GO2-24-051, Application to Revise Technical Specifications to Adopt TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements
| ML24267A302 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/23/2024 |
| From: | David Brown Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-24-051 | |
| Download: ML24267A302 (1) | |
Text
David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 509.377.8385 dpbrown@energy-northwest.com GO2-24-051 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 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-592, "REVISE AUTOMATIC DEPRESSURIZATION SYSTEM (ADS)
INSTRUMENTATION REQUIREMENTS"
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station.
Energy Northwest requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.
The enclosure provides a description and assessment of the proposed changes. provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.
Energy Northwest requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of acceptance. Once approved, the amendment shall be implemented within 90 days.
There are no regulatory commitments made in this submittal.
In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this application, with attachments to the designated State Official.
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September 23, 2024 ENERGY NORTHWEST
GO2-24-051 Page 2 of 2 If you should have any questions regarding this submittal, please contact Mr. R.M.
Garcia, Licensing Supervisor, at 509-377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this ________ day of ___________, 2024.
Respectfully, David P. Brown Site Vice President
Enclosure:
Description and Assessment Attachments:
1.
Proposed Technical Specification Changes (Mark-Up) 2.
Proposed Technical Specification Changes (Clean Pages) 3.
Proposed Technical Specification Bases Mark-Up Pages (For Information Only) cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSEC@efsec.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
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GO2-24-051 Enclosure Page 1 of 3 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
Energy Northwest requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The Technical Specifications (TS) 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation Energy Northwest has reviewed the safety evaluation for TSTF-592 provided to the Technical Specifications Task Force in a letter dated January 31, 2024. This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-592. Energy Northwest has concluded that the justifications presented in TSTF-592 and the safety evaluation prepared by the NRC staff are applicable to Columbia Generating Station (Columbia) and justify this amendment for the incorporation of the changes to the Columbia TS.
Columbias ADS System differs from the design described in the TSTF-592 Safety Evaluation. At Columbia, the ADS System does not use high drywell pressure or a drywell bypass timer to provide a signal to initiate the ADS System. As a result, Table 3.3.5.1-1 of the Columbia TS doHV not contain the functions Drywell Pressure - High or ADS Bypass Timer (High Drywell Pressure). This difference in design does not affect the applicability of the TSTF-592 safety evaluation to Columbia, because the changes being requested by this LAR are based on having two low pressure ECCS pumps, per ADS trip system, and each pump having two Required Channels, providing the permissive for the ADS system initiation. At Columbia the ADS system design has two low pressure ECCS pumps, per ADS trip system, with each pump having two Required Channels to provide the ADS initiation permissive.
2.2 Optional Changes and Variations The Columbia TS utilize different numbering than the STS on which TSTF-592 was based. Specifically, NUREG 1434 Table 3.3.5.1-1 function 4e, 4f, 4h, 5e, and 5g are listed as function 4d, 4e, 4g, 5d, and 5f in the Columbia TS. In addition, Columbia TS contain functions 4f and 5e, Accumulator Backup Compressed Gas System Pressure -
Low Functions and the STS do not. Functions 4f and 5e are not affected by this proposed LAR. These differences are administrative and do not affect the applicability of TSTF-592 to the Columbia TS.
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GO2-24-051 Enclosure Page 2 of 3 Additionally, Columbias TS 3.8.1 condition A has completion times that are different from the STS that TSTF-592 was based. Therefore, the changes to TS 3.8.1 in TSTF-592 that were made to provide consistency and clarity, without changing the intent of the TS do not apply to the Columbia TS and no changes to TS 3.8.1 are being requested at this time.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Analysis Energy Northwest requests adoption of TSTF-592, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements." The TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," Actions are revised to reflect the plant design and the safety significance of inoperable ADS monitoring channels.
Energy Northwest has evaluated if a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The actions taken when an ADS monitoring channel is inoperable are not an initiator of any accident previously evaluated.
The proposed actions implement the appropriate actions to be taken if automatic initiation of ADS is not available (i.e., declaring the ADS valves inoperable),
which ensures the equipment assumed to be available to mitigate the consequences of accidents previously evaluated is available or the plant is placed in a safe condition.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect the design function or operation of the ADS or the ADS initiation instrumentation.
