ML22301A143
| ML22301A143 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/28/2022 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Collis T Energy Northwest |
| References | |
| L-2022-LLA-0023 | |
| Download: ML22301A143 (5) | |
Text
From:
Mahesh Chawla Sent:
Friday, October 28, 2022 1:52 PM To:
Collis, Tracey M.
Cc:
Garcia, Richard M.; Jennifer Dixon-Herrity; Bob Pascarelli; Kristy Bucholtz; Todd Hilsmeier; Andrea Russell; Christopher Jackson; De Wu; Edmund Kleeh; Hanry Wagage; JS Hyslop; Keith Tetter; Michael Breach; Ming Li; Naeem Iqbal; Steve Wyman; Thinh Dinh; William Roggenbrodt
Subject:
Final - Request for Additional Information - Columbia Generating Station -
License Amendment Request to Adopt TSTF-505 - EPID L-2022-LLA-0023
Dear Ms Collis,
By letter dated February 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22034A992), Energy Northwest (the licensee) submitted a license amendment request (LAR) to amend Renewed Facility Operating License No. NPF-21 for Columbia Generating Station (Columbia). The proposed amendment would modify the Columbia Technical Specification (TS) requirements to permit the use of risk-informed completion times (RICTs) in accordance with Technical Specifications Task Force (TSTF) Traveler TSTF-505, Provide Risk-informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b, Revision 2 (ML18183A493). These RICTs would apply to certain actions required when limiting conditions for operation are not met. A regulatory audit was conducted from August 1, 2022, through August 4, 2022, during which the licensee addressed the audit questions and concerns submitted by the U.S. Nuclear Regulatory Commission (NRC) staff on July 6, 2022 (ML22165A296). During the audit, there were number of questions addressed by the licensee and closed out. For the remainder of the questions, licensee provided the response in a supplement dated October 4, 2022 (ML22277A603). During further review, the NRC staff has identified following additional information, which needs to be addressed, to complete the review of the subject application.
REQUEST FOR ADDITIONAL INFORMATION A Risk-Managed Technical Specifications (RMTS) program permits continued plant operation beyond the existing completion times (CTs) for certain TS Limiting Conditions for Operation (LCOs), provided risk is assessed and managed using the approach in Nuclear Energy Institute (NEI) Topical Report (TR) 06-09-A, Risk-Informed Technical Specifications Initiative 4b: Risk-Managed Technical Specifications (RMTS) Guidelines (ML122860402), approved by the NRC on May 17, 2007 (ML071200238). Limitation and Condition #2 delineated in NEI 06-09-A states, The LAR will provide identification of the TS LCOs and action requirements to which the RMTS will apply, with a comparison of the TS functions to the PRA [probabilistic risk assessment] modeled functions of the SSCs [structures, systems, and components]
subject to those LCO actions The comparison should justify that the scope of the PRA model are consistent [with the] licensing basis assumptions for each of the TS requirements, or an appropriate disposition or programmatic restriction will be provided.
Based on Table E1-1, In-scope TS/LCO Conditions to Corresponding PRA Functions, (Notes 1 and 6) of the Columbia TSTF-505 LAR dated February 3, 2022, it is NRC staffs understanding that the implementation items in LAR Attachment 5, Columbia
Generating Station RICT Program PRA Implementation Items, need to be completed to sufficiently calculate the risk-informed completion times (RICTs) for selected LCO conditions (e.g., those associated with LCO Conditions 3.3.1.1.A, 3.3.1.1.B, 3.3.5.1.F, and 3.3.5.1.G in LAR Table E1-1). However, the LAR does not provide a mechanism that will ensure the implementation items are completed prior to RICT program implementation. The staff requests the licensee to provide the following information.
(a) Clarify whether the implementation items in LAR Attachment 5 have been completed for the current base PRA model (e.g., PRA model of record) or the configuration risk monitor (CRM) model.
(b) If the implementation items in LAR Attachment 5 have been completed for the base PRA model and/or CRM model, then no additional information is needed.
Otherwise, the licensee should address one of the following:
(i) Provide a mechanism (e.g., add a license condition or specify in TS Section 5.5.16) that will ensure the implementation items in LAR are completed prior to RICT program implementation or appropriate RICT programmatic restrictions are taken until the implementation items are completed.
-OR-(ii) For those LCO Conditions in LAR Table E1-1 whose RICTs could be impacted by the implementation items in LAR Attachment 5, explain and justify how the associated RICTs will be appropriately (e.g.,
conservatively) calculated until the implementation items are completed,
-OR-(iii) Remove the applicable LCO Conditions from the scope of RICT.
A clarification call was held with your representatives on Wednesday, October 26, 2022, to discuss the resolution to address the NRC staffs concerns. After the call, you informed us that you can provide your response on the docket within 30 days. Therefore, we will look forward to your response in a supplement by November 28, 2020. Thanks Sincerely, Mahesh Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ph: 301-415-8371 Docket No. 50-483
OFFICE DORL/LPL4/PM DORL/LPL4/BC NAME MChawla JDixon-Herrity DATE 10/24/22 10/24/22
Hearing Identifier:
NRR_DRMA Email Number:
1818 Mail Envelope Properties (SA1PR09MB841571210EA6786E27C17577F1329)
Subject:
Final - Request for Additional Information - Columbia Generating Station -
License Amendment Request to Adopt TSTF-505 - EPID L-2022-LLA-0023 Sent Date:
10/28/2022 1:52:06 PM Received Date:
10/28/2022 1:52:06 PM From:
Mahesh Chawla Created By:
Mahesh.Chawla@nrc.gov Recipients:
"Garcia, Richard M." <rmgarcia@energy-northwest.com>
Tracking Status: None "Jennifer Dixon-Herrity" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Bob Pascarelli" <Robert.Pascarelli@nrc.gov>
Tracking Status: None "Kristy Bucholtz" <Kristy.Bucholtz@nrc.gov>
Tracking Status: None "Todd Hilsmeier" <Todd.Hilsmeier@nrc.gov>
Tracking Status: None "Andrea Russell" <Andrea.Russell@nrc.gov>
Tracking Status: None "Christopher Jackson" <Christopher.Jackson@nrc.gov>
Tracking Status: None "De Wu" <De.Wu@nrc.gov>
Tracking Status: None "Edmund Kleeh" <Edmund.Kleeh@nrc.gov>
Tracking Status: None "Hanry Wagage" <Hanry.Wagage@nrc.gov>
Tracking Status: None "JS Hyslop" <JS.Hyslop@nrc.gov>
Tracking Status: None "Keith Tetter" <Keith.Tetter@nrc.gov>
Tracking Status: None "Michael Breach" <Michael.Breach@nrc.gov>
Tracking Status: None "Ming Li" <Ming.Li@nrc.gov>
Tracking Status: None "Naeem Iqbal" <Naeem.Iqbal@nrc.gov>
Tracking Status: None "Steve Wyman" <Stephen.Wyman@nrc.gov>
Tracking Status: None "Thinh Dinh" <Thinh.Dinh@nrc.gov>
Tracking Status: None "William Roggenbrodt" <William.Roggenbrodt@nrc.gov>
Tracking Status: None "Collis, Tracey M." <tmcollis@energy-northwest.com>
Tracking Status: None Post Office:
SA1PR09MB8415.namprd09.prod.outlook.com
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