GO2-05-057, Emergency Technical Specification Change Request for One-Time Extension of Completion Time for Limiting Condition for Operation Condition 3.5.1.B

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Emergency Technical Specification Change Request for One-Time Extension of Completion Time for Limiting Condition for Operation Condition 3.5.1.B
ML050870461
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 03/23/2005
From: Atkinson D
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-05-057
Download: ML050870461 (23)
v • d • e


Text

E ENERGY W NORTHWEST People -Vision*Solutions P.O. Box 968

  • Richland, WA
  • 99352-0968 March 23, 2005 G02-05-057 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B

Dear Sir or Madam:

Energy Northwest is submitting herein a proposed extension to the Completion Time for Condition B of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.5.1, UECCS - Operating." Condition B addresses the condition of an inoperable High Pressure Core Spray (HPCS) system. Columbia is currently in Condition B due to an inoperable HPCS system. This one-time Completion Time extension to 17 days is being requested pursuant to 10 CFR 50.91 (a)(5) to avoid an unnecessary plant shutdown. The current 14-day Completion Time expires at 0943 on March 30, 2005.

Technical Specification LCO 3.5.1 Condition D requires plant operators to place Columbia in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if the restoration of

,/-the HPCS system cannot be accomplished within the 14-day Completion Time of LCO 3.5.1.B.

Efforts are in progress to perform necessary repairs and return the HPCS pump to service. At this time, the repairs are on schedule to be completed within the current 14-day Completion Time. However, as a contingency, an additional 3 days, for a total Completion Time of 17 days, is being requested should unexpected delays occur during the repairs and subsequent operability testing.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Page 2 of 3 On March 16 at 0943, Energy Northwest personnel removed the HPCS system from service to investigate a possible oil leak. During this maintenance activity, a degraded air deflector that functions to cool the pump motor was discovered. Engineering personnel determined that, in order to restore HPCS to operable status, replacement of the air deflector and other identified maintenance tasks were necessary. This discovery was reported to NRC pursuant to 10CFR 50.72(b)(3)(v)(D) (ref: EN 41499).

The scope of the maintenance and the time needed to procure the required parts has challenged to ability of Energy Northwest to restore the HPCS system to an operable status within the current limits of the Technical Specifications. Therefore, Energy Northwest requests approval of this license amendment application on an emergency basis by March 30, 2005 at 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> PST in order to avoid an unnecessary plant shutdown.

This request for a one-time Completion Time extension has been closely modeled after a similar request submitted by the South Texas Project Nuclear Operating Company on January 6, 2005. The NRC approved the South Texas Project request by letter dated January 10, 2005.

If the restoration of the HPCS system is achieved within the current 14-day Completion Time, Energy Northwest will promptly notify NRC and withdraw the proposed license amendment request.

The Columbia Plant Operations Committee and Corporate Nuclear Safety Review Board have reviewed the proposed change to the Technical Specifications.

In accordance with 10 CFR 50.91(b), Energy Northwest is notifying the State of Washington of this request for license amendment by providing a copy of this letter and its attachments.

The commitments made in this submittal are delineated in Attachment 4. If there are any questions regarding this submittal, please contact Greg Cullen, Licensing Supervisor, at phone number (509) 377-6105.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 23, 2005.

Respectfully, DK Atkinson Vice President, Nuclear Generation Mail Drop PE08

Enclosure:

Evaluation of the proposed changes Attachments:

1. Proposed Technical Specifications Changes (mark-up)
2. Proposed Technical Specifications pages (retyped)
3. Changes to Technical Specifications Bases
4. List of Regulatory Commitments cc: BS Malleft- NRC RIV BJ Benney- NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin -Winston & Strawn JO Luce - EFSEC RR Cowley - WDOH

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 1 of 10 Evaluation of Proposed Changes

1.0 DESCRIPTION

This submittal is a request to amend Operating License NPF-21 for Columbia Generating Station (Columbia). The proposed amendment would revise the Completion Time of Limiting Condition for Operation (LCO) 3.5.1 "ECCS - Operating" Condition B from 14 to 17 days, on a one-time basis. This completion time extension is being requested to allow additional time, if needed, to restore the High Pressure Core Spray System (HPCS) to operable status following required maintenance on the HPCS pump motor.

