ML23288A000
| ML23288A000 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/07/2023 |
| From: | Mahesh Chawla NRC/NRR/DORL/LPL4 |
| To: | Schuetz R Energy Northwest |
| Chawla M, NRR/DORL/LPL4 | |
| References | |
| EPID L-2023-LLA-006 | |
| Download: ML23288A000 (1) | |
Text
December 7, 2023 Mr. Robert Schuetz Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 Richland, WA 99352
SUBJECT:
COLUMBIA GENERATING STATION ISSUANCE OF AMENDMENT NO. 272 TO ADOPT TSTF-541, REVISION 2, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION (EPID L-2023-LLA-0063)
Dear Mr. Schuetz:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 272 to Renewed Facility Operating License No. NPF-21 for Columbia Generating Station. The amendment consists of changes to the Technical Specifications in response to your application dated March 27, 2023.
The amendment revises certain Surveillance Requirements (SRs) to add exceptions that consider the SR to be met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position. The revisions are consistent with Technical Specifications Task Force Traveler (TSTF)-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position.
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. 272 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. 272 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 March 27, 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. 272 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 120 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, 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: December 7, 2023 Jennivine K.
Rankin Digitally signed by Jennivine K. Rankin Date: 2023.12.07 18:23:35 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 272 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 3.5.1-5 3.5.1-5 3.5.2-5 3.5.2-5 3.5.3-3 3.5.3-3 3.6.4.3-2 3.6.4.3-2 3.7.1-3 3.7.1-3 3.7.2-1 3.7.2-1 3.7.3-3 3.7.3-3
Renewed License No. NPF-21 Amendment No. 272 (2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 272 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.
ECCS - Operating 3.5.1 Columbia Generating Station 3.5.1-5 Amendment No. 169,205,225,236 238 246 249 270 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.2
NOTE---------------------------
Not required to be met for system vent flow paths opened under administrative controls.
Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
In accordance with the Surveillance Frequency Control Program SR 3.5.1.3 Verify ADS accumulator backup compressed gas system average pressure in the required bottles is 2200 psig.
In accordance with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each ECCS pump develops the specified flow rate with the specified differential pressure between reactor and suction source.
DIFFERENTIAL PRESSURE BETWEEN REACTOR AND SYSTEM FLOW RATE SUCTION SOURCE LPCS 6200 gpm 128 psid LPCI 7200 gpm 26 psid HPCS 6350 gpm 200 psid In accordance with the INSERVICE TESTING PROGRAM SR 3.5.1.5
NOTE------------------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
RPV Water Inventory Control 3.5.2 Columbia Generating Station 3.5.2-5 Amendment No. 251 264 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.
In accordance with the Surveillance Frequency Control Program SR 3.5.2.5
NOTE------------------------------
- 1. Operation may be through the test return line.
- 2. Credit may be taken for normal system operation to satisfy this SR.
Operate the required ECCS injection/spray subsystem for 10 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.5.2.7
NOTE------------------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray subsystem can be manually operated, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
RCIC System 3.5.3 Columbia Generating Station 3.5.3-3 Amendment No. 238 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.5
NOTE------------------------------
Vessel injection may be excluded.
Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
SGT System 3.6.4.3 Columbia Generating Station 3.6.4.3-2 Amendment No. 169,199 225 238 239 251 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 15 continuous minutes with heaters operating.
In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.6.4.3.4 Verify each SGT filter cooling recirculation valve can be opened and the fan started, except for valves that are locked, sealed, or otherwise secured in the open position.
In accordance with the Surveillance Frequency Control Program
SW System and UHS 3.7.1 Columbia Generating Station 3.7.1-3 Amendment No. 149,169,225,236 238 270 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify the average water level in the UHS spray ponds is 432 feet 9 inches mean sea level.
In accordance with the Surveillance Frequency Control Program SR 3.7.1.2 Verify the average water temperature of each UHS spray pond is 77F.
In accordance with the Surveillance Frequency Control Program SR 3.7.1.3
NOTE------------------------------
Isolation of flow to individual components does not render SW subsystem inoperable.
Verify each SW subsystem manual, power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.
In accordance with the Surveillance Frequency Control Program SR 3.7.1.4 Verify average sediment depth in each UHS spray pond is < 0.5 ft.
