GO2-04-161, License Amendment Request Adoption of TS Task Force Traveler - 447, Revision 1, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors

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License Amendment Request Adoption of TS Task Force Traveler - 447, Revision 1, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors
ML042880374
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 09/21/2004
From: Atkinson D
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-04-161
Download: ML042880374 (30)
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Text

E ENERGY

  • PeopleNORTHWEST
  • Vision
  • Solutions P.O. Box 968
  • Richland, WA
  • 99352-0968 September 21, 2004 G02-04-161 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

COLUMBIA GENERATING STATION DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST ADOPTION OF TS TASK FORCE (TSTF) TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, "Application for Amendment of License or Construction Permit," Energy Northwest hereby requests an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia) Operating License (NPF-21). The purpose of this license amendment request is to eliminate the requirements for hydrogen recombiners and hydrogen/oxygen monitors from the TS.

The proposed amendment supports implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The proposed amendment is consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of TSTF-447 was announced in the Federal Register on September 25, 2003 (68FR55416) as part of the Consolidated Line Item Improvement Process (CLIIP).

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments.

Attachment 2 provides the existing TS pages marked-up to show the proposed change.

Attachment 3 provides the proposed TS Bases changes for information only.

Attachment 4 provides a listing of Regulatory Commitments made with this submittal.

00°

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Page 2 Energy Northwest requests approval of the proposed license amendment by April 30, 2005. Once approved, the amendment will be implemented within 120 days.

The proposed changes have been reviewed by the Columbia Generating Station Plant Operations Committee (POC) and Corporate Nuclear Safety Review Board (CNSRB) and recommended for submission to the NRC in accordance with the requirements of the Columbia Quality Assurance Program.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Columbia is notifying the State of Washington of this application for change to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information regarding this matter, please contact DW Coleman, Regulatory Programs Manager at (509) 377-4342.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on x,5 7, a/, 2004.

Respectfully, DK Atkinson Vice President, Technical Services Mail Drop PE08 Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (mark-up)
3. Changes to Technical Specification Bases Pages
4. List of Regulatory Commitments cc: BS Mallett - NRC RIV RN Sherman - BPA/1399 WA Macon - NRC NRR TC Poindexter - Winston & Strawn NRC Sr. Resident Inspector - 988C JO Luce - EFSEC RR Cowley - WDOH

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Page 1 of 5 ATTACHMENT I Columbia Generating Station Description and Assessment

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Attachment I Page 2 of 5 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed license amendment deletes Technical Specification (TS) 3.6.3.1 "Primary Containment Hydrogen Recombiners," reference to hydrogen recombiners in Section 5.5.2, and references to the Hydrogen/Oxygen monitors in Section 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," surveillance requirements (SR) and TS Table 3.3.3.1-1 "Post Accident Monitoring Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The proposed changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors" (Reference 1). The availability of this TS improvement was announced in the Federal Register on September 25, 2003 (Reference 2) as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1, of TSTF-447, the proposed TS changes include:

TS Section SR 3.3.3.1.2, Perform CHANNEL CALIBRATION for Deleted 3.3.3.1 SR TS Function 8, Drywell H2 Analyzer (Table 3.3.3.1-1)

TS Section SR 3.3.3.1.3, Perform CHANNEL CALIBRATION for Deleted 3.3.3.1 SR TS Function 9, Drywell 02 Analyzer (Table 3.3.3.1-1)

TS Table Item 8, Drywell H2 Analyzer; Item 9, Drywell 02 Deleted 3.3.3.1-1 Analyzer TS Section Primary Containment Hydrogen Recombiners Deleted 3.6.3.1 TS Section Primary Coolant Sources Outside Containment, Deleted 5.5.2 reference to "hydrogen recombiner_

.7 LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER -447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Attachment I Page 3 of 5

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (Reference 2), TSTF-447 (Reference 1),

the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (Reference 2), TSTF-447 (Reference 1), the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Energy Northwest has reviewed the Safety Evaluation (SE) published on September 25, 2003 (Reference 2) as part of the CLIIP. This verification included a review of the NRC staff's SE, as well as information provided to support TSTF-447. Energy Northwest has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Columbia Generating Station (Columbia) and justify approval of this amendment request.

6.0 REGULATORY ANALYSIS

A description of this proposed amendment and its relationship to regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (Reference 2), TSTF-447 (Reference 1), the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003, (Reference 2) for this TS improvement, Energy Northwest is making the following verifications and regulatory commitments.

