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| | issue date = 05/29/2014 | | | issue date = 05/29/2014 |
| | title = Response to Request for Additional Information Regarding License Amendment Request to Change Emergency Core Cooling Systems Surveillance Requirements | | | title = Response to Request for Additional Information Regarding License Amendment Request to Change Emergency Core Cooling Systems Surveillance Requirements |
| | author name = Javorik A L | | | author name = Javorik A |
| | author affiliation = Energy Northwest | | | author affiliation = Energy Northwest |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:ENERGY NORTHWEST Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509.377.8555 I F. 509.377.4150 aljavork@ | | {{#Wiki_filter:Alex L. Javorik ENERGY Columbia Generating Station P.O. Box 968, PE04 NORTHWEST Richland, WA 99352-0968 Ph. 509.377.8555 I F. 509.377.4150 aljavork@ energy-northwest.com MAY 2 9 2014 G02-14-088 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
| energy-northwest.com MAY 2 9 2014 G02-14-088 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 | |
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| ==Subject:== | | ==Subject:== |
| | COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS |
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| ==Reference:== | | ==Reference:== |
| | : 1. Letter, G02-13-151, dated October 31, 2013, AL Javorik (Energy Northwest) to NRC, "License Amendment Request for Change to Emergency Core Cooling Systems Surveillance Requirements" |
| | : 2. Letter, dated April 29, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Related to License Amendment Request for Change to Emergency Core Cooling Systems Surveillance p Requirements (TAC No. MF3055)" |
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| | ==Dear Sir or Madam:== |
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| COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS
| | By Reference 1, Energy Northwest requested approval of a license amendment request to revise Technical Specification (TS) Surveillance Requirements 3.5.1.4 and 3.5.2.5. |
| : 1. Letter, G02-13-151, dated October 31, 2013, AL Javorik (Energy Northwest) to NRC, "License Amendment Request for Change to Emergency Core Cooling Systems Surveillance Requirements" 2. Letter, dated April 29, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station -Request for Additional Information Related to License Amendment Request for Change to Emergency Core Cooling Systems Surveillance p Requirements (TAC No. MF3055)"
| | Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information. Attachment 1 provides the response to the requested information. |
| | This letter and its attachments contain no regulatory commitments. If there are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148. |
| | I declare under penalty of perjury that te and correct. |
| | Executed .ý- V,- I t A. L. Javorik Vice President, Engineering P~4iZL |
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| ==Dear Sir or Madam:==
| | RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Page 2 of 2 |
| By Reference 1, Energy Northwest requested approval of a license amendment request to revise Technical Specification (TS) Surveillance Requirements 3.5.1.4 and 3.5.2.5.Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information.
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| Attachment 1 provides the response to the requested information.
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| This letter and its attachments contain no regulatory commitments.
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| If there are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.
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| I declare under penalty of perjury that te and correct.Executed.ý- V,- I t A. L. Javorik Vice President, Engineering P~4iZL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Page 2 of 2
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| ==Attachment:== | | ==Attachment:== |
| | As stated cc: NRC RIV Regional Administrator, NRC NRR Project Manager NRC Senior .Resident Inspector/988C JO Luce - ESFEC (email) |
| | RR Cowley - WDOH (email) |
| | MA Jones - BPA/1.399 (email) |
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| | -4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Attachment 1 Page 1 of 2 NRC ReoUost: |
| | : 1. NEDO-33813, Revision 2, "Technical Specification Change Support for RHR/LPCI and LPCS Flow Rate Long-Term LOCA [Loss-of-Coolant Accident] |
| | Containment Response and ECCS [Emergency Core Cooling System]/Non-LOCA Evaluations," September 2013 (ADAMS Accession No. ML13316A010), |
| | Section 4.1.7, Refueling Operations and Spent Fuel Pool Cooling Assessment, states that refueling operations and spent fuel pool cooling may be affected if there is a reduction in the RHR heat exchanger heat removal capacity as a result of RHR/LPCI and LPCS flow rate reduction. NEDO-33813, Revision 2 also indicates that these evaluations were not included with the report, and that the assessments would be made by Energy Northwest outside of this report. |
