GO2-02-135, Revised Request for Amendment on the Alternate Source Term

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Revised Request for Amendment on the Alternate Source Term
ML022560162
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/27/2002
From: Webring R
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-02-135
Download: ML022560162 (47)
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Text

ENERGY NORTHWEST PO. Box 968 x Richland, Washington 99352-0968 August 27, 2002 G02-02-135 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REVISED REQUEST FOR AMENDMENT ON THE ALTERNATE SOURCE TERM

Reference:

Letter G02-01-156, dated December 3, 2001, RL Webring to NRC, "License Amendment Request - Alternative Source Term"

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Energy Northwest hereby requests an amendment to the Columbia Generating Station operating license. Specifically, we are requesting a revision to licensing and design bases pertaining to the application of alternative source term methodology. This request is a revision to the amendment request indicated in the reference.

On August 19, 2002, in a telephone conversation with NRC Project Manager, BJ Benney, Energy Northwest agreed to revise the referenced request to retain operability requirements for secondary containment and its attendant equipment (i.e. secondary containment isolation instrumentation, secondary containment isolation valves, and standby gas treatment systems) when moving recently irradiated fuel. Recently irradiated fuel will be defined in the Technical Specifications Bases as fuel that has occupied part of the critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Energy Northwest requests this proposed change be reviewed and approved concurrent with the referenced amendment request.

The proposed change is submitted to accommodate the initial assumption in the fuel handling accident that the fuel had decayed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to fuel handling. The proposed revision to the amendment request does not change the evaluations submitted in support of the reference.

The 10 CFR 50.92 evaluation of no significant hazards and the environmental considerations evaluation submitted in the reference are applicable to this request. However, to reflect the changes proposed in this amendment request, a 10 CFR 50.92 evaluation germane to this request is included in enclosure 1. Attachment 1 contains the marked up pages of the Technical Specifications showing the proposed changes. Attachment 2 contains the typed

REQUEST FOR AMENDMENT Page 2 Technical Specifications, as revised by this amendment request. For additional information, we have included attachment 3 to illustrate the changes as they would revise the pages of the request submitted in the reference. Technical Specifications bases changes associated with this proposed amendment request are also included.

This amendment request has been approved by the Columbia Generating Station Plant Operations Committee and reviewed by the Energy Northwest Corporate Nuclear Safety Review Board. In accordance with 10 CFR 50.91, the state of Washington has been provided a copy of this letter.

Respectfully, RL Webring Vice President, Operations Support/PIO Mail Drop PE08

Enclosures:

1. Notarized affidavit
2. Evaluation of the proposed changes Attachments:
1. Proposed Technical Specifications Changes (mark-up)
2. Proposed Technical Specifications pages (retyped)
3. Changes as they would revise the referenced amendment request (including Technical Specifications bases) cc: EW Merschoff - NRC RIV DL Williams - BPA/1399 BJ Benney - NRC NRR TC Poindexter - Winston & Strawn NRC Senior Resident Inspector/988C JO Luce - EFSEC

STATE OF WASHINGTON)

Subject:

Request for Amendment,

) Technical Specification COUNTY OF BENTON ) LCO 3.3.6.2, 3.6.4.1, 3.6.4.2,

) 3.6.4.3 I, RL Webring, being duly sworn, subscribe to and say that I am the Vice President, Operations Support/PIO ENERGY NORTHWEST, the applicant herein; that I have the full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief that the statements made in it are true.

DATE*27 _ 2002

-* Webring, Vice President Operations Support/PIO On this date personally appeared before me RL Webring, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.