In accordance with the Surveillance Frequency Control Program SR 3.7.1.5 Verify each SW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
HPCS SW System 3.7.2 Columbia Generating Station 3.7.2-1 Amendment No. 149,169 225 238 272 3.7 PLANT SYSTEMS 3.7.2 High Pressure Core Spray (HPCS) Service Water (SW) System LCO 3.7.2 The HPCS SW System shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. HPCS SW System inoperable.
A.1 Declare HPCS System inoperable.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1
NOTE------------------------------
Isolation of flow to individual components does not render HPCS SW System inoperable.
Verify each HPCS SW System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
In accordance with the Surveillance Frequency Control Program SR 3.7.2.2 Verify the HPCS SW System actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
CREF System 3.7.3 Columbia Generating Station 3.7.3-3 Amendment No. 199,207 225 238 239 272 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREF subsystem for 15 continuous minutes with the heaters operating.
In accordance with the Surveillance Frequency Control Program SR 3.7.3.2 Perform required CREF filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.3.3 Verify each CREF subsystem actuates on an actual or simulated initiation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.3.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 272 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 March 27, 2023 ADAMS Accession No. ML23086C103 December 7, 2023 Principal Contributors to Safety Evaluation Josh Wilson
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 (LAR, application). The proposed amendment is based on TSs Task Force (TSTF) Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A315), and the associated U.S. Nuclear Regulatory Commission (NRC, the Commission) staff safety evaluation (SE) for TSTF-541 (ML19323E926).
Limiting Conditions for Operation (LCOs) in the TSs identify the lowest functional capability or performance level of equipment required for safe operation of the facility. Surveillance requirements (SRs) 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 LCOs will be met. Several existing SRs require the licensee to verify that each train of specified trains actuates on an actual or simulated actuation signal.
When the trains actuate, valves and dampers within the trains will, if needed, reposition to their actuated position, which is the position appropriate to respond to the transient or accident that caused the actuation. The proposed amendment would eliminate the need to verify that a damper or valve has repositioned if the damper or valve is secured in its actuated position by adding a phrase to each SR as described in section 1.2 of this SE.
The proposed amendment is based on TSTF-541, Revision 2 and the associated NRC staff SE of TSTF-541. Section 1.1 of the NRC staffs SE of TSTF-541 discusses the reason for the proposed changes.
1.1 System Descriptions The emergency core cooling system (ECCS) is designed to limit the release of radioactive materials to the environment following a loss-of-coolant accident and consists of the high pressure core spray (HPCS) system, the low pressure core spray (LPCS) system, the low pressure coolant injection (LPCI) mode of the residual heat removal (RHR) system, and the automatic depressurization system. The purpose of SR 3.5.1.5 is to verify the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions on receipt of an actual or simulated actuation signal.
The reactor pressure vessel (RPV) contains penetrations below the top of the active irradiated fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced. Reduced decay heat removal could lead to elevated cladding temperatures and clad perforation. The purpose of SR 3.5.2.6 is to verify that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal. This is required to prevent RPV water inventory from dropping below the TAF, should an unexpected draining event occur. The purpose of SR 3.5.2.7 is to verify that an LPCI subsystem, or LPCS system, or HPCS system can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or condensate storage tank to the RPV.
The function of the reactor core isolation cooling (RCIC) system is to respond to transient events by providing makeup coolant to the reactor. The purpose of SR 3.5.3.5 is to verify the system operates as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions on receipt of an actual or simulated actuation signal.
The function of the standby gas treatment (SGT) system is to ensure that radioactive materials that leak from the primary containment into the secondary containment following a design-basis accident (DBA) are filtered and adsorbed prior to exhausting to the environment. The purpose of SR 3.6.4.3.3 is to verify that each SGT subsystem starts on receipt of an actual or simulated initiation signal. The purpose of SR 3.6.4.3.4 is to verify that the SGT filter cooling recirculation valve can be opened, and the fan started. This ensures that the ventilation mode of SGT system operation is available.
The standby service water (SW) system and ultimate heat sink are designed to provide cooling water for the removal of heat from equipment, such as the diesel generators, RHR pump coolers and heat exchangers, and room coolers for ECCS equipment, required for a safe reactor shutdown following a DBA or transient. The SW system also provides cooling to unit components, as required, during normal shutdown and reactor isolation modes. During a DBA, the equipment required only for normal operation is isolated and cooling is directed to only safety-related equipment. The purpose of SR 3.7.1.5 is to verify the systems will automatically switch to the position to provide cooling water exclusively to safety-related equipment during an accident.
