ML15083A094

Columbia Generating Station, TIA XXXX-XX, Tower Makeup System Unresolved Issue

ML15083A094
Person / Time
Site:	Columbia
Issue date:	03/06/2015
From:	Gregoire D W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-15-039, IR 2014002
Download: ML15083A094 (44)

Text

ENERGYNORTHWESTDonald W. GregoireP.O. Box 968, PE20Richland, WA 99352-0968Ph. 509-377-8616 1 F. 509-377-4317dwgregoire@energy-northwest.cornMarch 6, 2015G02-15-039U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397;TIA XXXX-XX, TOWER MAKEUP SYSTEM UNRESOLVED ISSUE

Reference:

Letter GI2-14-067 from NH Taylor (NRC) to ME Reddemann (EnergyNorthwest) dated May 7, 2014, "Columbia Generating Station -NRCIntegrated Inspection Report 05000397/2014002."

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) has identified unresolved issue (URI)05000397/2014002-02 (Reference), related to potential discrepancies noted whenreviewing Columbia Generating Station's licensing basis documents. This involved thesupport role of the Tower Makeup System (TMU) to the Ultimate Heat Sink (UHS)System and the TMU's safety classification.Energy Northwest (EN) has performed an extensive research of the licensing basis andsupport documentation, and has prepared the attached white paper report. The whitepaper summarizes findings from the research which support EN's proposed positionwith respect to URI 05000397/2014002-02. EN respectfully requests consideration ofthe position presented in the white paper as part of the TIA process for resolution of theURI.There are no commitments contained in this letter or the enclosure. Should you haveany questions, please call JR Trautvetter at (509) 377-4337.Respectf ullyDW GregoireManager, Regulatory Affairs

Attachment:

As statedCc: NRC RIV Regional AdministratorNRC NRR Project ManagerNRC Sr. Resident Inspector -988CAS Mohseni, Deputy Director, NRC Division of Policy and RulemakingC Sonoda -BPA/1 399 w/oWA Horin -Winston & Strawn TIA XXXX-XX, TOWER MAKEUP SYSTEM UNRESOLVED ISSUEAttachment License Basis EvaluationofColumbia Generating Station'sTower Makeup SystemWhite PaperMarch 2015 TABLE OF CONTENTSSECTION TITLE PAGE1.0 P U R P O S E ............................................................................................. .22.0 BACKGROUND .................................................................................... 32.1 Safety Assessment ......................................................................... 32.2 TMU Design, Operation, and Maintenance .................................... 32.3 Dates of Significance ...................................................................... 42.4 Changes of Company and Plant Names ......................................... 52.5 Historical License Basis for the TMU System .................................. 53.0 DEFINITION OF ULTIMATE HEAT SINK ............................................. 93.1 Response to NRC Position ............................................................. 93.2 NRC Provided References ........................................................... 103.3 Additional Supporting Information ............................................... 214.0 SAFETY CLASSIFICATION OF THE TMU SYSTEM .......................... 264.1 Response to NRC Position ........................................................... 264.2 NRC Provided References ........................................................... 264.3 Additional Supporting Information ............................................... 375.0 SUMMARY AND CONCLUSION ......................................................... 3

76.0 REFERENCES

.................................................................................... 38 License Basis Evaluation -CGS TMU System1.0 PURPOSEThe purpose of this license basis evaluation is to provide an Energy Northwest(EN) position paper that responds to specific concerns raised by the NRCResident staff related to the license basis of the Columbia Generating StationTower Makeup (TMU) and Ultimate Heat Sink (UHS) systems.It was identified that there were apparent inconsistencies in Columbia's licensebasis for the TMU System. These inconsistencies have led to confusion aboutthe role of the TMU system in support of the UHS. The areas of confusion haveled to the following questions:1. Is Columbia's TMU system considered part of the Ultimate Heat Sink andtherefore subject to the operability requirements of the UHS in LCO 3.7.1 or isit a support system for the Ultimate Heat Sink?There are two parts to this question that need to be addressed.a) Is the TMU system an SSC included within the definition of the UHS?b) If the TMU system is considered within the definition of the UHS, thenmust it meet single failure criterion to support operability of the UHS?2. Should the TMU system be considered "safety related" and should 10 CFR 50Appendix B quality requirements apply?The position provided by the NRC and the Energy Northwest Evaluation of eachof the questions is addressed in sections 3.0 and 4.0 of this report.Section 2.0 provides background information important to a completeunderstanding of this subject.2 License Basis Evaluation -CGS TMU System2.0 BACKGROUND -NRC IDENTIFIED CONCERNDuring the course of inspection in the first quarter of 2014, the Resident NRCInspector identified concerns with work that had previously been performed onTower Makeup (TMU) pump power supplies (4.16KV non-safety related busesSM-75 and SM-85) in 2012 and 2013 in which the buses were de-energized formaintenance. While the work was conducted, the NRC noted that the UltimateHeat Sink (UHS) was not considered inoperable by Energy Northwest staffduring the time that the buses'were de-energized when they believed it shouldhave been declared inoperable due to loss of single failure protection.It was shared by the resident inspector that initial discussions with the TechnicalSpecification Branch in NRR suggested that operability should have beenconsidered however, more information was needed to finalize that conclusion.After conducting further research the resident inspector identified inconsistenciesin Columbia's Licensing Basis documents which led to further concerns abouthow the TMU system was classified (safety related or non-safety related). Thishas led to two major concerns expressed by the resident inspectors as discussedin section 3.0 and 4.0 of this report.2.1 Safety AssessmentThe Columbia Generating Station TMU system continues to meet all applicableregulatory requirements. It has been operated and maintained in a manner toensure availability for the UHS in the event of a tornado.The probability of a smart tornado with sufficient magnitude impacting both pondsof the UHS and thereby impacting its ability to perform its safety function is verylow. Columbia's FSAR Section 2.3.1.2.1.3 provides the probability of a tornado atthe site of 6 x 10-6 events/year. The probability of a tornado causing a missile todestroy both spray rings or to travel over both spray ponds and removesubstantial volume is obviously much less.Although the TMU system may be classified by Energy Northwest as not safetyrelated, it has been treated as "important to safety." This is reflected in thesystem design, operation and maintenance. Based on this, there is no impact onthe health and safety of the public while resolving the issues presented in by theNRC for resolution in the Task Interface Agreement (TIA).2.2 TMU Design, Operation and MaintenanceSystem Design:The TMU system provides makeup water to the plant from the Columbia River.The system consists of three 50% capacity pumps (for Circ Water makeup)located in a pumphouse at the river which pump water through approximately 3.53 License Basis Evaluation -CGS TMU Systemmiles of buried piping to Columbia at a design flow up to 25,000 gpm to maintainlevel in the spray ponds and cooling tower basins.The system is designed with two divisions of power from safety related buseswhich are capable of being powered by the emergency diesel generators in caseof a loss of off-site power. TMU pump A and B are powered respectively fromDivision 1 and 2 buses. TMU pump C may be powered from either division. Theentire system has been designed to be protected from tornado missiles.System Operation:During normal operation, the TMU System supports the UHS with makeup fornormal losses due to evaporation and drift. The TMU system is used primarily toprovide makeup to the circulating water (CW) system to replace water lost via thecooling towers.In the event that all TMU capability to supply makeup water to the CW system islost during normal plant operation, abnormal procedure ABN-TMU requires arapid power reduction followed by a reactor scram.The 2 spray ponds provide for a minimum of 30-day cooling without makeup. Inthe event that both sets of spray headers become damaged (e.g., from a tornadomissile), abnormal procedure ABN-WIND provides guidance on how to providecooling for the spray ponds using a feed and bleed method with the TMU (feed)and CW (bleed) systems.System Maintenance:Maintenance on the system is scheduled divisionally, such that one division ofpower to the TMU system is always available and protected. While a division ofpower is under maintenance, TMU pump C will typically be aligned to theunaffected division to ensure two pumps are available for makeup. The TMUSystem is in scope for Maintenance Rule (10 CFR 50.65). Correctivemaintenance is prioritized based on the system being in scope for MaintenanceRule.2.3 Dates of SignificanceThe following dates should be used as reference points throughout thediscussions provided:August 10, 1971 -Submission of Application for Construction PermitMarch 19, 1973 -Construction Permit Issued for Hanford 2March 15, 1977 -Initial Submittal of Final Safety Analysis Report (FSAR) forApplication of Operating License for WNP-2March 1982 -Safety Evaluation Report for WNP-2 (NUREG-0892) Issued4 License Basis Evaluation -CGS TMU SystemAugust 1982 -Supplement 1December 1982 -Supplement 2May 1983 -Supplement 3December 1983 -Supplement 4April 1984 -Supplement 5December 20, 1983- Operating License Issued for WNP-2(Note: FSAR Amendment 33 was in effect at time of License issuance)2.4 Changes of Company and Plant NamesAs noted above, over 40 years has passed since the time of the originalapplication for a construction permit. Since then both the company and planthave undergone name changes:Original Company Name: Washington Public Power Supply System (WPPSS)Current Company Name: Energy NorthwestOriginal Plant Name: Hanford 2Other Plant Name: Washington Nuclear Project 