This request for a one-time Completion Time extension has been closely modeled after a similar request submitted by the South Texas Project Nuclear Operating Company on January 6, 2005. The NRC approved the South Texas Project request by letter dated January 10, 2005.

On March 16 at 0943 PST, Energy Northwest personnel removed the HPCS System from service to investigate a possible oil leak. During this maintenance activity, a degraded air deflector that functions to direct air internal to the pump motor was discovered. Engineering personnel determined that, in order to restore HPCS to operable status, replacement of the air deflector and other identified maintenance tasks would be necessary. This discovery was reported to NRC pursuant to 10 CFR 50.72(b)(3(v)(D) (ref: EN 41499).

Efforts are in progress to perform the identified maintenance tasks and restore the HPCS System to operable status. The Action specified in LCO 3.5.1.B requires restoration of the HPCS System to operable status within 14 days with the plant in Mode 1,2, or 3. If this cannot be accomplished, Technical Specification LCO 3.5.1 Condition D requires plant operators to place Columbia in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Repairs are currently scheduled to be completed within the current 14-day Completion Time. However, as a contingency, an additional 3 days, for a total Completion Time of 17 days, is being requested should unexpected delays occur during the performance of the motor maintenance tasks and subsequent operability testing.

The scope of the maintenance and the time needed to procure the required parts has challenged to ability of Energy Northwest to restore the HPCS system to an operable status within the current limits of the Technical Specifications. Therefore, Energy Northwest requests approval of this license amendment application on an emergency basis by March 30, 2005 at 0800 PST in order to avoid an unnecessary shutdown of Columbia.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 2 of 10 2.0 Proposed Change Energy Northwest proposes to extend, on a one-time basis, the Completion Time of Technical Specifications LCO 3.5.1 Condition B by a period of 3 days for a total Completion Time of 17 days. This change is proposed to be implemented by the addition of a footnote to the current 14-day Completion Time of LCO 3.5.1 Condition B.

The footnote would read as follows:

"On a one-time basis, the COMPLETION TIME for an inoperable HPCS System is extended to 17 days. This one-time extension expires on April 3, 2005."

A marked-up copy of proposed change to the Technical Specifications is provided in . A typed version of the revised Technical Specification is provided as .

Upon approval of the proposed license amendment, Energy Northwest would implement a change to the applicable Technical Specifications Bases to add the same footnote to the bases and an additional footnote that would read as follows:

"The one time extension to 17 days is based upon a risk assessment performed in accordance with Regulatory Guide 1.174 and selected risk management compensatory measures."

A marked-up copy of proposed change to the Technical Specifications Bases is provided in Attachment 3.

3.0 BACKGROUND

3.1 Reason for requesting change on an emergenc basis On March 16 at 0943 PST, Energy Northwest personnel removed the HPCS System from service to investigate a possible oil leak. During this maintenance activity, a degraded air deflector that functions to direct air internal to the pump motor was discovered. Engineering personnel determined that, in order to restore HPCS to operable status, replacement of the air deflector and other identified maintenance tasks would be necessary. The time required to perform the required maintenance could potentially exceed the Completion Time specified in the Technical Specifications.

The change in risk associated with the extension of the Completion Time is small and should be balanced against the risk associated with the alternative of shutting down the plant to effect the repairs. While not quantifiable at Columbia (Columbia does not have a quantitative transition and shutdown model), there are risks associated with manually shutting the plant down from a stable condition (a manual shutdown for Columbia has been evaluated to be an Incremental Conditional Core Damage Probability (ICCDP) of 2E-6). They include challenging systems that are currently in standby and requiring the

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 3 of 10 operation of the decay heat removal systems. Therefore, the risk impact of the proposed one-time Technical Specification change is low and the risk associated with the proposed request is preferable to the risk associated with a plant shutdown.

