GO2-07-156, Supplement to License Amendment Request for Proposed Changes to Technical Specifications: Miscellaneous Administrative Changes Including Adoption of Approved TSTF Travelers 284, 479, and 485
| ML073180488 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/06/2007 |
| From: | Gambhir S Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-07-156 | |
| Download: ML073180488 (31) | |
Text
1i Sudesh K. Gambhir Technical Services ENERGYP.O.
Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@energy-northwest.com November 6, 2007 G02-07-156 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50O6 SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485
Reference:
Letter G02-07-112, dated July 30, 2007, SK Gambhir (EN) to NRC, "License Amendment Request for Proposed Changes to Columbia Technical Specifications: Miscellaneous Administrative Changes Including Adoption of Approved TSTF Travelers 284, 479, and 485"
Dear Sir or Madam:
In a letter dated July 30, 2007, Energy Northwest requested an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia) pursuant to 10 CFR 50.90, "Application for Amendment of License or Construction Permit" (Reference). The amendment request proposed various miscellaneous administrative changes to Columbia TS including the adoption of TS Task Force (TSTF) Traveler 479, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a." The proposed adoption of TSTF-479 would modify TS 5.5.6.b to indicate that there may be some non-standard frequencies utilized in the Inservice Testing (IST) program in which the provisions of SR 3.0.2 are applicable.
Energy Northwest has received feedback from the Nuclear Regulatory Commission (NRC) that while TSTF-479 has been approved, the plant specific adoption of TSTF-479 will require the addition of a caveat that SR 3.0.2 only apply to Frequencies in the IST Program of 2 years or less. The inclusion of this caveat was prepared and approved as TSTF-497, Revision 0.
This supplement to the original License Amendment Request (LAR) of July 30, 2007 proposes that the language in TSTF-497 be incorporated into TS 5.5.6.b.
4mo/
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Page 2 provides an evaluation of the supplemental adoption of TSTF-497. provides a replacement to marked-up page of the original submittal impacted by the adoption of TSTF-497. Attachment 3 provides a clean copy all pages within the scope of this amendment request.
Energy Northwest determined that the supplemental adoption of TSTF-497 does not change the conclusions from the original LAR that there are no significant hazards considerations and categorical exclusion from environmental review pursuant to the provision of 10 CFR 51.22(c)(9) is appropriate.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington State Official.
No new regulatory commitments are made as part of this supplement.
Should you have any questions or require additional information regarding this matter, please contact Mr. GV Cullen, Licensing Supervisor, at (509) 377-6105.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Re ctfully, Vice President, Technical Services Attachments:
- 1. Evaluation of Supplemental Change
- 2. Replacement Technical Specification Page (mark-up)
- 3. Clean Technical Specification Pages cc:
EE Collins - NRC RIV CF Lyon - NRC NRR NRC Sr. Resident Inspector - 988C RN Sherman -BPA - 1399 WA Horin - Winston & Strawn RR Cowley - WDOH JO Luce - EFSEC
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Page 1 of 3 Evaluation of Supplemental Change 1.0
Background
In letter G02-07-112, dated July 30, 2007, Energy Northwest requested an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia) pursuant to 10 CFR 50.90, "Application for Amendment of License or Construction Permit" (Reference 1). The amendment request proposed various miscellaneous administrative changes to Columbia TS including the adoption of TS Task Force (TSTF)
Traveler 479, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a." The adoption of TSTF-479 would incorporate changes to TS 5.5.6, "Inservice Testing Program" (Reference 2). Specifically, the adoption of TSTF-479 would revise TS 5.5.6 to indicate that the Inservice Testing (IST) Program shall include testing frequencies applicable to the American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance (ASME OM Code). In addition, TS 5.5.6.b would be revised to indicate that there may be some non-standard frequencies utilized in the IST program in which the provisions of Surveillance Requirement (SR) 3.0.2 are applicable.
TSTF-479 was approved by the Nuclear Regulatory Commission (NRC) in a letter dated December 6, 2005 (Reference 3).
