ML21005A178

Issuance of Amendment No. 263 to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems Using the Consolidated Line Item Improvement Process

ML21005A178
Person / Time
Site:	Columbia
Issue date:	01/25/2021
From:	Mahesh Chawla Plant Licensing Branch IV
To:	Sawatzke B Energy Northwest
Chawla M
References
EPID L-2020-LLA-0020
Download: ML21005A178 (18)

Text

January 25, 2021 Mr. Bradley J. Sawatzke Chief Executive Officer Energy Northwest Mail Drop 1023 76 North Power Plant Loop P.O. Box 968 Richland, WA 99352

SUBJECT:

COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT NO. 263 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-566, REVISE ACTIONS FOR INOPERABLE RHR SHUTDOWN COOLING SUBSYSTEMS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2020-LLA-0020)

Dear Mr. Sawatzke:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 263 to Renewed Facility Operating License No. NPF-21 for Columbia Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 27, 2020.

The amendment revises the Columbia TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable. The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, dated January 19, 2018, using the consolidated line item improvement process.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosures:

1. Amendment No. 263 to NPF-21

2. Safety Evaluation cc: Listserv

ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 263 License No. NPF-21

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Energy Northwest (the licensee), dated January 27, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-21 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 263 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-21 And the Technical Specifications Date of Issuance: January 25, 2021 Perry H.

Buckberg Digitally signed by Perry H. Buckberg Date: 2021.01.25 14:42:19 -05'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 263 RENEWED FACILITY OPERATING LICENSE NO. NPF-21 COLUMBIA GENERATING STATION DOCKET NO. 50-397 Replace the following pages of Renewed Facility Operating License No. NPF-21 and the Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specification REMOVE INSERT 3.4.9-1 3.4.9-1 3.4.9-2 3.4.9-2 3.4.10-1 3.4.10-1 3.4.10-2 3.4.10-2

Renewed License No. NPF-21 Amendment No. 263 (2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 263 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

a. For Surveillance Requirements (SRs) not previously performed by existing SRs or other plant tests, the requirement will be considered met on the implementation date and the next required test will be at the interval specified in the Technical Specifications as revised in Amendment No. 149.

(3)

Deleted.

(4)

Deleted.

(5)

Deleted.

(6)

Deleted.

(7)

Deleted.

(8)

Deleted.

(9)

Deleted.

(10)

Deleted.

(11)

Deleted.

(12)

Deleted.

(13)

Deleted.

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 Columbia Generating Station 3.4.9-1 Amendment No. 169,187 225 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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NOTES-------------------------------------------

1.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

2.

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for performance of Surveillances.

APPLICABILITY:

MODE 3 with reactor steam dome pressure less than 48 psig.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown cooling subsystems inoperable.

A.1 Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and associated Completion Time of Condition A not met.

B.1 Initiate action to restore RHR shutdown cooling subsystem(s) to OPERABLE status.

Immediately 263

RHR Shutdown Cooling System - Hot Shutdown 3.4.9 Columbia Generating Station 3.4.9-2 Amendment No. 164,169 225 238 246 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling subsystem in operation.

AND No recirculation pump in operation.

C.1 Initiate action to restore one RHR shutdown cooling subsystem or one recirculation pump to operation.

AND C.2 Verify reactor coolant circulation by an alternate method.

AND C.3 Monitor reactor coolant temperature and pressure.

Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1

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

Not required to be met until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after reactor steam dome pressure is less than 48 psig.

Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control Program 263

RHR Shutdown Cooling System - Cold Shutdown 3.4.10 Columbia Generating Station 3.4.10-1 Amendment No. 149,169 225 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.10 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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NOTES-------------------------------------------

1.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

2.

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillances.

APPLICABILITY:

MODE 4.

ACTIONS

---

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown cooling subsystems inoperable.

A.1 Verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and associated Completion Time of Condition A not met.

B.1 Initiate action to restore RHR shutdown cooling subsystem(s) to OPERABLE status.

Immediately 263

RHR Shutdown Cooling System - Cold Shutdown 3.4.10 Columbia Generating Station 3.4.10-2 Amendment No. 149,169 225 238 246 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling subsystem in operation.

AND No recirculation pump in operation.

C.1 Verify reactor coolant circulating by an alternate method.

AND C.2 Monitor reactor coolant temperature and pressure.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control Program SR 3.4.10.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program 263

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 263 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397

1.0 INTRODUCTION

By application dated January 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20030C062), Energy Northwest (the licensee) submitted a license amendment request (LAR) for Columbia Generating Station (Columbia). The amendment would revise technical specification (TS) actions for inoperable residual heat removal (RHR) shutdown cooling (SDC) subsystems in the RHR SDC system limiting conditions for operation.