GIVEN under my hand and seal this Z 7 day of 2002 A Notary blic in and for the

/ x*.!i6 V .. <d 'STATE OF WASHINGTON

  • -PUBLIC Residing at
-M d Commission expires 3-

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Page 1 of 3 Licensee Evaluation

Subject:

Revision to the Alternate Source Term Technical Specification amendment request DESCRIPTION:

The proposed change would modify the referenced Technical Specifications amendment request to establish operability requirements for secondary containment and its attendant equipment (i.e. secondary containment isolation instrumentation, secondary containment isolation valves, and standby gas treatment systems) described in the safety analysis. This change is necessary to accommodate an assumption in the Columbia Generating Station design basis accident analysis. It is requested that this amendment request be reviewed and approved concurrent with the referenced amendment request.

PROPOSED CHANGE:

The proposed change would modify the referenced Technical Specification amendment request to require secondary containment to be operable during movement of recently irradiated fuel.

Recently irradiated fuel is defined as fuel that has occupied part of the critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed change is necessary to accommodate the initial assumption in the Fuel Handling Accident (FHA) that the fuel had decayed for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to fuel handling (ref: Columbia Generating Station FSAR 15.7.4.5). This accident analysis assumption is reasonable because it is highly unlikely that fuel could be removed from the reactor core within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after plant shutdown for refueling. The proposed revision to the amendment request will require secondary containment and its attendant equipment (i.e.

secondary containment isolation instrumentation, secondary containment isolation valves, and standby gas treatment systems) to be operable during this 24-hour decay period following reactor criticality when moving recently irradiated fuel assemblies. The need for this proposed revision to the referenced amendment request was identified by NRR staff and communicated to Energy Northwest on August 19, 2002.

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Page 2 of 3 Regulatory Safety Analysis 10 CFR 50.92 Evaluation Columbia Generating Station has evaluated whether or not 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The requirement for secondary containment operability while moving recently irradiated fuel is consistent with the current accident analysis. Furthermore, the accident analysis does not assume fuel movement from the reactor core can begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from reactor shutdown. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No Because the requirement for secondary containment operability while moving recently irradiated fuel is consistent with the current accident analysis, 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 change involve a significant reduction in a margin of safety?

Response: No Secondary containment operability during movement of recently irradiated fuel maintains a current margin of safety. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Page 3 of 3 Evaluation of Environmental Considerations Energy Northwest has evaluated the proposed amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10CFR51.22(c)(9). This evaluation has determined that the change requested does not pose a significant hazards consideration nor does it involve an increase in the amounts, or a change in the types of any effluent that may be released off-site.

Additionally, this request does not involve a significant increase in individual or cumulative occupational radiation exposure.

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Proposed Technical Specifications Changes (mark-up)

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES AND REQUIRED OTHER CHANNELS SPECIFIED PER TRIP SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE I. Reactor Vessel Water Level - Low Low. Level 2 1.2.3.(a) 2 (c) SR SR 3.3.6.2.2 3.3.6.2.3 Z -58 inches I

2. Drywell Pressure-High 1.2.3 SR 3.3.6.2.4 I 2(c) SR 3.3.6.2.2 < 1.88 psig SR 3.3.6.2.3 SR 3.3.6.2.4
3. Reactor Building Vent 1.2.3. 2 SR 3.3.6.2.1 1 16.0 mR/hr Exhaust Plenum (a).(b) SR 3.3.6.2.2 Radiation-High SR 3.3.6.2.3 SR 3.3.6.2.4
4. Manual Initiation 1.2.3. 4 SR 3.3.6.2.4 NA (a).(b)

(a) During operations with a potential for draining the reactor vessel.

(b) During CORE ALTERATIONS, and during movement of irradiated fuel assemblies in the secondary containment.

(c) Also required to initiate the associated LOCA(\Time Delay Relay Funciton pursuant to LCO 3.3.5.1.

Columbia Generating Station 3.3.6.2-4 Amendment No. i49.19 172

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3, During movement of irradiated fuel assemblies in the secondary containment.

During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS

-.... NOTES ........................ ----------

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each penetration flow path.
3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REOUIRED ACTION COMPLETION TIME A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow paths penetration flow path with one SCIV by use of at least inoperable, one closed and de-activated automatic valve, closed manual valve.

or blind flange.