2 (WNP-2)Current Plant Name: Columbia2.5 Historical License Basis for the TMU SystemMost, if not all, of the individuals involved in the early discussions surrounding thepermitting and licensing of Columbia no longer work in the industry or with theNRC. Regardless, an effort was undertaken by EN staff to identify and evaluatethe license basis for Columbia's TMU system. The results are summarizedbelow. This effort involved looking into the following:* Applicable regulatory requirements, associated regulatory guides, andendorsed industry documents* Regulatory correspondence (NRC, EN, and other utilities)* Columbia's Preliminary Safety Analysis Reports (PSAR)* Numerous versions of Columbia's Final Safety Analysis Report (FSAR)* NRC safety evaluation report for Columbia's initial and renewed operatinglicenses NUREG-0892 and NUREG-2123* Early TMU and UHS design drawings and system related documents* Internal memo's generated by construction contractor Burns and Roe* NRC positions (e.g., TIAs) on non-safety related systems and application ofsingle failure protection requirements5 License Basis Evaluation -CGS TMU SystemThis information was then used to capture the specific license basis forColumbia's TMU system. As specified in 10 CFR 54.3, the definition of "CurrentLicense Basis" consists of the following:* The set of NRC requirements applicable to a specific plant, and* A licensee's written commitments for ensuring compliance with andoperation within applicable NRC requirements, and* The plant-specific design basis (including all modifications and additions tosuch commitments over the life of the license) that are docketed and ineffect.In looking into the first attribute of this definition (NRC requirements), the onlyregulations of considerations to the TMU system were 10 CFR 50 Appendix B,and 10 CFR 50 Appendix A, General Design Criteria (GDC) 2.10 CFR 50 Appendix B states in part:Nuclear power plants and fuel reprocessing plants include structures,systems, and components that prevent or mitigate the consequences ofpostulated accidents that could cause undue risk to the health and safety ofthe public. This appendix establishes quality assurance requirements for thedesign, manufacture, construction, and operation of those structures,systems, and components.The pertinent requirements of this appendix apply to all activities affecting thesafety-related functions of those structures, systems, and components; theseactivities include designing, purchasing, fabricating, handling, shipping,storing, cleaning, erecting, installing, inspecting, testing, operating,maintaining, repairing, refueling, and modifying.A search through the license basis for the application of Appendix B to portionsof the TMU system reveals that Appendix B (Quality Class 1) requirements wereimposed only on "tornado protection" features of the TMU system. These includethe TMU pumphouse and the soil covering TMU system buried piping andcabling. The safety classification for the TMU system as documented inColumbia's FSAR and accepted by the NRC in NUREG-0892 is class G(General) which is equivalent to non-safety related. (Reference NUREG-0892section 3.2, FSAR Table 3.2-1, and WPPSS letter GC2-74-28 to NRC datedFebruary 27, 1974)6 License Basis Evaluation -CGS TMU SystemWith regard to the application of 10 CFR 50 Appendix A GDC 2, it is only used inlicense basis documents in terms of the UHS design. 10 CFR 50 Appendix AGDC 2 states:Criterion 2-Design bases for protection against natural phenomena.Structures, systems, and components important to safety shall be designed towithstand the effects of natural phenomena such as earthquakes, tornadoes,hurricanes, floods, tsunami, and seiches without loss of capability to performtheir safety functions. The design bases for these structures, systems, andcomponents shall reflect: (1) Appropriate consideration of the most severe ofthe natural phenomena that have been historically reported for the site andsurrounding area, with sufficient margin for the limited accuracy, quantity, andperiod of time in which the historical data have been accumulated, (2)appropriate combinations of the effects of normal and accident conditions withthe effects of the natural phenomena and (3) the importance of the safetyfunctions to be performed.It was determined early on in the licensing process for Columbia GeneratingStation (then Hanford 2) that tornado events can impact the function of the sprayrings in each of the two ponds (i.e., by tornado missiles) or else remove volumefrom the two ponds. Both of these postulated events impact the UHS' capabilityto perform its specified safety function under a design basis tornado. As statedpreviously, Columbia's FSAR Section 2.3.1.2.1.3 provides the probability of atornado at the site of 6 x 10-6 events/year. The probability of a tornado causing amissile to destroy both spray rings or to travel over both spray ponds and removesubstantial volume would be much less.However, in order for the UHS to meet GDC-2 requirements for these veryunlikely events, Energy Northwest proposed relying on the non-safety relatedTMU system to provide makeup if necessary as a source of cool water to theUHS ponds. The TMU system was provided with tornado protection (i.e., tornadoresistant pumphouse and protection of underground power cables and piping).This position was accepted by the NRC staff. Thus the TMU system nowbecomes a support system to the UHS only in the event of a tornado. (ReferenceNUREG-0892 section 9.2.5 and 9.4.6, FSAR section 3.3.2.3, 9.2.5, and 9.4.12)It should be noted that GDC 2 requirements do not impose single failureprotection criteria. The TMU system was never required to meet "single failure"protection as defined in 10 CFR 50 Appendix A which requires both active andpassive single failure protection. In addition, nowhere in NUREG-0892,Columbia's FSAR, or regulatory correspondence was single failure protection ofthe TMU system credited for meeting any regulatory requirement.It is recognized that the UHS must have single failure protection to meet GDC-44requirements. However, the NRC approved definition of the UHS does notinclude the TMU system (Reference Technical Specification Amendment 52).7 License Basis Evaluation -CGS TMU SystemAs will be shown in the responses described in Section 3.0 and 4.0 of this report,the TMU system license basis is simply as follows:* 10 CFR 50 Appendix B requirements were only imposed on the "tornadoprotection" features of the TMU supporting structures (pumphouse and soil).0 The TMU system is only needed to support the UHS during a design basistornado. As a support system it allows the UHS to meet GDC-2 requirements.* The TMU is not required to have single failure protection to meet anyregulatory requirements.Details of Columbia's TMU system can be found in all of the following sections ofthe initial Licensing Basis Documents:Columbia FSAR(Amendment33)Section1.2, General Plant Description2.2, Nearby Industrial Transportation and Military Facilities2.4, Hydrology Engineering3.1, Conformance with NRC General Design Criteria3.2, Classification of Structures Components and Systems3.3, Wind and Tornado Loading3.5, Missile Protection3.8, Design of Seismic Category I Structures8.3, Onsite Power Systems9.2, Water Systems9.4, Heating, Ventilating, and Air Conditioning Systems10.4, Other Features of Steam and Power Conversion SystemFSAR Appendix C, Compliance with Regulatory GuidesNRC SER(NUREG-0892)Section1.2, General Plant Description1.9, License Conditions2.2, Nearby Industrial Transportation and Military Facilities2.4, Hydrology Engineering2.5, Geology, Seismology, and Geotechnical Engineering3.2, Classification of Structures, Systems, and Components3.5, Missile Protection3.6, Protection Against Dynamic Effects Associated with the PostulatedRupture of Piping3.10, Seismic and Dynamic Qualification of Seismic Category IMechanical and Elect (NUREG-0892 Supplement 4)9.2, Water Systems9.2, Water Systems (NUREG-0892 Supplement 1)9.4, Heating, Ventilating, and Air Conditioning Systems10.4, Other Features of Steam and Power Conversion SystemI8 License Basis Evaluation -CGS TMU System3.0 DEFINITION OF THE ULTIMATE HEAT SINK3.1 Response to NRC PositionWith regard to the TMU system's role in the operability of the UHS, the questionraised by the resident inspector is summarized as follows:"Is Columbia's TMU considered part of the Ultimate Heat Sink or is it asupport system for the Ultimate Heat Sink and should the operability of theUHS in LCO 3.7.1 apply to it?"The position of the resident inspector with regard to this question that wascommunicated to Energy Northwest Licensing staff is summarized as follows:The TMU system is an SSC included within the definition of the UHS andtherefore a loss of single failure protection of TMU results in the UHS beinginoperable.This position is based on references provided to Energy Northwest listed insection 4.2 below as well as the associated arguments.Energy Northwest does not agree with this conclusion. It is Energy Northwest'sposition that the TMU system is a support system for the UHS and onlynecessary to support UHS operability in the event of a tornado.A loss of single failure protection for this support system does not impact UHSoperability for a tornado event and therefore does not require the UHS to bedeclared inoperable whenever the TMU is vulnerable to a single failure (e.g., adivision of power removed for maintenance).An Energy Northwest response is provided to each of the references provided tothe Energy Northwest staff.9 License Basis Evaluation -CGS TMU System3.2 NRC Provided References3.2.1 Washington Public Power Supply System (JJ Stein) letter to NRC(A. Giambusso), Ultimate Heat Sink, dated February 27, 1974In the letter referenced above the following statement was made which revealsthe TMU system as part of the UHS:The systems which act as an Ultimate Heat Sink on WNP-2 are shown onthe attached sketch labeled Figure 1.Figure 1 from the letter is depicted below:14AX0 Uri MPh1o'do10 License Basis Evaluation -CGS TMU SystemEnergy Northwest Response to Reference 3.2.11:The figure provided in the above mentioned letter was an early simplifieddepiction of the UHS that also included the Standby Service Water (SW), TowerMakeup (TMU), and the Circulating Water (CW) systems.Since that time, the depiction of the UHS had changed. For example, in 1982when NUREG-0892 was issued, the UHS and SW system was depicteddifferently. Figure 2.6 on page 2-19 of NUREG-0892 was used to depict the UHSand SW systems below. Note that it does not