The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, dated January 19, 2018 (ADAMS Accession No. ML18019B187). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation approving TSTF-566, Revision 0, on February 21, 2019 (ADAMS Accession No. ML19028A287), using the consolidated line item improvement process.

The licensee is not proposing any variations from the TS changes described in TSTF-566 or the applicable parts of the NRC staffs safety evaluation of TSTF-566.

2.0 REGULATORY EVALUATION

2.1 Description of the Residual Heat Removal Shutdown Cooling System The RHR SDC system is part of the Emergency Core Cooling System (ECCS). The safety function of the ECCS is to provide core cooling following a loss-of-coolant accident (LOCA).

The ECCS consists of two high-pressure and two low-pressure systems. The high-pressure systems are the high-pressure core spray system and the automatic depressurization system.

The low-pressure systems are the low-pressure coolant injection mode of RHR and the low-pressure core spray system.

The manner in which the ECCS operates to protect the core is a function of the rate at which reactor coolant inventory is lost from the break. The high-pressure core spray is designed to operate while the reactor coolant system is at high pressure. The low-pressure core spray and low-pressure coolant injection are designed for operation at low pressures. If the break in the nuclear system process barrier is of such a size that the loss-of-coolant exceeds the capability of the high-pressure core spray, reactor pressure decreases at a rate fast enough for the low-pressure ECCS to commence coolant injection into the reactor vessel in time to cool the core. Automatic depressurization is provided to reduce reactor pressure if a break has occurred and the high-pressure coolant injection system is inoperable.

The RHR system is a low-pressure system that can be used for cooling and for inventory control. The primary purposes of the RHR system low-pressure coolant injection mode is to automatically initiate and maintain reactor water level following a LOCA and the primary purpose of the RHR containment spray mode is to condense steam for primary containment pressure reduction and to reduce airborne activity in the primary containment following a LOCA.

The RHR system consists of three independent closed loops, each containing a motor-driven pump powered by an engineered safety feature system.

The SDC mode of the RHR system is operated during normal unit cooldown and shutdown to remove decay heat. The RHR system is placed in the SDC mode of operation when nuclear system temperature has decreased to where the steam supply pressure is not sufficient to maintain the turbine shaft gland seals nor the vacuum in the main condenser.

Columbia TS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable in Mode 3 with reactor steam dome pressure less than 48 pounds per square inch gauge. Columbia TS 3.4.10, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, is applicable in Mode 4. They both require two operable RHR SDC subsystems and, with no recirculation pump in operation, at least one RHR SDC subsystem in operation.

2.2 Proposed Changes to the Technical Specifications The licensee proposed to revise TS actions for inoperable RHR SDC subsystems in the RHR SDC system limiting conditions for operation, consistent with TSTF-566, Revision 0.

The proposed changes would revise TSs 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, and 3.4.10, Residual Heat Removal (RHR Shutdown Cooling System - Cold Shutdown, for Columbia. The proposed changes are described below.

2.2.1 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown Required actions for one or two RHR SDC subsystems inoperable (Condition A) of Columbia TS 3.4.9 require the operators to initiate action to restore RHR SDC subsystem(s) to operable status (Required Action A.1) immediately, verify an alternate method of decay heat removal is available for each inoperable RHR SDC subsystem (Required Action A.2) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and be in Mode 4 (Required Action A.3) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The licensee proposed to move Required Action A.1 to new Condition B (as Required Action B.1) and delete Required Action A.3. The LAR also proposed to add a recurring completion time (CT) to current Required Action A.2 of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. The

licensees proposed changes also renumber current Required Action A.2 as A.1 since Required Actions A.1 and A.3 are removed from Condition A.

The licensees proposed changes add a new Condition B for when the required action and associated CT of Condition A are not met. New Condition Bs Required Action B.1 is moved from current Required Action A.1, and requires operators to initiate action to restore RHR SDC subsystems(s) to operable status immediately.

Current Condition B and its required actions would be renamed C, C.1, C.2, and C.3, respectively, since a new Condition B is added.

2.2.2 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown Required actions for one or two RHR SDC subsystems inoperable (Condition A) of Columbia TS 3.4.10 require the operators to verify an alternate method of decay heat removal is available for each inoperable RHR SDC subsystem (Required Action A.1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.

The licensees proposed changes to Columbia TS 3.4.10 would add a new Condition B for when the required action and associated CT of Condition A are not met, which has a required action (new Required Action B.1) for operators to initiate action to restore RHR SDC subsystems(s) to operable status immediately.

Current Condition B and its required actions were renamed C, C.1, and C.2, respectively, since a new Condition B is added.