3.2 Condition that the proposed amendment is intended to resolve At this time, replacement of the air deflector and the performance of the other identified maintenance tasks associated with the HPCS pump motor are scheduled to be completed within the current 14-day Completion Time. The proposed license amendment would provide additional time should unexpected delays occur during the performance of this maintenance and subsequent testing that would require more than the current 14-day Completion Time.

4.0 TECHNICAL ANALYSIS

4.1 System Description The Emergency Core Cooling System (ECCS) is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA). The ECCS uses two independent methods (flooding and spraying) to cool the core during a LOCA. The ECCS network is composed of the High Pressure Core Spray (HPCS) System, the Low Pressure Core Spray (LPCS) System, and the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System. The ECCS also consists of the Automatic Depressurization System (ADS). The suppression pool provides the required source of water for the ECCS. Although no credit is taken in the safety analyses for the Condensate Storage Tanks (CSTs), they are capable of providing a source of water for the HPCS System.

The HPCS System consists of a single motor driven pump, a spray sparger above the core, and piping and valves to transfer water from the suction source to the sparger.

Suction piping is provided from the CSTs and the suppression pool. HPCS pump suction is normally aligned to the CST water source to minimize injection of suppression pool water into the RPV. However, ifthe CST water supply is low or the suppression pool level is high, an automatic transfer to the suppression pool water source ensures a water supply for continuous operation of the HPCS System. The HPCS System is designed to provide core cooling over the full range of RPV pressures (0 psid to 1160 psid, vessel to drywell). Upon receipt of an initiation signal, the HPCS pump automatically starts and valves in the flow path begin to open. Since the HPCS System is designed to operate over the full range of expected RPV pressures, HPCS flow begins as soon as the necessary valves start to open. Full flow test lines are provided to route water to the CST or suppression pool to allow testing of the HPCS System during normal operation without spraying water into the RPV.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 4 of 10 The Automatic Depressurization System (ADS) consists of 7 of the 18 Safety Relief Valves (SRVs). It is designed to provide depressurization of the primary system during a small break LOCA if HPCS fails or is unable to maintain required water level in the RPV. The ADS operation reduces the RPV pressure to within the operating pressure range of the low pressure ECCS subsystems, so that these subsystems can provide core cooling.

4.2 PRA Analysis An assessment of the change in Columbia's core damage frequency (CDF) due to extension of the Technical Specification LCO 3.5.1 Condition B Completion Time from 14 days to 17 days was performed. This assessment was performed with Columbia's Probabilistic Risk Assessment (PRA) model. The PRA model is an at-power model which includes both internal and external events. The current causal analysis of the HPCS inoperability has not identified any common cause issues that would impact any other system.

4.3 Requlatorv Guide 1.174 Evaluation Because the extended HPCS out-of-service condition is limited in time, the Incremental Core Damage Frequency (CDF) and the Incremental Large Early Release Frequency (LERF) are multiplied by the expected 3-day extension of the Completion Time to obtain a conditional probability. The conditional probability is treated as an Incremental Conditional Core Damage Probability (ICCDP) and Incremental Conditional Large Early Release Probability (ICLERP) for the evaluation against RG 1.174. [The PRA evaluation for extending the Completion Time an additional 3 days was performed assuming "zero maintenance" for that time.]

The table below depicts the acceptance criteria of Regulatory Guide (RG) 1.174 and the results calculated for the proposed change.

ACDF/yr ALERF/yr CCDP Total CD1 ICLERP Total LERFE Columbia before proposed change 2.80E-5/yr 7.69E-6/yr Results with 3 days additional HPCS 7.82E-7 2.88E-5/yr 2.59E-8 7.72E-6/yr AOT RG 1.174 Criteria (Acceptance Guidelines <1 .E- <1.DE <1.OE-05/yr Region 1ll) 014E0 <.O-7y1rE05y Note 1: The total CDF and LERF are calculated by aggregating the Internal, Fire, and Seismic events.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 5 of 10 The incremental risk values are within the criteria of Region III (where the increase in risk is considered "very small") established in RG 1.174.

