ML21273A167
| ML21273A167 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/22/2021 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID L-2020-LLA-0259 | |
| Download: ML21273A167 (1) | |
Text
November 22, 2021 Mr. Robert Schuetz Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352
SUBJECT:
COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT NO. 265 RE: ADOPTION OF TSTF-439, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO (EPID L-2020-LLA-0259)
Dear Mr. Schuetz:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 265 to Renewed Facility Operating License No. NPF-21 for the Columbia Generating Station. The amendment consists of changes to the Technical Specifications (TS) in response to Energy Northwests (the licensees) application dated December 2, 2020, as supplemented by letter dated August 20, 2021 The amendment revises the Columbia TSs to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], dated June 20, 2005 as described in the enclosed safety evaluation.
A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosures:
- 1. Amendment No. 265 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. 265 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 December 2, 2020, as supplemented by letter dated August 20, 2021, 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, 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. 265 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.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-21 and the Technical Specifications Date of Issuance: November 22, 2021 Jennifer L.
Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2021.11.22 07:25:22 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 265 COLUMBIA GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-21 DOCKET NO. 50-397 Replace the following pages of Renewed Facility Operating License No. NPF-21 and the 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 Specification REMOVE INSERT 1.3-2 1.3-2 1.3-3 1.3-3 1.3-6 1.3-6 1.3-7 1.3-7 3.8.1-2 3.8.1-2 3.8.1-3 3.8.1-3 3.8.7-1 3.8.7-1 3.8.7-2 3.8.7-2 3.8.7-3 3.8.7-4
Renewed License No. NPF-21 Amendment No. 265 (2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 265 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)
Deleted.
(12)
Deleted.
(13)
Deleted.
Completion Times 1.3 Columbia Generating Station 1.3-2 Amendment No. 149,169 225 259 1.3 Completion Times DESCRIPTION (continued) discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
a.
Must exist concurrent with the first inoperability; and b.
Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
a.
The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or b.
The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "
265
Completion Times 1.3 Columbia Generating Station 1.3-3 Amendment No. 149,169 225 259 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
265
Completion Times 1.3 Columbia Generating Station 1.3-6 Amendment No. 149,169 225 259 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Function X subsystem inoperable.
A.1 Restore Function X subsystem to OPERABLE status.
7 days B. One Function Y subsystem inoperable.
B.1 Restore Function Y subsystem to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C. One Function X subsystem inoperable.
AND One Function Y subsystem inoperable.
C.1 Restore Function X subsystem to OPERABLE status.
OR C.2 Restore Function Y subsystem to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 72 hours When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
265
Completion Times 1.3 Columbia Generating Station 1.3-7 Amendment No. 149,169 225 259 1.3 Completion Times EXAMPLES (continued)
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
EXAMPLE 1.3-4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more valves inoperable.
A.1 Restore valve(s) to OPERABLE status.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.
265
AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-2 Amendment No. 195,197,225 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)
A.2 Declare required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable.
AND A.3 Restore offsite circuit to OPERABLE status.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one division concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. One required DG inoperable.
B.1 Perform SR 3.8.1.1 for OPERABLE offsite circuit(s).
AND B.2 Declare required feature(s),
supported by the inoperable DG, inoperable when the redundant required feature(s) are inoperable.
AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) 265
AC Sources - Operating 3.8.1 Columbia Generating Station 3.8.1-3 Amendment No. 197,205 225 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)
B.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).
AND B.4.1 Restore required DG to OPERABLE status.
OR B.4.2.1 Establish risk management actions for the alternate AC sources.
AND B.4.2.2 Restore required DG to OPERABLE status.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours if not performed within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 72 hours from discovery of an inoperable DG 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 14 days 265
Distribution Systems - Operating 3.8.7 Columbia Generating Station 3.8.7-1 Amendment No. 149,169,225 254 258, 261 265 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems - Operating LCO 3.8.7 The following AC and DC electrical power distribution subsystems shall be OPERABLE:
a.
