GO2-08-071, License Amendment Request for Adoption of TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities

License Amendment Request for Adoption of TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities

ML081350610
Person / Time
Site:	Columbia
Issue date:	05/07/2008
From:	Lynch T Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-08-071, TSTF 484
Download: ML081350610 (15)

Text

Dale K. Atkinson ENERGY Columbia Generating Station P.O. Box 968, PE08 ONORTHW EST Richland, WA 99352-0968 Ph. 509.377.4302 IF. 509.377.4150 dkatkinson@energy-northwest.com May 7, 2008 G02-08-071 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR 50.90), Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia).

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 2001F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the proposed TS changes in final typed format. Attachment 4 provides the existing Bases pages marked up to show the proposed change.

There are no new regulatory commitments contained in this request.

Energy Northwest requests approval of the proposed license amendment by March 2, 2009, to support activities planned during the upcoming refueling outage (R19), with the amendment being implemented within 60 days.

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Page 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington State Official.

If you should have any questions or require additional information regarding this submittal, please contact M.C. Humphreys, Licensing Supervisor, at 509-377-4025.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, T.A. Lynch Acting Vice President, Nuclear Generation Attachments: 1. Evaluation of Proposed Change

2. Proposed Technical Specification Change (Mark-Up)

3. Proposed Technical Specification Change (Re-Typed)

4. Proposed Technical Specification Bases Change (Mark-Up) cc: EE Collins, Jr. - NRC RIV CF Lyon - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn RR Cowley - WDOH JO Luce - EFSEC

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Page 1 of 3 Evaluation of Proposed Change License Amendment Request for Adoption of TSTF-484, Rev. 0, "Use of TS 3.10.1 for Scram Time Testing Activities"

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS DETERMINATION 5.2 APPLICABLE REGULATORY REQUIREMENTS / CRITERIA

7.0 REFERENCES

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Page 2 of 3

1.0 DESCRIPTION

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200OF as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation."

Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

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-484, Revision 0, or the NRC staff's model safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

4.0 TECHNICAL ANALYSIS

Energy Northwest has reviewed the SE published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. Energy Northwest has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Columbia and therefore justify this amendment for the incorporation of the proposed changes to the Columbia TS.

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS DETERMINATION Energy Northwest has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Page 3 of 3 63050) as part of the CLIIP Notice of Availability. Energy Northwest has concluded that the determination presented in the notice is applicable to Columbia and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 APPLICABLE REGULATORY REQUIREMENTS I CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 ENVIRONMENTAL CONSIDERATION

Energy Northwest has reviewed the environmental evaluation included in the SE published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

Energy Northwest has concluded that the staff's findings presented in that evaluation are applicable to Columbia and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. Federal Register Notice, Notice of Availability published on October 27, 2006 (71 FR 63050).

2. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561).

3. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities."

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Proposed Technical Specification Change (Mark-Up)

REVISED TECHNICAL SPECIFICATION PAGES 3.10.1-1

Inservice Leak and Hydrostatic Testing Operation

3. .1 r vl e-ývr > 0 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspendedAo allow p .. .r.r . n 5 iQ 4.r..

P aek or hydrostatic to provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 200'F.

Columbia Generating Station 3.10.1-1 Amendment No. 449 1691

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Proposed Technical Specification Change (Re-Typed)

REVISED TECHNICAL SPECIFICATION PAGES 3.10.1-1

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspended to allow reactor coolant temperature > 200°F:

For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 200 0 F.

Columbia Generating Station 3.10.1-1 Amendment No. 149,169J

Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS

---

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

Separate Condition entry is.allowed for, each requirement of the LCO.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more of the A.1 .......-------- NOTE-------

above requirements not Required Actions to met. be in:,MODE 4 include reducing average reactor coolant temperature to

< 200 0 F.

Enter the applicable Immediately Condition of the affected LCO.

OR A.2.1 Suspend activities Immediately that could increase the average reactor coolant temperature or pressure.

AND A.2.2 Reduce average 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reactor coolant temperature to

< 200 0 F.

Columbia Generating Station 3.10.1-2 Amendment No. 4-44 1691

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-484, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES Proposed Technical Specification Bases Change (Mark-Up)*

REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.10.1-1 B 3.10.1-3

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at ,-

Ir~r temperatures > 200'F (normally corresponding to MODE 3)4.

Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation, decay heat, and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.11, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."

These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases for a given pressure.

Periodic updates to the RCS P/T limit curves are performed as necessary, based on the results of analyses of irradiated surveillance specimens removed from the vessel. <--- co,1,-e 2..A APPLICABLE Allowing the reactor to be considered in MODE 4 .r SAFETY ANALYSES hydrostatic or !cak tezting. when the reactor coolant temperature is > 200°F,Weffectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems (ECCS). Since the hydrost-tic or lco' tests are performed nearly water solid (except for an air bubble for pressure control), at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in (conti nued)

Columbia Generating Station B 3. 10. 1- 1 Revision 241

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO limits, however, which require testing at temperatures (continued) > 200'F, while performance of inservice leak and hydrostatic testing results in the inoperability of subsys ems required when > 200'F (i.e., MODE 3).-- com4i,iY-w i +, ',5e+ q If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures

> 200'F for the purposes of performing -the. an inservice leak or hydrostatic testh-This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements that ar- inf-efect immediately pror to and immed ytfly efterthis -cr.. .

,7 ser1 6 APPLICABILITY The MODE 4 requ/rements may only be modified for the performance of 'inservice leak or hydrostatic testsIso that-Aer- 7 these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 200'F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur.

Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation.

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the (continued)

Columbia Generating Station B 3 .10. 1-3 Revision 241

Tech Spec Bases Section B 3.10.1 Inserts in Support of LAR for Adoption of TSTF-484 or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 200 0 F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation 2 Hydrostatic and leak testing may eventually be required with minimum reactor coolant temperatures > 2000 F. However, even with required minimum reactor coolant temperatures < 2000 F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

The hydrostatic and leak tests require increasing pressure to approximately 1020 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures _>800 psig.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

3 during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, 4 Additionally, even with required minimum reactor coolant temperatures < 2000 F, RCS temperatures may drift above 200°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

Page 1 of 2

Tech Spec Bases Section B 3.10.1 Inserts in Support of LAR for Adoption of TSTF-484 5 , and for control rod scram time testing intitiated in conjunction with an inservice leak or hydrostatic test 6 , or as a consequence of, 7 , or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Page 2 of 2