GO2-21-108, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

ML21235A222
Person / Time
Site:	Columbia
Issue date:	08/20/2021
From:	David Brown Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-21-108
Download: ML21235A222 (7)

Text




       

David P Brown ENERGY Site Vice President Columbia Generating Station NORTHWEST P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.8385 l F. 509.377.4674 dpbrown@energy-northwest.com August 20, 2021 GO2-21-108 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-439, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO

References:

1. Letter from R.E. Schuetz, Energy Northwest, to NRC, License Amendment Request to Adopt TSTF-438, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Dated December 2, 2020 (ADAMS Accession Number ML20337A141)

2. Email from M. Chawla, NRC to Richard M. Garcia, Final - Request for Additional Information - Columbia Generating Station - License Amendment Request to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO - EPID L-2021-LLA-0259, dated August 3, 2021

Dear Sir or Madam:

By Reference 1 Energy Northwest submitted a License Amendment Request for Columbia Generating Station (Columbia) to Adopt Technical Specifications Task Force Traveler (TSTF) 439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [limiting conditions for operation]. By Reference 2 the Nuclear Regulatory Commission requested additional information related to the Energy Northwest submittal. The enclosure to this letter contains the requested information.

The No Significant Hazards Consideration Determination provided in the original submittal is not altered by this submittal. No new commitments are being made by this letter or the enclosure. If there are any questions or if additional information is needed, please contact Mr. R.M. Garcia, Licensing Supervisor, at 509-377-8463.




       

GO2-21-108 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed this ______ day of August 2021.

Respectfully, David P Brown Site Vice President

Enclosure:

As stated cc: NRC RIV Regional Administrator NRC Senior Resident Inspector NRC NRR Project Manager CD Sonoda - BPA EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH




       

GO2-21-108 Enclosure Page 1 of 5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated December 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20337A141), Energy Northwest (the licensee) submitted a license amendment request for Columbia Generating Station (Columbia) to adopt Technical Specifications Task Force Traveler (TSTF) 439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

[limiting conditions for operation]. The proposed change would revise Section 1.3 of the Columbia Technical Specifications (TS) to alter the discussion contained in Example 1.3-3 to eliminate second completion times (CT) as well as delete the second completion times associated with TS 3.8.1, AC [alternating current] Sources -

Operating, required actions A.3 and B.4.1, B.4.2.2 and TS 3.8.7, Distribution Systems

- Operating, required actions A.1 and B.1.

The NRC staff has reviewed the requested license amendment and determined that additional information is required to complete the review.

Regulatory Requirements:

Part 50.36, "Technical Specifications," of Title 10 of the Code of Federal Regulations requires, in part, that the operating license of a nuclear production facility include TS.

Paragraph 50.36(c)(2) of Title 10 of the Code of Federal Regulations requires, in part, that the TS include limiting conditions for operation (LCO), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS, until the condition can be met.

Background:

Section 2.2 of the Columbias application lists variations from the TS changes described in TSTF-439. The Staff is requesting additional information on two specific variations as discussed below:

x Regarding the first variation which concerns TS LCO 3.8.1, AC Sources-Operating, Required Action A.3, the LARs page 2 states:

TS 3.8.1, Required Action A.3 contains two second CT that will be removed. The first is 6 days from discovery of failure to meet LCO when not associated with Required Action B.4.2.2 and 17 days from discovery of failure to meet LCO. This plant-specific change is the result of license amendment 197 issued on April 14, 2006 - Extension of Diesel Generator Completion Time (ADAMS Accession No. ML061000672).




       

GO2-21-108 Enclosure Page 2 of 5 The LAR justifies the proposed change as follows:

The justification for removal of the Required Action B.4 second CT in TSTF-439 remains the same for the plant-specific completion times.

Therefore, this change does not impact the applicability of TSTF-439.

x Regarding the second variation which concerns TS LCO 3.8.1, AC Sources -

Operating, Required Action B.4.2.2, the LARs page 3 states:

TS 3.8.1, Condition B, contains two Required Actions to Restore required DG to OPERABLE status instead of one. Required Actions B.4.1 and B.4.2.2, Restore required DG to OPERABLE status are separated by the Logical Connector OR and each have a second CT. Required Action B.4.1 Restore required DG to OPERABLE status second Completion Time of 6 days from discovery of failure to meet LCO is being removed.

Required Action B.4.2.2 Restore required DG to OPERABLE status second Completion Time of 17 days instead of 6 days from discovery of failure to meet LCO is also being removed. This plant-specific change is the result of license amendment 197 issued on April 14, 2006, Extension of Diesel Generator Completion Time.

The LAR justifies the proposed change as follows:

The justification for removal of the Required Action B.4 second CT in TSTF-439 remains the same for the plant-specific completion times.