4.4 RG 1.182 Evaluation RG 1.182 and RG 1.160 are used in conjunction with NUMARC 93-01 as standards for implementation of 10 CFR 50.65 (Maintenance Rule). Section 11.3.7.2 of NUMARC 93-01 includes recommended quantitative risk action thresholds for maintenance activities, as reproduced in the table below:

Incremental Incremental [Conditional] Large

[Conditional] Core Early Release Probability Damage Probability (ICLERP)i (ICCDP)'

> 1E-05 Configuration should not > IE-06 normally be entered voluntarily 1E 1E-05 *Assess non-quantifiable 1E 1E-06 factors *Establish risk management actions

< IE-06 Normal work controls < 1E-07 Note 1: For clarity and consistency of terms, the term "conditional" is added to the table heading. The calculated ICDP includes the quantified effect of the maintenance configuration (condition).

The ICCDP for the proposed change is 7.82E-07, which is less than 1E-06 and the ICLERP for the proposed change is 2.59E-08, which is less than 1E-07.

4.5 PRA Evaluation Conclusions The final results of the risk evaluation were compared with the risk significance criteria from RGs 1.174 and 1.182. The calculated values for ICCDP and ICLERP demonstrate that the proposed one-time HPCS Completion Time extension has a very small quantitative impact on plant risk.

Station risk levels remain low (near baseline values) and manageable with sufficient margin to allow remedial and corrective actions to be implemented in the event unplanned equipment outages occur. Therefore, Energy Northwest concludes that, based on the very small quantitative plant risk impact and the compensatory measures described below, 'the risk associated with the extended HPCS Completion Time does not impose a significant risk to public health and safety.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 6 of 10 4.6 Compensatorv Measures The compensatory measures described below serve to reduce the risk of continued power operation. These compensatory measures were not modeled or credited in the risk values calculated in the RG 1.174 analysis other than through use of the zero maintenance model.

Loss of electrical power is an important risk consideration at Columbia and grid reliability is a factor in assessing its contribution to risk. Energy Northwest has contacted the Independent System Operator (Bonneville Power Administration) and confirmed the stability of the power grid and that there are no unusual factors (including weather conditions) that need to be considered in this evaluation. As committed below, Energy Northwest will continue to verify this information during the 3 day extension period.

The proposed action conforms to the Maintenance Rule requirements as specified in 10CFR50.65(a)(4). Energy Northwest will continue to use Columbia's Maintenance Rule Program to evaluate and manage the risk associated with extending HPCS out-of-service time.

The following compensatory actions have been implemented and will be continued until the HPCS system is restored to an operable status or the plant is shut down.

  • All normal entrances to the Columbia Generating Station transformer yard have been locked and posted. Planned maintenance in the transformer yard has been suspended. Access to the transformer yard is controlled in accordance with plant procedure PPM 1.9.13, Transformer Yard Access and Controls.
  • A daily tour of the transformer yard is being performed by Operations to identify concerns that could place offsite power or the transformers at risk.
  • Periodic daily briefings are being conducted on the status of HPCS restoration to station management.
  • Energy Northwest will reduce the duration of maintenance on the HPCS pump motor as much as practical by using a 24-hour work schedule, dedicated project management, and dedicated support for the activity.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 7 of 10

  • Energy Northwest will not perform any maintenance on the turbine-driven RCIC system.
  • Energy Northwest has installed protected train signs for the protected systems.
  • Energy Northwest will ensure that no maintenance activities are performed in the switchyard that could directly cause a Loss of Offsite Power event unless required to ensure the continued reliability and availability of the offsite power sources.

The following additional compensatory actions will be implemented if the HPCS system is not restored to an operable status before the expiration of the current 14-day Completion Time and the operation of the plant with an inoperable HPCS system continues into the 3-day extension period requested by this submittal.

