ML19343B974
| ML19343B974 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/05/2019 |
| From: | Schuetz R Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19343C030 | List: |
| References | |
| GO2-19-162 | |
| Download: ML19343B974 (11) | |
Text
Robert E. Schuetz Site Vice President P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-2425 F. 509-377-4674 reschuetz@energy-northwest.com December 5, 2019 10 CFR 50.71(e)
GO2-19-162 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, GO2-19-163, R.E. Schuetz (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 65 (Publicly Available)
- Licensee Controlled Specifications (LCS), Revision 111
- Technical Specification Bases (TSB), Revision 113
- Operational Quality Assurance Program Description (OQAPD), Revision 55 In addition to other changes, FSAR Amendment 65 removes some redundant information and excessive detail from the FSAR to improve its focus and clarity. In accordance with Nuclear Energy Institute (NEI) 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.
ENERGY NORTHWEST
G02-19-162 Page 2 of 3 contains the Columbia Generating Station 2018-2019 Commitment Change Report. This report is submitted pursuant to NEI 99-04, "Guidelines for Managing NRC Commitment Changes."
Columbia License Basis Documents are provided in electronic format in Attachments 4 and 5. The files are in the Portable Document Format (PDF). Attachment 3 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.
Energy Northwest has performed its biennial review of plant changes in accordance with 10 CFR 54.37(b) to determine whether there are any "newly identified structures, systems or component (SSCs)" that require aging management or there are any time limited aging analyses (TLAAs) that require re-evaluation. There were three SSCs that met the definition of "newly identified" and all newly identified SSCs are age managed under existing License Renewal Application (LRA) tables. There were no new materials or environments identified. There were also no time limited aging analyses that required re-evaluation.
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. A list of information removed from the FSAR submittal is contained in. A complete copy of the FSAR is submitted under separate cover.
There are no commitments being made 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. D.M. Wolfgramm, Licensing Supervisor, at (509)377-4792.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the _2_ day of December 2019.
Respectf u I ly, RE Schuetz Site Vice Presiden
GO2-19-162 Page 3 of 3 Attachments: 1. Redundant Information and Excessive Detail Removed from the FSAR
- 2. Regulatory Commitment Changes (NEI 99-04 Process)
- 3. Document Components
- 4. Licensee Controlled Specifications, Revision 111 Technical Specification Bases, Revision 113 Operational Quality Assurance Program Description, Revision 55
- 5. Columbia Generating Station FSAR, Amendment 65, Publicly Available
- 6. Information Withheld from Columbia Generating Station FSAR, Amendment 65, Publicly Available (Attachment 5) cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector/988C CD Sonoda-BPA/1399
GO2-19-162 Page 1 of 2 Redundant Information and Excessive Detail Removed from the FSAR CHAPTER 1 Section Description of Change Type 1.2.2.5.15 Eliminated Operations with a potential for Draining the Reactor Vessel (OPDRV) discussion.
Obsolete information CHAPTER 2 Section Description of Change Type 2.2.1 Removed the exact distance of the security training facility on Energy Northwest property.
Excessive detail 2.2.2.5 Removed discussion of Vista Airport.
Obsolete information CHAPTER 3 Section Description of Change Type 3.5.1.6 Removed discussion of Vista Airport.
Obsolete information CHAPTER 4 Section Description of Change Type 4.6.2.2.2.3 Removed specificity from bolting material.
Excessive detail 4.6.3.1.1.5 Removed a surveillance test requirement that is duplicative of Technical Specification 3.1.3.2.
Redundant information CHAPTER 6 Section Description of Change Type Table 6.2-12 Removed the above positions are in compliance with NRC Regulatory Guide 1.163.
Excessive detail 6.2.31 Eliminated Operations with a potential for Draining the Reactor Vessel (OPDRV) discussion.
Obsolete information CHAPTER 9 Section Description of Change Type 9.2.1.2 Eliminated the need for plant service water (TSW)
TSW-P-1A cooling for bearing lubrication of the replacement pump.
Obsolete Information 9.4.4 and Table 9.4-3 Eliminated information related to the Radwaste Building Chilled Water System (WCH) that was beyond what is needed for a system that has no safety function.
Excessive detail Table 9.5.2 Replaced Fluorescent with normal-emergency.
Excessive detail
GO2-19-162 Page 2 of 2 CHAPTER 12 Section Description of Change Type 12.5.2 Deleted references to Regulatory Guides (RGs) 8.3 and 8.6. They have been withdrawn.