The proposed change does not create a new or different type of failure for the
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GO2-24-051 Enclosure Page 3 of 3 ADS or the ADS initiation instrumentation due to credible new failure mechanisms, malfunctions, or accident initiators not currently considered in the design and licensing bases.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the TS Actions applicable when one or more ADS monitoring channels are inoperable to be consistent with the plant design and the safety significance of the condition. The proposed change does not affect any controlling values of parameters established in the design or licensing basis, and does not alter any design basis or safety limit.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Energy Northwest concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),
and, accordingly, a finding of "no significant hazards consideration" is justified.
3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.
4.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
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GO2-24-051 Proposed Technical Specification Changes (Mark-Up)
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-7 Amendment No. 169 172, 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.
G.1
NOTE--------------
Only applicable for Functions 4.b, 4.d, 4.e, 5.b, and 5.d.
Declare ADS valves inoperable.
AND G.2 Restore channel to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems
NOTE---------
The Risk Informed Completion Time Program is not applicable when a loss of function occurs.
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND
NOTE---------
The Risk Informed Completion Time Program is not applicable when a loss of function occurs.
8 days or in accordance with the Risk Informed Completion Time Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-8 Amendment No. 166, 169 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1 H.1
NOTE--------------
- 1. Only applicable for Functions 4.d, 4.e, and 5.d.
- 2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable.
Declare ADS valves inoperable.
AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-9 Amendment No. 166, 169 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME H. (continued)
H.2
NOTE--------------
- 1. Only applicable for Functions 4.d, 4.e, and 5.d.
- 2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable.
Restore affected channels to OPERABLE status.
AND H.3 Restore channel to OPERABLE status.
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels.
30 days
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-10 Amendment No. 166, 169 225 238 251 270 273 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME IH. Required Action and associated Completion Time of Condition B, C, D, E, F, G, or HG not met.
IH.1 Declare associated supported feature(s) inoperable.
Immediately
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-11 Amendment No.238 270 273 SURVEILLANCE REQUIREMENTS
NOTES----------------------------------------------------------
1.
Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.
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 as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 3.c, 3.f, and 3.g; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 3.c, 3.f, and 3.g provided the associated Function or the redundant Function maintains ECCS initiation capability.
SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-12 Amendment No. 270 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1.4 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.
In accordance with the Surveillance Frequency Control Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-13 Amendment No. 270 Table 3.3.5.1-1 (page 1 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.
Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)
Subsystems a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig c.
LPCS Pump Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 8.53 seconds and d 10.64 seconds d.
LPCI Pump A Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 17.24 seconds and d 21.53 seconds e.
LPCI Pump A Start -
LOCA/LOOP Time Delay Relay 1, 2, 3 1
C SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 t 3.04 seconds and d 6.00 seconds f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 psig and d 492 psig (a)
Deleted (b)
Also required to initiate the associated diesel generator (DG).
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-14 Amendment No. 270 Table 3.3.5.1-1 (page 2 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.
LPCS Pump Discharge Flow -
Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 668 gpm and d 1067 gpm h.
LPCI Pump A Discharge Flow -
Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 605 gpm and d 984 gpm i.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA 2.
LPCI B and LPCI C Subsystems a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig c.
LPCI Pump B Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 17.24 seconds and d 21.53 seconds d.
LPCI Pump C Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 8.53 seconds and d 10.64 seconds e.
LPCI Pump B Start -
LOCA/LOOP Time Delay Relay 1, 2, 3 1
C SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 t 3.04 seconds and d 6.00 seconds (a)
Deleted (b)
Also required to initiate the associated DG.
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-15 Amendment No.
Table 3.3.5.1-1 (page 3 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 2.
LPCI B and LPCI C Subsystems f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3, 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 psig and d 492 psig g.
LPCI Pumps B & C Discharge Flow -
Low (Minimum flow) 1, 2, 3 1 per pump E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 605 gpm and d 984 gpm h.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA 3.
High Pressure Core Spray (HPCS) System a.
Reactor Vessel Water Level - Low Low, Level 2 1, 2, 3 4(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -58 inches b.
Drywell Pressure -
High 1, 2, 3 4(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig c.
Reactor Vessel Water Level - High, Level 8 1, 2, 3 2
C SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 56.0 inches d.
Condensate Storage Tank Level - Low 1, 2, 3 2
D SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 ft 1 inch elevation (a)
Deleted (b)
Also required to initiate the associated DG.
(c)
Deleted
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-16 Amendment No.
Table 3.3.5.1-1 (page 4 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 3.
HPCS System e.
Suppression Pool Water Level - High 1, 2, 3 2
D SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 466 ft 11 inches elevation f.