include the TMU or CW systems.Figure 2.6 Simplified schematic of ultima te heat sink standbyservice water and spray systemsFurthermore, as documented in section 9.2.5 of NUREG 0892, the UHS wasmore specifically defined as follows:The UHS consists of two separate and redundant spray ponds and standbyservice water systems and their associated piping. Each spray pond has aring header for spray trees.In addition, Section 9.2.5.2 of FSAR Amendment 33 (initially licensed version)defined the UHS as follows:The ultimate heat sink consists of two concrete ponds with redundantpumping and spray facilities.Lastly, on April 4, 1988, the NRC concurred with the Energy Northwest definitionof the Ultimate Heat Sink in Technical Specification (TS) Amendment 52(ML022060624) as documented in the NRC safety evaluation. The change andthe abstract from the safety evaluation are documented below:Amendment 52 revised the definition of the ultimate heat sink as stated inLimiting Condition for Operation (LCO) 3.7.1.3:11 License Basis Evaluation -CGS TMU SystemULTIMATE HEAT SINKLIMITING CONDITION FOR OPERATION3.7.1.3 The ultimate heat sink consisting of two separate spray ponds withredundant pumping and spray facilities shall be OPERABLE with:Amendment 52 safety evaluation:The licensee also requested that the definition of the ultimate heat sink, assuccinctly expressed in the lead sentence of Technical Specification 3.7.1.3,be revised to be consistent with the wording in the WNP-2 Final SafetyAnalysis Report Section 9.2.5.2. This change in wording does not result froma design change nor does it authorize a design change. Furthermore, it doesnot alter the staff's understanding of the configuration of the ultimate heatsink. The staff finds the wording change proposed by the licenseeacceptable.This language is consistent with the existing Columbia TS and can be found inthe Technical Specifications Bases for TS 3.7.1.3.2.2. NRC letter (K Kniel) to Ecolaire Condenser, Inc. (WE Palmer), OrientedSpray Cooling System Topical Report, dated November 22, 1977In the above letter, the NRC concluded that the Oriented Spray Cooling System(OSCS) alone was an insufficient design for the UHS. Reference the applicabletext below:We cannot approve the OSCS as the only plant ultimate heat sink.However, the OSCS could be used as an alternate cooling source as part ofan ultimate heat sink. The other part of the heat sink would have to beprotected against tornado missiles, meet single failure criteria, and bedesigned to quality group "C". This other part need not be designed toseismic category I requirements.As documented in Columbia safety evaluation report (NUREG-0892) section2.4.5 and Columbia Final Safety Analysis Report (FSAR) Section 9.2.5.3, anEcolaire oriented spray cooling system (OSCS) is utilized at Columbia for coolingthe water inventory of the UHS.Energy Northwest Response to Reference 3.2.2As stated previously in response to reference 3.2.1, the definition of the UHS wasestablished in the initial FSAR (Amendment 33) and further supported by theNRC safety evaluation associated with Amendment 52 of the TS in 1988. Theletter referenced in 3.2.2 was part of early dialogue by the NRC with a vendor onthe design of the UHS but in of itself does not establish the definition of theColumbia UHS.12 License Basis Evaluation -CGS TMU SystemThe subject of these discussions was not Columbia's UHS but rather a proposedsystem to be used at Columbia. NUREG-0892 documents conclusions that donot involve altering the definition of the UHS because of the OCSC. For example,NUREG-0892 Section 2.4.5 Safety-Related Water Supply -Ultimate Heat Sink(UHS) contains the following:The safety-related water supply for the WNP-2 plant is provided by twoseismic Category I spray ponds designed to contain a 30-day supply ofcooling water for safe shutdown of the plant during accident conditions. Thetwo concrete ponds incorporate Ecolaire Condenser Inc. -oriented spraycooling systems. Each pond is 250 feet square and contains a useablevolume of 6.25 x 10(6) gal...Based on its review of the information provided by the applicant and its ownindependent analyses using both conservative and reasonable parameters,the staff concludes that the WNP-2 ultimate heat sink meets the criteria ofRegulatory Guide 1.27, and that its hydrologic and thermal performancemeets the requirements of GDC 44.In addition, NUREG-0892 Section 9.2.5 Ultimate Heat Sink contains the followingtext which treats the plant makeup water system as a separate support systemfor the UHS in the event of a tornado (emphasis added):The ultimate heat sink (UHS) provides cooling water to the standby servicewater systems during accident conditions for cooling of essential plantauxiliary components. The UHS consists of two separate and redundantspray ponds and standby service water systems and their associated piping.Each spray pond has a ring header for spray trees...The concrete spray ponds are designed to seismic Category I requirementsand are designed to withstand the effects of floods and tornadoes. The spraytrees are not tornado resistant. However, should a larme number of the sprayunits be damaged, cooling would still be available by way of the tornado-protected, plant makeup water system, which can be used to supply water tothe ponds from the Columbia River. Thus, the requirements of GDC 2, andthe guidelines of Regulatory Guide 1.29 are satisfied.Based on the above, the staff concludes that UHS meets the requirements ofGDC 2, 44, 45 and 46, with respect to protection against natural phenomena,cooling water, inservice inspection and functional testing, and the guidelinesof Regulatory Guides 1.27 and 1.29, with respect to seismic classificationand the capability to remove sufficient decay heat to maintain plant safety.The system is, therefore, acceptable.13 License Basis Evaluation -CGS TMU System3.2.3 FSAR Amendment 33 Section 3.3.2.3 (December 1983)Amendment 33 of the FSAR was the version in effect at the time of initiallicensing of Columbia (formerly WNP-2). In section 3.3.2.3 of this version thefollowing definition for the ultimate heat sink was provided:The makeup water system and the standby service water system, includingthe spray ponds, act as the ultimate heat sink.This text was later modified by Licensing Document Change Notice (LDCN)94-058 approved on July 22, 1994 and then eliminated altogether in LDCN 97-121approved on May 26,1998.Energy Northwest Response to Reference 3.2.3Section 3.3.2.3 of FSAR Amendment 33 contained an incorrect and inconsistentstatement that was later identified and corrected.In 1994 it was identified as being inconsistent with the understanding of the UHSand SW systems as defined and treated in other regulatory documents (RG 1.27and NUREG 0800). It was also recognized that it was inconsistent with thedefinition previously established in other sections of the FSAR and the TechnicalSpecifications that didn't include the TMU system. Therefore, LDCN-94-058simply corrected the inconsistency.In 1997, it was deemed that the language in section 3.3.2.3 was repetitious tolanguage in section 9.2.5.3 and therefore the language was deleted from this onelocation.3.2.4 WPPSS Response to NRC FSAR Review Question 10.24 (Amendment 5)In the WPPSS response to question 10.24, WPPSS declared that the UHSdesign provisions include continuous water make-up capability (see below).0. 010.24RSP(9.2.5)We require that you protect the sprays in the ultimate heat sink from theeffects of tornados and tornado missiles.Response:As discussed in 3.3.2.3, the WNP-2 UHS design provides for continuouswater make-up to the spray ponds in the event that both the spray systemsare rendered inoperable due to tornado missiles. Therefore, the sprays arenot required to be protected from the effects of tornado missiles since an14 License Basis Evaluation -CGS TMU Systemalternate UHS operating mode (continuous Make-up) is available which isprotected from the effects of tornadoes and tornado missiles.Energy Northwest Response to Reference 3.2.4Energy Northwest acknowledges that TMU is capable of providing continuousmake-up to support the alternate UHS operating mode (feed and bleed asopposed to use of sprays) in the event that a tornado renders both pond spraysystems inoperable due to tornado missiles. Therefore, Energy Northwestacknowledges that the TMU system is required as a support system for the UHSin the event of a tornado in order for the UHS to meet General Design Criteria(GDC) 2 requirements.3.2.5 WPPSS Response to NRC PSAR Review Question 10.8 (PSAR Amend 12)In the above referenced response, WPPSS indicated that TMU was designed tomeet single active failure protection during a tornado (see below).QUESTION 10.8 (June 12, 1972)Discuss the ability of the spray pond to perform its safety function in theevent of design basis tornado or earthquake. Discuss the possibility oftornado missiles or tornado or earthquake caused obstructions rendering theultimate heat sink unavailable.ANSWER... The river water pump house is designed to withstand the design basistornado and the pumps within are supplied power from the plant standbypower system via underground cabling. A redundant power supply isprovided to protect against single failure (as defined in AEC General DesignCriteria). No single active failure can prevent the river water pumping systemfrom providing water to replace water lost during high wind conditions.Energy Northwest Response to Reference 3.2.5Energy Northwest acknowledges that TMU is required as a support system forthe UHS in the event of a tornado. It was designed with single "active" failureprotection features. However, it is not designed to protect against single"passive" failures. The implication from the NRC comments is that since the TMUsystem has a single active failure protection design, the TMU system must alsobe part of the UHS and thus subject to the single failure protection requirementsof GDC-44.However, Energy Northwest disagrees. Single active failure protection of theTMU system was a design feature that provided additional margin of safety15 License Basis Evaluation -CGS TMU Systemduring the highly unlikely event of a tornado at the station and the equally unlikelyprobability that both spray header rings were destroyed by tornado missiles.The TMU system was never required to satisfy GDC-44 single failure protectionrequirements. Note that GDC-44 does not make the distinction that protectionshould be for single "active" failures but rather uses the all-encompassing "singlefailure" protection requirement. Also note