCE Verify each ECCS pump develops the specified flow rate with the specified differential pressure between reactor and suction source.

SYSTEM FLOW RATE LPCS LPCI HPCS z 6200 gpm z 7200 gpm z 6350 gpm DIFFERENTIAL PRESSURE BETWEEN REACTOR AND SUCTION SOURCE z 128 psid z 26 psid z 200 psid

NOTE------------------------------

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

NOTE------------------------------

Valve actuation may be excluded.

Verify the ADS actuates on an actual or simulated automatic initiation signal.

ECCS - Operating 3.5.1 FREQUENCY In accordance with the INSERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.5.1-5 Amendment No. 169,205,225,236 ' 246 I

SURVEILLANCE REQUIREMENTS SR 3.5.1.7 SR 3.5.1.8 SURVEILLANCE

NO TE------------------------------

N ot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify each required ADS valve opens when manually actuated.

NOTE------------------------------

ECCS actuation instrumentation is excluded.

Verify the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is within limits.

Columbia Generating Station 3.5.1-6 ECCS - Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 246 I

SURVEILLANCE REQUIREMENTS SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SURVEILLANCE Verify, for each required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

NOTES-----------------------------

1.

One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

2.

Not required to be met for system vent flow paths opened under administrative controls.

Verify each required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify each required ECCS pump develops the specified flow rate with the specified differential pressure between reactor and suction source.

SYSTEM FLOW RATE LPCS LPCI HPCS 2 6200 gpm 2 7200 gpm 2 6350 gpm DIFFERENTIAL PRESSURE BETWEEN REACTOR AND SUCTION SOURCE 2 128 psid 2 26 psid 2 200 psid ECCS - Shutdown 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the INSERVICE TESTING PROGRAM Columbia Generating Station 3.5.2-3 Amendment No. 499,~ ~

~

~.~

246

SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 SURVEILLANCE Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water.

NOTE------------------------------

N ot required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

NOTE------------------------------

N ot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure ~ 1035 psig and z 935 psig, the RCIC pump can develop a flow rate 2 600 gpm against a system head corresponding to reactor pressure.

NOTE------------------------------

N ot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure~ 165 psig, the RCIC pump can develop a flow rate z 600 gpm against a system head corresponding to reactor pressure.

RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.5.3-2 Amendment No. 4-W,489 ~

~

246

SURVEILLANCE REQUIREMENTS SR 3.6.1.5.1 SR 3.6.1.5.2 SR 3.6.1.5.3 SURVEILLANCE Verify each RHR drywell spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Verify each spray nozzle is unobstructed.

Verify RHR drywell spray subsystem locations susceptible to gas accumulation are sufficiently filled with water.

RHR Drywell Spray 3.6.1.5 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.6.1.5-2 Amendment No. 2-JO ~

246

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SR 3.6.2.3.1 SR 3.6.2.3.2 SR 3.6.2.3.3 SURVEILLANCE Verify each RHR suppression pool cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Verify each RHR pump develops a flow rate

~ 7100 gpm through the associated heat exchanger while operating in the suppression pool cooling mode.

Verify RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the INSERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.6.2.3-2 Amendment No. 169 225 230 '* 243 246

ACTIONS CONDITION REQUIRED ACTION B. (continued)

B.3 Initiate action to restore one standby gas treatment subsystem to OPERABLE status.

AND B.4 Initiate action to restore isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant cooling subsystem in circulation by an alternate operation.

method.

AND C.2 Monitor reactor coolant tern peratu re.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is operating.

RHR - High Water Level 3.9.8 COMPLETION TIME Immediately Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour FREQUENCY In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.9.8-2 Amendment 449,4-W ~

2J8 246

SURVEILLANCE REQUIREMENTS SR 3.9.8.2 SURVEILLANCE Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

Columbia Generating Station 3.9.8-3 RHR - High Water Level 3.9.8 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment 246

ACTIONS CONDITION REQUIRED ACTION B. ( continued)

B.3 Initiate action to restore isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant cooling subsystem in circulation by an alternate operation.

method.