Energy Northwest is not proposing any variations or deviations from the requirements of the STS changes described in TSTF-447, Revision 1 (Reference 1) or the NRC staffs model safety evaluation dated September 25, 2003 (Reference 2). Upon approval of this amendment request, the hydrogen and oxygen monitoring capability will be maintained but no longer considered safety-related as defined in 10 CFR 50.2 in accordance with the NRC staffs safety evaluation.

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Page 4 of 5

1. Energy Northwest has verified that a hydrogen monitoring system capable of diagnosing beyond design basis accidents is installed at Columbia and is making a regulatory commitment to maintain that capability. The hydrogen monitors are included in the plant's Emergency and Operating procedures and the Maintenance Program. This regulatory commitment is currently implemented.
2. Columbia has an inerted containment. Energy Northwest has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed at Columbia and is making a regulatory commitment to maintain that capability. The oxygen monitors are included in the plant's Emergency and Operating procedures and the Maintenance Program. This regulatory commitment is currently implemented.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Energy Northwest has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLIIP. Energy Northwest has concluded that the proposed NSHCD presented in the Federal Register (Reference 2) is applicable to Columbia and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION Energy Northwest has reviewed the environmental evaluation included in the model safety evaluation dated September 25, 2003 (Reference 2) as part of the CLIIP. Energy Northwest has concluded that the staffs findings presented in that evaluation are applicable to Columbia and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Energy Northwest is not proposing variations or deviations from the TS changes described in TSTF-447, Revision 1 or the NRC staffs model SE published on September 25, 2003 (Reference 2). This amendment request is consistent with the request submitted for Limerick Generating Station, Units 1 and 2 on April 13, 2004.

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Attachment I Page 5 of 5

10.0 REFERENCES

1. Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-447, Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors."
2. Federal Register, Volume 68, Number 186, Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003, (68FR55416).

z- T LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Attachment 2 ATTACHMENT 2 Columbia Generating Station Proposed Technical Specification Changes (mark-up)

Pages iii 3.3.3.1-3 3.3.3.1-4 3.6.3.1-1 3.6.3.1-2 5.5-2

TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.3.1 g)" Containme

- Hydrogen nt flozbincrs . . 3.G.3.1 1 3.6.3.2 Primary Containment Atmosphere Mixing System . . . . 3.6.3.2-1 3.6.3.3 Primary Containment Oxygen Concentration . . . . .. 3.6.3.3-1 3.6.4.1 Secondary Containment . . . . . . . . . . . . . .. 3.6.4.1-1 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) . . . 3.6.4.2-1 3.6.4.3 Standby Gas Treatment (SGT) System . . . . . . . .. 3.6.4.3-1 3.7 PLANT SYSTEMS 3.7.1 Standby Service Water (SW) System and Ultimate Heat Sink (UHS) . . . . . . . . . . .. 3.7.1-1 3.7.2 High Pressure Core Spray (HPCS) Service Water (SW) System ..... . . . . . . . . . . . . . 3.7.2-1 3.7.3 Control Room Emergency Filtration (CREF) System . . 3.7.3-1 3.7.4 Control Room Air Conditioning (AC) System . . . . . 3.7.4-1 3.7.5 Main Condenser Offgas . . . . . . . . . . . . . . . 3.7.5-1 3.7.6 Main Turbine Bypass System . . . . . . . . . . . . . 3.7.6-1 3.7.7 Spent Fuel Storage Pool Water Level . . . . . . . . 3.7.7-1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -Operating .. ... .. ... . . ... 3.8.1-1 3.8.2 AC Sources -Shutdown . . . . . . . . . . . . . ... 3.8.2-1 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air . . . . 3.8.3-1 3.8.4 DC Sources- Operating . . . . . . . . . . . . . . . 3.8.4-1 3.8.5 DC Sources -Shutdown . . . . . . . . . . . . . . . . 3.8.5-1 3.8.6 Battery Cell Parameters . . . . . . . . . . . . . . 3.8.6-1 3.8.7 Distribution Systems- Operating . . . . . . . . . . 3.8.7-1 3.8.8 Distribution Systems- Shutdown . . . . . . . . . . . 3.8.8-1 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks . . . . . . . . . . . 3.9.1-1 3.9.2 Refuel Position One-Rod-Out Interlock . . . . . . . 3.9.2-1 3.9.3 Control Rod Position . . . . . . . . . . . . . . . . 3.9.3-1 3.9.4 Control Rod Position Indication . . . . . . . . . . 3.9.4-1 3.9.5 Control Rod OPERABILITY- Refueling . . . . . . . . . 3.9.5-1 3.9.6 Reactor Pressure Vessel (RPV) Water Level- Irradiated Fuel . . . 3.9.6-1 3.9.7 Reactor Pressure Vessel (RPV) Water Level- New Fuel or Control Rods . . . . . ... 3.9.7-1 3.9.8 Residual Heat Removal (RHR)- High Water Level . . . 3.9.8-1 3.9.9 Residual Heat Removal (RHR)- Low Water Level . . . . 3.9.9-1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation . 3.10.1-1 3.10.2 Reactor Mode Switch Interlock Testing . . . . . . . 3.10.2-1 3.10.3 Single Control Rod Withdrawal -Hot Shutdown . . . . 3.10.3-1 (continued)