HPCS System Flow Rate - Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 1200 gpm and d 1512 gpm g.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA 4.
Automatic Depressurization System (ADS) Trip System A a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(d), 3(d) 2 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
ADS Initiation Timer 1, 2(d), 3(d) 1 G
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 d 115.0 seconds c.
Reactor Vessel Water Level - Low, Level 3 (Permissive) 1, 2(d), 3(d) 1 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 9.5 inches d.
LPCS Pump Discharge Pressure
- High 1, 2(d), 3(d) 2 HG SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 119 psig and d 171 psig e.
LPCI Pump A Discharge Pressure
- High 1, 2(d), 3(d) 2 HG SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 116 psig and d 134 psig (a)
Deleted (d)
With reactor steam dome pressure > 150 psig.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-17 Amendment No.
Table 3.3.5.1-1 (page 5 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 4.
ADS Trip System A f.
Accumulator Backup Compressed Gas System Pressure -
Low 1, 2(d), 3(d) 3 F
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 151.4 psig g.
Manual Initiation 1, 2(d), 3(d) 4 HG SR 3.3.5.1.6 NA 5.
ADS Trip System B a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(d), 3(d) 2 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
ADS Initiation Timer 1, 2(d), 3(d) 1 G
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 d 115.0 seconds c.
Low, Level 3 (Permissive) 1, 2(d), 3(d) 1 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 9.5 inches d.
LPCI Pumps B & C Discharge Pressure
- High 1, 2(d), 3(d) 2 per pump HG SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 116 psig and d 134 psig e.
Accumulator Backup Compressed Gas System Pressure -
Low 1, 2(d), 3(d) 3 F
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 151.4 psig f.
Manual Initiation 1, 2(d), 3(d) 4 HG SR 3.3.5.1.6 NA (d)
With reactor steam dome pressure > 150 psig.
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GO2-24-051 Proposed Technical Specification Changes (Clean Pages)
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-7 Amendment No. 169 172, 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G. As required by Required Action A.1 and referenced in Table 3.3.5.1-1.
G.1 Declare ADS valves inoperable.
AND G.2 Restore channel to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems
NOTE---------
The Risk Informed Completion Time Program is not applicable when a loss of function occurs.
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND
NOTE---------
The Risk Informed Completion Time Program is not applicable when a loss of function occurs.
8 days or in accordance with the Risk Informed Completion Time Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-8 Amendment No. 166, 169 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME H. As required by Required Action A.1 and referenced in Table 3.3.5.1-1 H.1
NOTE--------------
- 1. Only applicable for Functions 4.d, 4.e, and 5.d.
- 2. Only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable.
Declare ADS valves inoperable.
AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-9 Amendment No. 166, 169 225 238 251 270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME H. (continued)
H.2
NOTE--------------
- 1. Only applicable for Functions 4.d, 4.e, and 5.d.
- 2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable.
Restore affected channels to OPERABLE status.
AND H.3 Restore channel to OPERABLE status.
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCS or RCIC inoperable AND 8 days or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channels.
30 days
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-10 Amendment No. 166, 169 225 238 251 270 273 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I.
Required Action and associated Completion Time of Condition B, C, D, E, F, G, or H not met.
I.1 Declare associated supported feature(s) inoperable.
Immediately
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-11 Amendment No.238 270 273 SURVEILLANCE REQUIREMENTS
NOTES----------------------------------------------------------
1.
Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.
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 as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 3.c, 3.f, and 3.g; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 3.c, 3.f, and 3.g provided the associated Function or the redundant Function maintains ECCS initiation capability.
SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-12 Amendment No. 270 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1.4 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST.
In accordance with the Surveillance Frequency Control Program
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-13 Amendment No. 270 Table 3.3.5.1-1 (page 1 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.
Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)
Subsystems a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig c.
LPCS Pump Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 8.53 seconds and d 10.64 seconds d.
LPCI Pump A Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 17.24 seconds and d 21.53 seconds e.
LPCI Pump A Start -
LOCA/LOOP Time Delay Relay 1, 2, 3 1
C SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 t 3.04 seconds and d 6.00 seconds f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 psig and d 492 psig (a)
Deleted (b)
Also required to initiate the associated diesel generator (DG).
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-14 Amendment No. 270 Table 3.3.5.1-1 (page 2 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- g.
LPCS Pump Discharge Flow -
Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 668 gpm and d 1067 gpm
- h.
