ML20113E984
| ML20113E984 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 05/04/2020 |
| From: | Klos L Plant Licensing Branch IV |
| To: | Sawatzke B Energy Northwest |
| Klos L, 301-415-5136 | |
| References | |
| EPID L-2020-LLA-0079 | |
| Download: ML20113E984 (12) | |
Text
May 4, 2020 Mr. Bradley J. Sawatzke Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT NO. 257 TO EXTEND IMPLEMENTATION DATE FOR AMENDMENT NO. 255 REGARDING THE CONTROL ROOM AIR CONDITIONING SYSTEM (EXIGENT CIRCUMSTANCES) (EPID L-2020-LLA-0079)
Dear Mr. Sawatzke:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 257 to Renewed Facility Operating License No. NPF-21 for the Columbia Generating Station (Columbia). This amendment is in response to your application dated April 15, 2020.
The amendment extends the implementation date for Amendment No. 255, which was issued by the NRC on February 6, 2020, for Columbia. Amendment No. 255 was effective on the date of issuance (i.e., February 6, 2020) and was required to be implemented on or before May 6, 2020. As discussed in your application, the implementation date for Amendment No. 255 could not be met due to unforeseen circumstances associated with the ongoing COVID-19 pandemic and the resulting impact on Columbia. Amendment No. 257 extends the implementation date from May 6, 2020, to February 6, 2021.
Amendment No. 255 revised the Columbia Final Safety Analysis Report to allow use of the main control room chilled water system or the emergency service water system as acceptable cooling sources in support of the main control room air conditioning system.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
L. John Klos, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosures:
- 1. Amendment No. 257 to NPF-21
- 2. Safety Evaluation cc: Listserv
ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 257 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, April 15, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, by Amendment No. 257, Renewed Facility Operating License No. NPF-21 is hereby amended to extend the implementation date of Amendment No. 255, dated February 6, 2020, from May 6, 2020, to February 6, 2021, as set forth in the licensees application dated April 15, 2020, and evaluated in the NRC staffs safety evaluation with this amendment.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented by February 6, 2021.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: May 4, 2020 Jennifer L.
Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2020.05.04 14:43:47
-04'00'
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 257 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 INTRODUCTION
By application dated April 15, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20107G017), Energy Northwest (the licensee) submitted a license amendment request (LAR) for Columbia Generating Station (Columbia).
The proposed amendment would extend the implementation date for Amendment No. 255, which was issued by the U.S. Nuclear Regulatory Commission (NRC or the Commission) on February 6, 2020 (ADAMS Accession No. ML19337C368). Amendment No. 255, issued for Columbia, was effective on the date of issuance (i.e., February 6, 2020), and was required to be implemented on or before May 6, 2020. Due to unforeseen circumstances associated with the ongoing COVID-19 pandemic and the resulting impact on Columbia, Energy Northwest requested that the implementation date for Amendment No. 255 for Columbia be extended from May 6, 2020, to February 6, 2021.
Amendment No. 255 revised the Columbia Final Safety Analysis Report to allow use of the main control room chilled water system or the emergency service water system as acceptable cooling sources in support of the main control room air conditioning system.
As discussed in the application dated April 15, 2020, the licensee requested that the proposed amendment be processed by the NRC on an exigent basis in accordance with the provisions in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.91(a)(6). The NRC staffs evaluation regarding the exigent circumstances is discussed in Section 4.0 of this safety evaluation.
2.0 REGULATORY EVALUATION
2.1 Applicable Regulatory Requirements and Guidance The NRC staff identified the following regulatory requirements and guidance as applicable to Amendment No. 255, which was scheduled to be implemented by May 6, 2020.
The regulation under 10 CFR 50.36(c)(2), Limiting conditions for operation [LCO],
requires a technical specification LCO of a nuclear reactor must be established for each item meeting one or more of the four criteria stated in the regulation. The main control room air conditioning system is subject to Criterion 3, which states:
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The regulation under 10 CFR 50.48, Fire protection, requires each operating nuclear power plant to provide the means to limit fire damage to structures, systems, or components important to safety to ensure the ability to safely shut down the reactor.
Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, General Design Criterion 3, Fire protection, states, in part:
Structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light Water Reactor] Edition (SRP), Section 9.2.7, Chilled Water System, dated September 2015 (ADAMS Accession No. ML15103A559) and Section 9.4.1, Revision 3, Control Room Area Ventilation System, dated March 2007 (ADAMS Accession No. ML070550045).