Columbia Generating Station i ii Amendment No. +4-9 1691

-z PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS

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

1. These SRs apply to each Function in Table 3.3.3.1-1.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the other required channel(s) in the associated Function is OPERABLE.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK. 31 days SR 3.3.3.1.2 III g HANN[L-CALIBlRATIOJ for9 day SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for 18 months Functions 1, 2, 4, 5,s.t and 10. I SR 3.3.3.1.4 Perform CHANNEL CALIBRATION for 24 months Functions 3, 6, and 7.

Columbia Generating Station 3.3.3. 1-3 Amendment No. 149,169 179

r1 PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED FROM REQUIRED FUNCTION CHANNELS ACTION D.1

1. Reactor Vessel Pressure 2 E
2. Reactor Vessel Water Level
a. -150 inches to +60 inches 2 E
b. -310 inches to -110 inches 2 E
3. Suppression Pool Water Level
a. -25 inches to +25 inches 2 E
b. 2 ft to 52 ft 2 E
4. Suppression Chamber Pressure 2 E
5. Drywell Pressure
a. -5 psig to +3 psig 2 E
b. 0 psig to 25 psig 2 E
c. 0 psig to 180 psig 2 E
6. Primary Containment Area Radiation 2 F
7. PCIV Position 2 per penetration E flow path (a)(b)
8. CPywump Roo Flood Le 5 E
9. Dr t .. lceD-e e
10. ECCS Pump Room Flood Level 5 E (a) Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

Columbia Generating Station 3.3.3. 1-4 Amendment No. 14-9 1691

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 -P-,imny Cu.,laitlmtrmtt-H1sbtyrchagultci D eNe-s+e 8 CO 3.6.3.1 Two primary containment hydrogen recombiners shall be 0PERABLE.

APPLICABI TY: MODES 1 and 2.

ACTIONS CONDITIOi REQUIRED ACTION MPLETION TIME A. One primary A.1 Restore primary 30 days I containment hydrogen\ containment hydr gen recombiner inoperable. recombiner to OPERABLE s s.

4-B. Two primary B.1 ri by 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> containment hydrogen ad nistrative means recombiners Mat he hydrogen and AND inoperable. /oxygen ontrol function 's Once per maintained. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status.

C. Req Fred Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as ociated Completion

/ Plme not met.

i ii Columbia Generating Station 3.6.3.1-1 Amendment No. 149,169 187

Primary Containment Hydrogen Recombiners 3.6.3.1 I

SURVEILLANCE Perform a system functional test for each 24 primary containment hydrogen recombiner.

SR 3.6.3.1.2 Visually examine each primary containmen- 24 months hdrogen recombiner enclosure and verif thqre is no evidence of abnormal conk tions.

7 I LJUIi Columbia Generating Station 3.6.3. 1-2 Amendment No. 149,169 187

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include the Low Pressure Core Spray, High Pressure Core Spray, Residual Heat Removal, Reactor Core Isolation Cooling, hydroge" reComhincr process sampling, (the program requirements shall apply to the Post Accident Sampling System until such time as administrative controls provide for continuous isolation of the associated penetration(s) or a modification eliminates the potential leakage path(s)), containment monitoring, and Standby Gas Treatment. The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and
b. Integrated leak test requirements for each system at 24 month intervals or less.

The provisions of SR 3.0.2 are applicable to the 24 month Frequency for performing integrated system leak test activities.