Obsolete information CHAPTER 13 Section Description of Change Type 13.1.3.3.2 Deleted or the Corporate Nuclear Safety Review Board.
Obsolete information Appendix A Section Description of Change Type A.2.1.52 Removed discussion of Thermal aging and neutron embrittlement of Cast Austenitic Stainless Steel (CASS) from the program details. Now contained in another program.
Obsolete information Appendix F Section Description of Change Type F.2.6.1 Table F.3.-1 Replaced Fluorescent with normal-emergency.
Excessive detail Table F.2-1 Deleted isolation switch deviation description and FP-Zone deviation.
Obsolete information F.2.3 Removed the phrase closed valves.
Obsolete information F.2.4.1 Eliminate Fire Pump (FP) cooling for bearing lubrication for the replacement TSW-P-1A.
Obsolete information Table F.3-1 Removed text about valves having tamper switches that alarm in the control room.
Obsolete information
GO2-19-162 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 GI2-12-070 NUREG-2123 (#52) (RCC-AR 385567)
The License Renewal commitment to establish a Thermal Aging & Neutron Embrittlement aging management program for Cast Austenitic Stainless Steel (CASS) vessel internals XI.M13 is being revised to evaluate Thermal Aging & Neutron Embrittlement of CASS vessel internals under the BWR Vessel Internals Program XI.M9. The change is consistent with NUREG-1801 Rev 2 and meets the intent of Columbia's License Renewal Safety Evaluation, NUREG-2123. Managing the CASS components under the Boiling Water Reactor Vessel and Internals Project (BWRVIP)
Program reduces administrative overhead for the station without impacting safety. The change has been incorporated into the Final Safety Analysis Report (FSAR) Appendix A, Section A.2.1.10. The change was implemented via revision to the BWRVIP Program Plan, Revision 17.
The original commitment stated:
The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is a new program. The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will manage loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of CASS reactor vessel internals.
The program includes: (a) identification of susceptible components determined to be limiting from the standpoint of thermal aging or neutron irradiation embrittlement (neutron fluence), (b) a component specific evaluation to determine each identified components susceptibility to loss of fracture toughness, and (c) a supplemental examination of any component not eliminated by the component specific evaluation.
Implementation prior to the period of extended operation and ongoing thereafter.
Commitment description has been revised to say:
Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) activity. This is a new activity to be managed under the BWR Vessel Internals Program (FSAR Appendix A, Section A.2.1.10). Implementation prior to the period of extended operation and continue through the period of extended operation.
GO2-19-162 Page 2 of 2 From GO2-05-147 (RCC-AR 399858)
The commitment for Emergency Diesel Generator (EDG) Allowed Outage Time (AOT) extension is being revised to provide alternative conditions that are also appropriate for confirming the batteries have adequate capacity available for entering the extended completion time period by ensuring that the battery capacity meets or exceeds the capacity to support the extended Station Blackout (SBO) (ESBO) event as described in calculation 2.05.01, Revision 14, "Calculation for Battery and Battery Charger 250V DC 125V DC and 24V DC." This calculation describes necessary battery capacity for ESBO. The ESBO event is modeled in Probabilistic Risk Assessment (PRA) as the basis for the extended risk informed Completion Time.
The original commitment stated:
The battery capacity will be verified prior to entry into the extended Completion Time by the following: 1) The results of the last battery capacity surveillance was greater than or equal to 100%; 2) The battery surveillances are current. Short time excursions in battery parameters outside surveillance limits will not invalidate the risk management compensatory measure commitment as specific Technical Specification (TS) Actions exist to restore the conditions within a reasonable time.
Commitment description has been revised to say:
The battery capacity will be verified for E-B 1-1, E-81-2, and E-B2-1 prior to entry into the extended Completion Time by the following:
- The results of the last battery capacity surveillance was greater than or equal to 100%, or alternatively, the battery capacity surveillance results exceed station analysis for required capacity for the extended SBO (ESBO) event described in calculation 2.05.01, Division 1 and 2 Battery and Battery Charger 250V DC 125V DC and 24V DC Sizing.
- The battery surveillances are current.
Short time excursions in battery parameters outside surveillance limits will not invalidate the risk management compensatory measure commitment as specific TS Actions exist to restore the conditions within a reasonable time.
