Text

Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance...
	ML20050V454
Person / Time
Site:	Columbia
Issue date:	02/19/2020
From:	Schuetz R; Energy Northwest
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GO2-20-029
	Download: ML20050V454 (11)
	v • d • e

R.E. Schuetz Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.2425 l F. 509.377.4150 rescheutz@energy-northwest.com February 19, 2020 GO2-20-029 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-563, "REVISE INSTRUMENT TESTING DEFINITIONS TO INCORPORATE THE SURVEILLANCE FREQUENCY CONTROL PROGRAM"

References:

1. Letter from R. E. Schuetz, Energy Northwest to NRC, dated August 15, 2019 (ADAMS Accession Number ML19227A397)

2. Letter from R. E. Schuetz, Energy Northwest to NRC, dated September 12, 2019 (ADAMS Accession Number ML19255H995)

3. Email from J. Klos, NRC to D. M. Wolfgramm, Energy Northwest, dated February 3, 2020 (ADAMS Accession Number ML20034E608)

Dear Sir or Madam:

By Reference 1 and as supplemented by Reference 2, Energy Northwest submitted a license amendment request to adopt Technical Specification Task Force (TSTF)-563 into Columbia Generating Station (Columbia) Technical Specification (TS). By Reference 3 the U.S. Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. Enclosure 1 to this letter contains the requested information. Enclosure 2 provides a markup of Columbia TS. provides a clean copy of Columbia TS.

The No Significant Hazards Consideration Determination provided in the original submittal is not altered by this submittal. No new commitments are being made by this letter or the enclosure.

If there are any questions or if additional information is needed, please contact Ms. D.

M. Wolfgramm, Licensing Supervisor, at 509-377-4792.

GO2-20-029 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed this ______ day of ___________, 201x.

Respectfully, R. E. Schuetz Site Vice President

Enclosures:

As stated cc: NRC RIV Regional Administrator NRC Senior Resident Inspector/988C NRC NRR Project Manager CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH

GO2-20-029 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC REQUEST No. STSB-RAI-1:

The license proposes to delete the language, so that the entire channel is tested, from the Channel Functional Test definition in Columbia [Columbia Generating Station] TS

[Technical Specification]. Columbias Channel Functional Test definition states:

A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, so that the entire channel is tested.

Columbias Channel Functional Test definition differs from that in the Standard Technical Specifications on which TSTF-563 is based. The Channel Functional Test definition in the Boiling Water Reactor (BWR)/4 and BWR/6 Standard Technical Specifications NUREG- 1433 and 1434, Revision 4.0 states: (TSTF-563 Changes are shown in bold italics)

The CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

The technical evaluation for the addition of the phrase in bold italics above is contained in the NRC staffs final safety evaluation of TSTF-563, Revision 0, and final model safety evaluation of TSTF-563, Revision 03. These safety evaluations do not describe nor provide a technical evaluation for any deletions of any kind contained in TSTF-563.

The deletion of the language from Columbias Channel Functional Test definition is a variation from TSTF-563.

Background:

In the letter dated September 12, 2019, Energy Northwest stated that deleting, so that the entire channel is tested from the definition of Channel Functional Test more closely aligns with the definition as described in TSTF-563 and as a point of clarification and consistent with the understanding expressed in TSTF-563 and the NRC Safety Evaluation, the requirement to perform a Channel Functional Test on the entire channel has not changed. The deletion of the language, so that the entire channel is tested, from Columbias Channel Functional Test appears to change the requirement to test the entire channel. Because Columbias Channel Functional Test definition differs from the

GO2-20-029 Page 2 of 2 Standard Technical Specifications in that it does not contain the language to verify operability of, all devices in the channel, it appears that the requirement to perform the Channel Functional Test on the entire channel may have changed and that the NRC staff model safety evaluation may not be applicable to this proposed change. Therefore, the NRC staff is requesting the following additional information be submitted.

Explain if the language in Columbias Channel Functional Test that states, including required alarm, interlock, display, and trip functions, and channel failure trips, describes the entire channel leaving nothing out and is equivalent to the language, all devices in the channel, or alternatively provide the technical basis for removing the requirement to test the entire channel during the Channel Functional Test.

ENERGY NORTHWEST RESPONSE TO RAI 1:

Energy Northwest has modified the Columbia TS markup for the Channel Functional Test to align with the language in NUREG-1434. The markup shows the generic language used in the Standard Technical Specifications. Columbia will continue to test all the devices in the channel (i.e. required alarm, interlock, display, and trip functions, and channel trips). This is an acceptable variation and does not change the conclusion of Final Safety Evaluation provided in the December 4, 2018 letter to the Technical Specification Task Force (ADAMS Accession Number ML18333A146).

GO2-20-029 Technical Specification Markup

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL A CHANNEL FUNCTIONAL TEST shall be the injection of a TEST simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY, including required alarm, interlock, display, and trip functions, and Columbia Generating Station 1.1-1 Amendment No. 149,169 225

Definitions 1.1 channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, Columbia Generating Station 1.1-2 Amendment No. 149,169 225

Definitions 1.1 1.1 Definitions CHANNEL FUNCTIONAL TEST (Continued) overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step so that the entire channel is tested.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and

b. Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.3. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same Total Effective Dose Equivalent (TEDE) dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The dose conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1988.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; Columbia Generating Station 1.1-3 Amendment No. 190,199 225 251

GO2-20-029 Technical Specification Clean Pages

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the LHGRs for all the fuel rods in (APLHGR) the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL A CHANNEL FUNCTIONAL TEST shall be the injection of a TEST simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, Columbia Generating Station 1.1-1 Amendment No. 149,169 225

Definitions 1.1 1.1 Definitions CHANNEL FUNCTIONAL TEST (Continued) overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.