ML23083B401

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Issuance of Amendment No. 271 to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
ML23083B401
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/27/2023
From: Mahesh Chawla
Plant Licensing Branch IV
To: Schuetz R
Energy Northwest
Chawla M
References
EPID L-2022-LLA-0081
Download: ML23083B401 (1)


Text

April 27, 2023 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. 271 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-580, PROVIDE EXCEPTION FROM ENTERING MODE 4 WITH NO OPERABLE RHR SHUTDOWN COOLING (EPID L-2022-LLA-0081)

Dear Mr. Schuetz:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 271 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 your application dated May 25, 2022, as supplemented by letter dated March 9, 2023.

The amendment would revise Columbia Generating Station TS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, in accordance with Technical Specifications Task Force (TSTF) Traveler TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling. Specifically, the proposed changes provide a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

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. 271 to NPF-21
2. Safety Evaluation
3. Notices and Environmental Findings cc: Listserv

ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 271 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 May 25, 2022, as supplemented by letter dated March 9, 2023, 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. 271 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: April 27, 2023 Jennifer L.

Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2023.04.27 16:00:42 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 271 RENEWED FACILITY OPERATING LICENSE NO. NPF-21 COLUMBIA GENERATING STATION 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 3.4.9-1 3.4.9-1 3.4.9-2 3.4.9-2 3.4.9-3 3.4.9-3

Renewed License No. NPF-21 Amendment No. 271 (2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 271 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.

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 Columbia Generating Station 3.4.9-1 Amendment No. 169,187 225 263 271 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.


NOTES-------------------------------------------

1.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

2.

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for performance of Surveillances.

APPLICABILITY:

MODE 3 with reactor steam dome pressure less than 48 psig.

ACTIONS


NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR shutdown cooling subsystem inoperable.

A.1 Verify an alternate method of decay heat removal is available.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and associated Completion Time of Condition A not met.

B.1 Initiate action to restore RHR shutdown cooling subsystem to OPERABLE status.

Immediately

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 Columbia Generating Station 3.4.9-2 Amendment No. 164,169 225 238 246 263 271 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Two RHR shutdown cooling subsystems inoperable.

C.1 Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter D. Required Action and associated Completion Time for Condition C not met.


NOTE--------------------

LCO 3.0.3 and all other LCO Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

Immediately E. No RHR shutdown cooling subsystem in operation.

AND No recirculation pump in operation.

E.1 Initiate action to restore one RHR shutdown cooling subsystem or one recirculation pump to operation.

AND E.2 Verify reactor coolant circulation by an alternate method.

AND E.3 Monitor reactor coolant temperature and pressure.

Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 Columbia Generating Station 3.4.9-3 Amendment No. 246 271 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1


NOTE------------------------------

Not required to be met until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after reactor steam dome pressure is less than 48 psig.

Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control Program SR 3.4.9.2


NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is < 48 psig.

Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 271 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 Application (i.e., initial and supplements)

Safety Evaluation Date May 25, 2022, ML22145A465 March 9, 2023, ML23068A300 April 27, 2023 Principal Contributor to Safety Evaluation Ravi Grover

1.0 PROPOSED CHANGE

S Energy Northwest (the licensee) requested changes to the technical specifications (TSs) for Columbia Generating Station (Columbia) by license amendment request (application), dated May 25, 2022, as supplemented by letter dated March 9, 2023. The proposed changes would revise TS 3.4.9, Residual Heat Removal (RHR)] Shutdown Cooling System - Hot Shutdown, based on TSs Task Force (TSTF) Traveler TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21025A232), and the associated U.S.

Nuclear Regulatory Commission (NRC, the Commission) staff safety evaluation (SE) of TSTF-580 (ML21188A227). In its application, the licensee requested that the NRC process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP).

Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to less than or equal to 212 degrees Fahrenheit.

This decay heat is removed by the RHR shutdown cooling system in preparation for performing refueling or maintenance operations, or for keeping the reactor in the hot or cold shutdown condition.

The reactor coolant system design for Columbia consists of two redundant, manually controlled shutdown cooling subsystems of the RHR system to provide decay heat removal. Each loop consists of motor-driven pumps, a heat exchanger, and associated piping and valves. The RHR heat exchangers transfer heat to the service water system. Some piping and heat exchangers that are passive components may be common to both subsystems.

The Columbia TS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable in Mode 3, with the reactor steam dome pressure less than less than 48 pounds per square inch gauge (psig). The limiting condition for operation (LCO) requires two operable RHR shutdown cooling subsystems and, if no recirculation pump is in operation, then at least one RHR shutdown cooling subsystem needs to be in operation.

1.1 Proposed TS Changes to Adopt TSTF-580 In accordance with NRC staff approved TSTF-580, the licensee proposed changes that would revise Columbias TS 3.4.9. Specifically, the licensee proposed the following changes to adopt TSTF-580:

Condition A is changed to be limited to a single inoperable subsystem by revising it to state: One required RHR shutdown cooling subsystem inoperable with a Required Action to Verify an alternate method of decay heat removal is available.

Condition B addresses situations when Required Action A.1 and associated completion time (CT) are not met. The plural (s) is deleted in Required Action B.1 as a conforming change to Condition A, which now addresses a single inoperable RHR shutdown cooling subsystem.

A new Condition C is added, which addresses two RHR shutdown cooling subsystems inoperable with a Required Action C.1 to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem. The new Condition C Required Action has a CT of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.

