GO2-24-056, Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing

Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing

ML24164A214
Person / Time
Site:	Columbia
Issue date:	06/11/2024
From:	Hauger J Energy Northwest
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GO2-24-056
Download: ML24164A214 (1)

Text

Jeremy S. Hauger Columbia Generating Station P.O. Box 968, PE30 Richland, WA 99352-0968 509.377.8727 jshauger@energy-northwest.com GO2-24-056 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RELIEF REQUEST FOR THE COLUMBIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(z)(1), Energy Northwest hereby requests U.S. Nuclear Regulatory Commission (NRC) approval of the attached relief request for the fourth ten-year interval of the Inservice Testing (IST) Program at Columbia Generating Station (Columbia). The details of the 10 CFR 50.55a request are included as an attachment to this letter.

Energy Northwest requests relief due to alternatives providing an acceptable level of quality and safety.

Approval of the relief request is requested by April 1, 2025. Approval of the relief request is required prior to the start of refueling outage R-27. Once approved, the relief request shall be implemented within 30 days.

There are no regulatory commitments made in this submittal.





 

June 11, 2024 ENERGY NORTHWEST

GO2-24-056 Page 2 of 2 If you have any questions or require additional information, please contact Mr. R. M. Garcia at 509-377-8463.

Executed this ______ day of ___________, 2024.

Respectfully, Jeremy S. Hauger Vice President, Engineering

Attachment:

Relief Request 4IST-12 cc:

NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH





 





DocuSigned by:

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GO2-24-056 Attachment Page 1 of 5 Relief Request 4IST-12 RV05: Valve Position Indication Testing Frequency Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Components Affected Affected Valve Class Cat.

Function System CSP-V-93 2

A CONTAINMENT ISOLATION CONTAINMENT SUPPLY PURGE CSP-V-96 2

A CSP-V-97 2

A CSP-V-98 2

A PI-VX-250*

2 A

PROCESS INSTRUMENTATION PI-VX-251*

2 A

PI-VX-253*

2 A

PI-VX-256*

2 A

PI-VX-257*

2 A

PI-VX-259*

2 A

PSR-V-X73/1 2

A PRIMARY SAMPLING RADIOACTIVE PSR-V-X73/2 2

A PSR-V-X77A/1 1

A PSR-V-X77A/2 1

A PSR-V-X77A/3 1

A PSR-V-X77A/4 1

A PSR-V-X80/1 2

A PSR-V-X80/2 2

A PSR-V-X82/1 2

A PSR-V-X82/2 2

A PSR-V-X82/7 2

A PSR-V-X82/8 2

A PSR-V-X83/1 2

A PSR-V-X83/2 2

A PSR-V-X84/1 2

A PSR-V-X84/2 2

A PSR-V-X88/1 2

A PSR-V-X88/2 2

A TIP-V-1*

2 A

TRAVERSING IN-CORE PROBE TIP-V-2*

2 A

TIP-V-3*

2 A

TIP-V-4*

2 A

TIP-V-5*

2 A

TIP-V-15 2

A

• Relief is requested for only the close position verification testing frequency; the open position verification will remain on a two-year testing frequency.





 

GO2-24-056 Attachment Page 2 of 5

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition, including the 2005 and 2006 addenda.

3. Applicable Code Requirements

ASME OM Code Subsection ISTC-3700, Position Verification Testing, states, Valves with remote position indicators shall be observed locally at least once every 2 yr.

[years] to verify that valve operation is accurately indicated.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (a)(3), relief is requested from the requirement of ASME OM Code ISTC-3700 for the valves identified in Section 1 of this submittal. Specifically, Energy Northwest requests relief from performing the verification position indication (VPI) testing at the two-year frequency mandated by ISTC-3700. The basis of the relief is that the proposed alternative would provide an acceptable level of quality and safety.

The valves listed in Section 1 are containment isolation valves classified as Category A per ISTC-1300, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants. The subject valves have a safety function to close to isolate containment during a loss of coolant accident requiring containment isolation. These solenoid-operated valves are designed such that the position of the valve is not locally observable; the coil position is internal to the valve body and is not visible in either the energized or de-energized state.

ISTC-3700 contains an allowance that states, Where local observation is not possible, other indications shall be used for verification of valve operation. The VPI test method used at Columbia is a pressure test utilizing local leak rate testing (LLRT) equipment.

This method involves pressurizing the containment penetration volume to approximately 38 psi, and verifying the penetration remains pressurized while the valve is indicating closed on the main control room panel. The valve is then opened using the control switch in the main control room. The increase in flowrate is measured, along with the valve position indicating open in the main control room. This method satisfies the requirement for position indication verification and ensures that the indicating system accurately reflects the valve position.

The VPI test at Columbia is performed concurrently with the LLRT since both tests utilize the same testing equipment. To properly complete the testing, each individual valve must have its system thoroughly drained, vented, and aligned correctly, which results in unnecessary radiation exposure, as well as a significant impact to Operations and Maintenance personnel time. Decreasing the frequency of the VPI





 

GO2-24-056 Attachment Page 3 of 5 testing would result in dose savings and reductions in both staff labor and plant component manipulations.