5.5.3 Deleted (continued)

Columbia Generating Station 5.5-2 Amendment No. 149,169 184

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS ATTACHMENT 3 Columbia Generating Station Changes to Technical Specification Bases Pages Pages B iii B 3.3.3.1-6 B 3.3.3.1-11 B 3.6.3.1-1 B 3.6.3.1-2 B 3.6.3.1-3 B 3.6.3.1-4 B 3.6.3.1-5 B 3.6.3.1-6 B 3.6.3.1-7 B 3.6.3.3-1 B 3.6.3.3-2 B 3.7.1-4

TABLE OF CONTENTS B 3.6 (CONTAINMENT SYSTEMS (continued)

B 3.6.3.1 ~~PirryCcr eimctHydrogen Reeembiflerz . . . BR3.6.23.11 B 3.6.3.2 Primary Containment Atmosphere Mixing System . .B 3.6.3.2-1 B 3.6.3.3 Primary Containment Oxygen Concentration . . . . B 3.6.3.3-1 B 3.6.4.1 Secondary Containment . . . . . . . . . . . . . B 3.6.4.1-1 B 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) . . . . . . . . . . . . . . . B 3.6.4.2-1 B 3.6.4.3 Standby Gas Treatment (SGT) System . . . . . . . B 3.6.4.3-1 B 3.7 PLANT SYSTEMS B 3.7.1 Standby Service Water (SW) System and Ultimate Heat Sink (UHS) . . . . . . . . . . B 3.7.1-1 B 3.7.2 High Pressure Core Spray (HPCS) Service Water (SW) System . . . . . . . . . . . . . . B 3.7.2-1 B 3.7.3 Control Room Emergency Filtration (CREF) System B 3.7.3-1 B 3.7.4 Control Room Air Conditioning (AC) System . . . B 3.7.4-1 B 3.7.5 Main Condenser Offgas . . . . . . . . . . . . . B 3.7.5-1 B 3.7.6 Main Turbine Bypass System . . . . . . . . . . . B 3.7.6-1 B 3.7.7 Spent Fuel Storage Pool Water Level . . . . . . B 3.7.7-1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources- Operating . . . . . . . . . . . . . B 3.8.1-1 B 3.8.2 AC Sources- Shutdown . . . . . . . . . . . . . . B 3.8.2-1 B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air . . B 3.8.3-1 B 3.8.4 DC Sources- Operating . . . . . . . . . . . . . B 3.8.4-1 B 3.8.5 DC Sources- Shutdown . . . . . . . . . . . . . . B 3.8.5-1 B 3.8.6 Battery Cell Parameters . . . . . . . . . . . . B 3.8.6-1 B 3.8.7 Distribution Systems- Operating . . . . . . . . B 3.8.7-1 B 3.8.8 Distribution Systems -Shutdown . . . . . . . . . B 3.8.8-1 B 3.9 REFUELING OPERATIONS B 3.9.1 Refueling Equipment Interlocks . . . . . . . . . B 3.9.1-1 B 3.9.2 Refuel Position One-Rod-Out Interlock . . . . . B 3.9.2-1 B 3.9.3 Control Rod Position . . . . . . . . . . . . . . B 3.9.3-1 B 3.9.4 Control Rod Position Indication . . . . . . . . B 3.9.4-1 B 3.9.5 Control Rod OPERABILITY -Refueling . . . . . . . B 3.9.5-1 B 3.9.6 Reactor Pressure Vessel (RPV) Water Level -Irradiated Fuel . . . . . . . . . . . B 3.9.6-1 B 3.9.7 Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods . . . . . . . B 3.9.7-1 B 3.9.8 Residual Heat Removal (RHR) -High Water Level B 3.9.8-1 B 3.9.9 Residual Heat Removal (RHR) -Low Water Level B 3.9.9-1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation . . . . . . . . . . . . . . . B 3.10.1-1 B 3.10.2 Reactor Mode Switch Interlock Testing . . . . . B 3.10.2-1 B 3.10.3 Single Control Rod Withdrawal -Hot Shutdown . . B 3.10.3-1 (continued)

Columbia Generating Station B iii Revision 26

PAM Instrumentation B 3.3.3.1 BASES LCO 7. Primary Containment Isolation Valve (PCIV) Position (continued) penetration is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration is not required to be OPERABLE.

The indication for each PCIV is provided at the valve controls in the control room. Each indication consists of green and red indicator lights that illuminate to indicate whether the PCIV is fully open, fully closed, or in a mid-position. Therefore, the PAM specification deals specifically with this portion of the instrumentation channel.