AND (continued)

Columbia Generating Station 3.6.4.2-1 Amendment No. 4-4 1691

SCIVs 3.6.4.2 ACTIONS CONDITION IREQUIRED ACTION I COMPLETION TIME D. Required Action and associated Completion Time of Condition A or B notmt during "m of irradiated fuel assemblies in the Suspend movement of Immediately secondary containment.' Riscc-wL, rradiated fuel during CORE D ssemblies in the ALTERATIONS, or during secondary OPDRVs. containment.

AND D.2 Suspend CORE Immediately ALTERATIONS.

AND D.3 Initiate action to Immediately suspend OPDRVs.

_________________________________________ I Columbia Generating Station 3.6.4.2-3 Amendment No. 4-4 1691

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3, .

During movement of*irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable, to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met in MODE 1. 2.

or 3. B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C. Required Action and associated Completion Time of Cond'tion A not met during

~LCOY*.3 not a plicable.

)

movement ýofirradiated C.1 Place OPERABLE SGT Immediately fuel assemblies in the subsystem in secondary containment, operation.

during CORE ALTERATIONS, or during OR OPDRVs.

(continued)

J I Columbia Generating Station 3.6.4.3-1 Amendment No. 4.4 1691

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) .21 Suspend movement of Immediately irradiated fuel S;o Jassemblies in the secondary containment.

AND C.2.2 Suspend CORE Immediately ALTERATIONS.

AND C.2.3 Initiate action to Immediately suspend OPDRVs.

D. Two SGT subsystems D.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1.

t'

2. or 3.

E. Two SGT subsystems inoperable during

'movement of4'irradiated fuel assemblies in the secondary containment.

Sduring CORE Suspend movement of Immediately ALTERATIONS, or duringl Kirradiated fuel OPDRVs. assemblies in the secondary containment.

AND E.2 Suspend CORE Immediately ALTERATIONS.

AND E.3 Initiate action to Immediately suspend OPDRVs.

_____________________________________ I ______________________

Columbia Generating Station 3.6.4.3-2 Amendment No. 44. 1691

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2. and 3, During movement o dated fuel assemblie. s in the secondary containment, During CORE ALTERATIONS, During operations with a potential for drain ing the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1. containment to

2. or 3. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Columbia Generating Station 3.6.4.1-1 Amendment No. 44 1691

Secondary Containment 3.6.4.1 ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME C. Secondary containment inoperable during

> rmovement of irradiated fuel assemblies in the secondary containment, during CORE S.Suspend movement of Immediately ALTERATIONS, or during Cirradiated fuel OPDRVs. assemblies in the secondary containment.

AND C.2 Suspend CORE Immediately ALTERATIONS.

AND C.3 Initiate action to Immediately suspend OPDRVs.

______________________ J. ________________________ ______________

I Columbia GeneraLing Station 3.6.4.1-2 Amendment No. 4-- 1691

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Proposed Technical Specifications Pages (retyped)

Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.2.3 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months Columbia Generating Station 3.3.6.2-3 Amendment No. 4-- 1691

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page I of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES AND REQUIRED OTHER CHANNELS SPECIFIED PER TRIP SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE CONDITIONS SYSTEM FUNCTION 2 (c) SR 3.3.6.2.2 > -58 inches

1. Reactor Vessel Water 1,2,3,(a) SR 3.3.6.2.3 Level - Low Low, Level 2 SR 3.3.6.2.4 2 (c) SR 3.3.6.2.2 < 1.88 psig
2. Drywell Pressure - High 1,2,3 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.1 < 16.0 mR/hr 1,2,3, 2
3. Reactor Building Vent SR 3.3.6.2.2 (a),(b)

Exhaust Plenum SR 3.3.6.2.3 Radiation - High SR 3.3.6.2.4 SR 3.3.6.2.4 NA 1,2,3, 4

4. Manual Initiation (a), (b)

(a) During operations with a potential for draining the reactor vessel.

containment.