that the definition from 10 CFR 50Appendix A for the broader "single failure" term clearly includes the requirementfor protection against both single "active" and single "passive" failures:Fluid and electric systems are considered to be designed against anassumed single failure if neither (1) a single failure of any active component(assuming passive components function properly) nor (2) a single failure of apassive component (assuming active components function properly), resultsin a loss of the capability of the system to perform its safety functions.It is Energy Northwest's position that single failures (active or passive) in additionto the multiple failures assumed to occur during a tornado event do not need tobe considered in supporting the operability of the UHS during a tornado event.Therefore, potential single failures that could result in the complete loss of theTMU system used as an emergency makeup source to the UHS during a tornadodo not need to be considered in determining the operability of the ultimate heatsinks as it relates to tornado events.For example, should one division of power provided to the TMU system be takenout of service for maintenance leaving only one division of power to the TMUsystem, the UHS is not considered inoperable since no additional single failuresare presumed in addition to a tornado, loss of offsite power, and loss of bothpond spray headers.A more complete basis for why Energy Northwest does not assume single failureprotection in TMU support of the UHS is provided below:Basis:" The Columbia FSAR does not assume an additional single failure occurringsimultaneously with the assumed tornado event failures." NRC Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants,Revision 2 does not require that the Ultimate Heat Sink be designed towithstand a tornado event combined with a simultaneous single failure." GDC-2, Design Bases for Protection Against Natural Phenomena, does notrequire single failure protection along with the assumed natural phenomena." Previous NRC positions have concluded that an additional single failure doesnot have to be considered to occur simultaneously with external events.16 License Basis Evaluation -CGS TMU System* Previous NRC positions have concluded that single failure proof designcapability for non-Technical Specification related SSCs are not required forsupporting operability of Technical Specification related SSCs.Supporting Information:A. Columbia FSARTornado events are analyzed in the Columbia, FSAR section 3.3.2. Inaddition, as tornado events relates to the ultimate heat sink, more discussionis provided in FSAR section 9.2.5. Nowhere is it documented or assumed inthe FSAR that a single failure occurs in addition to the multiple failurescaused by the tornado itself (e.g., loss of offsite power, loss of all inventory inboth spray ponds, etc.).As noted in FSAR Table 3.2-1 note 31, the TMU system is protected fromtornado hazards such that the tornado will not have a direct impact of thecapability of the TMU system to provide the necessary makeup.B. NRC Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants,Rev 2Columbia FSAR section 1.8 states Columbia's compliance with revision 2 ofNRC RG 1.27. This Reg Guide describes four separate events that theultimate heat sink (UHS) must be able to withstand. It does not require theUHS to be capable to withstand a single failure in addition to a severe naturalphenomenon. As noted in section C.2 of NRC RG 1.27, the following are thedesign requirements regarding the capability of the ultimate heat sink:2. The ultimate heat sink complex, whether composed of single ormultiple water sources, should be capable of withstanding, without lossof the sink safety functions specified, in regulatory position 1, thefollowing events:a. The most severe natural phenomena expected at the site, withappropriate ambient conditions, but with no two or more suchphenomena occurring simultaneously,b. The site-related events (e.g., transportation accident, riverdiversion) that historically have occurred or that may occur duringthe plant lifetime,c. Reasonably probable combinations of less severe naturalphenomena and/or site-related events,d. A single failure of manmade structural features.17 License Basis Evaluation -CGS TMU SystemThis Reg Guide treats these as four separate events. Only item 2.c points to acombination of lesser versions of events 2.a and 2.b, but there are no othercombinations considered in the list of events. Only 2.d specifies single failureprotection; however it does not require it in addition to natural phenomena.C. GDC-2, Desigqn Bases for Protection Against Natural PhenomenaUnlike GDC-44, Cooling Water, which requires single failure protection duringnormal operation or design basis accidents, GDC-2 establishes no designrequirement to consider single failure protection during a natural event.D. Previous NRC Position -Single Failure Criteria and Coincident ExternalEventPrairie Island Nuclear Generating Plant, Unit 2 -Response to TIA-2001 "Design Basis Assumptions for Ability of Prairie Island, Unit 2, EmergencyDiesel Generators to Meet Single Failure Criteria for External Events"September 4, 2003. (ML032040412)Similar to GDC-44, GDC-1 7, Electric power systems, imposes single failurerequirements on the design of the onsite electric power supplies (i.e.,emergency AC power system). However, after reviewing Prairie Island'sFSAR, the GDCs, and the Safety Evaluation Report for the station, the NRCmade the following conclusion (emphasis added):In summary, neither the GDCs, the FSAR, or the staff's September 28,1972, safety evaluation, specify that the emergency AC power system isrequired to meet single failure criteria coincident with an external event.Even knowing full well that GDC-1 7 imposes single failure criteria onemergency AC power systems, the NRC staff still concluded that for thepurposes of an external event, the GDCs do not impose the requirement tomeet a coincident single failure.E. Previous NRC Position -Single Failure Criteria for non-Tech Spec SSCsIn NRC Letter from NRC (Douglas V. Pickett Senior Project Manager, Section2) to Guy G. Campbell (Vice President -Nuclear, Perry), "Application ofGeneric Letter 80-30 Guidance to an Inoperable Non-Technical SpecificationSupport Subsystem" (ML020950074), the following NRC position wascommunicated (emphasis added):In some designs, the non- TS support system has two redundant 100percent capacity subsystems, each capable of supporting both TS trains.Loss of one support subsystem does not result in a loss of support foreither train of TS equipment. Both TS trains remain operable, despite aloss of support function redundancy, because the TS definition of18 License Basis Evaluation -CGS TMU Systemoperability does not require a TS subsystem's necessary support functionto meet the single-failure design criterion.3.2.6 NUREG-0892, WNP-2 Safety Evaluation Report (SER) Section 9.2.5The NRC SER concludes that Columbia (formerly WNP-2) meets therequirements of GDC-44 for the UHS:..Based on the above, the staff concludes that UHS meets the requirementsof GDC 2, 44, 45, and 46, with respect to protection against naturalphenomena, cooling water, inservice inspection and functional testing, andthe guidelines of Regulatory Guide 1.27 and 1.29, with respect to seismicclassification and the capability to remove sufficient decay heat to maintainplant safety. The system is, therefore, acceptable.Energy Northwest Response to Reference 3.2.6Energy Northwest agrees that the design of Columbia's UHS meets therequirements of GDC-44 as documented and described in NUREG-0892.However, it is EN's position that the TMU system is only used as a supportsystem to allow the UHS to meet GDC-2 requirements and not GDC-44. Both theColumbia FSAR and NUREG-0892 only referred to the TMU system in terms ofGDC-2 support. For example:In section 9.2.5 of NUREG-0892The concrete spray ponds are designed to seismic Category I requirementsand are designed to withstand the effects of floods and tornadoes. The spraytrees are not tornado resistant. However, should a large number of the sprayunits be damaged, cooling would still be available by way of the tornado-protected, plant makeup water system, which can be used to supply water tothe ponds from the Columbia River. Thus, the requirements of GDC 2, andthe guidelines of Regulatory Guide 1.29 are satisfied.In section 9.4.6 of NUREG-0892 the following text is found:The only natural design-basis event that would significantly reduce the waterin the spray ponds is a tornado. Thus, the makeup water system is onlyrequired to operate durinq a tornado (refer to Section 9.2.5 of this SER for adiscussion of the spray ponds). Therefore, the portion of the ventilationsystem providing air to the makeup water transformers is tornado andtornado-missile protected. Thus, the requirements of GDC 2 and theguidelines of Position C.2 of Regulatory Guide 1.29 are met. No other GDCare applicable.19 License Basis Evaluation -CGS TMU SystemIn Section 9.4.11 of NUREG-0892 the following text is found... The makeup water pumps are not needed in a seismic event but areneeded during a tomado (refer to Section 9.2.5 of this SER). Therefore, themakeup water pump house HVAC is nonseismic Category I but is tornadoprotected. Thus, the requirements of GDC 2 are met.It is evident from the language in NUREG-0892 that the TMU system is onlyrecognized as being needed by the UHS to satisfy GDC 2 criteria. GDC-44 is metthrough the use of the Standby Service Water (SW) System and the UHS asdefined in the Columbia FSAR and approved in TS Amendment 52.3.2.7 General Design Criteria (GDC) 44, Cooling WaterGDC-44 requires single failure protection for ensuring the safety function of thecooling water system can be accomplished. See below:Criterion 44 -Cooling water. A system to transfer heat from structures,systems, and components important to safety, to an ultimate heat sink shallbe provided. The system safety function shall be to transfer the combinedheat load of these structures, systems, and components under normaloperating and accident conditions.Suitable redundancy in components and features, and suitableinterconnections, leak detection, and isolation capabilities shall be providedto assure that for onsite electric power system operation (assuming offsitepower is not available) and for offsite electric power system operation(assuming onsite power is not available) the system safety function can beaccomplished, assuming a single failure.Energy Northwest Response to Reference 3.2.7Discussion on