GO2-20-071, Response to Request for Additional Information Related to Exigent License Amendment Request for One-Time Change to Completion Times for Inoperable Electrical Distribution Systems
| ML20114E280 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/23/2020 |
| From: | Schuetz R Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-20-071 | |
| Download: ML20114E280 (4) | |
Text
Robert E. Schuetz Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.2425 l F. 509.377.4150 reschuetz@energy-northwest.com GO2-20-071 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXIGENT LICENSE AMENDMENT REQUEST FOR ONE-TIME CHANGE TO COMPLETION TIMES FOR INOPERABLE ELECTRICAL DISTRIBUTION SYSTEMS
References:
- 1. Letter from R.E. Schuetz (Energy Northwest) to NRC, Exigent License Amendment Request for One-Time Change to Completion Times for Inoperable Electrical Distribution Systems, dated April 15, 2020 (ADAMS Accession Number ML20107G972)
- 2. Email from John Klos (NRC) to Rick Garcia (Energy Northwest),
Official release of NRC RAIs for Columbia COVID exigent due Friday April 24, 2020, dated April 21, 2020
Dear Sir or Madam:
By Reference 1 Energy Northwest submitted an exigent license amendment request for a one-time change to the completion times for Columbia Generating Station Technical Specification required actions 3.8.4.G.1, 3.8.7.A.1 and 3.8.7.B.1. By Reference 2 the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. The enclosure to this letter contains the requested information.
Energy Northwest further clarifies in the commitment attached to Reference 1, the reference to Section 3.2.3.4 should be Section 3.3.
The No Significant Hazards Consideration Determination (NSHCD) provided in the original submittal is not altered by this submittal. No new commitments are being made by this letter or the enclosure. If there are any questions or if additional information is needed, please contact Mr. R. M. Garcia, Licensing Supervisor, at 509-377-8463.
April 23, 2020 ENERGY NORTHWEST
GO2-20-071 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed this ______ day of April 2020.
Respectfully, R. E. Schuetz Site Vice President
Enclosure:
As stated cc:
NRC RIV Regional Administrator NRC Senior Resident Inspector/988C NRC NRR Project Manager CD Sonoda - BPA/1399 (email)
EFSECutc.wa.gov - EFSEC (email)
E Fordham - WDOH (email)
R Brice - WDOH (email)
L Albin - WDOH (email)
GO2-20-071 Enclosure Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)
NRC REQUEST RAI:
By letter dated April 15, 2020 (Agencywide Documents Access management System (ADAMS) Accession No ML20107G972), Energy Northwest (the licensee) requested an exigent amendment to Operating License NPF-21 of Columbia Generating Station (Columbia). The proposed amendment would revise the Technical Specification (TS) 3.8.4 DC (Direct Current) Sources - Operating and TS 3.8.7 Distribution Systems -
Operating. This request adds a one-time extension for TS Required Actions 3.8.4.G.1, 3.8.7.A.1, and 3.8.7.B.1 completion time, specifically associated with Division 2 4160 V AC (Alternating Current) and 125 V DC electrical power distribution inoperability.
The following request for additional information is needed to complete the NRCs review of the Columbia exigent license amendment request (LAR).
Regulatory Requirements:
General Design Criterion (GDC) 17, Electric power systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, states in part that an onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.
GDC 18, Inspection and Testing of Electric Power Systems, requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.
RAI In the third paragraph of Section 2.4.1 of the LAR, the licensee stated that a bucket could be changed in approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> including the following approximate tasks and durations, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to verify job conditions and establish clearance order control, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the actual electrical work, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of job closeout and removal of clearances and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of post modification testing. However, in the first paragraph of Section 2.4.1, the licensee stated that it will take approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to replace the bucket and the starter coil. Please explain the discrepancy.
GO2-20-071 Enclosure Page 2 of 2 ENERGY NORTHWEST RESPONSE TO RAI:
The last sentence of the first paragraph in Section 2.4.1 of the LAR was meant to explain that the bucket replacement of approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> bounds the 2-hour starter coil (WMA-42-8F1E) replacement activity.