LPCI Pump A Discharge Flow -
Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 605 gpm and d 984 gpm
- i.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA
- a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches
- b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig
- c.
LPCI Pump B Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 17.24 seconds and d 21.53 seconds
- d.
LPCI Pump C Start -
LOCA Time Delay Relay 1, 2, 3 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6 t 8.53 seconds and d 10.64 seconds
- e.
LPCI Pump B Start -
LOCA/LOOP Time Delay Relay 1, 2, 3 1
C SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 t 3.04 seconds and d 6.00 seconds (a)
Deleted (b)
Also required to initiate the associated DG.
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-15 Amendment No.
Table 3.3.5.1-1 (page 3 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 2.
LPCI B and LPCI C Subsystems f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3, 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 psig and d 492 psig g.
LPCI Pumps B & C Discharge Flow -
Low (Minimum flow) 1, 2, 3 1 per pump E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 605 gpm and d 984 gpm h.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA 3.
High Pressure Core Spray (HPCS) System a.
Reactor Vessel Water Level - Low Low, Level 2 1, 2, 3 4(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -58 inches b.
Drywell Pressure -
High 1, 2, 3 4(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 1.88 psig c.
Reactor Vessel Water Level - High, Level 8 1, 2, 3 2
C SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 56.0 inches d.
Condensate Storage Tank Level - Low 1, 2, 3 2
D SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 448 ft 1 inch elevation (a)
Deleted (b)
Also required to initiate the associated DG.
(c)
Deleted
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-16 Amendment No.
Table 3.3.5.1-1 (page 4 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 3.
HPCS System e.
Suppression Pool Water Level - High 1, 2, 3 2
D SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 d 466 ft 11 inches elevation f.
HPCS System Flow Rate - Low (Minimum Flow) 1, 2, 3 1
E SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 1200 gpm and d 1512 gpm g.
Manual Initiation 1, 2, 3 2
C SR 3.3.5.1.6 NA 4.
Automatic Depressurization System (ADS) Trip System A a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(d), 3(d) 2 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
ADS Initiation Timer 1, 2(d), 3(d) 1 G
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 d 115.0 seconds c.
Reactor Vessel Water Level - Low, Level 3 (Permissive) 1, 2(d), 3(d) 1 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 9.5 inches d.
LPCS Pump Discharge Pressure
- High 1, 2(d), 3(d) 2 H
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 119 psig and d 171 psig e.
LPCI Pump A Discharge Pressure
- High 1, 2(d), 3(d) 2 H
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 116 psig and d 134 psig (a)
Deleted (d)
With reactor steam dome pressure > 150 psig.
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ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-17 Amendment No.
Table 3.3.5.1-1 (page 5 of 5)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 4.
ADS Trip System A f.
Accumulator Backup Compressed Gas System Pressure -
Low 1, 2(d), 3(d) 3 F
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 151.4 psig g.
Manual Initiation 1, 2(d), 3(d) 4 H
SR 3.3.5.1.6 NA 5.
ADS Trip System B a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2(d), 3(d) 2 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t -142.3 inches b.
ADS Initiation Timer 1, 2(d), 3(d) 1 G
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6 d 115.0 seconds c.
Low, Level 3 (Permissive) 1, 2(d), 3(d) 1 F
SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 9.5 inches d.
LPCI Pumps B & C Discharge Pressure
- High 1, 2(d), 3(d) 2 per pump H
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 116 psig and d 134 psig e.
Accumulator Backup Compressed Gas System Pressure -
Low 1, 2(d), 3(d) 3 F
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6 t 151.4 psig f.
Manual Initiation 1, 2(d), 3(d) 4 H
SR 3.3.5.1.6 NA (d)
With reactor steam dome pressure > 150 psig.
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GO2-24-051 Proposed Technical Specification Bases Mark-Up Pages (For Information Only)
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-5 Revision 73 BASES BACKGROUND (continued) and LPCS systems are unable to adequately cool the fuel if the HPCS fails to maintain level. An alarm in the control room is annunciated when either of the timers is running. Resetting the ADS initiation signals resets the ADS Initiation Timers.
The ADS also monitors the discharge pressures of the three LPCI pumps and the LPCS pump. Each ADS trip system includes two discharge pressure permissive switches from each of the two low pressure ECCS pumps in the associated Division (i.e., Division 1 ECCS inputs to ADS trip system A and Division 2 ECCS inputs to ADS trip system B). The signals are used as a permissive for ADS actuation, indicating that there is a source of core coolant available once the ADS has depressurized the vessel. Any one of the four low pressure pumps provides sufficient core coolant flow to permit automatic depressurization.