the application of GDC-44 and single failure protection to the TMUsystem is provided in response to references 3.2.5 and 3.2.6 of this positionpaper.3.2.8 FSAR Amendment 33 Section 9.4.12.3 (December 1983)Amendment 33 of the FSAR was the version in effect at the time of initiallicensing of Columbia (formerly WNP-2). In section 9.4.12.3 of this version thefollowing single failure protection design is discussed:.. The heating and ventilating systems provided in the make-up water pumphouse incorporates the following safety features to ensure that a singlecomponent failure will not prevent the system from performing its operationalfunction.20 License Basis Evaluation -CGS TMU Systema. Two full capacity air handling units are provided for the electricalequipment area and two full capacity fan coil units are provided for themake-up pump area; therefore, failure of any one unit will not effectsystem operation.b. The redundant HVAC equipment is powered from different divisions ofthe emergency diesel generator buses; therefore, failure of any one buswill affect only one train of ventilating equipment.This text still exists in the current version of the FSAR.Energy Northwest Response to Reference 3.2.8FSAR section 9.4.12.3 provides details about the robust design of the heatingand ventilating systems used to support cooling in the TMU pump house. It doesnot state nor imply that this design feature is present in order to meet any GDCrequirements.3.3 Additional Supporting InformationIn addition to the references already provided ion response to the NRC concernsin Section 3.2 of this position paper, Section 3.3.1 of this position paper providesother references regarding the definition of the UHS. Similarly, section 3.3.2 ofthis position paper provides additional references regarding the TMU as only asupport system for the UHS during tornado events to support the UHS meetingGDC 2 design criteria alone.3.3.1 TMU Definition References3.3.1.1 FSAR Amendment 33The following references (emphasis added) were contained within the versionof the FSAR that was in effect when the plant was licensed (Amendment 33).They demonstrate consistency with the Energy Northwest position on thedefinition of the UHS which treats the TMU system as a separate system:* FSAR Section 1.2.2.12.3 Ultimate Heat SinkTwo sWray ponds that serve as the ultimate heat sink conservativelyhave a combined equivalent storage of thirty days, assuming no makeupand maximum evaporation and drift losses." FSAR Section 2.2.3.1 Determination of Design Basis EventsThe Seismic Category I spray ponds provide for 30 day cooling withoutmakeup." FSAR Section 2.4.8 Cooling Water Canals and Reservoirs21 License Basis Evaluation -CGS TMU SystemThe two spray ponds located southeast of the reactor building (seeFigure 2.1-4), designed as Seismic Category I structures... The sprayponds are the ultimate heat sink for normal reactor cool down and arethe ultimate heat sink for emergency cooling." FSAR Section 2.4.11.5 Plant RequirementsMakeup to the plant cooling towers and spray ponds comes from theColumbia River. Should this capability be lost, the cooling load is takenover by the spray ponds. These ponds have sufficient capacity toprovide shutdown cooling water for thirty days without makeup.* FSAR 3.1.2.4.15.1 Evaluation Against Criterion 44The safety related cooling water system is the standby service watersystem, which supplies the RHR System, HPCS System, and the HVACessential systems.The redundant standby service water systems are open loop systemswhich transfer heat from structures, systems and safety relatedcomponents to the ultimate heat sink.The ultimate heat sink consists of two man made Seismic Cateaory Ispray ponds and is designed to withstand extreme natural phenomena* FSAR Section 9.2.5.1 (See Appendix A for additional details)The ultimate heat sink, a spray pond system, supplies cooling water toremove heat from all nuclear plant equipment that is essential for a safeand orderly shutdown of the reactor and to maintain it in a safe condition* FSAR Section 9.2.5.2 (UHS) System DescriptionFollowing any event that would prevent the use of the plant coolingtowers, the heat rejection duties are transferred to the spray ponds. Theultimate heat sink consists of two concrete ponds with redundantpumping and spray facilities. The pond and pumphouse arrangementsare shown on Figure 9.2-11. The ponds and pumphouses are designedto Seismic Category I requirements. Standby service water (SW) loop Adraws water from pond A, cools the Division I equipment required forsafe shutdown, and discharges through the spray ring in pond B for heatdissipation. Similarly, SW loop B draws water from pond B, coolsDivision II equipment, and discharges through the spray ring in pond A.The HPCS SW system draws water from pond A, cools Division Ill anddischarges without spray into pond A. A syphon between the pondsallows for water flow from one pond to the other...22 License Basis Evaluation -CGS TMU SystemThe ultimate heat sink consists of two concrete ponds with redundantpumping and spray facilities...Although the pond is not used for cooling during normal operation, somesmall losses are to be expected due to normal evaporation from thesurface and occasional blowdown needed to maintain water chemistry.The ponds can also be supplied directly from the plant makeup waterpump s.3.3.1.2 NUREG-0892, Safety EvaluationThe following references (emphasis added) were contained within NUREG-0892. They demonstrate consistency with the Energy Northwest position onthe definition of the UHS which treats the TMU system as a separate system:* NUREG-0892 Section 2.5.4.1, GeneralThe seismic Category I UHS system consists of two concrete sprayponds, two standby service water (SSW) pumphouses, and pipelinesand conduits between the pumphouses and the power block structures." NUREG-0892 Section 9.2.5, Ultimate Heat SinkThe UHS consists of two separate spray ponds and two separate andredundant standby service water systems and their associated piping.* NUREG-0892 Section 9.2.7, Standby Service WaterThe standby service water system (SSWS) supplies cooling water to theplant from the two spray ponds which serve as the ultimate heat sink(refer to Section 9.2.5 of this SER).3.3.2 TMU Support to the UHS in the Event of a Tornado3.3.2.1 FSAR Amendment 33The following FSAR Amendment 33 references demonstrate consistency withthe Energy Northwest position that TMU is a support system for the UHS onlyin the case of a tornado with additional failures. The FSAR language treatsthe TMU as a "separate" but important system from the UHS (emphasisadded):* FSAR Section 3.3.2.3, Effect of Failure of Structures or Components NotDesigned for Tornado LoadsThe spray pond piping and supports are designed to withstand theeffects of the design basis tornado. The piping system cannot beprotected from the impact of tornado generated missiles. In the event of23 License Basis Evaluation -CGS TMU Systemmissile damage to one of the pond spray headers, the alternate spraysystem which is 100% redundant is placed in operation.In the event that both spray systems are rendered inoperative, thecooling tower makeup water system is placed into operation to providecontinuous makeup to the spray ponds with Columbia River water, thetemperature of which never exceeds 70 OF. The cooling tower makeupwater system is provided with sufficient protection to prevent its loss offunction in the event of a design basis tornado passing over the projectsite.Since the makeup water flow rate exceeds that of the standby servicewater systems, and since the makeup water temperature is substantiallylower than the standby service water system design temperature of85 OF, the continuous availability of cooling water at a maximumtemperature of 70 IF is assured. The method of detection of spray pondheader failure and procedures for alternate spray pond usage isdescribed in 9.6.* FSAR Section 3.5.2, Systems to be ProtectedThe TMU system is required for safe shutdown only when both sprayring headers are lost to tornado missiles" FSAR Section 9.2.5.3, (UHS) Safety EvaluationThe possibility of a tornado passing over the spray pond and removing asignificant amount of water is considered a credible event. For thisreason, the makeup water pumphouse is designed to be tornado proof,with all piping and electrical power supply between the plant and thepumphouse underground.Since it is not credible to assume an earthquake coincident with atornado, this system need not be Seismic Category I. Two 12,500 gpmplant makeup water pumps are provided, one powered from eachemergency diesel generator. Should pond water be lost due to atornado, one of these pumps will be started to provide makeup. Makeupsupply to the spray ponds is controlled by level switches thatautomatically open a supply valve to allow gravity drain from thecirculating water pump basin to replenish spray pond level when itreaches the makeup setpoint.24 License Basis Evaluation -CGS TMU System* FSAR Section 9.2.7.2, (Standby Service Water System) SystemDescriptionThe two spray ponds provided are sized to have a combined equivalentstora-ge for at least thirty days of operation, assuming no makeup andmaximum evaporation and drift losses. (See 9.2.5).The makeup water system supplies Columbia River water to the coolingtowers or spray pond to replace water lost during normal operation dueto evaporation and drift." FSAR Section 9.4.12, (Makeup Water Pumphouse Ventilation) SafetyEvaluationIn the event of the hypothesized dewaterinq of the standby service waterspray ponds due to a tornado, the make-up water pumps may beoperated to refill the spray ponds.25 License Basis Evaluation -CGS TMU System4.0 SAFETY CLASSIFICATION OF THE TMU SYSTEM4.1 Response to NRC PositionWith regard to the safety classification of the TMU system, the question raised bythe resident inspector is summarized as follows:"Should the TMU system be considered safety related and should 10 CFR 50Appendix B quality requirements apply?"The position of the resident inspector with regard to this question that wascommunicated to Energy Northwest Licensing staff is summarized as follows:Those portions of the TMU system credited for the support of the UHSfunction during a tornado event should be characterized as safety related.This position is based on references provided to Energy Northwest listed insection 5.2 below as well as the associated arguments.Energy Northwest does not agree with this conclusion. It is Energy Northwest'sposition that the TMU system was always classified as non-safety