| | Please provide the assessments for refueling operations and spent fuel pool cooling to determine acceptability. |
| | Energy Northwest Resmone: |
| | Three situations describe Columbia Generating Station's (Columbia's) refueling and spent fuel pool cooling operations: 1) the use of shutdown cooling for heat removal from the reactor core during refueling, 2) the use of the Fuel Pool Cooling (FPC) system during normal reactor operations and refueling outages to cool the spent fuel pool, and |
| | : 3) the use of the Residual Heat Removal (RHR) system to provide supplemental cooling during a full core offload. A discussion of the impact of the flow rate reduction for RHR on each situation is provided below. There is no impact from the flow rate reduction for the Low Pressure Core Spray (LPCS) system since it does not support refueling operations and spent fuel pool cooling. |
| | : 1. NEDO-33813 Sections 4.1.5 and 4.1.6 provide an evaluation of the impact of the change on the shutdown cooling and alternate shutdown cooling modes of operation of RHR. These evaluations are directly applicable during refueling operations while using shutdown cooling for decay heat removal of the reactor core given Columbia's configuration. |
| | 2, During normal reactor operation (non-outage) and refueling operations not involving a full core off load, the FPC system is designed to remove decay heat released from the stored spent fuel elements and maintain a specified fuel pool water temperature and water level. The RHR system is not credited for supplemental cooling of the spent fuel pool other than for a full core offload to the pool. |
| | : 3. During refueling, in the event of a full core offload, additional heat removal capacity is available from the B loop of the RHR system. To provide |
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| As stated cc: NRC RIV Regional Administrator, NRC NRR Project Manager NRC Senior .Resident Inspector/988C JO Luce -ESFEC (email)RR Cowley -WDOH (email)MA Jones -BPA/1.399 (email)
| | RESPONSE TO. REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Page 2 of 2 supplemental cooling to the spent fuel pool, the RHR flow is throttled to 5400-5600 gpm during system realignment and then is further limited to less than or equal to 3000 gpm during the FPC Assist mode. Since these flow rates are less than the new lower Technical Specification flow rate of 7200 gpm, the relaxed RHR flow rate has no adverse effect on the supplemental cooling to the spent fuel pool.}} |
| -4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Attachment 1 Page 1 of 2 NRC ReoUost: 1. NEDO-33813, Revision 2, "Technical Specification Change Support for RHR/LPCI and LPCS Flow Rate Long-Term LOCA [Loss-of-Coolant Accident]Containment Response and ECCS [Emergency Core Cooling System]/Non-LOCA Evaluations," September 2013 (ADAMS Accession No. ML 13316A010), Section 4.1.7, Refueling Operations and Spent Fuel Pool Cooling Assessment, states that refueling operations and spent fuel pool cooling may be affected if there is a reduction in the RHR heat exchanger heat removal capacity as a result of RHR/LPCI and LPCS flow rate reduction.
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| NEDO-33813, Revision 2 also indicates that these evaluations were not included with the report, and that the assessments would be made by Energy Northwest outside of this report.Please provide the assessments for refueling operations and spent fuel pool cooling to determine acceptability.
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| Energy Northwest Resmone: Three situations describe Columbia Generating Station's (Columbia's) refueling and spent fuel pool cooling operations:
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| : 1) the use of shutdown cooling for heat removal from the reactor core during refueling, 2) the use of the Fuel Pool Cooling (FPC) system during normal reactor operations and refueling outages to cool the spent fuel pool, and 3) the use of the Residual Heat Removal (RHR) system to provide supplemental cooling during a full core offload. A discussion of the impact of the flow rate reduction for RHR on each situation is provided below. There is no impact from the flow rate reduction for the Low Pressure Core Spray (LPCS) system since it does not support refueling operations and spent fuel pool cooling.1. NEDO-33813 Sections 4.1.5 and 4.1.6 provide an evaluation of the impact of the change on the shutdown cooling and alternate shutdown cooling modes of operation of RHR. These evaluations are directly applicable during refueling operations while using shutdown cooling for decay heat removal of the reactor core given Columbia's configuration.