The HPCS SW system provides cooling water for the removal of heat from components of the Division 3 HPCS system. The purpose of SR 3.7.2.2 is to verify that the automatic valves of the HPCS SW system will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety-related equipment on an actual or simulated initiation signal.
The control room emergency filtration (CREF) system provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The purpose of SR 3.7.3.3 is to verify that each subsystem starts and operates on an actual or simulated actuation signal.
1.2 Description of Proposed Changes to Adopt TSTF-541 In accordance with NRC staff approved TSTF-541, the licensee proposed to revise certain SRs by adding exceptions to the SRs for automatic valves or dampers that are locked, sealed, or otherwise secured in the actuated position. The proposed revisions, therefore, allow the licensee to meet the LCOs without having to test for actuation of those values or dampers that are already secured in the actuated position. Specifically, the licensee proposed the following changes to adopt TSTF-541. The proposed new text is shown in italics.
SR 3.5.1.5 Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.5.2.6, Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated actuation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.5.2.7, Verify the required ECCS injection/spray subsystem can be manually operated, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.5.3.5 Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.6.4.3.4 Verify each SGT filter cooling recirculation valve can be opened and the fan started, except for valves that are locked, sealed, or otherwise secured in the open position.
SR 3.7.1.5 Verify each SW subsystem actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.2.2 Verify the HPCS SW System actuates on an actual or simulated initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.3.3 Verify each CREF subsystem actuates on an actual or simulated initiation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
1.3 Additional Proposed TS Changes In addition to the changes proposed consistent with the traveler discussed in section 1.2 of this SE, the licensee proposed the following variations.
1.3.1 Editorial Variations The licensee noted that Columbia TSs have different numbering and nomenclature than standard technical specifications (STS).
1.3.2 Other Variations The licensee did not propose changes to all SRs in STS modified by TSTF-541. The LAR indicates that the Columbia TS do not require modification of all the equivalent SRs affected by TSTF-541.
The licensee identified a variation from changes approved in TSTF-541 in which the exception inserted into certain SRs would be applied to Columbia SRs 3.5.2.6 and 3.5.2.7. Columbia SRs 3.5.2.6 and 3.5.2.7 had not been incorporated into the version of STS on which TSTF-541 was based.
Columbia TSs contain a Surveillance Frequency Control Program (SFCP).
2.0 REGULATORY EVALUATION
The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires that:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information.] The Commission may include such additional technical specifications as the Commission finds appropriate.
Additionally, under 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The considerations for issuance of operating licenses in 10 CFR 50.57(a)(3) provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public. The LAR asks for changes to SRs, which are controlled by 10 CFR 50.36(c)(3) (saying that SRs 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 LCOs will be met). Accordingly, the amended SRs that no longer require verification of valves and dampers already in, and secured in, their actuated positions, must continue to provide reasonable assurance that the LCOs will be met and the other standards of 10 CFR 50.36(c)(3) will be met.
The NRC staffs guidance for the review of TSs is 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 STS for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the NRC, Standard Technical Specifications, General Electric BWR [Boiling Water Reactor]/6 Plants NUREG 1434, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, dated September 2021 (ML21271A582 and ML21271A596, respectively), as modified by NRC-approved travelers.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes to Adopt TSTF-541 The NRC staff compared the licensees proposed TS changes in section 1.2 of this SE against the changes approved in TSTF-541. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-541 are applicable to Columbias TSs because Columbia is a General Electric BWR and the NRC staff approved the TSTF-541 changes for BWR designs. Therefore, the NRC staff concludes that the licensees proposed changes to the Columbia TSs in section 1.2 of this SE are consistent with TSTF-541.
As defined in TS 1.1, a train shall be operable:
when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
The proposed SRs would exclude the need to verify actuation of dampers and valves that do not, in fact, actuate (e.g., change position) in response to an actuation signal. The licensees LAR contains the following statements:
While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic valve or damper in the actuated position to be considered operable. As stated in the SR 3.0.1 Bases, Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the SRs.
Energy Northwest acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position. However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the valve or damper in the actuated position, then the system cannot perform its specified safety function and is inoperable regardless of whether the SR is met.