The ADS logic in each trip system is arranged in two strings. One string has a contact from each of the following variables: Reactor Vessel Water Level - Low Low Low, Level 1; Reactor Vessel Water Level - Low, Level 3; ADS Initiation Timer; and two low pressure ECCS Pump Discharge Pressure - High contacts (one from each divisional pump).
The other string has a contact from each of the following variables:
Reactor Vessel Water Level - Low Low Low, Level 1; and two low pressure ECCS Pump Discharge Pressure - High contacts (one from each divisional pump). To initiate an ADS trip system, the following applicable contacts must close in the associated string: Reactor Vessel Water Level - Low Low Low, Level 1; Reactor Vessel Water Level - Low, Level 3 (one string only); ADS Initiation Timer; and one of the two low pressure ECCS Pump Discharge Pressure - High contacts.
Either ADS trip system A or trip system B will cause all the ADS relief valves to open. Once an ADS trip system is initiated, it is sealed in until manually reset.
Manual initiation for each trip system is accomplished by use of two manual switches and push buttons, whose four contacts (two per manual switch and push button) are arranged in a four-out-of-four logic (two contacts per ADS logic string). Manual inhibit switches are provided in the control room for ADS; however, their function is not required for ADS OPERABILITY (provided ADS is not inhibited when required to be OPERABLE).
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-24 Revision 132 BASES ACTIONS (continued)
For Required Action B.1, the Completion Time only begins upon discovery that a redundant feature in both Divisions (e.g., any Division 1 ECCS and Division 2 ECCS) cannot be automatically initiated due to inoperable, untripped channels within the same variable as described in the paragraph above. For Required Action B.2, the Completion Time only begins upon discovery that the HPCS System cannot be automatically initiated due to two inoperable, untripped channels for the associated Function in the same trip system. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status.
Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action B.3. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition HI must be entered and its Required Action taken.
C.1 and C.2 Required Action C.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within the same variable result in redundant automatic initiation capability being lost for the feature(s).
Required Action C.1 features would be those that are initiated by Functions 1.c, 1.d, 1.e, 1.f, 2.c, 2.d, 2.e, and 2.f (i.e., low pressure ECCS). For Functions 1.c, 1.d, 2.c, and 2.d, redundant automatic initiation capability is lost if the Function 1.c or 1.d channel concurrent with the Function 2.c or 2.d channel are inoperable. For Functions 1.e and 2.e, redundant automatic initiation capability is lost if the Function 1.e and Function 2.e channels are inoperable. For Functions 1.f and 2.f, redundant automatic initiation capability is lost if one Function 1.f channel and one Function 2.f channel are inoperable. Since each inoperable channel would have Required Action C.1 applied separately (refer to
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-26 Revision 132 BASES ACTIONS (continued)
Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition HI must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would either cause the initiation or would not necessarily result in a safe state for the channel in all events.
D.1, D.2.1, and D.2.2 Required Action D.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same Function result in a complete loss of automatic component initiation capability for the HPCS System. Automatic component initiation capability is lost if two Function 3.d channels or two Function 3.e channels are inoperable and untripped. In this situation (loss of automatic suction swap), the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of Required Actions D.2.1 and D.2.2 is not appropriate and the HPCS System must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of HPCS initiation capability. As noted, the Required Action is only applicable if the HPCS pump suction is not aligned to the suppression pool, since, if aligned, the Function is already performed.
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action D.1, the Completion Time only begins upon discovery that the HPCS System cannot be automatically aligned to the suppression pool due to two inoperable, untripped channels in the same Function. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-27 Revision 132 BASES ACTIONS (continued) clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action D.2.1 or the suction source must be aligned to the suppression pool within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per Required Action D.2.2. Placing the inoperable channel in trip performs the intended function of the channel (shifting the suction source to the suppression pool). Performance of either of these two Required Actions will allow operation to continue. If Required Action D.2.1 or Required Action D.2.2 is performed, measures should be taken to ensure that the HPCS System piping remains filled with water.
Alternately, if it is not desired to perform Required Actions D.2.1 and D.2.2 (e.g., as in the case where shifting the suction source could drain down the HPCS suction piping), Condition HI must be entered and its Required Action taken.
