GO2-25-088, Supplement for License Amendment Request for Change to Technical Specification TSTF-65-A, Revision 1, Use of Generic Titles for Utility Positions
| ML25174A209 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/19/2025 |
| From: | David Brown Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-25-088 | |
| Download: ML25174A209 (1) | |
Text
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENT FOR LICENSE AMENDMENT REQUEST FOR CHANGE TO TECHNICAL SPECIFICATION TSTF-65-A, REVISION 1, USE OF GENERIC TITLES FOR UTILITY POSITIONS
References:
- 1. Letter from D.P. Brown (Energy Northwest) to NRC, License Amendment Request for Change to Technical Specification TSTF-65-A, Revision 1, Use of Generic Titles for Utility Positions, dated February 27, 2025 (ADAMS Accession Number ML25058A497)
- 2. Letter from D.P. Brown (Energy Northwest) to NRC, Supplement for Change to Revise Technical Specification TSTF-65-A, Revision 1, Use of Generic Titles for Utility Positions, dated April 1, 2025 (ADAMS Accession Number ML25091A193)
Dear Sir or Madam:
By Reference 1, Energy Northwest submitted an amendment request to the Columbia Generating Station (Columbia) Technical Specifications (TS). Energy Northwest submitted Reference 2 containing supplemental information to Reference 1.
Attachments 1 and 2 to this letter replace, in their entirety, the attachments in both References 1 and 2. The information provided in this supplement does not affect the Technical Analysis or No Significant Hazards Consideration conclusions contained in the license amendment request and does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.8385 dpbrown@energy-northwest.com
June 19, 2025 GO2-25-088 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 ENERGY NORTHWEST
GO2-25-088 Page 2 of 2 In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this supplement by transmitting a copy of this letter and attachments to the designated State Official.
This letter and its attachments contain no regulatory commitments.
If there are any questions or if additional information is needed, please contact Ms. T.M.
Collis, Licensing Supervisor, at 509-377-8395.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this ______ day of June 2025.
Respectfully, David P. Brown Site Vice President Attachments: 1. Proposed Columbia Technical Specification Changes (Mark-Up)
- 2. Proposed Columbia Technical Specification Changes (Clean Pages) cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector CD Sonoda - BPA EFSEC@efsec.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
GO2-25-088 Proposed Columbia Technical Specification Changes (Mark-Up)
(6 pages follow)
Responsibility 5.1 Columbia Generating Station 5.1-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The Plant General Manager plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
The Plant General Manager plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety.
5.1.2 The Shift Manager (SM) shall be responsible for the control room command function. During any absence of the SM from the control room while the unit is in MODE 1, 2, or 3, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.
During any absence of the SM from the control room while the unit is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.
Organization 5.2 Columbia Generating Station 5.2-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.
a.
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the FSAR or Operational Quality Assurance Program Description.
b.
The Plant General Manager plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c.
The Chief Executive Officer A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
d.
The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
5.2.2 Unit Staff The unit staff organization shall include the following:
a.
At least two Equipment Operators non-licensed operators shall be assigned when the unit is in MODES 1, 2, or 3; and at least one Equipment Operator non-licensed operator shall be assigned when the unit is in MODE 4 or 5.
b.
Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
Organization 5.2 Columbia Generation Station 5.2-2 Amendment 182,213 225 273 5.2 Organization 5.2.2 Unit Staff (continued) c.
An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d.
Deleted.
e.
The Operations operations Director director or Assistant assistant Operations operations Manager manager shall hold an SRO license.
f.
An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
Unit Staff Qualifications 5.3 Columbia Generation Station 5.3-1 Amendment 169,182 225 273 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS N18.1-1971, for comparable positions described in the FSAR, except for:
a.
The Operations operations Directordirector, who shall meet the requirements of ANSI/ANS N18.1-1971 with the exception that in lieu of meeting the stated ANSI/ANS requirement to hold a Senior Reactor Operator (SRO) license at the time of appointment to the position, the Operations operations Director director shall:
1.
