ML18206A324

Supplemental Information Needed for Acceptance of Requested Licensing Action Operating License and Technical Specification Clean-Up Amendment

ML18206A324
Person / Time
Site:	Columbia
Issue date:	07/31/2018
From:	Klos L Plant Licensing Branch IV
To:	Sawatzke B Energy Northwest
Klos L, 301-415-5136
References
EPID L-2018-LLA-0176
Download: ML18206A324 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 31, 2018 Mr. Bradley J. Sawatzke Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352

SUBJECT:

COLUMBIA GENERATING STATION-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE:

RENEWED FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATION CLEAN-UP (EPID L-2018-LLA-0176)

Dear Mr. Sawatzke:

By letter dated June 12, 2018 (Agencywide Documents Access and Management System Accession No. ML18163A351), Energy Northwest (the licensee) submitted a license amendment request for Columbia Generating Station. The proposed amendment would remove the Table of Contents from the Technical Specifications (TSs) and place it under licensee control, and clean-up the renewed facility operating license and TSs, including editorial changes, the removal of obsolete TS information, renumbering TS pages and the removal of obsolete license conditions and attachments.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the TSs) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.

In order to make the application complete, the NRC staff requests that Energy Northwest supplement the application to address the information requested in the enclosure by Friday, August 10, 2018. This will enable the NRC staff to begin its detailed technical review. If the

B. Sawatzke information responsive to the staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.

The information requested and associated timeframe in this letter were discussed with Mr. Rick Garcia of your staff on July 24, 2018.

If you have any questions, please contact me at (301) 415-5136 or by e-mail at John.Klos@nrc.gov.

Sincerely, L. Jo n s, Proje t Manager Plant Licensing Branch LPL4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

Supplemental Information Needed cc: Listserv

SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT REQUEST REGARDING RENEWED FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATION CLEAN-UP ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 By letter dated June 12, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18163A351), Energy Northwest (the licensee) submitted a license amendment request (LAR) for Columbia Generating Station (Columbia). The proposed amendment would remove the Table of Contents from the Technical Specifications (TSs) and place it under licensee control, and clean-up the renewed facility operating license (RFOL) and TSs, including editorial changes, the removal of obsolete TS information, renumbering TS pages and the removal of obsolete license conditions and attachments. The NRC staff has concluded that supplemental information is required in order to make the application complete, as discussed below.

Background

The LAR's cover letter introduction states, in part, that this request is an administrative change that does not "result in changes to the technical or operating requirements" of Columbia. The LAR further states, in Section 2.2.4, that as low as reasonable achievable (ALARA) reviews were made of areas where shield walls were deferred (not constructed per Columbia Amendment No. 7) and these results were considered acceptable.

Reference 12 of the LAR (Inspection Report 05000397 /2016003 for Columbia; ADAMS Accession No. ML16302A315), states that in 2015 certain shield wall location areas found in , "List of Shield Walls," of RFOL NPF-21 for Columbia (where a shield wall does not physically exist) have exceeded radiation and ALARA controls. These areas are locations that are also related to the RFOL License Condition 2.C.(11 ), "Shield Wall Deferral (Section 12.3.2, SSER #4, License Amendment #7)."

Reference 12 of the LAR, states that non-compliance in Attachment 3 areas related to the license condition stated above, have occurred in 2010 and 2015, and that in 2015, a licensee-identified non-cited violation for this non-compliance issue was issued, which subsequently created two licensee corrective action program entries (Action requests (ARs) 00354266 and 0035320).

Reference 12 of the LAR, also states that the intent of the ARs included an "update [to Columbia's] [license] condition to accurately reflect current operations." Therefore, the amendment's proposed changes are to remove License Condition 2.C(11) and Attachment 3 from the TSs. Reference 12 of the LAR, further states that an ALARA program was not practiced in full for areas of Attachment 3 related to the license condition from 2009 to 2015.

Enclosure

The amendment's proposed changes to remove License Condition 2.C(11 ), concerning Shield Wall deferment (Columbia's Amendment No. 7) and the associated areas stated in , would then omit documentation of Columbia's current licensing basis.

Specifically, the proposed changes would therefore not reflect Columbia's current operations nor the technical and operating requirements associated with Columbia's Amendment No. 7 and the areas related to shield wall deferment.

Supplemental Information Requested:

1. The licensee is requested to provide a supplement that either; a) Retains and documents licensing basis continuity for the items above rather than deleting them per the current submittal; or b) Provides a full justification for the intended change that includes the complete licensing history, documentation and discussion that would support the proposed change while still representing the full technical and operating arrangement of Columbia. Additionally, a full justification should fully document, as proposed in the amendment, that License Condition 2.C(11) is obsolete.

ML18206A324 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JKlos PBlechman RPascarelli JKlos DATE 7/31/2018 7/31/2018 7/31/2018 7/31/2018