Energy Northwest acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the valve or damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a valve or damper and the specified Frequency of the SR is exceeded without testing the component, the SR must be performed on the component when it is returned to service in order to meet the SR.
Given the statements provided on the docket to adopt TSTF-541, the NRC staff determined that there is reasonable assurance that the licensee will continue to properly control affected equipment in accordance with existing regulations and requirements when using the exceptions added to the respective SRs.
The amended SRs will continue to require the licensee to verify that valves and dampers that must actuate perform their safety functions and support functions by being able to change position. The NRC staff finds that it is not necessary to verify actuation of valves and dampers that are already in their actuated positions, and are locked, sealed, or otherwise secured in those positions.
Therefore, the NRC staff determined that the amended Columbia TSs will continue to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide reasonable assurance that necessary quality of systems and components is maintained and that the LCOs will be met.
3.2 Additional Proposed TS Changes 3.2.1 Editorial The licensee noted that Columbia TSs have different numbering and nomenclature than STS.
The NRC staff finds that the different TS numbering and nomenclature changes are acceptable because they do not substantively alter TS requirements.
3.2.2 Other Variations The NRC staff reviewed the variations from TSTF-541 changes described in section 1.3.2 of this SE.
The licensee did not propose changes to all SRs in STS modified by TSTF-541. The LAR indicates that the Columbia TSs do not require modification of all the equivalent SRs affected by TSTF-541. The NRC staff determined that this does not affect the applicability of TSTF-541 to the TSs and is acceptable.
The licensee identified a variation from changes approved in TSTF-541 in which the exception inserted into certain SRs would also be applied to Columbia SR 3.5.2.6 and SR 3.5.2.7.
Columbia SR 3.5.2.6 and SR 3.5.2.7 had not been incorporated into the version of STS on which TSTF-541 was based. The NRC staff reviewed the variation from changes approved in TSTF-541 in which the exception inserted into certain SRs would be applied to Columbia SR 3.5.2.6 and SR 3.5.2.7. The NRC staff determined that SR 3.5.2.6 and SR 3.5.2.7, which were proposed for addition to the TSs via TSTF-542, had not been incorporated into the version of STS on which TSTF-541 was based because these SRs were created after TSTF-541 development began.
The NRC staff determined that these SRs are similar to the type of SRs included in TSTF-541, and the proposed changes are equivalent. Specifically, the proposed changes to these SRs would exclude the need to verify actuation or repositioning of valves that do not that do not need to actuate or reposition to perform their safety function in response to an actuation signal because they are secured in a position where they are already performing their safety function.
The amended SRs would still require the licensee to verify that the affected valves and dampers that must reposition to perform their safety functions and support functions are able to change position when they are not locked in their actuated position.
The NRC staff reviewed the justification provided in TSTF-541, and the associated NRC staff SE, and found that it was equally applicable to the proposed changes to these SRs. Therefore, the proposed changes for SR 3.5.2.6 and 3.5.2.7 are acceptable to the NRC staff for the same reasons discussed in section 3.1 of this SE. Specifically, the NRC staff finds that it is not necessary to verify actuation or repositioning of valves that are locked, sealed, or otherwise secured in their actuated positions for these SRs.
Additionally, the NRC staff reviewed the licensees statement regarding the Columbia SFCP and determined that the existence of a SFCP in the Columbia TSs has no effect on the applicability of the proposed change and is, therefore, acceptable.
3.3 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. 272 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 March 27, 2023 ADAMS Accession No. ML23086C103 December 7, 2023
1.0 INTRODUCTION
Energy Northwest (the licensee) requested changes to the technical specifications (TSs) for Columbia Generating Station (Columbia) by license amendment request (LAR, application). The proposed amendment is based on TSs Task Force (TSTF) Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (TSTF-541) (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML19240A315), and the associated U.S. Nuclear Regulatory Commission (NRC, the Commission) staff safety evaluation of TSTF-541 (ML19323E926).
2.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Washington, State official was notified of the proposed issuance of the amendment on October 11, 2023. The State official had no comments.
3.0 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 and changes surveillance requirements. 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 June 13, 2023 (88 FR 38551), 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.
- concurrence by email NRR-058 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC (A)*
NAME MChawla PBlechman SMehta DATE 10/23/2023 10/17/2023 10/30/2023 OFFICE OGC*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME BVaisey JRankin MChawla DATE 11/16/2023 12/7/2023 12/7/2023