5. Proposed Alternative and Basis for Use

As an alternative to the ISTC-3700 test interval of at least once every two years, Energy Northwest proposes that the VPI testing of the valves listed in Section 1 be performed in conjunction with the LLRT at a frequency in accordance with 10 CFR 50, Appendix J, Option B. Energy Northwest was approved to utilize this performance-based option for the Primary Containment Leakage Rate Testing (CLRT) Program in NRC letter dated March 30, 2018 (ADAMS Accession Number ML18052B185).

Option B of 10 CFR 50, Appendix J, permits the extension of the Appendix J seat leakage testing to a frequency corresponding to the specific valve performance.

Valves whose leakage test results indicate good performance may have their testing interval increased based on these test results, not to exceed 75 months.

Columbias CLRT Program, which implements Appendix J, Option B, requires individual containment isolation valves to pass two successful as-found seat leakage tests before it can be placed on extended seat leakage testing frequency. In the event a valve cannot meet test criteria, there is Appendix J leakage, or a VPI test failure, then the surveillance would be reset to the base frequency of 24 months. Only after three consecutive as-found tests in consecutive refueling outages with acceptable results would the frequency be returned to an extended interval. Table 1 below shows successful test results from the most recent refueling outages, demonstrating good performance of the valves.

Table 1.

Affected Valve Leakage Admin.

Limit (sccm) 2021 As-Found Leakage (sccm) 2021 VPI Result 2023 As-Found Leakage (sccm) 2023 VPI Result CSP-V-93 148 96 Pass 79 Pass CSP-V-96 148 140 Pass 27 Pass CSP-V-97 148 90 Pass 2

Pass CSP-V-98 148 95 Pass 125 Pass PI-VX-250 148 2

Pass 2

Pass PI-VX-251 148 6

Pass 4

Pass PI-VX-253 450 27.5 Pass 30 Pass PI-VX-256 148 1

Pass 2

Pass PI-VX-257 148 2

Pass 2

Pass PI-VX-259 450 1

Pass 2

Pass PSR-V-X73/1 450 59 Pass 106 Pass PSR-V-X73/2 450 199 Pass 277 Pass PSR-V-X77A/1 750 0

Pass 2

Pass PSR-V-X77A/2 750 33 Pass 53 Pass





 

GO2-24-056 Attachment Page 4 of 5 Table 1 continued.

Affected Valve Leakage Admin.

Limit (sccm) 2021 As-Found Leakage (sccm) 2021 VPI Result 2023 As-Found Leakage (sccm) 2023 VPI Result PSR-V-X77A/3 750 2

Pass 96 Pass PSR-V-X77A/4 750 18 Pass 33 Pass PSR-V-X80/1 450 133 Pass 124 Pass PSR-V-X80/2 450 214 Pass 255 Pass PSR-V-X82/1 148 9

Pass 2

Pass PSR-V-X82/2 148 3

Pass 2

Pass PSR-V-X82/7 450 45 Pass 28 Pass PSR-V-X82/8 450 58 Pass 60 Pass PSR-V-X83/1 450 50 Pass 30 Pass PSR-V-X83/2 450 46 Pass 24 Pass PSR-V-X84/1 450 16 Pass 169 Pass PSR-V-X84/2 450 28 Pass 311 Pass PSR-V-X88/1 148 2

Pass 2

Pass PSR-V-X88/2 148 1

Pass 3

Pass TIP-V-1 110 5

Pass 6

Pass TIP-V-2 110 36 Pass 35 Pass TIP-V-3 110 13 Pass 15 Pass TIP-V-4 110 4

Pass 6

Pass TIP-V-5 110 9

Pass 86 Pass TIP-V-15 110 23 Pass 43 Pass In addition to the VPI and seat leakage testing, each of the valves listed in Section 1 is exercised on a quarterly frequency. The valve stroke times are measured and compared to the ASME OM Code acceptance criteria, providing further data for station personnel to use for assessing the health of the valves. This multi-faceted approach to testing provides the station ample opportunity to assess valve performance. Therefore, the ability to detect valve degradation is not jeopardized by performing the VPI testing at the same frequency as specified by Appendix J, Option B. This frequency of testing provides reasonable assurance of the operational readiness of the valves and provides an acceptable level of quality and safety.

6. Duration of Proposed Relief Alternative The proposed alternative will be utilized for the remainder of the fourth ten-year IST Program interval, which began on December 13, 2014, and ends on December 12, 2025.





 

GO2-24-056 Attachment Page 5 of 5

7. Precedent The following similar relief requests for Beaver Valley, Fermi, and Palo Verde were approved by the NRC.

Request Number VRR3 for Beaver Valley Units 1 and 2 was approved by the NRC by letter dated February 7, 2012 (ADAMS Accession Number ML120270298).

Request Numbers VRR-012 and VRR-013 for Fermi Units 1 and 2 were approved by the NRC by letter dated March 7, 2018 (ADAMS Accession Number ML17354B002).

Request Number VRR-01 for Palo Verde Units 1, 2, and 3 was approved by the NRC by letter dated November 13, 2019 (ADAMS Accession Number ML19310F679).