  • The Bonneville Power Administration (BPA), the offsite power grid operator, will be informed of the unavailability of HPCS System and will be requested to defer discretionary maintenance on the local network around Columbia Generating Station. The local network is defined as all 500 kV, 230 kV and 115 kV transmission system equipment located in an area bounded by the Midway Substation, White Bluffs Substation, Benton Substation, and Ashe Substation.
  • Energy Northwest will request BPA notification of any emergent conditions that could affect local grid stability or reliability.
  • Energy Northwest will contact the BPA Munro and Dittmer Dispatching Centers on a daily basis to verify no unusual conditions exist that could affect the reliability of the plant offsite power circuits.
  • A daily check of the weather forecast will be performed to anticipate severe weather. Severe weather is currently defined in plant procedures as wind gusts greater than or equal to 58 mph, hail greater than or equal to 3/4" in diameter, visual sighting of a funnel cloud or tornado, or lighting strikes in the local area. If severe weather conditions are forecasted, an assessment of the risk will be performed and appropriate actions will be implemented.
  • During the time HPCS is inoperable in excess of the current 14 day Completion Time, maintenance and testing will be limited on all risk significant equipment.

Only required surveillance testing will be performed. Plant General Manager approval is required for all discretionary maintenance on risk significant equipment.

  • Energy Northwest will not perform any planned voluntary maintenance during the extended HPCS Completion Time that would increase the ICCDP.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 8 of 10

  • Energy Northwest will complete 'just-in-time" simulator training for all control room operating crews to practice procedures for performing plant shutdown without HPCS.
  • Energy Northwest will limit and control welding, grinding, brazing, and transient combustibles in the vicinity of protected equipment.

5.0 REGULATORY ANALYSIS

5.1 Determination of No Significant Hazards In accordance with 10 CFR 50.92(c), a proposed change to the operating license involves a no significant hazards consideration if operation of the facility in accordance with the proposed change would not: 1) involve a significant increase in the probability or consequences of any accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety. Energy Northwest has evaluated the proposed changes to the Columbia Generating Station Technical Specifications using the three criteria set forth in 10 CFR 50.92(c) and has determined that they warrant a no significant hazards consideration as described below:

1. Does the operation of Columbia Generating Station in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No Since only one train of Emergency Core Cooling System (ECCS) components is affected by the condition and an additional failure is not considered while a plant is in a Limiting Condition for Operation (LCO) Action, the operable ECCS trains are adequate to maintain compliance with the plant's design basis. Thus, this condition will not alter assumptions relative to the mitigation of an accident or transient event.

Considering compensatory action and risks involved in a plant shutdown, Energy Northwest has determined that there is no significant risk associated with extending the Completion Time for the High Pressure Core Spray (HPCS)

System for an additional 3 days. The incremental change in risk has been quantitatively evaluated using the guidance of Regulatory Guide 1.174. The incremental risk values are within the criteria of Region IlIl (where the increase in risk is considered "very small") established in RG 1.174.

Based on this evaluation, there is no significant increase in the probability or consequence of an accident previously evaluated.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 9 of 10

2. Does the operation of Columbia Generating Station in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No This proposed action only extends the Completion Time and will not physically alter the plant. No new or different type of equipment will be installed by this action. The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. No change to the system as evaluated in the Columbia Generating Station safety analysis is proposed. Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the operation of Columbia Generating Station in accordance with the proposed amendment involve a significant reduction in the margin of safety?

Response: No Considering compensatory actions and risks involved in a plant shutdown, Energy Northwest has determined that there is no significant risk associated with extending the Completion Time for the HPCS systems for an additional 3 days.

Based on the availability of redundant systems, the compensatory actions that have been taken, and the low probability of an accident that could not be mitigated by the available systems, Energy Northwest concludes that there is no significant reduction in the margin of safety.

Based upon the analysis provided herein, the proposed amendments do not involve a significant hazards consideration.

5.2 Applicable Regulatorv Requirements/Criteria With the implementation of the proposed change, Columbia continues to meet applicable design criteria. The proposed change is a one-time extension to the TS LCO 5.3.1.B Completion Time and does not affect the design basis of the plant. In addition, Columbia will remain within the scope of the proposed TS Limiting Conditions for Operation and is still subject to the requirements of the TS action statements.