Therefore, this change does not impact the applicability of TSTF-439.

The above variations refer to the Staffs approved license amendment 197 issued on April 14, 2006, Extension of Diesel Generator Completion Time, (ADAMS Accession No. ML0610006720, shown in bolded text). The staffs approval for amendment 197 was based on the licensees Deterministic Evaluation, Risk Evaluation, PRA Capability and Insights, and several regulatory commitments as specified the Staffs technical evaluation on pages 8, 13, 14 and 25 of the approved amendment.




       

GO2-21-108 Enclosure Page 3 of 5 NRC REQUEST No. STSB-1:

Please confirm that the proposed deletion of specific second completion times for TS 3.8.1 Required Actions mentioned above, does not adversely affect any operational restrictions or requirements imposed on plant operation by Amendment 197. If they are affected, please provide an evaluation and justification. The licensees proposed amendment does not address such evaluation for the specified variations.

ENERGY NORTHWEST RESPONSE TO RAI STSB-1:

The design and engineered features that were rooted in the staffs approval for amendment 197 continue to remain integrated into Columbias design. Enhancements that were realized through implementation of a series of commitments reflected in amendment 197 continue to remain an integral part of Columbias conduct of operations. Columbias commitment to the operational restrictions or requirements imposed on plant operation by Amendment 197 remains in place.

NRC REQUEST No. STSB-2:

The licensee proposes to delete the Second CT associated with TS LCO 3.8.7 Distribution Systems - Operating, Required Action A.1 and Required Action B.1 (TS pages 3.8.7-2 and 3.8.7-3) which currently states, AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO 3.8.7.a or b. This particular CT appears to apply when LCO 3.8.7 a or b is not met, and the version of the Distribution Systems TS on which TSTF-439s changes are based does not contain an LCO structure divided into subparts in the manner of the LCO for Columbia TS 3.8.7. Please explain the variation and justify the applicability of TSTF-439 for the proposed deletion.

ENERGY NORTHWEST RESPONSE TO RAI STSB-2:

While the division in Columbias LCO 3.8.7 does not exactly match the standard TS LCO 3.8.9, it is functionally equivalent and therefore the overall logic basis of TSTF-439 is applicable. The second completion time associated with standard TS 3.8.9 allows a maximum of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> which is twice the longest completion time (associated with CONDITION A). The second completion time of Columbias TS 3.8.7 similarly allows a maximum of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, again twice the longest completion time associated with CONDITION A. Columbias CONDITION A applies when Division 1 OR Division 2 AC subsystems are inoperable. Standard TS CONDITION A applies with one or more AC subsystems inoperable. Loss of Division 1 and 2 AC subsystems at Columbia would trigger safety function assessment and CONDITION F entry as warranted. A scenario in which any of the standard completion times would be further limited by the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> second completion time would only apply in a highly unlikely scenario directly as depicted in Figure 2 of TSTF-439 (see figure below) whereby CONDITION A was entered, exited and re-entered in a span of less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with a CONDITION B




       

GO2-21-108 Enclosure Page 4 of 5 entry ongoing to bridge the period between the two entries of CONDITION A. The lack of a dedicated condition in Columbias LCO 3.8.7 associated with inoperable AC vital busses does not change this logic since the completion time associated with inoperable vital buses is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in the standard TS. This 2-hour time is comparable to the 2-hour time associated with DC subsystems, Columbias Condition B. Overlapping inoperabilities with 2-hour completion times will already result in less than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of total action time. As outlined below, the programs established as an acceptable basis for eliminating second completion times in TSTF-439 are present at Columbia and justify the deletion of Columbias 16-hour second completion times.

Time = 0 Limited by second Completion Time to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AC subsystem inoperable AC subsystem inoperable

~ 1--------=--1 Condition A Condition A Inoperabilities must overlap. If loss of safety function, enter LCO 3.0.3 Vital AC bus immediately by Condition E inoperable Condition B or DC Less subsystem than 2 inoperable hours Condition C Figure associated with Example 2 of TSTF-439 Consistent with the justification provided in TSTF-439, the second completion time is not needed. Credit is taken for the Maintenance Rule and example 2 of TSTF-439.

Should any overlapping inoperabilities that result in a loss of safety function occur (TS 3.8.7, CONDITION F), a plant shutdown in accordance with LCO 3.0.3 is required (TS 3.8.7, REQUIRED ACTION F.1).

The Maintenance Rule, 10 CFR 50.65(a)(1), requires each licensee to monitor the performance or condition of structures, systems, and components (SSC) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken.

The NRC Resident Inspectors monitor the Corrective Action process and could take action if the licensees maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor




       

GO2-21-108 Enclosure Page 5 of 5 maintenance practices resulted in multiple entries into the actions of the TS and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).

Columbias Maintenance Rule provides a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.