(b) During movement of recently irradiated fuel assemblies in the secondary Function pursuant to LCO 3.3.5.1.

(c) Also required to initiate the associated LOCA Time Delay Relay Station 3.3.6.2-4 Amendment No. -4749,169 ,1ý2-Columbia Generating

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1. containment to 2, or 3. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C. Secondary containment C.1 Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in irradiated fuel the secondary assemblies in the containment.

secondary contrainment or during OPDRVs. AND C.2 Initiate action to Immediately suspend OPDRVs.

Columbia Generating Station 3.6.4.1-1 Amendment No.

  • 149,169

Secondary Containment 3.6.4.1 ANIfL DLCIITDIMFNiTS rrHFTil

)U ~V LILLMINUL IL' FREQUENCY SURVEILLANCE Verify secondary containment vacuum is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.6.4.1.1

> 0 inch of vacuum water gauge. I 1-Verify all secondary containment 31 days SR 3.6.4.1.2 equipment hatches are closed and sealed.

Verify each secondary containment access 31 days SR 3.6.4.1.3 inner door or each secondary containment access outer door in each access opening is closed.

1*

Verify each SGT subsystem can maintain 24 months on a SR 3.6.4.1.4 STAGGERED TEST

> 0.25 inch of vacuum water gauge in the BASIS secondary containment for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at an inleakage flow rate K 2240 cfm.

3.6.4.1-2 Amendment No. 149,469 Columbia Generating Station

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS

. .. NOT ES -----------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each penetration flow path.
3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow paths penetration flow path with one SCIV by use of at least inoperable, one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND (continued)

Columbia Generating Station 3.6.4.2-1 Amendment No. 149,169*

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 --------- NOTE Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

B.---------- NOTE--------- B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path penetration flow paths by use of at least with two isolation one closed and valves. de-activated

. automatic valve ,

closed manual valve, One or more or blind flange.

penetration flow paths with two SCIVs inoperable.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND or B not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Columbia Generating Station 3.6.4.2-2 Amendment No. 4-4 1691

SCIVs 3.6.4.2 ACTIONS __ __ I CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Suspend movement of Immediately associated Completion recently irradiated Time of Condition A fuel assemblies in or B not met during the secondary movement of recently containment.

irradiated fuel assemblies in the AND secondary containment or during OPDRVs. D.2 Initiate action to Immediately suspend OPDRVs.

Columbia Generating Station 3.6.4.2-3 Amendment No. 149,169n

SCIVs 3.6.4.2 DnIITDrMrNITR 3UMVLILL

..*U KV E I L LMI"Ib KMrU L I1LUU I I\kl IL.I'I I -- '

D(:nHTDFMFNT(ý SURVEILLANCE FREQUENCY i

SR 3.6.4.2.1 ------------------NOT ES -----------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative controls.
2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment 31 days isolation manual valve and blind flange that is required to be closed during accident conditions is closed.

SR 3.6.4.2.2 Verify the isolation time of each power In accordance operated and each automatic SCIV is with the within limits. Inservice Testing Program SR 3.6.4.2.3 Verify each automatic SCIV actuates to 24 months the isolation position on an actual or simulated automatic isolation signal.

Columbia Generating Station 3.6.4.2-4 Amendment No. 4-- 1691

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable, to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met in MODE 1, 2.

or 3. B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Columbia Generating Station 3.6.4.3-1 Amendment No. 149,1691*~

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Place OPERABLE SGT Immediately associated Completion subsystem in Time of Condition A operation.

not met during movement of recently OR irradiated fuel assemblies in the C.2.1 Suspend movement of Immediately secondary containment recently irradiated or during OPDRVs. fuel assemblies in the secondary containment.

AND C.2.2 Initiate action to Immediately suspend OPDRVs.