Following its approval, the NRC concluded that TSTF-479 did not provide adequate justification for applying SR 3.0.2 to Frequencies specified in the IST Program as greater than 2 years. The NRC has indicated that they would not approve plant-specific amendments based on TSTF-479 without incorporating a caveat that SR 3.0.2 only apply to Frequencies in the IST Program of 2 years or less. The inclusion of this caveat to the TSTF-479 language was developed as TSTF-497, Revision 0, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less" (Reference 4). TSTF-497 was approved by the NRC in a letter dated October 4, 2006 (Reference 5).
This supplement to the original License Amendment Request (LAR) of July 30, 2007 proposes that the language in TSTF-497 be incorporated into TS 5.5.6.b.
2.0 PROPOSED CHANGE
In the July 30, 2007 LAR, Energy Northwest proposed that TS 5.5.6.b be revised to indicate that there may be some non-standard Frequencies utilized in the IST program in which the provisions of SR 3.0.2 are applicable. This was accomplished by proposing that TSTF 5.5.6.b be revised to state:
"The provisions of SR 3.0.2 are applicable to the above required Frequencies and other normal and accelerated Frequencies specified in the Inservice Testing Program for performing inservice testing activities;"
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Page 2 of 3 Adopting TSTF-497 would add the caveat that SR 3.0.2 would only apply to Frequencies specified in the IST Program as 2 years or less. This would be accomplished by revising TS 5.5.6.b to state (added language underlined):
"The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Test Program for performing inservice testing activities;"
This change is consistent with approved TSTF-497 and does not require an update to the TS Bases.
Adoption of TSTF-479, Revision 0 with the inclusion of the caveat proposed in TSTF-497 has been approved at other nuclear facilities. Amendments No. 222 and 228 to the Renewed Facility Operating Licenses for Point Beach Unit 1 and 2 respectively, were approved by the NRC in a letter dated June 8, 2006 (Reference 6). In these amendments, the caveat that SR 3.0.2 would only apply to IST Program Frequencies specified as 2 years or less was approved and is considered suitable precedent for Columbia's adoption of TSTF-497.
3.0 TECHNICAL ANALYSIS
This supplement to the July 30, 2007 LAR is an administrative change to the Columbia TS which modifies TS 5.5.6.b to remove the provisions that were deemed by the NRC to not be adequately justified in TSTF-479. As such, this administrative change does not require any technical analyses to support its justification outside of the basis for the proposed change as previously discussed.
4.0 REGULATORY ANALYSIS
The supplemental adoption of TSTF-497 is an administrative change. Energy Northwest determined that this administrative change does not alter the regulatory analysis of the original LAR including the statement of no significant hazards consideration. Specifically, the proposed change does not (i) involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) does not create the possibility of a new or different kind of accident from any accident previously evaluated, or (iii) involve a significant reduction in a margin of safety.
5.0 ENVIRONMENTAL CONSIDERATION
The supplemental adoption of TSTF-497 is an administrative change. Energy Northwest determined that this administrative change does not alter the conclusion of the environmental consideration in the original LAR. Specifically, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Page 3 of 3 types or significant increase in the amounts of any effluent 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.
6.0 REFERENCES
- 1. Letter G02-07-112, dated July 30, 2007, SK Gambhir (EN) to NRC, "License Amendment Request for Proposed Changes to Columbia Technical Specifications:
Miscellaneous Administrative Changes Including Adoption of Approved TSTF Travelers 284, 479, and 485."
- 2. TSTF-479, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," December 2, 2004.
- 3. Letter dated December 6, 2005, T.H. Boyce (NRC) to TSTF, "Status of TSTF 343, 479, 482, 485" (ML053460302).
- 4. TSTF-497, "Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less," July 12, 2006.
- 5. Letter dated October 4, 2006, T.J. Kobertz (NRC) to TSTF (ML0627803210).
- 6. Letter dated June 8, 2006, C.F. Lyon (NRC) to D.L. Koehl (NMC), "Point Beach Nuclear Plant, Units 1 and 2 - Issuance of Amendments Re: Inservice Testing Program (TAC Nos. MC8929 and MC8930)" (ML061280013).
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Replacement Technical Specification Page (mark-up)
TECHNICAL SPECIFICATION PAGE 5.5-6
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Inservice Testing Program (continued)
- b.
The provisions of SR 3.0.2 are applicable to the above and to other normal and required Frequencies for performing inservice testing accelerated Frequencies activities;
.c.