Hold an SRO license at the time of appointment; 2.
Have held an SRO license; or 3.
Have been certified for equivalent SRO knowledge; and b.
The Radiation radiation Protection protection Managermanager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1-R, May 1977.
5.3.2 For the purpose of 10 CFR 55.4, a licensed SRO and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).
Programs and Manuals 5.5 Columbia Generating Station 5.5-1 Amendment 169,190 225 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.
5.5.1 Offsite Dose Calculation Manual (ODCM) a.
The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and b.
The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release reports required by Specification 5.6.1 and Specification 5.6.2.
c.
Licensee initiated changes to the ODCM:
1.
Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
(a)
Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s),
and (b)
A determination that the change(s) maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.
Shall become effective after review and acceptance by the Plant Operations Committee and the approval of the Plant General Manager plant manger; and 3.
Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.
High Radiation Area 5.7 Columbia Generating Station 5.7-2 Amendment 169,182 225 5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation)
(continued)
(ii)
Be under the surveillance, as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.
e.
Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.
5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation sources or from any surface penetrated by the radiation) a.
Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and in addition:
1.
All such door and gate keys shall be maintained under the administrative control of the Shift Supervisor, Radiation radiation Protection protection Managermanager, or his or her designee.
2.
Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b.
Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c.
Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.
GO2-25-088 Proposed Columbia Technical Specification Changes (Clean Pages)
(6 pages follow)
Responsibility 5.1 Columbia Generating Station 5.1-1 Amendment 149,169
5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety.
5.1.2 The Shift Manager (SM) shall be responsible for the control room command function. During any absence of the SM from the control room while the unit is in MODE 1, 2, or 3, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.
During any absence of the SM from the control room while the unit is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.
Organization 5.2 Columbia Generating Station 5.2-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.
a.
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the FSAR or Operational Quality Assurance Program Description.
b.
The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c.
A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
d.
The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
5.2.2 Unit Staff The unit staff organization shall include the following:
a.
At least two non-licensed operators shall be assigned when the unit is in MODES 1, 2, or 3; and at least one non-licensed operator shall be assigned when the unit is in MODE 4 or 5.
b.
Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
Organization 5.2 Columbia Generation Station 5.2-2 Amendment 182,213 225
5.2 Organization 5.2.2 Unit Staff (continued) c.
An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d.
Deleted.
e.
The operations director or assistant operations manager shall hold an SRO license.
f.
An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
Unit Staff Qualifications 5.3 Columbia Generation Station 5.3-1 Amendment 169,182 225
5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS N18.1-1971, for comparable positions described in the FSAR, except for:
a.
The operations director, who shall meet the requirements of ANSI/ANS N18.1-1971 with the exception that in lieu of meeting the stated ANSI/ANS requirement to hold a Senior Reactor Operator (SRO) license at the time of appointment to the position, the operations director shall:
1.
Hold an SRO license at the time of appointment; 2.
Have held an SRO license; or 3.
Have been certified for equivalent SRO knowledge; and b.
The radiation protection manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1-R, May 1977.
5.3.2 For the purpose of 10 CFR 55.4, a licensed SRO and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).
Programs and Manuals 5.5 Columbia Generating Station 5.5-1 Amendment 169,190
5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.
5.5.1 Offsite Dose Calculation Manual (ODCM) a.
The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and b.
The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release reports required by Specification 5.6.1 and Specification 5.6.2.
c.
Licensee initiated changes to the ODCM:
1.
Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
(a)
Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s),
and (b)
A determination that the change(s) maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.
Shall become effective after review and acceptance by the Plant Operations Committee and the approval of the plant manger; and 3.
Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.
High Radiation Area 5.7 Columbia Generating Station 5.7-2 Amendment 169,182
5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation)
(continued)
(ii)
Be under the surveillance, as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.
e.
Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.
5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation sources or from any surface penetrated by the radiation) a.
Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and in addition:
1.
All such door and gate keys shall be maintained under the administrative control of the Shift Supervisor, radiation protection manager, or his or her designee.
2.
Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b.
Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c.
Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.