Division 1 and Division 2 AC electrical power distribution subsystems; b.
Division 1 and Division 2 125 V DC electrical power distribution subsystems; c.
Division 1 250 V DC electrical power distribution subsystem; and d.
Division 3 AC and DC electrical power distribution subsystems.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Division 1 or 2 AC electrical power distribution subsystem inoperable.
A.1 Restore Division 1 and 2 AC electrical power distribution subsystems to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> B. Division 1 or 2 125 V DC electrical power distribution subsystem inoperable.
B.1 Restore Division 1 and 2 125 V DC electrical power distribution subsystems to OPERABLE status.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> C. Required Action and associated Completion Time of Condition A or B not met.
C.1
NOTE-----------
---LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
Distribution Systems - Operating 3.8.7 Columbia Generating Station 3.8.7-2 Amendment No. 149, 169,225 254 258, 261
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Division 1 250 V DC electrical power distribution subsystem inoperable.
D.1 Declare associated supported feature(s) inoperable.
Immediately E. One or more Division 3 AC or DC electrical power distribution subsystems inoperable.
E.1 Declare High Pressure Core Spray System inoperable.
Immediately F.
Two or more divisions with inoperable electrical power distribution subsystems that result in a loss of function.
F.1 Enter LCO 3.0.3.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and indicated power availability to required AC and DC electrical power distribution subsystems.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 265 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 INTRODUCTION
By application dated December 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20337A141), as supplemented by letter dated August 20, 2021 (ADAMS Accession No. ML21235A222), Energy Northwest, (the licensee) requested changes to the Technical Specifications (TSs) for Columbia Generating Station (Columbia).
The amendment would revise the Columbia TSs to adopt with certain variances Technical Specifications Task Force (TSTF) Traveler TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], dated June 20, 2005 (ADAMS Accession No. ML051860296). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved the traveler on January 11, 2006 (ADAMS Accession No. ML060120272). Specifically, the amendment would delete second completion times (CTs) from the affected required actions contained in the TSs, would remove the example contained in TS 1.3, Completion Times, and would add a discussion about alternating between TS conditions.
The supplement letter dated August 20, 2021, provided additional information that clarified information in the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 26, 2021 (86 FR 7115).
2.0 REGULATORY EVALUATION
2.1
System Description
2.1.1 Completion Times The CT is the amount of time allowed for completing a required action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an action condition unless otherwise specified, provided the unit is in a mode or specified condition stated in the applicability of the LCO. Required actions must be completed prior to the expiration of the specified CT. An action condition remains in effect, and the required actions apply until the condition no longer exists or the unit is not within the LCO applicability.
The description section of Columbia TS 1.3 states, in part, that:
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
For certain required actions, a second completion time was included to establish a limit on the maximum time allowed for any combination of CTs that result in a single, continuous failure to meet the LCO. The intent of these second CTs, such as limits on the period of time from discovery of the failure to meet the LCOs discussed below, was to prevent repeated entry and exit from alternating TS required actions.
2.1.2 Alternating Current Sources - Operating The unit Class 1E alternating current (AC) electrical power distribution system sources consist of the offsite power sources and the onsite standby power sources (Diesel Generators 1, 2, and 3). The design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the engineered safety feature systems. TS 3.8.1, AC Sources - Operating, requires two qualified circuits between the offsite transmission network and the onsite Class 1E distribution system, and three separate and independent diesel generators (1, 2, and 3), to ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence or a postulated design-basis accident.
2.1.3 Distribution Systems - Operating Columbias onsite Class 1E AC and direct current (DC) electrical power distribution systems are divided by division into three independent AC and DC electrical power distribution subsystems.
The required AC and DC power distribution subsystems ensure the availability of AC and DC electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated design-basis accident. In accordance with TS 3.8.7, Distribution Systems - Operating, the Division 1, 2, and 3 AC and DC electrical power distribution subsystems are required to be OPERABLE.
2.2 Proposed Changes to the Technical Specifications The licensee proposed to delete the following statement from Example 1.3 in Columbia TS 1.3, Completion Times.:
Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.