The provisions of SR 3.0.3 are applicable to inservice less in the Inservice testing activities; and Testing Program
- d.
Nothing in the ASME C ler*And Piessu.
VeelC sh construed to supersede the requirements of any TS.
5.5.7 Ventilation Filter Testing Program (VFTP)
The VFTP shall establish the required testing of Engineered Safety Feature (ESF) filter ventilation systems.
Tests described in Specification 5.5.7.a and 5.5.7.b shall be performed once per 24 months; after each complete or partial replacement of the HEPA filter train or charcoal adsorber filter; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.
Tests described in Specification 5.5.7.c shall be performed once per 24 months; after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.
Tests described in Specification 5.5.7.d and 5.5.7.e shall be performed once per 24 months.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below:
(continued)
Columbia Generating Station 5.5-6 Amendment No. 149,169 182
SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO COLUMBIA TECHNICAL SPECIFICATIONS: MISCELLANEOUS ADMINISTRATIVE CHANGES INCLUDING ADOPTION OF APPROVED TSTF TRAVELERS 284, 479, AND 485 Clean Technical Specification Pages TECHNICAL SPECIFICATION PAGES 1.4-1 1.4-2 1.4-3 1.4-4 1.4-5 1.4-6 1.4-7 1.4-8 3.1.5-2 3.4.1-2 3.5.1-5 3.5.2-4 3.7.1-2 3.8.1-3 3.8.2-3 5.5-5 5.5-6
Freq u e ncy 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.
DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Conditions for Operation (LCO).
An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.
The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, "Surveillance Requirement (SR)
Applicability."
The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.
Sometimes special situations dictate when the requirements of a Surveillance are to be met.
They are "otherwise stated" conditions allowed by SR 3.0.1.
They may be stated as clarifying Notes in the Surveillance, as part of the Surveillance, or both.
Situations where a Surveillance could be required (i.e.,
its Frequency could expire),
but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts.
To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed.
With an SR satisfied, SR 3.0.4 imposes no restriction.
The use of "met" or "performed" in these instances conveys specified meanings.
A Surveillance is "met" only when the acceptance criteria are satisfied.
Known failure of the requirements of a Surveillance, even w)ithout a Surveillance specifically being "performed," constitutes a Surveillance not "met."
"Per formance" refers only to the requi rement to peci fical ly determine the ability to meet the acceptance criteria.
Some Survei 11 ances contain notes that mod ify the Frequency of performance or the conditions during wh I ch the (con Li nued ColI uiubi a Genera t I no Stati)
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Frequency 1.4 1.4 Frequency DESCRIPTION (Conti nUed) acceptance criteria must be satisfied.
For these Surveillances, the MODE-entry restrictions of SR 3.0.4 may not apply.
Such a Surveillance is not required to be performed prior to entering a MODE or other specified condition in the Applicability of the associated LCO if any of the following three conditions are satisfied:
- a.
The Surveillance is not required to be met in the MODE or other specified condition to be entered; or
- b.
The Surveillance is required to be met in the MODE or' other specified condition to be entered, but has been performed within the specified Frequency (i.e., it is current) and is known not to be failed; or
- c.
The Surveillance is required to be met, but not performed, in the MODE or other specified condition be entered, and is known not to be failed.
Examples 1.4-3, 1.4-4, 1.4-5, and 1.4-6 discusses these special situations.
to EXAMPLES The following examples illustrate the various ways that Frequencies are speci fi ed.
In these examples, the Applicability of the LCO (LCO not shown) is MODES 1,
2, and 3.
EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVE I LLANCE FREOUENCY Perform CHANNEL CHECK.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Fxample 1.4-1 contains the type of SR most often encountered in the Technical Specifications (US).
Fhe Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveil lance nuslt be performed at 1east one time.
( con ti n u ed )
Co Iumb i a Generat i n: Sta ti on I. 4 - 1 I] L No. 4 1 q. 1. ý 9
Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-1 (continued)
Performance of the Surveillance initiates the subsequent interval.
Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility.
The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO).
If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable.
If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable.
The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.
EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits.
Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after
> 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter (continued)
Columbia Generating Station 1.4-3 Amendment No.