related andonly certain support structures (e.g., TMU pumphouse, soil covering the piping tothe UHS, etc.) were loosely characterized as safety related.An Energy Northwest response is provided to each of the references provided tothe Energy Northwest staff.4.2 NRC Provided References4.2.1 10 CFR 50.2 DefinitionsThe definition of "safety related" is found in 10 CFR 50.2:Safety-related structures, systems and components means those structures,systems and components that are relied upon to remain functional during andfollowing design basis events to assure:(1) The integrity of the reactor coolant pressure boundary(2) The capability to shut down the reactor and maintain it in a safeshutdown condition; or(3) The capability to prevent or mitigate the consequences of accidentswhich could result in potential offsite exposures comparable to theapplicable guideline exposures set forth in § 50.34(a)(1) or § 100.11 ofthis chapter, as applicable.26 License Basis Evaluation -CGS TMU SystemThe TMU system is relied upon to remain functional during and following atornado (i.e., a design basis event) to assure the capability to shut down thereactor and maintain it in a safe shutdown condition.Energy Northwest Response to Reference 4.2.1There are two fundamental concerns with the application of this definition toColumbia's TMU system: 1) the formal definition was established well afterColumbia was licensed, and 2) the NRC approved the current safetyclassification of the TMU system in NUREG-0892 that is not consistent with thisdefinition.The formal definition for "safety related" was not established by the NRC until1997, well after Columbia's license was issued in 1983. As documented in theFederal Register, Volume 61, No. 239, dated December 11, 1996, the formaldefinition of "safety related" was made effective January 10, 1997 when it wasincluded in 10 CFR 50.2. The associated backfit analysis documented in thefederal register states the following (emphasis added):XV. Backfit AnalysisThe NRC has determined that the backfit rule, 10 CFR 50.109, does not applyto this regulation, and, therefore, a backfit analysis is not required for thisregulation because these amendments do not involve any provisions thatwould impose backfits as defined in 10 CFR 50.109(a)(1). The regulationwould apply only to applicants for future nuclear power plant constructionpermits, preliminary design approval, final design approval, manufacturinglicenses, early site reviews, operating licenses, and combined operatinglicenses.At the time of construction and licensing of Columbia, a formal definition of theterms "important to safety" and "safety related" did not exist, usage of theseterms by both the industry and the NRC was inconsistently applied andoccasionally used interchangeably. It was generally accepted that the term"safety related" had a much narrower scope than the term "important to safety".This was reinforced by the NRC's response to two industry related letters asdocumented by Harold Denton, Director of NRR, in Generic Letter 84-01:I agree that the use of these terms in a variety of contexts over the pastseveral years has not been consistent. In recognition of this problem /attempted in my 1981 memorandum to NRR personnel to set forth definitionsof these terms for use in all future regulatory documents and staff testimonybefore the .adjudicatory boards. As you are aware, the position taken in thatmemorandum was that "important to safety" and "safety-related" are notsynonymous terms as used in Commission regulations applicable to nuclearpower reactors.27 License Basis Evaluation -CGS TMU SystemThe former encompasses the broad scope of equipment covered by AppendixA to 10 CFR Part 50, the General Design Criteria, while the latter refers to anarrower subset of this class of equipment defined in Appendix A to 10 CFRPart 100 Section VI(a)(1) and, more recently, in 10 CFR 50.49(b)(I). Basedon such a distinction between these terns, it generally has been staff practiceto apply the quality assurance requirements of Appendix B to 10 CFR Part 50only to the narrower class of "safety-related" equipment, absent a specificregulations directing otherwise.Therefore, it is not reasonable to assume that today's definition for safety relatedfound in 10 CFR 50.2 specifically applied to Columbia's TMU system. In addition,it would not be consistent with the NRC approval of the TMU system safetyclassification in NUREG-0892. Section 3.2 of NUREG-0892, Classification ofStructures, Systems, and Components, the following text is found (emphasisadded)The systems and components important to safety of WNP-2 have beenidentified in an acceptable manner in FSAR Table 3.2-1. Table 3.2-1, in part,identifies the major components in fluid systems such as--pressure vessels,heat exchangers, storage tanks, pumps, piping, and valves--and mechanicalsystems--such as cranes, refueling platforms, and other miscellaneoushandling equipment. In addition, the piping and instrumentation diagrams inthe FSAR identify the Quality Group classification boundaries of theinterconnecting piping and valves. The staff has reviewed Table 3.2-1 and thefluid system piping and instrumentation diagrams and concludes thatpressure-retaining components have been properly classified as QualityGroup A, B, C, or D components in conformation with Regulatory Guide 1.26,Revision 3.The staff finds this summary list of codes and standards used in theconstruction of components to be acceptable. The applicant has also utilizedthe American Nuclear Society (ANS) Safety Classes 1, 2, 3 and "GENERAL"as defined in ANS-22, "Nuclear Safety Criteria for the Design of StationaryBoiling Water Reactor Plants," in the classification of system componentsconsidered by the applicant to be beyond the scope of Regulatory Guide1.26. Safety Classes 1, 2, 3, and "GENERAL" correspond to theCommission's Quality Group A, B, C and D in Regulatory Guide 1.26 andhave been used by the applicant to supplement the Commission's QualityGroup classification system. A summary of the relationship of the NRCQuality Group and ANS Safety Classes is shown in Table 3. 1.28 License Basis Evaluation -CGS TMU SystemTable 3.1 Relationship between NRC Quality Group and ANS safety classesNRC Quality GroupABCDWNP-2 BWR Safety Class123GENERALThe staff has reviewed the use of ANS Safety Classes in Table 3.2-1 andfinds the classification of components to be acceptable. The staff concludesthat construction of the components in fluid systems important to safety inconformance with the ASME Code, the Commission's regulations, and theguidance provided in Regulatory Guide 1.26 and ANS-22; provides assurancethat component quality is commensurate with the importance of the safetyfunction of these systems; and constitutes an acceptable basis for satisfyingthe requirements of GDC 1.With regard to the TMU system and the TMU pumphouse, Amendment 33 ofFSAR Table 3.2-1, Equipment Classification, is provided below. Note that thesafety class is G (i.e., General) applicable for both which is equivalent to a "non-safety related" system. However, only the TMU pumphouse is documented asmeeting Quality Class I requirements. Note 31 recognizes the TMU system ashaving tornado protection by virtue of the TMU pumphouse construction and soilcovering various portions of the TMU system:ScopeofSupply(2)QualityGroupSafety Loca- Classifi-Class tion cation(3) (4) (5)Principal Component(1)Quality Seismic Com-Class Category ments(6) (7)44. Circulating Water and Cool-ing Tower Makeup Water Sys-tem(s)(See Figure 10.4-3).1 Piping and valves P G P D II II (31).2 Pumps P G P D II IT.3 Cooling tower fans P G P D II II47. Buildings.8 Makeup Water Pumphouse N/A G 0 N/A I II (31)31. The makeup water pumphouse is designed to withstand the design basis tornado. Thedesign also considers the possible effects of tornado generated missiles. The towermakeup water piping, valves, and cabling located underground are provided withadequate earth cover to be resistant to tornado generated missiles or are protected bytornado resistant structures.29 License Basis Evaluation -CGS TMU System4.2.2 Washington Public Power Supply System (JJ Stein) letter to NRC(A. Giambusso), Ultimate Heat Sink, dated February 27,1974In the letter referenced above the following statement was made by WPPSS:In addition the Cooling Tower Makeup System will be constructed under 10CFR 50 Appendix B, Quality Assurance Requirements to provide assurancethat tornado protection is actually provided. The Cooling Tower MakeupSystem is not a Seismic Category I system since seismic protection isprovided by the standby Service Water System.Energy Northwest Response to Reference 4.2.2The letter that is referenced is a summary of a meeting that took place betweenthe NRC and WPPSS (now Energy Northwest) in October 1973. EnergyNorthwest understood that the Appendix B quality requirements applied to the"tornado protection" aspect of the TMU system (e.g., TMU Pumphouse, soilcovering both the piping to the UHS and power cabling to the TMU pumphouse).Note that the language in the letter points to the intent of the Appendix Bapplication: "to provide assurance that tornado protection is actually provided'.This was accomplished for the pumphouse and the soil used for covering thepiping and cabling.This was further supported in an August 1974 letter from Burns and Roe, theprimary architectural engineering firm for WNP-2 (now Columbia) to WPPSS, inwhich John J. Verdeber, Project Engineering Manager, an attendee at theOctober 1973 meeting with the NRC makes the following response to commentsraised by WPPSS staff:WPPSS CommentThose portions of the makeup water pumphouse required for tornadoprotection and for operability in providing a source of makeup water should beQuality Class I. This would be consistent with the fact that the river watermakeup pumps are provided with emergency power through the buriedredundant feeders running from the reactor area to the river waterpumphouse. In addition, we have told the AEC in our letter GC2-74-28 datedFebruary 27. 