8. 9. ,rorgn anod n JneAltn well hydrogen and oxygen analyzers are Category I ins ments provided to detect high hydrogen or oxyge concent ion conditions that represent a potenti for containment each. This variable is also im tant in verifying the a uacy of mitigating ac .

High hydrogen and oxy oncentr ns are measured by two independent analyzers and c nuously record on two recorders in the control om. e analyzers are capable of operating from 12 ps' o 45 psig. e available 0% to 30%

range of these a yzers satisfies the tteria of RG 1.97.

These record are the primary indication d by the operator ring an accident. Therefore, the PA speci~cation deals specifically with this portion the trument channel.

10. ECCS Pump Room Flood Level ECCS pump room flood level is a Type A and Category I variable provided to indicate ECCS pump room flooding. High water level in the ECCS pump rooms is indicated on five (one for each room) separate annunciators in the control room.

Each annunciator alarms at a setpoint of 6 inches above the (continued)

Columbia Generating Station B 3.3.3.1-6 Revision 241

PAM Instrumentation B 3.3.3.1 BASES SURVEILLANCE SR 3.3.3.1. 2 gSR 3.3.3.1.3, and SR 3.3.3.1.4 REQUIREMENTS (continued) A CHANNEL CALIBRATION is performed evesy 92 days fo -c Function- 8, every 18 months for Functions 1, 2, 4, 5,-47 and 10, and every 24 months for Functions 3, 6, and 7. CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. For Function 6, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, excluding the detector, for range decades > 10 R/hour and a one point calibration check of the detector with an installed or portable gamma source for range decades

< 10 R/hour. The 92 day, 18 month, and 24 month Frequencies are based on operating experience and engineering judgment.

REFERENCES 1. Regulatory Guide 1.97, "Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, December 1980.

2. NRC Safety Evaluation Report, "Washington Public Power Supply System, Nuclear Project No. 2, Conformance to Regulatory Guide 1.97," dated March 23, 1988.
3. 10 CFR 50.36(c)(2)(ii).

Columbia Generating Station B 3.3.3.1-11 Revision 29

Primary Containment Hydrogen Recombiners B 3.6.3.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 We-1.a~ CntainmeRt erimar-y Hydrogen Pecombiners XES/

BC ND The primary containment hydrogen recombiners elimint he potential breach of primary containment due to a h dogn oxygen reaction and are part of combustiblegacorl required by 10 CFR 50.44, "Standards for Combust le Gas Control in Light-Water-Cooled Reactors" (Ref. , and GDC 41, "Containment Atmosphere Cleanup" (Re. 2). The rimary containment hydrogen recombiners a required to r uce the hydrogen and oxygen concentra ons in the primary containment following a loss of coolan accident (LOCA).

The p imary containment hydrogen rec biners accomplish this by reco ining hydrogen and oxygen o form water vapor. The vapor rem ins in the primary con inment, thus eliminating any dischar to the environme . The primary containment hydrogen re o iners are manuly initiated, since flammability li its would t be reached until several days after a Design Ba is Acc' ent (DBA).

Two 100% capacity in endent primary containment hydrogen recombiners are pr ide. Each consists of controls located in the control r m, a porer supply, and a recombiner located in the eactor bui ing. Recombination is accomplished/y heating a hy ogen and oxygen air mixture to

> 500F an passing it through platinum on alumina catalyst The resulting water va or and discharge gases are cooled ior to discharge from the nit. Air flows through the it at > 112 scfm (which includ 60% recycle flow),

wi a constant speed rotary lobe blow providing the m ive force. A single recombiner is ca ble of maintaining he hydrogen and oxygen concentrations in imary containment below the 4.0 volume percent (v/ and 5.0 v/o, respectively, flammability limit. Two recombi rs are provided to meet the requirement for redundancy d independence. Each recombiner is powered from a searate Engineered Safety Feature bus and is provided with searate power panel and control panel.

(continue Columbia Generating Station B 3.6.3.1- 1 Revision 241

Primary Containment Hydrogen Recombiners B 3.6.3.1 ASES BACK OUND Emergency operating procedures direct that the hydroge and (con inued) oxygen concentrations in primary containment be moni red following a DBA and that the primary containment hydrogen recombiners be manually activated to prevent the imary containment atmosphere from reaching a bulk hydr gen and oxygen concentrations of 4.0 v/o and 5.0 v/o espectively.