The licensee proposed to revise TS Example 1.3-3 to eliminate the second CT for Required Actions A.1 and B.1 and to replace the discussion regarding the second completion time with the following:
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
The licensee also proposed to delete the second CTs associated with the following TS LCOs required actions:
TS 3.8.1, AC Sources - Operating, Required Actions A.3, B.4.1, and B.4.2.2 TS 3.8.7, Distribution Systems - Operating, Required Actions A.1 and B.1.
In addition, the licensee proposed to remove two notes specified in LCO 3.8.7. According to the licensee, these notes are obsolete. The licensee stated that:
NOTE 1 is result of a Change to Technical Specification Limiting Condition for Operation 3.8.7 (Exigent Circumstances), issued September 4, 2020 ([ADAMS Accession No.] ML20242A002).
NOTE 2 is result of Changes to Technical Specification Limiting Conditions for Operations 3.8.4 and 3.8.7 (Exigent Circumstances), issued May 12, 2020
([ADAMS Accession No.] ML20125A080).
2.3 Regulatory Requirements and Guidance 2.3.1 Technical Specification Requirements The NRCs regulatory requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, and require, in part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a production or utilization facility.
Specifically, the requirements for TS content in 10 CFR 50.36(c) include the following categories related to facility operation: (1) safety limits, limiting safety systems settings, and control settings; (2) LCOs; (3) surveillance requirements; (4) design features; and (5) administrative controls.
The regulation in 10 CR 50.36(c)(2)(i), states, in part:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The regulation in 10 CFR 50.36(c)(3), Surveillance requirements, states:
Surveillance requirements 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 limiting conditions for operation will be met.
The regulation in 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants (the maintenance rule), provides performance-based requirements to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.
2.3.2 Guidance The guidance that the NRC staff considered in its review of this license amendment request (LAR) dated December 2, 2020, as supplemented, included the following:
The NRC staffs guidance for the review of TSs is in Section 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the LWR nuclear designs. Since Columbia is a General Electric Plant (boiling water reactor (BWR)/6) facility, accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with NUREG-1434, Revision 4.0, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Specifications, and Volume 2, Bases, dated April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196), as modified by NRC-approved travelers.
Furthermore, in NUREG-1434, the guidance states, in part, that a second CT was included in the STSs for certain required actions to establish a limit on the maximum time allowed for any combination of conditions that would result in a single continuous failure to meet the LCO. The intent of the second CT was to preclude entry into and out of the actions for an indefinite period of time without meeting the LCO. The second CT provides a limit on the amount of time the LCO would not be met for various combinations of conditions. As explained above, TSTF-439, Revision 2, deletes these second CTs from the affected STS required actions.
3.0 TECHNICAL EVALUATION
3.1 Evaluation of Proposed Changes to Technical Specifications Second CTs (such as limits on the period of time from discovery of the failure to meet the LCO) were specified for the specified TSs to prevent repeated entry into and exit from alternating TS required actions. Administrative controls will replace second CTs as described in the LAR. In addition, two programs provide a strong disincentive to the licensee continuing operation with alternating required actions as described above. These programs are the maintenance rule program and the NRCs reactor oversight process (ROP).
Prior to the promulgation of 10 CFR 50.65 and the ROP, TSs were the primary requirements governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary, mitigate accidents and transients.
The maintenance rule and the ROP support this same goal by requiring a comprehensive process for performance and condition monitoring activities. As required by 10 CFR 50.65, the licensee assesses and manages the inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the CT for one system within an LCO is not generally affected by inoperable equipment in another LCO. However, the second CT influenced the CT for one system based on the condition of another system, but only if the two systems were required by the same LCO. As described in the LAR, the plant-specific maintenance rule program implements the risk-based configuration management program that augment the deterministic CTs in the TSs. The performance and condition monitoring activities required by 10 CFR 50.65, as further monitored by the ROP (also described in the LAR), identify poor maintenance practices that would result from multiple entries into the actions of the TSs, which could contribute to unacceptable unavailability of these SSCs.