1974 that "The cooling tower makeup system will be constructedunder 1 OCFR50 Appendix B, Quality Assurance requirements, to provideassurance that tornado protection is actually provided." The easiest way ofmeeting this requirement would be to require all construction in the makeupwater pump house to be Quality Class I with no exceptions. Lacking this, thedrawings should be very specific in what work is required to be Quality Class Iand what work does not have to meet these requirements.30 License Basis Evaluation -CGS TMU SystemBurns and Roe ResponseThe application of the Q.A. I designation applies only to that portion of thework required to provide tornado protection. Since this mainly refers to missileprotection, only the structure has been classified Q.A. I. This position isconsistant with the commitment to the A.E.C.This position communicated by Mr. Verdeber is consistent with the responseprovided by WPPSS to the NRC in the referenced letter. In addition this positionhas been further promulgated in the Columbia FSAR Table 3.2-1 (Amendment33 to the current version). As documented in response to reference 5.2.1 above,this position was accepted by the NRC in section 3.2 of NUREG-0892.4.2.3 WPPSS Response to NRC FSAR Review Question 10.12 (Amendment 33)In the WPPSS response to question 10.12, WPPSS identified what items in theturbine building have safety related functions (see below).0. 010.012Provide the results of your evaluation of the jet impingement forces and theenvironmental effects, including pressure, temperature, humidity, andflooding, resulting from a postulated failure of the main steam and mainfeedwater systems in the Turbine Building. This evaluation should onlyaddress those safety-related components, systems and structures, if any, in(or immediately adjacent to) the Turbine Building (e.g., the walls of theAuxiliary Building)Response:It has been determined that the only items with safety-related functions in theTurbine Building are some RPS sensor inputs from the Main Steam System,MSIV isolation logic inputs from the Main Steam System, and the TowerMake-up Transformers located in the basement of the Turbine Building whichare required to function only for the Design Basis Tornado event.Energy Northwest Response to Reference 4.2.3This is an example of a misuse of the "safety-related" terminology. As noted inGL 84-01, the subset of SSCs considered to be safety-related were thosecredited in 10 CFR 100 Appendix A Sections IV(a)(1) and IV(a)(2). Therequirements of 10 CFR 100 outlined what SSCs were required in the event of asafe shutdown earthquake (SSE) and operating basis earthquake (OBE). TheTMU system is not now nor has it ever been credited for performing a safetyfunction in the event of an SSE or OBE.31 License Basis Evaluation -CGS TMU SystemThe TMU system is and has always been a non-safety related system used tosupport the safety related UHS in the very unlikely probability that both ponds ofthe UHS (i.e., spray systems or water volume) are impacted by a tornado.This concept that a non-safety related system could support a safety relatedfunction is also presumed in 10 CFR 50.65(b)(2) (emphasis added):b) The scope of the monitoring program specified in paragraph (a)(1) of thissection shall include safety related and nonsafety related structures, systems,and components, as follows:(2) Nonsafety related structures, systems, or components:(i) That are relied upon to mitigate accidents or transients or are used in plantemergency operating procedures (EOPs); or4.2.4 WPPSS Response to NRC FSAR Review Question 10.40 (Amendment 21)In the WPPSS response to question 10.40, WPPSS calls the TMU system asafety-related piping system (see below).Q. 010.040(3.5.1)The FSAR states that the water lines are "... tornado-hardened." State yourcriteria for protecting pipes located outside buildings from tornado missiles,including depth below grade requirements and provide drawings which showall pertinent tornado protection features as necessary.Response:... The standby service water piping and the tower makeup water systemfrom the river are the only safety-related water piping systems outside oftornado protected buildings.Energy Northwest Response to Reference 4.2.4Similarly to that described in response to reference 4.2.3, this statement is animprecise use of the term "safety-related".32 License Basis Evaluation -CGS TMU System4.2.5 WPPSS letter (GD Bouchey) to NRC (A Schwencer) Submittal ofInformation Provided NRC Representatives During a Site Visit April 26-27,1982, dated May 12, 1982In attachment 3 of the above letter, WPPSS concluded that the safety function ofthe UHS was assured following a tornado because of the provisions of the TMUsystem. Reference the applicable text below:The Ultimate Heat Sink (UHS) spray piping networks are not consideredtornado resistant and are assumed to be lost functionally following a tornado.The safety function of the UHS is assured by providing cooling water from theColumbia River via buried makeup water system piping. This system hasthree (3) pumps each capable of providing over 12,000 gpm to the sprayponds. The river water enters the pond near the standby service water intake,is pumped to the plant and back to the other pond where it overflows the pondweir and goes back to the river. The makeup pumps and pipe to the spraypond are protected from the effects of tornados, but the syphon is notprotected since it is not required following a tornado.Energy Northwest Response to Reference 4.2.5Refer to Energy Northwest response to references 4.2.3 and 4.2.4.4.2.6 FSAR Amendment 33 Sections 3.5.2, 3.8.4.1, 3.8.5.1.7, 9.2.5.3, 9.2.7,9.4.12.3, and Appendix C (December 1983)Amendment 33 of the FSAR was the version in effect at the time of initiallicensing of Columbia (formerly WNP-2). The connection with TMU being safetyrelated was documented in the following sections:* Section 3.5.2, Systems To Be Protected.. The plant structures, systems, equipment, and components that arerequired to bring the plant to a safe shutdown condition, or whose failurecould lead to offsite radiological consequences under accident conditions,are protected from external (outdoor) missiles by barrier structures orredundant systems as follows:b. The standby service water (SSW) and the tower makeup water (TMU)pipelines and electrical lines between the SSW pumphouses, the TMUpumphouse, the reactor building, and the diesel generator building arelocated below grade and are protected from external missiles bysufficient Quality Class 1 earth cover of high relative density (describedin 3.5.3). The SSW and the TMU piping systems are the only safety-related water piping systems outside of tornado protected buildings. TheTMU system is required for safe shutdown only when both spray ringheaders are lost to tornado missiles (see 3.3.2).33 License Basis Evaluation -CGS TMU System* Section 3.8.4.1, Description of Structures (Other Non-Seismic Category ISafety Related Structures)The following provides descriptive information of the various structures,other than the primary containment vessel and its internal structures, todefine their primary structural aspects and elements relied on to performtheir safety-related functions. The relation between adjacent structures,including the separations provided, is also discussed. Figures 1.2-1 through1.2-24, 3.8-1, 3.8-2, 3.8-27 through 3.8-42, and 3.8-49 show arrangementsand details of these structures.The various plant structures discussed are the following:f. Makeup water pump house and associated structures of the coolingtower makeup water system, such as valve box structures at pointsalong the makeup water underground pipe line," Section 3.8.5.1.7, Non-Seismic Category I Safety Related FoundationsThe makeup water pumphouse is a non-Seismic Category I structure but isa safety related installation designed to withstand the Design Basis Tornadoand tornado-generated missiles.* Appendix C, Conformance With NRC Regulatory GuidesRegulatory Guide 1.27, Rev. 2, January 1976Ultimate Heat Sink for Nuclear Power PlantsCompliance or Alternate Approach Statement:WNP-2 does not comply with the guidance set forth in Revision 2 of thisregulatory guide.WNP-2 complies with the intent of the guidance set forth in Revision 1 ofthis regulatory guide by an alternate approach.General Compliance or Alternate Approach Assessment:... Two Seismic Category I spray ponds are used, each with a capacity of6.5 million gallons each. The makeup for these ponds is supplied fromthe pumphouse at the Columbia River. The makeup water piping isburied under a minimum of 5 feet of Quality Class I fill. The makeupwater supply system is utilized only in the event of a design basistornado, and therefore, it is not designed and constructed to withstandthe effects of the OBE and water flow based on severe historical eventsin the region.34 License Basis Evaluation -CGS TMU SystemThe connection with TMU being safety related was documented in the followingFSAR Amendment 33 sections:" Section 9.2.5.3, Safety Evaluation (Ultimate Heat Sink)... The possibility of a tornado passing over the spray pond and removing asignificant amount of water is considered a credible event. For this reason,the makeup water pumphouse is designed to be tornado proof, with allpiping and electrical power supply between the plant and the pumphouseunderground.Since it is not credible to assume an earthquake coincident with a tornado,this system need not be Seismic Category I. Two 12,500 gpm plant makeupwater pumps are provided, one powered from each emergency diesel.generator. Should pond water be lost due to a tornado, one of these pumpswill be started to provide makeup. Makeup supply to the spray ponds iscontrolled by level switches that automatically open a supply valve to allowgravity drain from the circulating water pump basin to replenish spray pondlevel when it reaches the makeup setpoint." Section 9.2.7.2, System Description (Standby Service Water)The spray ponds are provided with makeup water by the circulating watersystem. The makeup water system supplies Columbia River water to thecooling towers or spray pond to replace water lost during normal operationdue to evaporation and drift. In addition, the makeup system is designed toreplace spray pond water lost during a tornado. To ensure systemavailability for this mode of operation, the makeup system is designed towithstand a design basis tornado coincident with a loss of offsite power.