Regulatory Guide 1.189, Revision 3, Fire Protection for Nuclear Power Plants, dated February 2018 (ADAMS Accession No. ML17340A875), which provides for a means to meet the fire protection provisions of 10 CFR 50.48.
NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire, Final Report, dated October 2007 (ADAMS Accession No. ML073020676).
2.2 License Amendment Implementation Dates In issuing an amendment to an operating license, the NRC staff specifies when the amendment is effective and when the amendment must be implemented. Enclosure 1 to the NRCs letter dated February 6, 2020, contained Amendment No. 255, for Columbia. The amendment stated, in part, that:
The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.
There are no specific regulatory requirements regarding the time period for amendment implementation. The NRC staff generally specifies an implementation period consistent with that requested in the application. For Columbias, Amendment No. 255, the 90-day (i.e., May 6, 2020) implementation date was requested in Energy Northwests letter dated February 25, 2019 (ADAMS Accession No. ML19057A549). The LAR dated April 15, 2020, requested that the NRC extend the implementation date to February 6, 2021.
Implementation periods or dates requested by licensees may vary based on the extent of the physical changes needed to the plant, the associated documentation that needs to be revised, and/or personnel training that is required. For example, sometimes licensees request that it be allowed to implement the amendment during the next refueling outage to support physical changes that the licensee wants to make when the plant is shut down.
Since the implementation period specified by the NRC in an amendment is considered part of the operating license, the licensee is required to fully implement the amendment by the date specified (i.e., by a date no later than that specified) or be in violation of its operating license.
Any extension of the implementation period requires prior NRC approval as a license amendment pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit.
3.0 TECHNICAL EVALUATION
By letter dated February 6, 2020, the NRC staff approved Amendment No. 255, which was to be implemented by May 6, 2020; however, due to unforeseen circumstances associated with the ongoing COVID-19 pandemic and the resulting impact on Columbia, Energy Northwest requested that implementation of this amendment not be required until February 6, 2021. As noted above, there are no specific regulatory requirements regarding the time period for amendment implementation and the NRC staff typically specifies an implementation period consistent with that requested in the application. Additionally, operation of the plant, while the implementation of Amendment No. 255 is extended, will have no impact on nuclear safety since the existing alignment of the control room air conditioning system, prior to Amendment No. 255, is adequate to perform its design function, and the subsequent implementation of that amendment will then add an additional layer of safety in the event of a design-basis event. The NRC staff finds that this change is administrative in nature, and therefore, acceptable.
This exigent amendment does not change the NRC staffs summary finding that Amendment No. 255, based on the licensees LAR, as supplemented, is acceptable and 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 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. Further, the NRC staff notes that after the implementation of Amendment No. 255, the change will provide maximum flexibility with regard to allowable control room air conditioning system cooling sources.
4.0 EXIGENT CIRCUMSTANCES
4.1 Background
The NRCs regulations contain provisions for issuance of amendments when the usual 30-day public comment period cannot be met. These provisions are applicable under exigent circumstances. Consistent with the requirements in 10 CFR 50.91(a)(6), exigent circumstances exist when: (1) a licensee and the NRC must act quickly; (2) time does not permit the NRC to publish a Federal Register notice allowing 30 days for prior public comment; and (3) the NRC determines that the amendment involves no significant hazards consideration. As discussed in the licensees application dated April 15, 2020, the licensee requested that the proposed amendment be processed by the NRC on an exigent basis.
Under the provisions in 10 CFR 50.91(a)(6), the NRC notifies the public in one of two ways:
(1) by issuing a Federal Register notice providing an opportunity for hearing and allowing at least 2 weeks from the date of the notice for prior public comments; or (2) by using local media to provide reasonable notice to the public in the area surrounding the licensees facility. In this case, the NRC published a public notice in the Tri-City Herald, located in Kennewick, Washington 99336 (https://www.tri-cityherald.com), a newspaper local to the licensees facility, from April 28, 2020, through April 30, 2020.
4.2 Licensees Basis for Exigency The licensee provided the following information to support its need for this exigent LAR. The licensee indicates that a State of Emergency was declared by the State of Washington on February 29, 2020, and that a national emergency was declared on March 13, 2020, by the Federal Government due to a pandemic related to COVID-19. Additionally, a Stay Home -
Stay Healthy proclamation was made by the State of Washington on March 23, 2020, due to the COVID-19 pandemic.