APPLICABLE The primary containment hydrogen recombin s provide the SAFETY ANALYSES pability of controlling the bulk hydr en and oxygen co centrations in primary containment o less than the lower fla able concentrations of 4.0 v/o d 5.0 v/o, respe ively, following a DBA. Thi control would prevent a primary containment wide hydrogen/ xygen burn, thus ensuring that pre ure and temperature co ditions assumed in the analysis a not exceeded. Thylimiting DBA relative to hydrogen an oxygen generatio is a LOCA.

Oxygen may accu ulate in e primary containment following a LOCA as a result f radi ytic decomposition of water in the Reactor Coolant Sy e Hydrogen may accumu in primary containment following a LOCA as a result o

a. A metal s am reactio between the zirconium fuel rod cladding and the reacto coolant;
b. Radio tic decomposition o water in the Reactor Coo nt System; or
c. reaction between the reactor oolant and the zinc rich paints used in the primary b'ntainment. However, since Columbia Generating Station an oxygen control plant, this form of hydrogen generat on is not assumed (minimizing hydrogen production is co ervative in calculating peak oxygen concentration).

To evaluate the potential for hydrogen and oxyg accumulation in primary containment following a L CA, the hydrogen and oxygen generation as a function of ti following the initiation of the accident is calculat d.

Assumptions recommended by Reference 3 are used to ma xmize the amount of oxygen calculated.

(continue Columbia Generating Station B 3.6.3.1-2 Revision 241

-e s -

Primary Containment Hydrogen Recombiners B 3.6.3.1 B ES APPLI BLE The calculation confirms that when the mitigating Sys ms SAFETY ALYSES are actuated in accordance with plant procedures, th peak (contin ed) hydrogen and oxygen concentrations in the primary containment remains < 4.0 v/o and < 5.0 v/o, resp ctively (Ref. 4).

The primary containment hydrogen recombiners atisfy Criterion 3 of Reference 5.

LCO Two rimary containment hydrogen reco iners must be OPERA LE. This ensures operation of/at least one primary contain ent hydrogen recombiner in he event of a worst case single a ive failure.

Operation w h at least one p mary containment hydrogen recombiner su system ensures hat the post LOCA hydrogen and oxygen concent tions can prevented from exceeding their flammability lim tS.

APPLICABIL-ITY In MODES 1 and 2, th two primary containment hydrogen recombiners are re ir to control the hydrogen and oxygen concentrations wi in prmary containment below their flammability li ts of 4. v/o and 5.0 v/oy respectively following a L A, assuming worst case single failure.

In MODE 3, oth the hydrogen a oxygen production rates and the total ydrogen and oxygen pr duction after a LOCA would be less han that calculated for e DBA LOCA. Also, becaus of the limited time in this MODE, the probability of an a ident requiring the primary co ainment hydrogen rec mbiner is low. Therefore, the pri ary containment h rogen recombiners are not required i MODE 3.

In MODES 4 and 5, the probability and cons uences of a LOCA are low due to the pressure and temperature imitations in these MODES. Therefore, the primary containme t hydrogen recombiners are not required in these MODES.

( ntinued)

Columbia Generating Station B 3.6.3.1-3 Revision 241

. Als ;.

Primary Containment Hydrogen Recombiners B 3.6.3.1 ASES (continued)

ACTI S A.1 With one primary containment hydrogen recombiner in erable, the inoperable primary containment hydrogen recomn er must be restored to OPERABLE status within 30 days. n this condition, the remaining OPERABLE primary cont nment recombiner is adequate to perform the hydroge and oxygen control function. However, the overall reV bility is reduced because a single failure in the OP RABLE recombiner uld result in reduced hydrogen and oxy en control ca ability. The 30 day Completion Tim is based on the low pro bility of the occurrence of a LOPA that would generate hydro en and oxygen in amounts capa e of exceeding the flamma lity limits, the amount of/time available after the event fo operator action to presnt hydrogen and oxygen accumulati n exceeding this limt, and the low probability of failure f the OPERABLE pr ary containment hydrogen recombiner.