D. Two SGT subsystems D.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3.

E. Two SGT subsystems E.1 Suspend movement of Immediately inoperable during recently irradiated movement of recently fuel assemblies in irradiated fuel the secondary assemblies in the containment.

secondary containment or during OPDRVs. AND E.2 Initiate action to Immediately suspend OPDRVs.

Columbia Generating Station 3.6.4.3-2 Amendment No. 149,169

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.6.4.3.1 Operate each SGT subsystem for 31 days SR

> 10 continuous hours with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 24 months actual or simulated initiation signal and reaches > 5000 cfm in < 2 minutes.

SR 3.6.4.3.4 Verify each SGT filter cooling 24 months recirculation valve can be opened and the fan started.

)

Columbia Generating Station 3.6.4.3-3 Amendment No. +4- 1691

LICENSE AMENDMENT REQUEST FOR REVISION TO ALTERNATIVE SOURCE AMENDMENT REQUEST TERM Changes as they would revise the reference amendment request (including Technical Specifications bases)

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES AND REQUIRED OTHER CHANNELS SPECIFIED PER TRIP SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE

1. Reactor Vessel Water 1,2,3,(a) 2 (c) SR 3.3.6.2.2 > -58 inches I

Level - Low Low, Level 2 SR SR 3.3.6.2.3 3.3.6.2.4 I

2. Drywell Pressure-High 1,2,3 2 (c) SR 3.3.6.2.2 < 1.88 psig SR 3.3.6.2.3 SR 3.3.6.2.4
3. Reactor Building Vent 1.2,3. 2 SR 3.3.6.2.1 < 16.0 mR/hr Exhaust Plenum (a).(b) SR 3.3.6.2.2 Radiation - High SR 3.3.6.2.3 SR 3.3.6.2.4
4. Manual Initiation 1.2,3, 4 SR 3.3.6.2.4 NA (a),(b)

(a) During operations with a potential for draining the reactor vessel.

(b) Durinn ;RA; -n-dTT dwr4nj movement of i radiated fuel assemblies in the secondary contaisment. a rieae

  • t"' Im (c) Also required to initiate the as oc e line Delay Relay(F$c~~npursuant to LCQ 3.3.5.1.

I Columbia Generating Station 3.3.6.2-4 Amendment No. 149,169 172

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, [

  • During movement of rradiae fuel assemblies in the econa y co3ný t potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Columbia Generating Station 3.6.4.1-1 Amendment No. +4- 1691

Secondary Containment 3.6.4.1 Suspend movement of Immediately irradiated fuel assemblies in the containment.

Initiate action to suspend OPDRVs.

Columbia Generating Station 3.6.4.1-2 Amendment No. 4-- 1691

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY:

During movement ofvrradiated fuel a semblies in the rnis . otential for draining the reactor vessel (OPDRVs).

ACTIONS

-N NOTES .........................

O T E ---------

1. Penetration flow paths may be unisolated intermittently under administrative controls.
2. Separate Condition entry is allowed for each penetration flow path.
3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow paths penetration flow path with one SCIV by use of at least inoperable, one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND (continued)

Columbia Generating Station 3.6.4.2-1 Amendment No. +4- 1691

SCIVs 3.6.4.2

'i Columbia Generating Station 3.6.4.2-3 Amendment No. +4- 1691

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and During movement -Duel assemblies in the sc y n nt, (DUrirng PflE ALTERATI!rIZ13

  • potential for draining the reactor vessel (OPDRVs).

Columbia Generating Station 3.6.4.3-1 Amendment No. 4-4 1691

SGT System 3.6.4.3 Iwo SGT s:ubsystems movement of irradiated) fuel assemblies in the secondary containment, 0 uring I RVs.