Since the mid-1980s, the NRC has been reviewing and granting improvements to TS that are based, at least in part, on PRA insights. In its final policy statement on TS improvements of July 22, 1993, the NRC stated that it expects that licensees, in preparing their Technical Specification related submittals, will utilize any plant-specific PSA (probabilistic safety assessment) or risk survey and any available literature on risk insights and PSAs. Similarly, the NRC staff will also employ risk insights and PSAs in

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Enclosure Page 10 of 10 evaluating Technical Specification related submittals. Further, as a part of the Commission's ongoing program of improving Technical Specifications, it will continue to consider methods to make better use of risk and reliability information for defining future generic Technical Specification requirements. The NRC reiterated this point when it issued the revision to 10 CFR 50.36, "Technical Specifications," in July 1995.

In August 1995, the NRC adopted a final policy statement on the use of PRA methods in nuclear regulatory activities that improve safety decision making and regulatory efficiency. The PRA policy statement included the following points:

1 The use of PRA technology should be increased in all regulatory matters to the extent supported by state-of-the-art in PRA methods and data and in a manner that compliments the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

2 PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements.

3 PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

In conclusion, based on the deterministic and PRA considerations discussed in this submittal, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's 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.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve; (i) a significant hazards consideration; (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite; or, (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs be prepared in connection with the proposed amendment.

(EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Proposed Technical Specifications Changes (mark-up)

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS- Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1.

MODES 2 and 3. except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig.

ACTIONS

NOTE-------------------------------------

LCO 3.0.4.b is not applicable to HPCS.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --.- - I CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. High Pressure Core B.1 Verify by Immediately Spray (HPCS) System administrative means inoperable. RCIC System is OPERABLE when RCIC System is required to be OPERABLE.

AND B.2 Restore HPCS System 14 day to OPERABLE status.

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EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Proposed Technical Specifications Pages (retyped)

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3. except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig.

ACTIONS

NOTE-----------------------------------

LCO 3.0.4.b is not applicable to HPCS.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. High Pressure Core B.1 Verify by Immediately Spray (HPCS) System administrative means inoperable. RCIC System is OPERABLE when RCIC System is required to be OPERABLE.

AND (continued) I Columbia Generating Station 3.5. 1-1I Amendment No. 149,169,18.7-

ECCS - Operating 3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Restore HPCS System 14 days*.

to OPERABLE status. I C. Two ECCS injection C.1 Restore one ECCS 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystems inoperable. injection/spray subsystem to OPERABLE OR status.

One ECCS injection and one ECCS spray subsystem inoperable.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A. AND B. or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. One required ADS valve E.1 Restore ADS valve to 14 days inoperable. OPERABLE status.

F. One required ADS valve F.1 Restore ADS valve to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.

AND OR One low pressure ECCS F.2 Restore low pressure 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

(continued)

  • On a one-time basis, the COMPLETION TIME for an inoperable HPCS System is extended to 17 days. This one-time extension expires on April 3, 2005. I Columbia Generating Station 3.5. 1-2 Amendment No. 149,169

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B Changes to Technical Specifications Bases

ECCS - Operating B 3.5.1 BASES (

ACTIONS or other specified condition in the Applicability with the (continued) LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.S If any one low pressure ECCS injection/spray subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a LOCA may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 13) that evaluated the impact on ECCS availability by assuming that various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.1 and B.2 If the HPCS System is inoperable, and the RCIC System is immediately verified to be OPERABLE (when RCIC is required to be OPERABLE), the HPCS System must be restored to OPERABLE status within 14 days-I In this condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with the ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Immediate verification of RCIC OPERABILITY is therefore required when HPCS is inoperable and RCIC is required to be OPERABLE. This may be performed by an administrative check, by examining logs or other information, to determine if RCIC'is out of service for maintenance or other reasons. It is not necessary to perform the Suryeillances needed to demonstrate the

  • OPERABI.LITY of the RCIC System. However, if the OPERABILITY of the RCIC System cannot be immediately verified and RCIC z * (co tnued

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ECCS - Operating B 3.5.1 BASES ACTIONS B.1 and B.2 (continued) is required to be OPERABLE, Condition D must be immediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minim m required ECCS equipment will not be available. A 14 dag'Completion Time is based on the results of a reliability study (Ref. 13) and has been found to be acceptable through operating experience.