E.1 and E.2 Required Action E.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within the LPCS and LPCI Pump Discharge Flow - Low (Minimum Flow) Functions result in redundant automatic initiation capability being lost for the feature(s). For Required Action E.1, the features would be those that are initiated by Functions 1.g, 1.h, and 2.g (e.g., low pressure ECCS). Redundant automatic initiation capability is lost if three of the four channels associated with Functions 1.g, 1.h, and 2.g are inoperable. Since each inoperable channel would have Required Action E.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected low pressure ECCS pump to be declared inoperable. However, since channels for more than one low pressure ECCS pump are inoperable, and the Completion Times started concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable.
In this situation (loss of redundant automatic initiation capability), the 7 day allowance of Required Action E.2 is not appropriate and the feature(s) associated with each inoperable channel must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of initiation capability for feature(s) in both Divisions. A Note is provided (the Note to Required Action E.1) to delineate that Required Action E.1 is only applicable to low pressure ECCS Functions. Required Action E.1 is not applicable to HPCS Function 3.f since the loss of one channel results in a loss of the Function (one-out-of-one logic). This loss was considered during the development of Reference 5 and considered acceptable for the 7 days allowed by Required Action E.2.
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-28 Revision 132 BASES ACTIONS (continued)
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action E.1, the Completion Time only begins upon discovery that three channels of the variable (Pump Discharge Flow - Low) cannot be automatically initiated due to inoperable channels. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels.
If the instrumentation that controls the pump minimum flow valve is inoperable such that the valve will not automatically open, extended pump operation with no injection path available could lead to pump overheating and failure. If there were a failure of the instrumentation such that the valve would not automatically close, a portion of the pump flow could be diverted from the reactor injection path, causing insufficient core cooling.
These consequences can be averted by the operator's manual control of the valve, which would be adequate to maintain ECCS pump protection and required flow. Furthermore, other ECCS pumps would be sufficient to complete the assumed safety function if no additional single failure were to occur. The 7 day Completion Time of Required Action E.2 to restore the inoperable channel to OPERABLE status is reasonable based on the remaining capability of the associated ECCS subsystems, the redundancy available in the ECCS design, and the low probability of a DBA occurring during the allowed out of service time. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition HI must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b.
F.1 and F.2 Required Action F.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS. Automatic initiation capability is lost if either (a) one or more Function 4.a channel and one or more Function 5.a channel are inoperable and untripped, (b) one Function 4.c channel and one Function 5.c channel are inoperable and untripped, or (c) two or more Function 4.f channels and two or more Function 5.e channels are inoperable and untripped.
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-29 Revision 132 BASES ACTIONS (continued)
In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action F.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems.
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action F.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable, untripped channels within similar ADS trip system Functions as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status if both HPCS and RCIC are OPERABLE. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If either HPCS or RCIC is inoperable, the time is shortened to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability.
However, total time for an inoperable, untripped channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable, untripped channel.
If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action F.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g.,
as in the case where placing the inoperable channel in trip would result in an initiation), Condition HI must be entered and its Required Action taken.
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-30 Revision 132 BASES ACTIONS (continued)
G.1 and G.2 Required Action G.1 is intended to ensure that appropriate actions are taken if multiple, inoperable channels within similar ADS trip system Functions result in automatic initiation capability being lost for the ADS.
Automatic initiation capability is lost if either (a) one Function 4.b channel and one Function 5.b channel are inoperable, (b) one or more Function 4.d channels and one or more Function 5.d channels are inoperable, or (c) one or more Function 4.e channels and one or more Function 5.d channels are inoperable.
In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action G.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Note to Required Action G.1 states that Required Action G.1 is only applicable for Functions 4.b, 4.d, 4.e, 5.b, and 5.d. Required Action G.1 is not applicable to Functions 4.g and 5.f (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 days (as allowed by Required Action G.2) is allowed.
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action G.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable channels within similar ADS trip system Functions, as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.
Because of the diversity of sensors available to provide initiation signals and the redundancy of the ECCS design, an allowable out of service time of 8 days has been shown to be acceptable (Ref. 5) to permit restoration of any inoperable channel to OPERABLE status if both HPCS and RCIC are OPERABLE (Required Action G.2). Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If either HPCS or RCIC is inoperable, the time is reduced to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Alternatively, a Completion Time can be determined in accordance with the Risk Informed
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-31 Revision 132 BASES ACTIONS (continued)
Completion Time Program. This Completion Time is modified by a Note to clarify that the Risk Informed Completion Time Program is not applicable to a Required Action associated with a Condition that represents a loss of safety function as defined in TS 5.11.b. If the status of HPCS or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC inoperability. However, total time for an inoperable channel cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition HI must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.