The NRC staff finds the proposed changes to TS 1.3 acceptable because administrative control requirements added in Example 1.3-3 of the TSs would limit the maximum time allowed for any combination of conditions that results in a single contiguous occurrence of failing to meet the LCO and would ensure that CTs are not inappropriately extended. In addition, the licensees maintenance rule program requires the licensee to monitor the performance or conditions of SSCs in a manner sufficient to provide reasonable assurance that SSCs can fulfill their specified safety functions, and thus, prevent indefinite operation without restoration of the systems.
The licensees proposed change deletes the second CT associated with the following TS LCO Required Actions: TS 3.8.1, Required Actions A.3, B.4.1, and B.4.2.2; and TS 3.8.7, Required Actions A.1 and B.1. These additional second CTs were specified for these instances to prevent repeated entry and exit from alternating TS-required actions. Administrative controls will replace second CTs as described by the licensee in its LAR, as supplemented by letter dated August 20, 2021.
The NRC staff finds the proposed deletion of the second CTs listed above acceptable because multiple, continuous entries into TS conditions, without meeting the LCO, would be adequately controlled by the licensees administrative controls and configuration risk management programs, which were implemented to meet the requirements of the maintenance rule to assess and manage risk, and would be controlled by the use and application convention discussed in Section 1.3 of the TSs. In addition, the NRC staff finds that the ROP, coupled with the maintenance rule, provide adequate assurance against inappropriate use of combinations of TS conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, the NRC staff finds the proposed TS changes acceptable.
3.2 Evaluation of Variations The LAR identified variations from TSTF-439 associated with numbering differences and site-specific features for each of the second CTs requested to be deleted. One of the two specific variations concerns a plant-specific change to TS 3.8.1, Required Action A.3 CT, which was the result of Amendment No. 197 dated April 14, 2006, regarding the extension of diesel generator CT (ADAMS Accession No. ML061000672). The licensees supplement dated August 20, 2021, stated:
The design and engineered features that were rooted in the staffs approval for amendment 197 continue to remain integrated into Columbias design.
Enhancements that were realized through implementation of a series of commitments reflected in amendment 197 continue to remain an integral part of Columbias conduct of operations. Columbias commitment to the operational restrictions or requirements imposed on plant operation by Amendment 197 remains in place.
The second variation concerns TS LCO 3.8.7, Required Actions A.1 and B.1 CTs. The licensees detailed explanation as documented in its supplement dated August 20, 2021, compared the variation with the TSTF-439 bases versus its plant specific design features, and concluded that its performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the actions of the TS and unacceptable unavailability of these SSCs.
Based on the information in the licensees supplement, the NRC staff finds that the variations do not affect the applicability of TSTF-439, and since the licensee confirmed that Columbias commitment to the operational restrictions or requirements imposed on plant operation by Amendment 197 remains in place, the NRC staff finds the variations acceptable.
The NRC staff also finds the proposed administrative revision to TSs 3.8.4 and 3.8.7, which would remove two notes as stated in Section 2.2 of this safety evaluation, acceptable because these notes are obsolete.
3.3 Technical Evaluation Conclusion
The NRC staff reviewed the proposed changes to the TSs and determined that they meet the standards for TSs in 10 CFR 50.36 and are acceptable for the reasons described in Sections 3.1 and 3.2 of this safety evaluation. As required by 10 CFR 50.36(c)(2), the LCOs specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The proposed changes 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.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Washington State official was notified of the proposed issuance of the amendment on September 23, 2021. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of facility components 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 previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on January 26, 2021 (86 FR 7115), and there has been no public comment on such finding. 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 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: R. Grover Date: November 22, 2021
- via email OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC(A)*
NAME MChawla PBlechman NJordan DATE 09/29/2021 10/7/2021 9/20/2021 OFFICE OGC - NLO*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME JEzell JDixon-Herrity MChawla (SLee for)
DATE 11/10/2021 11/22/2021 11/22/2021