Columbia Generating Station 3.6.4.3-2 Amendment No. 4-4 1691

Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES APPLICABLE 3. Reactor Building Vent Exhaust Plenum Radiation-Hiqh SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY isolation and actuation of the SGT System are initiate limit the releasee. f ission products sumein e F AR

__pr yys a.ef-.2 SO C* *O m*.* th Reactor Building Vent Exhaust Plenum Radiation-High

~ ~'c~t

'ecd'e~i ~ s gnals are initiated from radiation detectors that are 44e cated in the ventilation exhaust plenum, which is the

,c ollection point of all reactor building and refueling floor O4cde , air flow prior to its exhaust to atmosphere. The signal from each detector is input to an individual monitor whose trip outputs are assigned to an isolation channel. Four channels of Reactor Building Vent Exhaust Plenum Radiation-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.

The Allowable Value is chosen to promptly detect gross failure of the fuel cladding.

The Reactor Building Vent Plenum Exhaust Radiation-High Function is required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists; thus, there is a probability of pipe breaks resulting in significant releases of radioactive steam and gas. In MODES 4 and 5, the probability and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES; thus, this Function is not required. In addition, the i r "r t e OPER r RE OPDRVs and movement o irradiated fuel assemblies in th o y con am t ecause e apa ity o -detec-ting radiation relaases due to fu fa* ures (due to fuel uncoveryýýýM *mus 6 e ensure thatOTSno e xceeded.

4. Manual Initiation The Manual Initiation switch and push button channels introduce signals into the secondary containment isolation logic that are redundant to the automatic protective instrumentation channels, and provide manual isolation capability. There is no specific FSAR safety analysis that (continued)

Columbia Generating Station B 3.3.6.2-6 Revision 28

Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES APPLICABLE 4. Manual Initiation (continued)

SAFETY ANALYSES, LCO, and takes credit for this Function. It is retained for the APPLICABILITY overall redundancy and diversity of the secondary containment isolation instrumentation as required by the NRC approved licensing basis.

There are four switch and push buttons (with two channels per switch and push button) for the logic, two switch and push buttons per trip system. Eight channels of the Manual Initiation Function are available and arA OPERABLE in MODES 1, 2, and 3 and durin in i OPDRVs, and movement of irradiated fuel as4-ssem i-es secondary con-ainment, since these are the MODES and other specified conditions in which the Secondary Containment Isolation automatic Functions are required to be OPERABLE.

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the switch and push buttons.

ACTIONS A Note has been provided to modify the ACTIONS related to secondary containment isolation instrumentation channels.

Section 1.3, Completion Times, specifies that 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 that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable secondary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable secondary containment isolation instrumentation channel.

A.1 Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or (continued)

Columbia Generating Station B 3.3.6.2-7 Revision 28

Secondary Containment B 3.6.4.1 BASES APPLICABLE associated leakage rates assumed in the accident analysis, SAFETY ANALYSES and that fission products entrapped within the secondary (continued) containment structure will be treated by the SGT System prior to discharge to the environment.

Secondary containment satisfies Criterion 3 of References.

LCO An OPERABLE secondary containment provides a control volume into which fission products that bypass or leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, can be diluted and processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained.

APPLICABILITY ---- 0TE----------

O---

Handlin a cask/canist oaded with nt fuel, af tir ti cani er is seal we ed and leak t ed, is nt nsider(

Ibe movement o irradiated fu In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs).1 urip.- CnOR.

ALTERATIOTIS, or during movement of rradiated fuel assemblies in the secondary contai t.

(continued) exx-taa.r. -1 wy,+m-, -n me-P ý 11S Vlot er4Wt+e-J 8-n Columbia Generation Station B 3.6.4.1-2 V.

%am Ct V4 k3l Revision 28 GLC.C,%Cie

Secondary Containment

- B 3.6.4.1 BASES (continued)

ACTIONS A.I If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

B.1 and B.2 If the secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To "achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.I.Y Movement of\* radiated fuel assemblies in the secondary containment. CORE ALTERATIONS, and OPDRVs can be postulated to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environment. CORE ,LTERATIONS andQK vement oftirradiated fuel assemblies must be immediately suspended e/f secondary containment is inoperable.