GO2-19-162 Page 1 Document Components TSB, LCS, OQAPD File Name Description _1.pdf LCS _2.pdf TSB _3.pdf OQAPD FSAR Amendment 65, Publicly Available _1 of 10.pdf General Table of Contents &
List of Effective Pages _2 of 10.pdf Chapters 1 & 2 _3 of 10.pdf Chapters 3 and 3a _4 of 10.pdf Chapters 4, 5 & 6 _5 of 10.pdf Chapter 7 _6 of 10.pdf Chapter 8 _7 of 10.pdf Chapter 9 _8 of 10.pdf Chapters 10 & 11 _9 of 10.pdf Chapter 12 _10 of 10.pdf Chapters 13, 14, 15 16 & 17 Appendices A, B, F, I & J
GO2-19-162 Page 1 of 3 Information Withheld From Columbia Generating Station FSAR Amendment 65, Publicly Available (Attachment 5)
Figure Figure/Table Figure Figure Figure 1.2-1 Figure 3.2-5 Figure 3.5-36 Figure 3.6-35.1 Figure 1.2-2.1 Figure 3.2-6 Figure 3.5-37 Figure 3.6-35.2 Figure 1.2-2.2 Figure 3.2-7 Figure 3.5-38 Figure 3.6-36.1 Figure 1.2-3.1 Table 3.5-5 Figure 3.5-39 Figure 3.6-36.2 Figure 1.2-3.2 Figure 3.5-1 Figure 3.5-41 Figure 3.6-37.1 Figure 1.2-4.1 Figure 3.5-2 Figure 3.5-42 Figure 3.6-37.2 Figure 1.2-4.2 Figure 3.5-3 Figure 3.5-43 Figure 3.6-38.1 Figure 1.2-5 Figure 3.5-4 Figure 3.5-44 Figure 3.6-38.2 Figure 1.2-6 Figure 3.5-5 Figure 3.5-45 Figure 3.6-38.3 Figure 1.2-7 Figure 3.5-6 Figure 3.5-46 Figure 3.6-39.1 Figure 1.2-8 Figure 3.5-7 Figure 3.5-47 Figure 3.6-39.2 Figure 1.2-9 Figure 3.5-8 Figure 3.5-49 Figure 3.6-39.3 Figure 1.2-10 Figure 3.5-9 Figure 3.5-50 Figure 3.6-40.1 Figure 1.2-11 Figure 3.5-10 Figure 3.6-1 Figure 3.6-40.2 Figure 1.2-12 Figure 3.5-11 Figure 3.6-2 Figure 3.6-41.1 Figure 1.2-13 Figure 3.5-12 Figure 3.6-3 Figure 3.6-41.2 Figure 1.2-14 Figure 3.5-13 Figure 3.6-4 Figure 3.6-42.1 Figure 1.2-15 Figure 3.5-14 Figure 3.6-5 Figure 3.6-42.2 Figure 1.2-16 Figure 3.5-15 Figure 3.6-6 Figure 3.6-43.1 Figure 1.2-17.1 Figure 3.5-16 Figure 3.6-7 Figure 3.6-43.2 Figure 1.2-17.2 Figure 3.5-17 Figure 3.6-8 Figure 3.6-44.1 Figure 1.2-18 Figure 3.5-18 Figure 3.6-9 Figure 3.6-44.2 Figure 1.2-19 Figure 3.5-19 Figure 3.6-10 Figure 3.6-45.1 Figure 1.2-20 Figure 3.5-20 Figure 3.6-11 Figure 3.6-45.2 Figure 1.2-21 Figure 3.5-21 Figure 3.6-12 Figure 3.6-46.1 Figure 1.2-22 Figure 3.5-22 Figure 3.6-13 Figure 3.6-46.2 Figure 1.2-23 Figure 3.5-23 Figure 3.6-14 Figure 3.6-47.1 Figure 1.2-24 Figure 3.5-24 Figure 3.6-15 Figure 3.6-47.2 Figure 2.1-3 Figure 3.5-25 Figure 3.6-16 Figure 3.6-48.1 Figure 2.4-6.1 Figure 3.5-26 Figure 3.6-17 Figure 3.6-48.2 Figure 2.4-6.2 Figure 3.5-27 Figure 3.6-18 Figure 3.6-49.1 Figure 2.4-6.3 Figure 3.5-28 Figure 3.6-19 Figure 3.6-49.2 Figure 2.4-6.4 Figure 3.5-29 Figure 3.6-20 Figure 3.6-50.1 Figure 2.4-6.5 Figure 3.5-30 Figure 3.6-32.1 Figure 3.6-50.2 Figure 2.4-16 Figure 3.5-31 Figure 3.6-32.2 Figure 3.6-50.3 Figure 2.4-28 Figure 3.5-32 Figure 3.6-33.1 Figure 3.6-51.1 Figure 3.2-2 Figure 3.5-33 Figure 3.6-33.2 Figure 3.6-51.2 Figure 3.2-3 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