AND C.2 Monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.9.1 Verify one RHR shutdown cooling subsystem is operating.

RHR - Low Water Level 3.9.9 COMPLETION TIME Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.9.9.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program Columbia Generating Station 3.9.9-2 Amendment 449,499 ~

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246

1.0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 246 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 INTRODUCTION By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated March 27, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17086A587), Energy Northwest (the licensee) requested changes to the Technical Specifications (TSs) for the Columbia Generating Station (Columbia). The requested changes would revise the TS requirements in order to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008 (ADAMS Accession No. ML072910759),

as described in Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" (ADAMS Accession No. ML13053A075).

The proposed changes would revise surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS) and reactor core isolation cooling (RCIC) system. The proposed changes would also add new SRs related to gas accumulation for the residual heat removal (RHR) shutdown cooling system, RHR drywell spray system, and RHR suppression pool cooling system. TS Bases changes associated with these SRs would also be made.

The licensee stated that the license amendment request is consistent with NRG-approved TSTF-523, Revision 2. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700) as part of the consolidated line item improvement process.

2.0

2.1 REGULATORY EVALUATION

Background Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued GL 2008-01 to address the issue of gas accumulation in ECCS, Decay Heat Removal (OHR), and containment spray systems. The industry and NRC staff agreed that a change to the STS and plant-specific TSs would be necessary to address some issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the Columbia TSs using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.1.1, 3.5.1.2, 3.5.2.3, 3.5.2.4, 3.5.3.1, and 3.5.3.2 as well as the addition of new SRs 3.4.9.2, 3.4.10.2, 3.6.1.5.3, 3.6.2.3.3, 3.9.8.2, and 3.9.9.2 to TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown"; TS 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown"; TS 3.5.1, "ECCS - Operating"; TS 3.5.2, "ECCS - Shutdown"; TS 3.5.3, "RCIC System"; TS 3.6.1.5, "Residual Heat Removal (RHR) Drywall Spray"; TS 3.6.2.3, "Residual Heat Removal (RHR)

Suppression Pool Cooling"; TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level"; and TS 3.9.9, "Residual Heat Removal (RHR)- Low Water Level," respectively. Associated Bases changes were proposed for the respective limiting conditions for operation {LCOs), SR changes, and SR additions.

2.3 Regulatory Review The regulations in Appendix A to Title 10 of the Code of Federal Regulations ( 1 O CFR) Part 50 or similar plant-specific principal design criteria provide design requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39, and 40.

GDC 1, "Quality standards and records," requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34, "Residual heat removal," requires an RHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, "Emergency core cooling"; GDC 36, "Inspection of emergency core cooling system"; and GDC 37, "Testing of emergency core cooling system," require an ECCS design that meets performance, inspection, and testing requirements. Additionally, the regulations in 1 O CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," provide specified ECCS performance criteria. GDC 38, "Containment heat removal"; GDC 39, "Inspection of containment heat removal system"; and GDC 40, "Testing of containment heat removal system," require a containment heat removal system design that meets performance, inspection, and testing requirements.

Appendix B to 1 O CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. Quality assurance criteria provided in 10 CFR Part 50, Appendix 8, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII.

Criterion Ill, "Design Control," and Criterion V, "Instructions, Procedures, and Drawings," require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI, "Test Control," requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI, "Corrective Action," requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management. Criterion XVII, "Quality Assurance Records," requires maintenance of records of activities affecting quality.

The regulations at 10 CFR 50.36, "Technical specifications," require that the TSs include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)" (ADAMS Accession No. ML13109A458), which identifies instructions for filling and venting the ECCS and OHR system, as well as for draining and refilling heat exchangers.

Standard TSs and most licensee TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in both NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants" and NUREG-1434, "Standard Technical Specifications General Electric BWR/6 Plants" (ADAMS Accession Nos. ML12104A192 and ML12104A195, respectively).

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR [Light-Water Reactor] Edition" (SRP) during the review.