449-74-ý,'ý
F req ue ncy 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 (continued)
Example 1.4-2 has two Frequencies.
The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1.
The logical connector "AND" indicates that both Frequency requirements must be met.
Each time reactor power is increased from a power level < 25% RTP to
> 25% RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").
This type of Frequency does not qualify for the extension allowed by SR 3.0.2.
"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e.. the "once" performance in this example).
If reactor power decreases to < 25% RTP, the measurement of both intervals stops.
New intervals start upon reactor power reaching 25% RTP.
EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY NOTE----------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after > 25% RTP.
Perform channel adjustment.
7 days The interval continues whether or not the
< 25% RTP between performances.
unit operation is (conti nued)
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Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency."
Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches > 25% RTP to perform the Surveillance.
The Surveillance is still considered to be within the "specified Frequency."
Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2),
but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO.
- Also, no violation of SR 3.0.4 occurs when changing
- MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power > 25% RTP.
Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance.
If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
NOTE----------------
Only required to be met in MODE 1.
Verify leakage rates are within limits.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-4 specifies that the requirements of this Surveil lance do not have to be met until the unit is in MODE I.
The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1.
- However, the Note const i tutes an "otherwi se stated" excepti on to the Appl i cabi 1 i ty of1 this Survei 1 ance.
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- 1..4 - 5 Ampndm,ýn t, No.
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Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-4 (continued)
Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2),
but the unit was not in MODE 1, there would be no failure of the SR nor failure to meet the LCO.
Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met),
SR 3.0.4 would require satisfying the SR.
EXAMPLE 1.4-5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
NOTE---------------
Only required to be performed in MODE 1.
Perform complete cycle of the valve.
7 days The interval continues, whether or not the unit operation is in MODE 1, 2, or 3 (the assumed Applicability of the associated LCO) between performances.
As the Note modifies the required performance of the Surveillance, the Note is construed to be part of the "specified Frequency."
Should the 7 day interval be exceeded while operation is not in MODE 1, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance.
The Surveillance is still considered to be performed within the "specified Frequency" if completed prior to entering MODE 1.
Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was not in MODE 1, it would not constitute a failure of the SR or failure to meet the LCO.
Also no (continued)
Columbia Generating Station 1.4-6 Amendment No.
Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-5 (continued) violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not result in entry into MODE 1.
Once the unit reaches MODE 1, the requirement for the Surveillance to be performed within its specified Frequency applies and would require that the Surveillance had been performed.
If the Surveillance were not performed prior to entering MODE 1, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
EXAMPLE 1.4-6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY NOTE-----------------
Not required to be met in MODE 3.
Verify-parameteris-within-limit...24.hou Verify parameter is within limits.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-6 specifies that the requirements of this Surveillance do not have to be met while the unit is in MODE 3 (the assumed Applicability of the associated LCO is MODES 1, 2, and 3).
The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1.
However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.
Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2),
and the unit was in MODE 3, there would be no failure of the SR nor failure to meet the LCO.
Therefore, no violation of SR 3.0.4 occurs when changing MODES to enter MODE 3, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency (continued)
Columbia Generatinq Sli*ution
- 1..4-7 Amendment No.
Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-6 (continued)
- exceeded, provided the MODE change does not result in entry into MODE 2.
Prior to entering MODE 2 (assuming agin that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met),
SR 3.0.4 would require satisfying the SR.
Columbia Generafing S La. tion
- 1. d-8 Amendment No.
Control Rod Scram Accumulators 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Control Rod Scram Accumulators LCO
3.1.5 APPLICABILITY
Each control rod scram accumulator shall be OPERABLE.
MODES 1 and 2.
ACTIONS Separate Condition entry is allowed
.- NOTE--------------------------------
for each control rod scram accumulator.
CONDITION f
REQUIRED ACTION COMPLETION TIME A.
One control rod scram accumulator inoperable with reactor steam dome pressure
> 900 psig.
A.1 OR NOTE--------
Only applicable if the average scram times of the two-by-two arrays associated with the control rod with the inoperable accumulator are within the limits of Table 3.1.4-1 during the last scram time Surveillance.