GO2-19-162 Page 2 of 3 Information Withheld From Columbia Generating Station FSAR Amendment 65, Publicly Available (Attachment 5)
Figure/Section Figure Figure Figure 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
GO2-19-162 Page 3 of 3 Information Withheld From Columbia Generating Station FSAR Amendment 65, Publicly Available (Attachment 5)
Figure/Section Figure/Table Figure/Section Figure Figure 6.2-23 Figure 8.3-2 Figure 12.3-1 Figure F.6-21 Figure 6.2-32 Figure 8.3-4.1 Figure 12.3-2 Figure J.6-1.1 Figure 6.2-33 Figure 8.3-4.2 Figure 12.3-3 Figure J.6-1.2 Figure 8.1-1 Figure 8.3-4.3 Figure 12.3-4 Figure J.6-2.1 Figure 8.1-2.1 Figure 8.3-4.4 Figure 12.3-5 Figure J.6-2.2 Figure 8.1-2.2 Figure 8.3-4.5 Figure 12.3-6 Figure J.6-3.1 Figure 8.1-2.3 Figure 8.3-4.6 Figure 12.3-7 Figure J.6-3.2 Figure 8.1-2.4 Figure 8.3-5 Figure 12.3-8 Figure J.6-4 Figure 8.1-3 Figure 8.3-6 Figure 12.3-9 Figure J.6-5 Figure 8.1-4 Figure 8.3-7 Figure 12.3-10 Figure J.6-6 Figure 8.1-5 Figure 8.3-8 Figure 12.3-11 Figure J.6-7 Figure 8.1-6.1 Figure 8.3-9 Figure 12.3-12 Figure J.6-8 Figure 8.1-6.2 Figure 8.3-10 Figure 12.3-13 Figure J.6-9 Section 8.2.2 Figure 8.3-23 Figure 12.3-14 Figure J.6-10 Figure 8.2-1.1 Figure 8.3-24 Figure 12.3-15 Figure J.6-11 Figure 8.2-1.2 Figure 8.3-25 Figure 12.3-16 Figure J.6-12 Figure 8.2-2.1 Figure 8.3-26 Figure 12.3-17 Figure J.6-13 Figure 8.2-2.2 Figure 8.3-27 Figure 12.3-18 Figure J.6-14 Figure 8.2-3.1 Figure 8.3-28 Figure 12.3-22 Figure J.6-15 Figure 8.2-3.2 Figure 8.3-29 Section F.4.4.4 Figure J.6-16 Figure 8.2-3.3 Figure 8.3-30 Figure F.6-1 Figure J.6-17 Figure 8.2-3.4 Figure 8.3-32 Figure F.6-2 Figure J.6-18 Figure 8.2-4.1 Figure 8.3-33 Figure F.6-3 Figure 8.2-4.2 Figure 8.3-34 Figure F.6-4 Figure 8.2-4.3 Figure 8.3-35 Figure F.6-5 Figure 8.2-4.4 Figure 8.3-36 Figure F.6-6 Figure 8.2-5.1 Figure 8.3-37 Figure F.6-7 Figure 8.2-5.2 Figure 8.3-38 Figure F.6-8 Figure 8.2-5.3 Figure 8.3-52.1 Figure F.6-9 Figure 8.2-5.4 Figure 8.3-52.2 Figure F.6-10 Figure 8.2-6.1 Figure 8.3-53 Figure F.6-11 Figure 8.2-6.2 Figure 9.1-4 Figure F.6-12 Figure 8.2-6.3 Figure 9.1-5 Figure F.6-13 Figure 8.2-6.4 Figure 9.1-13 Figure F.6-14 Figure 8.2-7.1 Figure 9.2-7 Figure F.6-15 Figure 8.2-7.2 Figure 9.2-13 Figure F.6-16 Figure 8.2-7.3 Figure 9.2-14 Figure F.6-17 Figure 8.2-7.4 Table 9.5-1 Figure F.6-18 Figure 8.3-1 Figure 9.5-2 Figure F.6-19 Figure F.6-20