A new Condition D is added to address situations when new Required Action C.1 and associated CT are not met. New Required Action D.1 requires action be initiated to restore one RHR shutdown cooling subsystem to operable status immediately. Required Action D.1 is modified by a note that states that LCO 3.0.3 and all other LCO Required Actions requiring a mode change to Mode 4 may be suspended until one RHR shutdown cooling subsystem is restored to operable status.

Existing Condition C and associated Required Actions are renumbered as Condition E due to the new Conditions C and D.

The application provides additional information as follows, TSTF-580 makes additional changes to the Actions of TS 3.4.9 that were revised by TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, which is consistent with the NRC staffs approval of TSTF-580. The TSTF-580 justification states that adoption is dependent on previous adoption of TSTF-566-A, which was implemented at Columbia on March 4, 2021.

1.2 Additional Proposed TS Changes The application states that Energy Northwest is not proposing any variations from the TS changes described in TSTF-580 or the applicable parts of the NRC SE dated July 11, 2021.

2.0 REGULATORY EVALUATION

The regulation at paragraph 50.36(c)(2) of Title 10 of the Code of Federal Regulations (10 CFR) requires that TSs include LCOs. Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The NRC staffs guidance for the review of TSs is provided in chapter 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),

March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard TSs (STSs) for each of the LWR nuclear designs.

Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the STSs, as modified by NRC approved travelers.

Traveler TSTF-580 revised the STSs related to RHR shutdown cooling system. The NRC approved TSTF-580 under the CLIIP on July 11, 2021 (ML21188A283).

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-580 The NRC staff compared the licensees proposed TS changes in section 1.1 of this SE against the changes approved in TSTF-580. In accordance with SRP, chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-580 are applicable because Columbia is a boiling-water reactor (BWR) design plant, and the NRC staff approved the TSTF-580 changes for BWR designs. The NRC staff finds that the licensees proposed changes, as stated in section 1.1 of this SE are consistent with those found acceptable in TSTF-580.

In the SE of TSTF-580, the NRC staff concluded that TSTF-580 changes to STS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, Condition A, Required Actions A.1 and B.1, and new Condition C, Required Action C.1 and associated CTs were acceptable because these changes preserve the existing requirements and do not alter the way the TSs are implemented. Therefore, the NRC staff finds these changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) by providing remedial actions for when the LCO is not met.

The NRC staff also concluded that TSTF-580 proposed addition of new Condition D to STS 3.4.9 is acceptable, because, without an operable RHR shutdown cooling subsystem and in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition within the CT. Under this condition, remaining in Mode 3 allows fission product decay heat and other residual heat from the reactor core to be transferred at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary will not be exceeded. The CT reflects the importance of restoring a normal path for heat removal. The NRC staff finds that proposed new Condition D and associated Required Action D.1 and CT, are acceptable because they provide appropriate remedial actions if the LCO is not met and, therefore, continues to meet the requirements of 10 CFR 50.36(c)(2)(i).

3.1.1 Conclusion The NRC staff finds that the proposed changes to Columbia TS LCO 3.4.9 are acceptable because remedial actions continue to be required when the LCO is not met and provide adequate protection of the health and safety of the public. Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) as discussed in section 3.0 of the NRC staffs SE of TSTF-580.

3.2 TS Change Consistency The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with chapter 16.0 of the SRP and are therefore acceptable.

4.0 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.

NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. 271 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 Application (i.e., initial and supplements)

Safety Evaluation Date May 25, 2022, ML22145A465 March 9, 2023, ML23068A300 April 27, 2023

1.0 INTRODUCTION

Energy Northwest (the licensee) requested changes to the technical specifications (TSs) for Columbia Generating Station (Columbia) by license amendment request (application), dated May 25, 2022, as supplemented by letter dated March 9, 2023. The proposed changes would revise TS 3.4.9, Residual Heat Removal (RHR)] Shutdown Cooling System - Hot Shutdown, based on TSs Task Force (TSTF) Traveler TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21025A232), and the associated U.S.

Nuclear Regulatory Commission (NRC, the Commission) staff safety evaluation (SE) of TSTF-580 (ML21188A227). In its application, the licensee requested that the NRC process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP).

The supplemental letter dated March 9, 2023, provided additional information that clarified 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 August 9, 2022 (87 FR 48516).

2.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Washington State official was notified of the proposed issuance of the amendment on March 3, 2023. The State official had no comments.

3.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirements 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 previously issued a proposed finding that the amendment involves no significant hazards consideration, which was published in the Federal Register on

August 9, 2022 (87 FR 48516), 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.

SUBJECT:

COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT NO. 271 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-580, PROVIDE EXCEPTION FROM ENTERING MODE 4 WITH NO OPERABLE RHR SHUTDOWN COOLING (EPID L-2022-LLA-0081) DATED APRIL 27, 2023 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrDssStsb Resource RidsNrrLAPBlechman Resource RidsNrrPMColumbia Resource RidsRgn4MailCenter Resource RGrover, NRR ADAMS Accession No.: ML23083B401

  • concurrence via email OFFICE NRR/DORL/LPL4/PM*

NRR/DORL/LPL4/LA*

NRR/DSS/STSB/BC*

NAME MChawla PBlechman VCusumano DATE 3/29/2023 3/27/2023 12/16/2022 OFFICE OGC NRR/DORL/LPL4/BC*

NRR/DORL/LPL4/PM*

NAME MCarpenter JDixon-Herrity MChawla DATE 4/24/2023 4/25/2023 4/27/2023