C.1 With two ECCS injection subsystems inoperable or one ECCS injection and one ECCS spray.subsystem inoperable, at least one ECCS injection/spray subsystem must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced in this Condition because a single failure in one of the remaining OPERABLE subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function. Since the ECCS availability is reduced relative to Condition A, a more restrictive Completion Time is imposed. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on a reliability study, as provided in Reference 13.

D.1 and D.2 If any Required Action and associated Completion Time of Condition A, B. or C are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 The LCO requires six ADS valves to be OPERABLE to provide the ADS function. Reference 14 contains the results of an rig (continued)V

$,kCC A.o Columbia Generating Stat-ion B 3.5.1-7 Revision 36

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EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B List of Regulatory Commitments If the restoration of the HPCS system is achieved within the current 14-day Completion Time, Energy Northwest will promptly notify NRC and withdraw the proposed license amendment request.

Upon approval of the proposed license amendment, Energy Northwest would implement a change to the applicable Technical Specifications Bases to add the same footnote to the bases and an additional footnote that would read as follows:

"The one time extension to 17 days is based upon a risk assessment performed in accordance with Regulatory Guide 1.174 and selected risk management compensatory measures."

The following compensatory actions have been implemented and will be continued until the HPCS system is restored to an operable status or the plant is shut down.

  • All normal entrances to the Columbia Generating Station transformer yard have been locked and posted. Planned maintenance in the transformer yard has been suspended. Access to the transformer yard is controlled in accordance with plant procedure PPM 1.9.13, Transformer Yard Access and Controls.
  • A daily tour of the transformer yard is being performed by Operations to identify concerns that could place offsite power or the transformers at risk.
  • Periodic daily briefings are being conducted on the status of HPCS restoration to station management.
  • Energy Northwest will reduce the duration of maintenance on the HPCS pump motor as much as practical by using a 24-hour work schedule, dedicated project management, and dedicated support for the activity.
  • Energy Northwest will maintain station awareness via daily status meetings.
  • Energy Northwest will not perform any maintenance on the turbine-driven RCIC system.
  • Energy Northwest has installed protected train signs.
  • Energy Northwest will ensure that no maintenance activities are performed in the switchyard that could directly cause a Loss of Offsite Power event unless required to ensure the continued reliability and availability of the offsite power sources.

EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR LIMITING CONDITION FOR OPERATION CONDITION 3.5.1.B The following additional compensatory actions will be implemented if the HPCS system is not restored to an operable status before the expiration of the current 14-day Completion Time and the operation of the plant with an inoperable HPCS system continues into the 3-day extension period requested by this submittal.

  • The Bonneville Power Administration (BPA), the offsite power grid operator, will be informed of the unavailability of HPCS System and will be requested to defer discretionary maintenance on the local network around Columbia Generating Station. The local network is defined as all 500 kV, 230 kV and 115 kV transmission system equipment located in an area bounded by the Midway Substation, White Bluffs Substation, Benton Substation, and Ashe Substation.
  • Energy Northwest will request BPA notification of any emergent conditions that could affect local grid stability or reliability.
  • Energy Northwest will contact the BPA Munro and Dittmer Dispatching Centers on a daily basis to verify no unusual conditions exist that could affect the reliability of the plant offsite power circuits.
  • A daily check of the weather forecast will be performed to anticipate severe weather. Severe weather is currently defined in plant procedures as wind gusts greater than or equal to 58 mph, hail greater than or equal to 3/44" in diameter, visual sighting of a funnel cloud or tornado, or lighting strikes in the local area. If severe weather conditions are forecasted, an assessment of the risk will be performed and appropriate actions will be implemented.
  • During the time the HPCS is inoperable in excess of the current 14 day CT, maintenance and testing will be limited on all risk significant equipment. Only required surveillance testing will be performed. Plant General Manager approval is required for all discretionary maintenance on all risk significant equipment.
  • Energy Northwest will not perform any planned voluntary maintenance during the extended HPCS Completion Time that would increase the ICCDP.
  • Energy Northwest will complete just-in-time" simulator training for all control room operating crews to practice procedures for performing plant shutdown without HPCS.
  • Energy Northwest will limit and control welding, grinding, brazing, and transient combustibles in the vicinity of protected equipment.
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