B.1 and B.2 With two primary con inment hydrogen recombiners inoperable, the ab it to perform the hydrogen and oxygen control function ia a lternate capability must be verified by admn istrativ means within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The alternate hydr gen and oxyg n control capability is provided by the Containment Purge Sys m. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time allows a r sonable period of ime to verify that a loss of hydrogen nd oxygen control fun ion does not exist. In additio the alternate hydrogen nd oxygen control capabi ity must be verified once p 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to ensu e its continued availability. oth the initial Columbia Generating Station B 3.6.3.1-4 Revision 36

Primary Containment Hydrogen Recombiners B 3.6.3.1 B ES ACTIO B.1 and B.2 (continued) verification and all subsequent verifications may e performed as an administrative check by examinin logs or other information to determine the availabilityof the alternate hydrogen and oxygen control system. It does not mean to perform the Surveillances needed to emonstrate OPERABILITY of the alternate hydrogen and xygen control stem. If the ability to perform the h rogen and oxygen co trol function is maintained, continu d operation is per itted with two hydrogen recombine inoperable for up to 7 da . Seven days is a reasonable ime to allow two hydrog recombiners to be inopera e because the hydrogen and oxyg n control function is m ntained and because of the low proba blity of the occurren e of a LOCA that would generate hydrogen and oxygen the amounts capable of exceeding th flammability lmits.

C.1 If any Required Acti and associated Completion Time cannot be met, the plant st be brought to a MODE in which the LCO does not apply. o ach iee this status, the plant must be brought to at 1est MODE within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Ti of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating ex rience, to rea h MODE 3 from full power conditionsyf an orderly m nnis nd without challenging plant sys ems.\

SURVEILLANCE SR 3.6.3 .1.1\

REQUIREMENTS/\

P formance of a system functional tes for each primary ontainment hydrogen recombiner ensures at the recombiners are OPERABLE and can attain and sustain t temperature necessary for hydrogen recombination. In p ticular, this SR requires verification that the minimum hea er outlet temperature increases to > 500 0F in < 90 minut and that it is maintained > 500OF and cycles about its setpont for > 45 minutes to check the capability of the recombiner o properly function (and that significant heater elem nts are not burned out). The SR also verifies that the cata st efficiency is confirmed. This is performed by introdu ing

> 1 v/o hydrogen into the catalyst bed preheated to a (continu

/ olumbia Generating Station B 3.6.3.1-5 Revision 24[

- -sw :

Primary Containment Hydrogen Recombiners /

B 3.6.3.1/

ASES/

SURV LLANCE SR 3.6.3.1.1 (continued)

REQUI MENTS/

temperature < 300 0F, and verifying: a) the effluent stream has a hydrogen concentration < 25 ppm by volume; a d b)

> 75% of the temperature increase occurs above t fourth temperature measuring device in the catalyst be .

Operating experience has shown that these co ponents usually ass the Surveillance when performed at th 24 month equency. Therefore, the Frequency was oncluded to be ac ptable from a reliability standpoin SR 3.K.1.2/

This SR en ures that there are o physical problems (i.e.,

loose wirin or structural co ection, or deposits of foreign mater ls) that coul affect primary containment hydrogen recomb ner operat' n. Since the recombiners are mechanically pas ve, th are not subject to mechanical failure. The only credyble failures involve loss of power, blockage of the int flow path, missile impact, etc. A visual inspection is fficient to determine abnormal conditions that co d use such failures.

Operating exper nce ha s own that these components usually pass the Surv llance when rformed at the 24 month Frequency. erefore, the Fr quency was concluded to be acceptable rom a reliability andpoint.

SR 3 .31.3\

TW SR requires performance of a resi ance to ground test o each heater phase to ensure that ther are no detectable grounds in any heater phase. This is acc plished by verifying that the resistance to ground for ny heater phase is > 10,000 ohms within 30 minutes following ompletion of a system functional test or heatup of the system o normal operating temperature.

Operating experience has shown that these componen usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to acceptable from a reliability standpoint.

(continued Columbia Generating Station B 3.6.3.1-6 Revision 241

Primary Containment Hydrogen Recombiners B 3.6.3.1 IA SES (continued)

REFE h ES 1. 10 CFR 50.44./

\2. 10 CFR 50, Appendix A, GDC 41./

3. Regulatory Guide 1.7, Revision 1, September 76.

4.

\ FSAR, Section 6.2.5.