Declare the average scram time in all two-by-two arrays associated with the control rod with the inoperable accumulator not within the limits of Table 3.1.4-1 and declare the associated control rod "slow."
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)
I
.1.
Columbia Generating Station 3.1.5-1 Amendment No. 4-44 1691
Control Rod Scram Accumul ators 3.1.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2 Declare the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated control rod inoperable.
B.
Two or more control rod scram accumulators inoperable with reactor steam dome pressure > 900 psig.
B. I Restore charging water header pressure to > 940 psig.
AND B.2.1 NOTE--------
Only applicable if the average scram times of the two-by-two arrays associated with the control rod with the inoperable accumulator are within the limits of Table 3.1.4-1 during the last scram time Surveillance.
Declare the average scram time in all two-by-two arrays associated with the control rod with the inoperable accumulator not within the 1 imits of Table 3.1.4-I and declare the associated control rod "slow."
OR 20 minutes from discovery of Condition B concurrent with charging water header pressure
< 940 psig I hour I
(continued) 3. 1
. 5 Ainedl)maent t o.
Pin.
49
Recirculation Loops Operating 3.4.1 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 Recirculation Loops Operating LCO 3.4.1 Two recirculation loops with matched flows shall be in operation.
O R I
I One recirculation loop shall be in operation provided that the following limits are applied when the associated LCO is applicable:
- a.
LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR),"
single loop operation limits specified in the COLR; and
- b.
LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR),"
single loop operation limits specified in the COLR.
APPLICABILITY:
MODES 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Recirculation loop A.1 Declare the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> flow mismatch not recirculation loop within limits, with lower flow to be "not in operation."
B.
Requirements of the B.1 Satisfy the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LCO not met for requirements of the reasons other than LCO.
Condition A.
(continued)
Columbia Generating Station 3.4.1-1 Amendment No. 149,169 171
Recirculation Loops Operating 3.4.1 CONDITION REQUIRED ACTION COMPLETION TIME 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 or B not met.
OR No recirculation loops in operation.
SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.4.1.1
NOTE------------------
Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after both recirculation loops are in operation.
Verify recirculation loop drive flow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mismatch with both recirculation loops in operation is:
- a.
K 10% of rated recirculation loop drive flow when operating at < 70% of rated core flow; and
- b.
< 5% of rated recirculation loop drive flow when operating at > 70% of rated core flow.
I Columb ia GeneratLing Stat;ion 3.4. 1-2 Amendment No, 149,090147
ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.4 Verify each ECCS pump develops the specified flow rate with the specified differential pressure between reactor and suction source.
In accordance with the Inservice Testing Program SYSTEM LPCS LPCI HPCS FLOW RATE 6350 gpm 7450 gpm 6350 gpm DIFFERENTIAL PRESSURE BETWEEN REACTOR AND SUCTION SOURCE 128 psid 26 psid 200 psid SR 3.5.1.5 NOTE--------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem 24 months actuates on an actual or simulated automatic initiation signal.
NOTE-----------------
Valve actuation may be excluded.
Verify the ADS actuates on an actual or 24 months simulated automatic initiation signal.
(continued)
Columbia Generating Station 3.5.1 -5 Amendment No. +44-0-04
ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.7
NOTE-------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify each required ADS valve opens when manually actuated.
24 months on a STAGGERED TEST BASIS for each valve solenoid SR 3.5.1.8 NOTE-------------------
ECCS actuation instrumentation is excluded.
Verify the ECCS RESPONSE TIME for each ECCS 24 months injection/spray subsystem is within limits.
Columbia Generating Station 3.5.1-6 Amendment No. 149,IS9 1691
ECCS -Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> injection/spray subsystem, the suppression pool water level is
> 18 ft 6 inches.
SR 3.5.2.2 Verify, for the required High Pressure Core 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Spray (HPCS)
System, the:
- a.
Suppression pool water level is
> 18 ft 6 inches; or
- b.
Condensate storage tank (CST) water level is > 14.8 ft in a single CST or
> 9.1 ft in each CST.
SR 3.5.2.3 Verify, for each required ECCS injection/
31 days spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.
SR 3.5.2.4 NOTE-------------------
One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat
- removal, if capable of being manually realigned and not otherwise inoperable.