Revision 5 of SRP, Section 6.2.2, "Containment Heat Removal Systems," dated March 2007 (ADAMS Accession No. ML070160661 ), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

Revision 3 of SRP, Section 6.3, "Emergency Core Cooling System," dated March 2007 (ADAMS Accession No. ML070550068), provides the procedures concerning the review of ECCS to help ensure compliance with GDC 35, 36, and 37.

Revision 5 of SRP, Section 5.4.7, "Residual Heat Removal (RHR) System," dated May 2010 (ADAMS Accession No. ML100680577), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system (RCS) during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensee's proposed changes against the applicable regulatory guidance in the STS, as modified by TSTF-523. The proposed changes adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433 and NUREG-1434 by TSTF-523. The NRC staff found that the proposed changes are consistent with guidance in the STS, as modified by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36.

The licensee proposed the following TS changes:

1.

Add SR 3.4.9.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water with a note that states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is< [less than] 48 psig [pounds per square inch gauge]," and a frequency of "In accordance with the Surveillance Frequency Control Program."

2.

Add SR 3.4.10.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

3.

Revise the language for SR 3.5.1.1 from "Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

4.

Add a note to SR 3.5.1.2, which states, "Not required to be met for system vent flow paths opened under administrative control."

5.

Revise the language for SR 3.5.2.3 from "Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

6.

Add a note to SR 3.5.2.4, which states, "Not required to be met for system vent flow paths opened under administrative controls."

7.

Revise the language for SR 3.5.3.1 from "Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve" to "Verify the RCIC system locations susceptible to gas accumulation are sufficiently filled with water."

8.

Add a note to SR 3.5.3.2, which states, "Not required to be met for system vent flow paths opened under administrative control."

9.

Add SR 3.6.1.5.3, which states, "Verify RHR drywell spray subsystem locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

10.

Add SR 3.6.2.3.3, which states, "Verify RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

11.

Add SR 3.9.8.2, which states, "Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

12.

Add SR 3.9.9.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

13.

Add and revise the affected TS SR Bases language to state the purpose of the SR, discuss methods of identifying locations susceptible to gas accumulation, discuss gas volume acceptance criteria, discuss methods for performing the SR, consistent with licensee actions and on-going programs related to GL 2008-01, and describe the SR frequency.

14.

Add and revise TS LCO Bases language to describe what is required for Operability of the systems and reiterate the importance of gas management.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state "full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that states that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is less than the RHR cut-in permissive pressure is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules, Section 1.4 of NUREG-1433 and NUREG-1434, the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

The language for the notes that allows the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR.

Therefore these notes are acceptable.

The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCOs will be met. Therefore, the NRC staff finds the proposed changes acceptable.

The regulation at 10 CFR 50.36(a)(1) states, in part: "A summary statement of the bases or reasons for such specifications... shall also be included in the application, but shall not become part of the technical specifications." The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the TS Bases Control Program, TS 5.5.10. Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors dated July 22, 1993 (58 FR 39132).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Washington State official was notified of the proposed issuance of the amendment on January 23, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

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 significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on June 6, 2017 (82 FR 26132). 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) there is reasonable assurance that 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 Contributor: T. Sweat, NRR/DSS/STSB Date: February 16, 2018

SUBJECT:

COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT RE:

REVISION OF TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, REVISION 2, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (CAC NO. MF9468; EPID L-2017-LLA-0196)

DATED FEBRUARY 16, 2018 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrDssStsb Resource RidsNrrLAPBlechman Resource RidsNrrPMColumbia Resource RidsRgn4MailCenter Resource TSweat, NRR/DSS/STSB ADAMS A ccess1on N ML 1802 A213

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5 1yema1 OFFICE NRR/DORL/LPL4/PM N RR/DORL/LPL4/LA NAME JKlos PBlechman DATE 01/30/2018 02/13/2018 OFFICE OGC NLO**

N RR/DORL/LPL4/BC NAME JWachutka RPascarelli DATE 02/13/2018 02/15/2018 OFFICIAL RECORD COPY

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VCusumano 11/29/2017 NRR/DORL/LPL4/PM JKlos 02/16/2018

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