2.3 Applicable Regulatory Requirements and Guidance Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application proposed TSs. Section 50.36(a)(1) states, in part, that [a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

The regulation at 10 CFR 50.36(b) states:

Each license authorizing operation of a... utilization facility... will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation at 10 CFR 50.40(a) states, in part, that the TS shall provide reasonable assurance that the health and safety of the public will not be endangered.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition (SRP), dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization

effort, the NRC staff has prepared Standard Technical Specifications (STS) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the following applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers.

The STS applicable to the proposed changes are provided in NUREG-1434, Standard Technical Specifications, General Electric BWR [Boiling-Water Reactor]/6 Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, respectively).

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to Columbia Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown The licensee proposed to revise Columbia TS 3.4.9. The NRC staffs evaluation of the licensees changes to Columbia TS 3.4.9 is described below.

3.1.1 Evaluation of Changes to Condition A The licensees proposed changes would add a recurring CT to current Required Action A.2 of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter, to Columbia TS 3.4.9, Condition A. Current Required Action A.2 requires verification that an alternate method of decay heat removal is available for each inoperable RHR SDC subsystem within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The NRC staff finds this change is acceptable, since it requires continuous verification of alternate methods of decay heat removal every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provides assurance of continued heat removal capability.

The licensee proposed changes would delete current Required Action A.3, which requires the plant to be in Mode 4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when one or two RHR SDC subsystems are inoperable.

Current Required Action A.3 requires operators to reduce the reactor coolant system temperature to the point where Mode 4 is entered, due to the potentially reduced reliability of the alternate methods of decay heat removal. However, if there is no operable RHR SDC subsystem and the plant is in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition (typically less than 200 degrees Fahrenheit) within the CT. In addition, in a typical BWR design, the RHR SDC system has a heat rejection capability many times greater than alternate methods available.

Therefore, for periods in which there is high decay heat load, the BWR design does not include any system that can satisfy Required Action A.3. The NRC staff finds the deletion of current Required Action A.3 is acceptable because, at below the RHR cut in permissive pressure, the remaining required action will continue to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Current Required Action A.2 would be renumbered as A.1, since Required Actions A.1 and A.3 are removed from Condition A. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.1.2 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met. New Condition Bs Required Action, B.1, is moved from current

Required Action A.1 and would require operators to initiate action to restore RHR SDC subsystems(s) to operable status immediately. The NRC staff finds that relocating the required action from A.1 to new Required Action B.1 is acceptable because other ways of removing decay heat are available, such as natural circulation, the spent fuel pool cooling system, the reactor water cleanup system and an inoperable, but functional, RHR SDC subsystem.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR SDC subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the Columbias TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required Action B.1 continues to apply until the inoperable RHR SDC subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B, with its Required Action B.1, provides an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.1.3 Evaluation of Changes to Existing Condition B Current Required Action A.2 would be renumbered as A.1, since Required Actions A.1 and A.3 are deleted. Current Condition B and its required actions would be renamed C, C.1, C.2, and C.3, respectively, since new Condition B is added. The NRC staff finds these changes are acceptable since it provides the correct number sequence.

3.1.4 Conclusion of Proposed Changes to Residual Heat Removal (RHR)

Shutdown Cooling System - Hot Shutdown The NRC staff concludes that the proposed changes are acceptable since the TSs continue to meet the requirements of 10 CFR 50.40(a) because they provide reasonable assurance that the health and safety of the public will not be endangered.

3.2 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown The licensee proposed to revise Columbia TS 3.4.10. The NRC staffs evaluation of the licensees changes to Columbia TS 3.4.10 is described below.

3.2.1 Evaluation of New Condition B The licensee proposed a new Condition B to Columbia TS 3.4.10 for when the required action and associated CT of Condition A is not met, which has a required action (new Required Action B.1) for operators to initiate action to restore RHR SDC subsystems(s) to operable status immediately.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR SDC subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the Columbia TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required

Action B.1 continues to apply until the inoperable RHR SDC subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds that this change is acceptable because new Condition B with its Required Action B.1 provide an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.2.2 Evaluation of Changes to Existing Condition B Current Condition B and its required actions would be renamed C, C.1, and C.2, respectively, since new Condition B is added. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.2.3 Conclusion of Proposed Changes to Residual Heat Removal (RHR)

Shutdown Cooling System - Cold Shutdown The NRC staff concludes that the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Washington State official was notified of the proposed issuance of the amendment on August 4, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on April 7, 2020 (85 FR 19510), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: A. Russell Date: January 25, 2021

ML21005A178 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC NAME MChawla PBlechman VCusumano DATE 01/06/2021 01/06/2021 04/30/2020 OFFICE OGC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME TJones Dixon-Herrity (PBuckberg for)

MChawla DATE 01/21/2021 01/22/2021 01/25/2021