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License Amendment Request for Adoption of Technical Specification Task Force (TSTF) - 425, Revision 3, Request for Additional Information
	ML15307A825
Person / Time
Site:	Columbia
Issue date:	11/03/2015
From:	Balwant Singal; Plant Licensing Branch IV
To:	Linda Williams; Energy Northwest
References
	MF6042
	Download: ML15307A825 (5)
	v • d • e

1 NRR-PMDAPEm Resource From: Singal, Balwant Sent: Tuesday, November 03, 2015 12:58 PM To:Williams, Lisa L.

Subject:

License Amendment Request for Adoption of Technical Specification Task Force (TSTF) - 425, Revision 3, Request for A dditional Information (CAC No. MF6042)

Attachments:

MF6042-RAI-STSB.docxBy letter dated March 17, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15093A178), Energy Northwest (the licensee) submitted a license amendment request (LAR) for adoption of TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." The U.S. Nuclear Regulatory Commission (NRC) requests the attached additional information to complete its review of the request.

Draft Request for Additional Information (RAI) were transmitted to the licensee by e-mail dated October 26, 2015. The NRC staff was informed by you on October 29 that a clarification call is not required. Please treat this e-mail as formal transmittal of RAIs.

You are requested to provide your response within 30 days from the date of this e-mail.

Thanks.

Balwant K. Singal Senior Project Manager (Comanche Peak and Columbia)

Nuclear Regulatory Commission

Division of Operating Reactor Licensing

Balwant.Singal@nrc.gov Tel: (301) 415-3016 Fax: (301) 415-1222

Hearing Identifier: NRR_PMDA Email Number: 2487 Mail Envelope Properties (Balwant.Singal@nrc.gov20151103125700)

Subject:

License Amendment Request for Adoption of Technical Specification Task Force (TSTF) - 425, Revision 3, Request for Additional Information (CAC No. MF6042) Sent Date: 11/3/2015 12:57:58 PM Received Date: 11/3/2015 12:57:00 PM From: Singal, Balwant Created By: Balwant.Singal@nrc.gov Recipients: "Williams, Lisa L." <llwilliams@energy-northwest.com> Tracking Status: None

Post Office: Files Size Date & Time MESSAGE 1044 11/3/2015 12:57:00 PM MF6042-RAI-STSB.docx 21825

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: ZZZ REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST (LAR) TO ADOPT TECHNICAL SPECIFICATION TASK FO RCE (TSTF) - 425, REVISION 3 COLUMBIA GENERATING STATION

By letter dated March 17, 2015 (Agencyw ide Documents Access and Management System (ADAMS) Accession No. ML15093A178), Energy Northwest (the licensee) submitted a license amendment request (LAR) for adoption of TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." The U.S. Nuclear Regulatory Commission (NRC) requests the following additional information to complete it s review of the request.

DRAFT REQUEST FOR ADDITIONAL IN FORMATION (RAI) (TECHNICAL SPECIFICATION BRANCH)

STSB-RAI-1 In Attachment-3, "Markup of Proposed Technical Specification Pages," of the LAR submittal, the licensee proposed to revise surveillance requirement (SR) 3.3.1.1.15 by changing the frequency from "24 months on a STAGGERED TEST BASIS" to "In accordance with the Surveillance Frequency C ontrol Program." The notes in SR 3.3.1.1.15 were not revised to reflect this change, and they still provide instruction concerning the "STAGGERED TEST BASIS." Since the STAGGERED TEST BASIS is part of the SR frequency that is being transferred to the Surveillance Frequency Control Program (SFCP), please justify why this information should remain in the SR notes. This RAI applies to both versions of the SR 3.3.1.1.15 revision that were submitted (i.e., "Prior to Implementation of PRNM [Power Range Neutron Monitoring]

Upgrade" and "After Implement ation of PRNM Upgrade").

STSB-RAI-2 In multiple technical specification (TS) sect ions of Attachment 3 (e.g., 3.2.4, 3.3.1.1, 3.3.1.3, 3.3.2.1, 3.

4.1, 3.10.8), the licensee provided two versions of page markups for the proposed SR revisions. The versions were titled, "Prior to Implementation of PRNM Upgrade" and "After Implementat ion of PRNM Upgrade." In the license submittal, there was no sufficient discussion concerning the r eason for submitting the two versions, and, and, in at least two cases, a "Prior" version of a revis ed SR was submitted with no corresponding "After" version (i.e

., TS sections 3.2.4 and 3.3.

1.3). Also, for the "After Implementation of PRNM Upgrad e" version of the SR revisions, the licensee did not submit TS bases.

Please provide the following: (1) a discussion of why two versions (i.e., "Prior" versus "After") of TS markups were s ubmitted, (2) a justif ication for not submitting both a "Prior" and "After" version for each proposed SR revi sion, and (3) the TS bases for the "After Implementation of PRNM Upgrade" SR revisions.

STSB-RAI-3 On marked-up TS bases page B 3.3.1.1-23 subm itted by the licensee, a reference to the "7 day frequency" still remains in the revised bases description for SR 3.3.1.1.2. Since, SR 3.3.1.1.2 is being incorporated into the SFCP, this represents erroneous information.

Please justify why this information should be retained in the TS bases or revise the bases description appropriately.

STSB-RAI-4 On marked-up TS bases page B 3.6.1.3-14 s ubmitted by the licensee, the following language associated with SR 3.6.1.3.8 was deleted:

The nominal 10 year interval is based on performance testing. Furthermore, any EFCV [excess flow check valve] failures will be

evaluated to determine if additional testi ng in that test interval is warranted to ensure overall reliability is maintained. Operating experience has

demonstrated that these components ar e highly reliable and that failures to isolate are very infrequent. Ther efore, testing of a representative sample was concluded to be accept able from a reliability standpoint (Reference 5).

Also, Reference 5 (i.e., NEDO-32977-A, "Excess Flow Check Valve Testing Relaxation," dated June 2000) was deleted from a list of references on page B 3.6.1.3-

16.

This deleted information relates directly to the basis for "representative sample," which is the language used in SR 3.6.1.3.8. The NRC staff issued a previous safety evaluation (SE) approving a Topical Report (i.e., Safety Evaluation by the Office of Nuclear Reactor Regulation Boiling Water Reactor Owners Group General Electric Nuclear Energy Topical Report B21-00658-01 "Excess Flow Check Valve Testing Relaxation; March 14, 2000") (ADAMS Accession No. ML003729011) that allows relaxation associated with the EFCV test ing (i.e., allowance of representative sampling). One of the staff's findings in the SE was that "representative sampling" needed to be defined, and it was acceptable to locate the definition in the TS bases. The exact wording deleted in the TS bases submittal was the same wording referenced in the SE. Also, the Reviewer's Note of NUREG-1433, Revision 4, "Standard Technical Specificat ions, General Electric BWR/

4 Plants, Revision 4.0," (ADAMS Accession No. ML12104A192) states that this information applies to the representative sample that is allo wed by this specification.

Since this change relates to representativ e sampling versus SR frequency, please provide a justification for removing this language from the TS bases or revise the submittal appropriately.