In order to support those governmental actions, only employees designated by the licensee as essential are physically reporting to the site, and the only work being performed are those activities that must be done to continue the safe operation of the plant while maintaining a focus on the health and safety of the plant employees. The implementation of Amendment No. 255 would require those individuals who are currently considered non-essential to be onsite, which would violate the government mandates described above.
Additionally, the licensee states that operation of the plant, while the implementation of Amendment No. 255 is extended, will have no impact on nuclear safety since the existing alignment of the control room air conditioning system, prior to Amendment No. 255, is adequate to perform its design function. Further, the subsequent implementation of the amendment will add an additional layer of safety in the event of a design-basis event and provide maximum flexibility with regard to allowable control room air conditioning system cooling sources.
4.3 NRC Staff Conclusion
Based on the above circumstances, the NRC staff finds that the licensee made a timely application for the proposed amendment following identification of the issue. In addition, the NRC staff finds that exigent circumstances exist in that the licensee and the NRC must act quickly and that time does not permit the NRC staff to publish a Federal Register notice allowing 30 days for prior public comment. Further, the NRC staff finds that the licensee could not avoid the exigency because the timeframe to implement Amendment No. 255 is near and due to unforeseen circumstances associated with the ongoing COVID-19 pandemic. Based on these findings, and the determination that the amendment involves no significant hazards consideration, as discussed below in Section 6.0, the NRC staff has determined that a valid need exists for issuance of the license amendment using the exigent provisions of 10 CFR 50.91(a)(6).
5.0 PUBLIC COMMENTS Under the provisions in 10 CFR 50.91(a){6), the NRC used local media and published a public notice in the Tri-City Herald located in Kennewick, Washington 99336 (https://www.tri-cityherald.com); a newspaper local to the licensees facility, from April 28, 2020, through April 30, 2020. The notice included the NRC staffs proposed no significant hazards consideration determination. The notice also provided an opportunity for public comment until May 1, 2020, regarding the NRC staffs proposed no significant hazards consideration determination. No public comments were received regarding the proposed amendment.
6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
As required by 10 CFR 50.91(a), in its application dated April 15, 2020, the licensee provided its analysis of the issue of no significant hazards consideration, which is presented below:
- 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment to implement a schedule extension is administrative in nature and does not require any physical plant modifications, physically affect any plant systems or components, or entail changes in plant operation. The amendment implementation schedule extension does not increase the probability or consequences of an accident previously evaluated in the Final Safety Analysis Report. The change in the implementation schedule of the Control Room Air Condition System License Amendment Request (LAR) will have no impact on the initiation or the consequences of any accidents previously evaluated.
Technical Specification requirements that govern operability or routine
testing of plant instruments are not assumed to be initiators of any analyzed event.
The change in implementation schedule will not increase the consequences of an accident since the existing plant configuration is in accordance with the plants design and licensing bases. All acceptance criteria continue to be met. Given the Novel Coronavirus Disease (COVID-19) pandemic precautions in place in Washington State, delay of implementation is the no risk option. Therefore, there is no significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?
Response: No.
There are no postulated hazards, new or different, contained in this amendment. The proposed amendment to the implementation schedule extension is administrative in nature and does not require any physical plant modifications, physically affect any plant systems or components, or entail changes in plant operation. Given the COVID-19 pandemic precautions in place in Washington State, delay of implementation is the no risk option. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment to the implementation schedule extension is administrative in nature and does not require any physical plant modifications, physically affect any plant systems or components, or entail changes in plant operation. The existing plant configuration maintains the required redundancy, diversity and capability to ensure plant design and licensing basis are met. Given the COVID-19 pandemic precautions in place in Washington State, delay of implementation is the no risk option. Therefore, the proposed change does not involve a significant reduction in the margin of safety.
The NRC staff reviewed the licensees no significant hazards consideration analysis. Based on the review and on the NRC staffs evaluation of the underlying LAR as discussed above, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.
7.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Washington State official was notified of the proposed issuance of the amendment on April 23, 2020. The State official had no comments.
8.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 made a final determination that no significant hazards consideration is involved for the proposed amendment as discussed above in Section 6.0 of this safety evaluation.
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.
9.0 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 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.
Principal Contributor: J. Klos Date: May 4, 2020
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NAME JKlos PBlechman VCusumano JWhitman DATE 04/22/2020 04/23/2020 04/23/2020 04/23/2020 OFFICE NRR/DSS/SCPB/BC*
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