10 CFR 50.36(c)(2)(ii).

Columbia Generating Station B 3.6.3.1-7 Revision 241

Primary Containment Oxygen Concentration B 3.6.3.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.3 Primary Containment Oxygen Concentration BASES BACKGROUND The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 3.5 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. Thw capability to inert the primary containment and maintain axygen

-3 5 vlo works together with the Hydrogen Recombincr System

-(LCO 3.63 1, "Pri mary Cpontainment Hydroen Recomioners") to prnvrdw roHiindant ind divorep mcthodS to mitigate egents that produce hydrogen and )aygnm. For exapl^e, An event that rapidly generates hydrogen from zirconium metal water reaction will result in excessive hydrogen in primary containment, but oxygen concentration will remain < 5.0 v/o and no combustion can occur. Long term generation of both hydrogen and oxygen from radiolytic decompoesition of watcr Mia eventi ally rpiOit in a rnmhictihihp miyturp in primary cnntainmont, ezceP tthat the hydrongn recombiners rMove hydrogen and oxygen gases faster than they can be produced from radiolysis and again no combustion can occur. This LCO ensures that oxygen concentration does not exceed 3.5 v/o during operation in the applicable conditions.

APPLICABLE The Reference 1 calculations assume that the primary SAFETY ANALYSES containment is inerted when a Design Basis Accident loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.

Oxygen, w:hieh 4o eubsequently generhated by Fradiclyti.+

decomposition of water, is recombingd by the hydrogen recombiners ('CO 3 6 3 1) more rapirl y than it is produced.

Primary containment oxygen concentration satisfies Criterion 2 of Reference 2.

(continued)

Columbia Generating Station B 3.6.3.3-1 Revision 241

Primary Containment Oxygen Concentration B 3.6.3.3 BASES (continued)

LCO The primary containment oxygen concentration is maintained

< 3.5 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. As long as reactor power is < 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

ACTIONS A.1 If oxygen concentration is > 3.5 v/o at any time while operating in MODE 1, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 3.5 v/o within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is allowed when oxygen concentration is

> 3.5 v/o because of the Availability of other hydrogen and oxgenn Ritigating Systems (e.g., hydrogen reormWncre) anrd the low probability and long duration of an event that would generate significant amounts of hydrogen and oxygen occurring during this period.

(continued)

Columbia Generating Station B 3.6.3.3-2 Revision 241

SW System and UHS B 3.7.1 BASES LCO The isolation of the SW System to components or systems may (continued) render those components or systems inoperable, but does not affect the OPERABILITY of the SW System if those component's or system's applicable LCO Conditions and Required Actions are entered. For example, if SW cooling to a #xtiLPC-5 pivot ior rcntainment hydroen rQhombiner was isolated, entry into IJb-?6-r5--+/- Conditions and Required Actions,,tould beI' (sufficient and SW OPERABILITY would not be affected.'-

03. 5 .1 or 3,5,:1 For addressing appropriate LCO conditions using LCO 3.0.6, entry into SW LCO Conditions and Required Actions would still require supported system(s) to be declared inoperable, however, it is not necessary to enter the supported systems LCO Conditions and Required Actions. For example, if DC Sources -Operating CLCO 3.8.4) is not met solely due to room cooler degradation and entry into LCO 3.7.1 Conditions and Required Actions is made, the electrical equipment in the affected equipment room(s) are required to be declared inoperable, however, the Conditions and Required Actions associated with this supported system (LCO 3.8.4) are not required to be entered.

OPERABILITY of the High Pressure Core Spray (HPCS) Service Water (SW) System is addressed by LCO 3.7.2.

APPLICABILITY In MODES 1, 2, and 3, the SW System and UHS are required to be OPERABLE to support OPERABILITY of equipment serviced by the SW System and UHS that is required to be OPERABLE in these MODES.

In MODES 4 and 5, the OPERABILITY requirements of the SW System and UHS are determined by the systems they support, and therefore, the requirements are not the same for all facets of operation in MODES 4 and 5. Thus, the LCOs of the systems supported by the SW System and UHS will govern SW System and UHS OPERABILITY requirements in MODES 4 and 5.

(continued)

Columbia Generating Station B 3.7.1-4 Revision 241

-- 'G. -^

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS Attachment 4 ATTACHMENT 4 Columbia Generating Station List of Regulatory Commitments

LICENSE AMENDMENT REQUEST, ADOPTION OF TS TASK FORCE (TSTF)

TRAVELER - 447, REVISION 1, ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN AND OXYGEN MONITORS LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Energy Northwest in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE Energy Northwest will maintain the Currently implemented in the plant capability of monitoring containment emergency and operating procedures and Hydrogen for beyond design basis the maintenance program accidents Energy Northwest will maintain the Currently implemented in the plant capability of monitoring containment emergency and operating procedures and Oxygen to verify the status of the inerted the maintenance program containment

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