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| 2, During normal reactor operation (non-outage) and refueling operations not involving a full core off load, the FPC system is designed to remove decay heat released from the stored spent fuel elements and maintain a specified fuel pool water temperature and water level. The RHR system is not credited for supplemental cooling of the spent fuel pool other than for a full core offload to the pool.3. During refueling, in the event of a full core offload, additional heat removal capacity is available from the B loop of the RHR system. To provide RESPONSE TO. REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Attachment 1 Page 2 of 2 supplemental cooling to the spent fuel pool, the RHR flow is throttled to 5400-5600 gpm during system realignment and then is further limited to less than or equal to 3000 gpm during the FPC Assist mode. Since these flow rates are less than the new lower Technical Specification flow rate of 7200 gpm, the relaxed RHR flow rate has no adverse effect on the supplemental cooling to the spent fuel pool.}}
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Letter Sequence Response to RAI |
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MONTHYEARGO2-13-151, NEDO-33813, Rev. 2, Technical Specification Change Support for Rhr/Lpci and LPCS Flow Rate. Long-Term LOCA Containment Response and ECCS/Non-LOCA Evaluations.2013-09-30030 September 2013 NEDO-33813, Rev. 2, Technical Specification Change Support for Rhr/Lpci and LPCS Flow Rate. Long-Term LOCA Containment Response and ECCS/Non-LOCA Evaluations. Project stage: Other ML13316A0092013-10-31031 October 2013 License Amendment Request for Change to Emergency Core Cooling Systems Surveillance Requirements Project stage: Request ML14038A0262014-02-0707 February 2014 NRR E-mail Capture - Acceptance Review Project stage: Acceptance Review ML14056A1202014-03-0505 March 2014 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML14111A0832014-04-29029 April 2014 Request for Additional Information, License Amendment Request to Modify Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: RAI ML14163A4822014-05-29029 May 2014 Response to Request for Additional Information Regarding License Amendment Request to Change Emergency Core Cooling Systems Surveillance Requirements Project stage: Response to RAI ML14192B0312014-08-13013 August 2014 Redacted, Request for Additional Information, Nrr/Dss/Scvb, Request to Modify Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: RAI ML14335A1892015-01-0707 January 2015 Redacted, Issuance of Amendment No. 229, Revise Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: Approval 2014-03-05
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Category:Letter
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan IR 05000397/20230042024-01-29029 January 2024 Integrated Inspection and Independent Spent Fuel Storage Installation Report 05000397/2023004 and 07200035/2023001 GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing ML24011A1522024-01-10010 January 2024 March 2024 Emergency Preparedness Exercise Inspection-Request for Information GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report ML23288A0002023-12-0707 December 2023 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 GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000397/20230122023-11-20020 November 2023 Commercial Grade Dedication Inspection Report 05000397/2023012 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV IR 05000397/20230102023-11-0909 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000397/2023010 IR 05000397/20230932023-11-0101 November 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023093 ML23299A2072023-10-26026 October 2023 Biennial Requalification Inspection Request for Information IR 05000397/20230032023-10-25025 October 2023 Integrated Inspection Report 05000397/2023003 IR 05000397/20230112023-10-0404 October 2023 License Renewal Phase 2 Report 05000397/2023011 IR 05000397/20234012023-09-11011 September 2023 Security Baseline Inspection Report 05000397/2023401 GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) ML24032A2182023-09-0101 September 2023 Information Request, Security IR 2024401 GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling IR 05000397/20230052023-08-22022 August 2023 Updated Inspection Plan for Columbia Generating Station (Report 05000397/2023005) - Mid Year Letter IR 05000397/20230022023-08-0101 August 2023 Integrated Inspection Report 05000397/2023002 GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 ML23206A2442023-07-25025 July 2023 Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation ML23143A1202023-06-27027 June 2023 Request Number 4ISI-11 to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Regarding Alternate Examination of Reactor Vessel Welds GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance ML23163A2502023-06-12012 June 2023 Summary of Changes and Analysis for Revision 41 of Plant Procedures Manual 13.8.1 Emergency Dose Projection System Operations GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report ML23157A2702023-06-0101 June 2023 4-2022-011 -022 Letter - OI Closure to Licensee IR 05000397/20230922023-06-0101 June 2023 NRC Inspection Report 05000397/2023092 and Preliminary White Finding IR 05000397/20230902023-06-0101 June 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023090 GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report IR 05000397/20230012023-05-0505 May 2023 Integrated Inspection Report 05000397/2023001 - April 26, 2023 GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications IR 05000397/20233012023-05-0101 May 2023 NRC Examination Report 05000397/2023301 GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report ML23110A2642023-04-20020 April 2023 Request for Information License Renewal Phase 2 Inspection GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report ML23013A0812023-03-15015 March 2023 Issuance of Amendment No. 270 Revision to Technical Specifications to Adopt TSTF 505, Revision 2, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 2024-01-08
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Alex L. Javorik ENERGY Columbia Generating Station P.O. Box 968, PE04 NORTHWEST Richland, WA 99352-0968 Ph. 509.377.8555 I F. 509.377.4150 aljavork@ energy-northwest.com MAY 2 9 2014 G02-14-088 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS
Reference:
- 1. Letter, G02-13-151, dated October 31, 2013, AL Javorik (Energy Northwest) to NRC, "License Amendment Request for Change to Emergency Core Cooling Systems Surveillance Requirements"
- 2. Letter, dated April 29, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Columbia Generating Station - Request for Additional Information Related to License Amendment Request for Change to Emergency Core Cooling Systems Surveillance p Requirements (TAC No. MF3055)"
Dear Sir or Madam:
By Reference 1, Energy Northwest requested approval of a license amendment request to revise Technical Specification (TS) Surveillance Requirements 3.5.1.4 and 3.5.2.5.
Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information. Attachment 1 provides the response to the requested information.
This letter and its attachments contain no regulatory commitments. If there are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.
I declare under penalty of perjury that te and correct.
Executed .ý- V,- I t A. L. Javorik Vice President, Engineering P~4iZL
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Page 2 of 2
Attachment:
As stated cc: NRC RIV Regional Administrator, NRC NRR Project Manager NRC Senior .Resident Inspector/988C JO Luce - ESFEC (email)
RR Cowley - WDOH (email)
MA Jones - BPA/1.399 (email)
-4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Attachment 1 Page 1 of 2 NRC ReoUost:
- 1. NEDO-33813, Revision 2, "Technical Specification Change Support for RHR/LPCI and LPCS Flow Rate Long-Term LOCA [Loss-of-Coolant Accident]
Containment Response and ECCS [Emergency Core Cooling System]/Non-LOCA Evaluations," September 2013 (ADAMS Accession No. ML13316A010),
Section 4.1.7, Refueling Operations and Spent Fuel Pool Cooling Assessment, states that refueling operations and spent fuel pool cooling may be affected if there is a reduction in the RHR heat exchanger heat removal capacity as a result of RHR/LPCI and LPCS flow rate reduction. NEDO-33813, Revision 2 also indicates that these evaluations were not included with the report, and that the assessments would be made by Energy Northwest outside of this report.
Please provide the assessments for refueling operations and spent fuel pool cooling to determine acceptability.
Energy Northwest Resmone:
Three situations describe Columbia Generating Station's (Columbia's) refueling and spent fuel pool cooling operations: 1) the use of shutdown cooling for heat removal from the reactor core during refueling, 2) the use of the Fuel Pool Cooling (FPC) system during normal reactor operations and refueling outages to cool the spent fuel pool, and
- 3) the use of the Residual Heat Removal (RHR) system to provide supplemental cooling during a full core offload. A discussion of the impact of the flow rate reduction for RHR on each situation is provided below. There is no impact from the flow rate reduction for the Low Pressure Core Spray (LPCS) system since it does not support refueling operations and spent fuel pool cooling.
- 1. NEDO-33813 Sections 4.1.5 and 4.1.6 provide an evaluation of the impact of the change on the shutdown cooling and alternate shutdown cooling modes of operation of RHR. These evaluations are directly applicable during refueling operations while using shutdown cooling for decay heat removal of the reactor core given Columbia's configuration.
2, During normal reactor operation (non-outage) and refueling operations not involving a full core off load, the FPC system is designed to remove decay heat released from the stored spent fuel elements and maintain a specified fuel pool water temperature and water level. The RHR system is not credited for supplemental cooling of the spent fuel pool other than for a full core offload to the pool.
- 3. During refueling, in the event of a full core offload, additional heat removal capacity is available from the B loop of the RHR system. To provide
RESPONSE TO. REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO CHANGE EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS Page 2 of 2 supplemental cooling to the spent fuel pool, the RHR flow is throttled to 5400-5600 gpm during system realignment and then is further limited to less than or equal to 3000 gpm during the FPC Assist mode. Since these flow rates are less than the new lower Technical Specification flow rate of 7200 gpm, the relaxed RHR flow rate has no adverse effect on the supplemental cooling to the spent fuel pool.