Suspension of these activities shall not preclude completing an action that involves moving a component to a safe position. Also, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

(continued)

Columbia Generation Station B 3.6.4.1-3 Revision 28

Secondary Containment B.3.6.4.1 BASES ACTIONS C.1 .2 an C.3 (continued LCO 3.0. is not applica e while in MODEeor 5. However, since

  • radiated fuel s/sembly movement an occur in MODE 1 2, o 3, Required A ion C.1 has been odified by a Note st ing that LC0 .0.3 is not appl* able.

assemblie while in MODE 1, If moving rradiated fue IVassemblies while n MODE 4 or 5, LCO .0.3 would not s cify any action. f moving irradiate fuel

, or 3, the fuel m ement is I

indepen n of reacto Therefore in either case, inality to susp movement of irr lated fuel ass blies would not a sufficient rea n to require a reactor shutdown.

I I SURVEILLANCE "'_ýSR ý36. ý41 .

REOUIREMENTS This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under lepected wind conditions. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR was developed based on operating experience related to secondary containment vacuum variations during the applicable MODES and the low probability of a DBA occurring between surveillances.

Furthermore, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert- the operator to an abnormal secondary containment vacuum condition.

SR 3-6-4.-1 2 And SR .6.4 1 -

Verifying that secondary containment equipment hatches and each inner access door or each outer access door in each access opening are closed ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur. SR 3.6.4.1.2 also requires equipment hatches to be sealed. In this application, the term "sealed" has no connotation of leak tightness. Maintaining (continued)

Columbia Generation Station B 3.6.4.1-4 Revision 28

SCIVs B 3.6.4.2 BASES APPLICABILITY OPERABLE is not required in MODE 4 or 5, except for other (continued) situations under which significant releases of radioactive material can be postulated, such as during operatio*nkwth a odraining the reactor vessel (OPDRVs , i A or during movement of irradiatedd ue

.aem jes in the secondary containment. r ACTIONS The ACTIONS are modified by three Notes. The first Note allows penetration flow paths to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at the controls of the isolation device. In this way, the penetration can be rapidly isolated when the need for secondary containment isolation is indicated.

The second Note provides clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable SCIV. Complying with the Required Actions may allow for continued operation, and subsequent inoperable SCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The third Note ensures appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable SCIV.

A.1 and A.2 In the event that there are one or more penetration flow paths with one SCIV inoperable, the affected penetration flow path(s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criteria are a closed and de-activated automatic SCIV, a closed manual valve, and a blind flange. For penetrations isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available device to (continued)

Columbia Generating Station B 3.6.4.2-3 Revision 28

SCIVs B 3.6.4.2 BASES ACTIONS B.1 (continued) considering the time required to isolate the penetration and the low probability of a DBA, which requires the SCIVs to close, occurring during this short time.

The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of two penetrations.

C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.I , and D If any Required Action and associated Completion Time cannot be met, the plant must be placed in ýctthe LCO does not apply. If applicableLOTh ;tce movement of irradiated fuel assemblies 1ý containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release.

Actions t cotnue i1 UW S d (continued)

Columbia Generating Station B 3.6.4.2-5 Revision 28

SCIVs B 3.6.4.2 BASES f ".1 ACTIONS D.1, D.2, and D3 (continued) would not sp ify any action. I moving irradiated f assemblies hile in MODE 1, 2 or 3, the fuel movee t is indepen nt of reactor oper ions. Therefore, i either case./nability to suspe movement of irradia<ed fuel ass blies would not a sufficient reasonito require a reactor shutdown.

_ J SURVEILLANCE SR 3.6.4.2.1 REOUIREMENTS This SR verifies each secondary containment isolation manual valve and blind flange that is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position.