* Section 9.4.12.3, Safety Evaluation (HVAC Systems)The makeup water pumps are required to supply water to the SW sprayponds in the event a design basis tornado empties the ponds of theircoolant (see Section 9.2.7).Energy Northwest Response to Reference 4.2.6As noted in response to reference 4.2.1 and documented in GL 84-01, the use ofphrase "safety related" was not always consistently applied. Energy Northwestacknowledges that the language in the referenced sections was not alwaysconsistently applied.In every case where the phrase was documented in terms of the characterizationof structures, systems, or components (SSCs) associated with the TMU systemor TMU pumphouse, it was used inconsistent with that established in FSARTable 3.2-1 and section 3.2 of NUREG-0892 (e.g., FSAR sections 3.5.2 and3.8.5.1.7). It would be more consistent to state that although these SSCs are35 License Basis Evaluation -CGS TMU Systemnon-safety related, they do provide an important to safety function associatedwith tornado events.In all other cases, where it was used to simply describe a "function" of the TMUsystem in the event of a tornado under the circumstances described in responseto reference 5.2.3, Energy Northwest agrees that it was commonlymischaracterized as a "safety related" function. This would also be true for anysection that implies a safety related function but does not declare the function tobe safety related in the text (e.g., FSAR Section 3.8.4.1, Appendix C, NUREG0892 sections 9.2.5.3, 9.2.7.2, and 9.4.12.3).4.2.7 NUREG-0892, WNP-2 Safety Evaluation Report Sections 3.5.2 and 9.4.6In SER section 3.5.2, Structures, Systems, and Components to be Protectedfrom Externally Generated Missiles, the NRC infers that the TMU systemequipment in the TMU pumphouse is safety-related:Except for the diesel generator exhausts, the fresh air intakes and exhaustsfor safety-related ventilation systems that service safety-related equipmentare protected from tornado missiles by a concrete barrier or labyrinth, therebyprotecting the safety-related equipment and areas from driving rains, snow,sleet, hail, and other natural phenomena. The safety-related equipment islocated in seismic Category I, tornado-missile-protected buildings, except forthe makeup water pumphouse that is seismic Category II and is not requiredafter an SSE. Therefore, the equipment inside this structure is protected fromthe effects of natural phenomena.In SER section 9.4.6, the NRC concludes the following regarding the turbinebuilding ventilation systems:The turbine building ventilation system provides the turbine building airflowrequirements and is classified as nonsafety related (Quality Group D,nonseismic Category I) except for the makeup water transformer ventilationsystem. The ventilation system is capable of adequately maintaining anacceptable environment for personnel and the nonessential equipment servedduring normal plant operation. Except for the makeup water transformerventilation system, failure of the system does not compromise the operationof any essential systems and does not affect the capability to safely shutdown the plant.Energy Northwest Response to Reference 4.2.7Refer to the Energy Northwest response to reference 4.2.6.36 License Basis Evaluation -CGS TMU System4.3 Additional Supporting InformationIn addition to the references already provided in response to the NRC concernsin Section 4.2 of this position paper, Section 4.3.1 of this position paper providesother references regarding the non-safety classification of the TMU system.4.3.1 The TMU system was initially characterized as non-safety related as can befound in the following documents:" Figure 10.8-1 of the PSAR (submitted February 25, 1972) shows theMakeup Water from the river as Class UBC -Uniform Building Code.* Procurement Specification No. 225 purchased TMU valves as QualityClass II.* Procurement Specification No. 215 purchased TMU piping as QualityClass II (ANSI B31.1)." Construction Drawings for TMU (C536-C51 and C870) show all piping asQuality Class II4.3.2 In response to a violation identified by the NRC in Inspection Report 84-007 inwhich a QC 1 system was not appropriately classified as QC 1 on workdocuments or the FSAR. WPPSS investigated the matter and noted in letter Lo2-84-007 a review of QC 1 components in QC 2 systems. This review identified theTMU as QC 2 system.5.0 SUMMARY AND CONCLUSIONBased on a thorough review of NRC requirements and early and currentLicensing documentation it is Energy Northwest's position that the TMU systemis a non-safety related support system for the Ultimate Heat Sink and does notrequire single failure protection to ensure the UHS remains operable.37 License Basis Evaluation -CGS TMU System

6.0 REFERENCES

The following references were reviewed in the development of this positionpaper. Not all were referenced within the text of the report.6.1 Regulatory References1. 10 CFR 50.2, Definitions2. 10 CFR 100, Reactor Site Criteria3. 10 CFR 50, Appendix A General Design Criteria for Nuclear Power Plants4. 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plantsand Fuel Reprocessing Plants5. NRC Regulatory Guide 1.26, Quality Group Classifications and Standards forWater-, Steam-, and Radioactive-Waste-Containing Components of NuclearPower Plants, Revision 3 (February 1976)6. NRC Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants,Revision 2 (January 1976)7. NRC Regulatory Guide 1.117, Tornado Design Classification, Revision 1(April 1978)8. NUREG-0542 Evaluation of External Hazards to Nuclear Power Plants in theUnited States, December 19879. NUREG-0800, Standard Review Plan for the Review of Safety AnalysisReports for Nuclear Power Plants10. NUREG-0892, Safety Evaluation Report Related to the Operation of WPPSSNuclear Project No. 2, March 198211. NUREG-2123, Safety Evaluation Report Related to the License Renewal ofColumbia Generating Station, May 201212. Federal Register, Volume 61, Number 239 (65157-65177)13. Generic Letter 80-30, Clarification of the Term "Operable" As It Applies toSingle Failure Criterion For Safety Systems Required by TS14. Generic Letter 84-01 NRC use of the terms, "Important to Safety" and"Safety Related38 License Basis Evaluation -CGS TMU System6.2 Correspondence (by date)1. Letter, Lo2-71-001, WPPSS (JJ Stein) to AEC (Dr. PA Morris), Applicationfor Construction Permit and Facility License for Hanford No. 2 Nuclear PowerPlant, dated August 10, 19712. Internal Memo, Burns & Roe (M. HroncichlWJ Ritsch to JJ Byrnes), W.O.2808, Washington Public Power Supply System, Hanford No. 2, MakeupWater System Safety Design Considerations, T.M. #200, dated April 25,19723. Internal Memo, Burns & Roe (M. Hroncich to RT Richards), W.O. 2808-31,WPPSS, Hanford Project #2, River Water Pumps and Pump Structure,Technical Memorandum No. 525, dated June 7, 19734. Announcement, AEC, Forthcoming Meeting with Washington Public PowerSupply System -Hanford No. 2, (Date unknown -prior to October 1973?)5. Letter, AEC (WR Butler) to WPPSS (JJ Stein), transmitting minutes ofOctober 17-18, 1973 meeting, meeting agenda item No.6, dated November20, 19736. Letter, AEC (VA Moore) to WPPSS (JJ Stein), no title (Construction PermitNo. CPPR-93), dated March 19, 19737. Letter, GC2-74-28, WPPSS (JJ Stein) to AEC (A Giambusso), Ultimate HeatSink, dated February 27, 19748. Letter, AEC (WR Butler) to WPPSS (JJ Stein), no title, dated July 26, 19749. Letter, BRWP-74-718, Burns & Roe (JJ Verderber) to WPPSS (JE Woolsey),W.O. 2808, Washington Public Power Supply System, Hanford No. 2,contract No. 225 Make Up water Pump House, dated August 14, 197410. Letter, Go2-74-30, WPPSS (JJ Stein) to AEC (A Giambusso), Ultimate HeatSink Makeup Supply System Tornado Missile Protection, dated September16,197411. Internal Memo, Burns & Roe (J Foreman to JJ Verderber), W.O. 2808Washington Public Power Supply System, WPPSS Nuclear Project No. 2,Quality Assurance Classification of Piping and Fitting, to be Prepurchased,for the 225 Contractor by WPPSS, Technical Memorandum No. 705, datedOctober 8, 197412. Internal Memo, Burns & Roe (J Foreman to JJ Verderber), W.O. 2808,WPPSS, Nuclear Project No. 2, Ultimate Heat Sink Design, TechnicalMemorandum No. 770, dated February 14, 197539 License Basis Evaluation -CGS TMU System13. Internal Memo, Burns & Roe (J Foreman to JJ Verderber), W.O. 2808,WPPSS Nuclear Project No. 2, Plant Service Water Pumps and Other Non-Class 1 E 4160 Volt Switchgear Connections to Emergency Buses, TechnicalMemorandum No. 895, Rev. 1, dated May 26,197614. Letter, Go2-82-036, WPPSS (GD Bouchey) to NRC (A Schwencer), NuclearProject No. 2 Submittal of Information Provided NRC Representatives DuringA Site Visit April 26-27, 1982, dated May 12, 198215. Letter Go2-82-523, WPPSS (RG Matlock) to NRC (RH Engelken), SupplySystem Nuclear Project No. 2 Tenth Progress Report -1OCFR50.54(f), datedJune 10, 198216. Letter, NRC (DG Eisenhut) to WPPSS (DW Mazur), Issuance of FacilityOperating License NPF-21 -WPPSS, Nuclear Project No. 2, datedDecember 20, 198317. NRC Inspection Report 84-07, dated April 18, 198418. Letter, WPPSS (J. D. Martin) to NRC (RA Scarano), Nuclear Plant No. 2,License No. NPF-21, NRC Inspection 84-07 March 19-23, 1984, dated June15, 198419. Letter, Go2-86-243, WPPSS (GC Sorensen) to NRC (EG Adensam), NuclearPlant No. 2 Operating License NPF-21, Request for Amendment to License -(Ultimate Heat Sink), dated March 21, 198620. Letter, NRC (RB Samworth) to WPPSS (GC Sorensen), Issuance OfAmendment No. 52 to Facility Operating License NPF-21 -WPPSS NuclearProject No. 2 (Tac No 61014), dated April 4, 198821. NRC Inspection Report 93-201, Service Water System OperationalPerformance Inspection, dated April 1, 199322. NRC Memorandum, Response to Task Interface Agreement (TIA) RegardingNorthern States Power Company (Monticello) Definition of Non-SafetyRelated (AIT 97-018), dated February 2, 199923. NRC Memorandum, DC Cook -Task Interface Agreement (TIA)99-031 -Evaluation of the Acceptability of the Classification and Field Installation ofNon-Safety-Related Control Cables Used in the Load Shedding Circuitry toPerform the Safety-Related Function of Shedding Loads off Safety-RelatedBuses, dated February 29, 200024. NRC Letter to Perry Nuclear Station, Application of Generic Letter 80-30Guidance to an Inoperable Non-Technical Specification Support Subsystem,dated April 5, 200240 License Basis Evaluation -CGS TMU System25. NRC Inspection Report 2003-06, Columbia Generating Station -NRCIntegrated Inspection Report dated November 5, 200326. NRC Memorandum, Final Response to Task Interface Agreement 2012-03,Regarding Plant Design and Licensing Basis on Diesel Fuel Oil Supply of theEmergency Diesel Generators at Monticello Nuclear Generating Plant, datedAugust 20, 20136.3 Columbia Specific Documents1. Preliminary Safety Analysis, August 10, 19712. Final Safety Analysis Report, Amendment 33 (Initial Licensed version)3. Final Safety Analysis Report, Amendment 63 (current)4. Technical Specifications, Amendment 575. Technical Specifications, Amendment 230 (current)6. Operational Quality Assurance Description Program (OQAPD), Revision 47(current)7. Design Basis Document 309, Standby Service Water System, Revision 841