GO2-17-194, Supplement to License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

Supplement to License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

ML17320A314
Person / Time
Site:	Columbia
Issue date:	11/15/2017
From:	Hettel W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-17-194
Download: ML17320A314 (8)

Text

William G. Hettel Vice President, Operations P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-8311 F. 509-377-4674 wghettel@energy-northwest.com November 15, 2017 GO2-17-194 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENT TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL"

Reference:

1. Letter, GO2-17-038, R. E. Schuetz (Energy Northwest) to NRC, "License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"," dated October 23, 2017 (ML17296B380)

2. Public Meeting Announcement (NRC), "Forthcoming Public Meeting between the U.S. Regulatory Commission and the Technical Specifications Task Force." Meeting date November 9, 2017 (ML17303A162)

Dear Sir or Madam:

Please replace Technical Specification (TS) markup Page 3.5.1-1 in Attachment 2 of Reference 1 with the enclosed markup TS Page 3.5.1-1. This change incorporates Columbia Generating Station (Columbia) Amendment 245 into the Reference 1 markup.

Columbia Amendment 245 was issued after Reference1 was submitted. Please replace markup TS Page 3.5.2-8 in Attachment 2 of Reference 1 with the enclosed markup TS Page 3.5.2-8. This change incorporates the Technical Specification Task Force (TSTF)-

542 Level 8 variation for TS Surveillance Requirement (SR) 3.5.2.8 discussed with the Nuclear Regulatory Commission (NRC) on November 9, 2017 (Reference 2).

Please replace TS clean Page 3.5.1-1 in Attachment 3 of Reference 1 with the enclosed clean TS Page 3.5.1-1. This change incorporates Columbia Amendment 245 into the Reference 1 clean pages. Please replace clean TS Page 3.5.2-6 in Attachment 3 of Reference 1 with the enclosed clean TS Page 3.5.2-6. This change incorporates the revision to TS SR 3.5.2.8 into the Reference 1 clean pages.

G02-17-194 Page 2of2 Please replace TS Bases markup Page B 3.5.2-14 in Attachment 4 of Reference 1 with the enclosed TS Bases markup Page B 3.5.2-14. This change is provided for information only. This change incorporates the revision to TS SR 3.5.2.8 into the Bases markup of Reference 1.

The conclusions of the No Significant Hazards Consideration determination in the original submittal are not altered by this submittal.

Pursuant to 10 CFR 50.91, a copy of this supplement is being sent to the designated official of the State of Washington.

There are no new or revised commitments with this letter.

If you should have any questions regarding this submittal, please contact Ms. L. L.

Williams, Licensing Supervisor, at 509-377-8148 I declare under penalty of perjury that the foregoing is true and correct. Executed this

~day of November, 2017.

Respectfully, JJ -

W.G. Hettel Vice President, Operations

Enclosure:

As stated cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector - 988C CD Sonoda - BPA 1399 (email)

WA Horin -Winston & Strawn (email)

RR Cowley - WDOH (email)

EFSECutc.wa.gov - EFSEC (email)

GO2-17-194 Enclosure License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Replacement Pages

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

---

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

LCO 3.0.4.b is not applicable to HPCS.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days(1) injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B High Pressure Core B.1 Verify by administrative Immediately Spray (HPCS) System means RCIC System is inoperable. OPERABLE when RCIC System is required to be OPERABLE.

AND B.2 Restore HPCS System to 14 days OPERABLE status.

(1)

The Completion Time that one train of RHR (RHR-A) can be inoperable as specified by Required Action A.1 may be extended beyond the 7 day completion time up to 7 days to support restoration of RHR-A following pump and motor replacement. This footnote will expire at 23:59 PST February 28, 2019.

Columbia Generating Station 3.5.1-1 Amendment No. 187 225 230 245

RPV Water Inventory ControlECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.68 -------------------------------NOTE------------------------------

Vessel injection/spray may be excluded.

Verify each the required ECCS injection/sprayLPCI or In accordance LPCS subsystem actuates on a n actual or simulated with the automaticmanual initiation signal or the required HPCS Surveillance subsystem can be manually operated. Frequency Control Program Columbia Generating Station 3.5.2-8 Amendment No.

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

---

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

LCO 3.0.4.b is not applicable to HPCS.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days(1) injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B High Pressure Core B.1 Verify by administrative Immediately Spray (HPCS) System means RCIC System is inoperable. OPERABLE when RCIC System is required to be OPERABLE.

AND B.2 Restore HPCS System to 14 days OPERABLE status.

(1)

The Completion Time that one train of RHR (RHR-A) can be inoperable as specified by Required Action A.1 may be extended beyond the 7 day completion time up to 7 days to support restoration of RHR-A following pump and motor replacement. This footnote will expire at 23:59 PST February 28, 2019.

Columbia Generating Station 3.5.1-1 Amendment No. 187 225 230 245

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.8 -------------------------------NOTE------------------------------

Vessel injection/spray may be excluded.

Verify the required LPCI or LPCS subsystem actuates In accordance on a manual initiation signal or the required HPCS with the subsystem can be manually operated. Surveillance Frequency Control Program Columbia Generating Station 3.5.2-6 Amendment No.

RPV Water Inventory ContolECCS - Shutdown B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.8 The required ECCS subsystem is required to have a manual start capability. This Surveillance verifies that a manual initiation signal will cause the required LPCI subsystem or LPCS System to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions. The HPCS system is verified to start manually from a standby configuration, and includes the ability to override the RPV Level 8 injection valve isolation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.FSAR, Section 6.3.3.4.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.10 CFR 50.36(c)(2)(ii).

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), " August 1992.E/I-02-91-1011.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.E/I-02-98-1002.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.TM 2092.

6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6,"

February 1983.

7. E/I-02-91-1011.

8. E/I-02-98-1002.

9. TM 2092.

Columbia Generating Station B 3.5.2-14 Revision 93