Since these SCIVs are readily accessible to personnel during normal unit operation and verification of their position is relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct positions.

Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these isolation devices, once they have been verified to be in the proper position, is low.

A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. These controls consist of stationing a dedicated operator at the (continued)

Columbia Generating Station B 3.6.4.2-6 Revision 28

SGT System B 3.6.4.3 BASES APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product (continued) release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System OPERABLE is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations w'th a ot t' I f raining the reactor vessel (OPDRVs ng C RE ERR N or during movement of irr~adiate*dfue secondary containment.

ACTIONS A.1 With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a DBA occurring during this period.

B.1 and B.2 If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Columbia Generating Station B 3.6.4.3-3 Revision 28

SGT System B 3.6.4.3 BASES ACTIONS C.I C.2.1,V-A /

(continued)-,

During movement of r " e ass m *n the secondary containmenCdOP TATIOSý,or during OPDRVs, when Required urd eted within the required Completion Time, the OPERABLE SGT subsystem should be immediately placed in operation. This Required Action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation will occur, and that any other failure would be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive placing th material to the secondary containment, thus I

" a " that

,t minimizes risk. If applicabl_ A*5 . cý'I),ovement of irradIated uel assemblies e 'uspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must t"* unti PD suI If movi g irradiated fuel as mblies while in MODE or 5, LCO .0.3 would not speci any action. If movi it adiated fuel mas assemb while in MODE 1, 2 or 3, the uel movement is in endent of reactor ope tions.

Therefore, in eit r case, inability to spend movement of

-irradiated fue assemblies would not b a sufficient reason to require a eactor shutdown.

If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactive release control function. Therefore, actions are required to enter LCO 3.0.3 immediately.

(continued)

Columbia Generating Station B 3.6.4.3-4 Revision 241

SGT System B 3.6.4.3 BASES ACTIONS E.1, E.2, and E.3 (continued)

_Yftun-Twc,ýýubsystems are linoperable, if applicable 4,44--ýýýjnovement of irradiated fuel assemblies in

"-ýe ý 6ntainment must be immediately suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must cDn.Li n nti :1,

ý:I' LCO 33.0.33 is nnot aa icable while in MODE E 4 4 or 5. However, n0e irradiated since ad a d uel assembly movement ca c a occur in MODE 1, cl 2, or 33, R 2s e u e d Action Requi A t E.1 has b n mo ed by a Note a jn tha stating t a LCO0 33.0.3 is not appl7eca ,,,pe e. f iIf moving dc00g 'Y-fuel irradiat u e taassemblies while iy60DE 4 or 5, LCO 3.0.3 would a t specify fy any an y action. jXmoving irradiated fuel I fuel ass blies 1 while in MODE 1, r ope tions. the j4r f

ý)r 3,Therefore,ur0 movement e

in e er

[i i d p dt p rtdependent of f reacto r ct0 Def riLti

ýý e m j rtr sI j case, inability ec toss su:s RKd' movement of irrad' n M f uel w u Id assemblies j would e i 11 not,-le sufficient su reason to equi e a 0rreactor shutdown.

SURVEILLANCE SR 3.6.4.3.1 REOUIREMENTS Operating (from the control room) each SGT subsystem for

> 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for > 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

(continued)

Columbia Generating Station B 3.6.4.3-5 Revision 241

INSERT A [B 3.6.4.1 -- LCO]

In addition, secondary containment must be maintained at a vacuum during normal operation to ensure secondary containment effluent is monitored. In the event that the normal secondary containment ventilation system is secured, secondary containment could become pressurized such that the maximum accident design basis pressure of >

0.25-inch vacuum water gauge on all surfaces of secondary containment is exceeded.

Therefore, operating the SGT System when the normal secondary containment ventilation system is secured provides assurance that secondary containment is operable.

INSERT - X (i.e., fuel that has occupied part of the critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

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