H.1, H.2, and H.3 Required Action H.1 requires that the ADS valves be declared inoperable when a combination of Functions 4.G, 4.H, and 5.G channels are inoperable such that neither ADS Trip System A or B has two OPERABLE Pump Discharge Pressure - High channels associated with one low pressure ECCS pump.
In this situation (loss of automatic initiation capability), the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action H.2 is not appropriate, and all ADS valves must be declared inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discovery of loss of ADS initiation capability in both trip systems. The Notes to Required Action H.1 state that Required Action H.1 is only applicable for Functions 4.G, 4.H, and 5.G, and that it is only applicable when both ADS trip systems are inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels being inoperable. Required Action H.1 is not applicable to Functions 4.J and 5.I (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." For Required Action H.1, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperableFKDQQHOVZLWKLQVLPLODU$'6WULSV\VWHP
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-32 Revision 132 Functions, as described in the paragraph above. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration of channels. If the inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.
Required Action H.2 is intended to ensure that appropriate actions are taken if there are not two OPERABLE Pump Discharge Pressure -
High channels associated with one low pressure ECCS pumpwithin one ADS trip system, which results in automatic initiationcapability being lost for that ADS trip system. Because of thediversity of sensors available to provide initiation signals and theredundancy of the ECCS design, a Completion Time of 8 days has beenshown to be acceptable (Ref. 5) to permit restoration of twoinoperable Pump Discharge Pressure - High channels associatedwith one low pressure ECCS Pump to OPERABLE status if bothHPCS and RCIC are OPERABLE (Required Action H.2).
Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either HPCS or RCIC is inoperable, the Completion Time is reduced to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If the status of HP&S or RCIC changes such that the Completion Time changes from 8 days to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCS or RCIC
inoperability. However, the total time to restore the required inoperable channels to OPERABLE status cannot exceed 8 days. If the status of HPCS or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the "time zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel. If the minimum required inoperable channels cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. The Notes to Required Action H.2 state that Required Action H.2 is only applicable for Functions 4.G, 4.H, and 5.G, and that it is only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure - High functions EHLQJ inoperable. Required Action H.2 is not applicable to Functions 4.J and 5.I (which also require entry into this Condition if a channel in these Functions is inoperable), since they are the Manual Initiation Functions and are not assumed in any accident or transient analysis. Thus, a total loss of these functions for 30 days (as allowed by Required Action H.3) is allowed.
BASES ACTIONS (continued)
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ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-33 Revision 132 BASES ACTIONS (continued) 5HTXLUHG$FWLRQ+LVLQWHQGHGWRHQVXUHWKDWDSSURSULDWHDFWLRQVDUH
WDNHQLILQRSHUDEOHFKDQQHOVZLWKLQRQH$'6WULSV\VWHPGRQRWresult in loss of automatic initiation capability to respond to a design basis event, but require restoration per Table 3.3.5.1-1. This applies to Functions 4.G, 4.H, 4.J, 5.G, and 5.I. The 30 day Completion Time of Required Action H.3 is acceptable, based on operating experience, considering the multiple channels available for meeting the low
pressure ECCS pump discharge pressure permissive, and the availability of automatic ADS initiation. If the inoperable channel cannot be restored to OPERABLE status within the Completion Time, Condition I must be entered and its Required Action taken.
H,.1 With any Required Action and associated Completion Time not met, the associated feature(s) /3&6/3&,+3&6RU$'6 may be incapable of performing the intended function and the supported feature(s) associated with the inoperable untripped channels must be declared inoperable immediately.
SURVEILLANCE As noted at the beginning of the SRs, the SRs for each ECCS REQUIREMENTS instrumentation Function are found in the SRs column of Table 3.3.5.1-1.
The Surveillances are modified by a Note to indicate that 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 /> as follows: (a) for Functions 3.c, 3.f, and 3.g; and (b) for Functions other than 3.c, 3.f, and 3.g provided the associated Function or redundant Function maintains ECCS initiation capability.
Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 5) assumption of the average time required to perform channel Surveillance. That analysis demonstrated that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> testing allowance does not significantly reduce the probability that the ECCS will initiate when necessary.
Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a
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