Verify each required ECCS injection/spray 31 days subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in
- position, is in the correct position.
(continued)
Columbia Generating Station 3.5.2-3 Amendment No.
149,159,16SC 1691
ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the specified flow rate with the specified differential pressure between reactor and suction source.
In accordance with the Inservice Testing Program DIFFERENTIAL PRESSURE BETWEEN REACTOR AND SUCTION SOURCE
> 128 psid
> 26 psid
> 200 psid SYSTEM LPCS LPCI HPCS FLOW RATE
> 6350 gpm
> 7450 gpm
> 6350 gpm SR 3.5.2.6 NOTE-------------------
Vessel injection/spray may be excluded.
Verify each required ECCS injection/spray 24 months subsystem actuates on an actual or simulated automatic initiation signal.
Columbi a Generting Station 3.5.2-4 Amendment No.
1ý9,159,161ý
SW System and UHS 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Standby Service Water (SW)
System and Ultimate Heat Sink (UHS)
LCO
3.7.1 APPLICABILITY
Division 1 and 2 SW subsystems and UHS shall be OPERABLE.
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Average sediment depth A.1 Restore average 30 days in one or both spray sediment depth to ponds > 0.5 ft and within limits.
< 1.0 ft.
(continued)
Columbia Generating Station 3.7.1-1 Amendment No. +44 1691
SW System and UHS 3.7.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.
One SW subsystem B.1
NOTES-------
- 1.
Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating,"
for diesel generator made inoperable by SW System.
- 2.
Enter applicable Conditions and Required Actions of LCO 3.4.9, "Residual Heat Removal (RHR)
Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling subsystem made inoperable by SW System.
Restore SW subsystem 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to OPERABLE status.
(continued)
I Col umbi a Generati ng Stati on 3.7. 1-2 I cn i oc'.
AmendmenL No.
- 149, V, I,,
AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.
(continued)
B.2 Declare required feature(s), supported by the inoperable DG, inoperable when the redundant required feature(s) are inoperable.
AND B.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).
AND B.4.1 Restore required DG to OPERABLE status.
OR 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours if not performed within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 72 hours from discovery of an inoperable DG AND 6 days from discovery of failure to meet LCO (continued)
I I
Columbia Generating Station 3.8.1-3 Amendment No.
149,169,19,*197
AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.
(continued)
B.4.2.1 Establish risk 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> management actions for the alternate AC sources.
AND B.4.2.2 Restore required DG 14 days to OPERABLE status.
AND 17 days from discovery of failure to meet LCO C.
Two offsite circuits C.1 Declare required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from inoperable, feature(s) inoperable discovery of when the redundant Condition C required feature(s) concurrent with are inoperable.
inoperability of redundant required feature(s)
AND C.2 Restore one offsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> circuit to OPERABLE status.
(continued)
Columbia Generating Station 3.8.1-4 Amendment No. 149,169 197
AC Sources Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
Required Division 3 DG C.1 Declare High Pressure 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable.
Core Spray System inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 NOTE------------------
The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19.
For AC sources required to be OPERABLE, In accordance the SRs for Specification 3.8.1 except SR with applicable 3.8.1.8, SR 3.8.1.17, and SR 3.8.1.20, SRs are applicable Columbia Generating Station 3.8.2-3 Amendment No. 149,169,199,
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.4 5.5.5 Radioactive Effluent Controls Program (continued)
- 1.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.
Component Cyclic or Transient Limit This program provides controls to track the FSAR, Table 3.9-1, Note 1, cyclic and transient occurrences to ensure that components are maintained within the design limits.
Inservice Testina Proaram 5.5.6 This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 pumps and valves.
- a.
Testing Frequencies applicable to the ASME Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as follows:
ASME OM Code and applicable Addenda terminology for inservice testing activities I
Required Frequencies for performing inservice testinq activities Weekly Monthi y Quarterly or every 3 months Semiannually or every 6 months Every 9 months Yearly or annually Biennially or every 2 years At least once per At least once per 7 days 31 days At least once per 92 days At At At least least least once once once per 184 days per 276 days per 366 days At least once per 731 days (cont in ue d)
Columbia Generating Station 5.5-5 Amendment No.
47iP,-, 4-ýý,
-ý
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Inservice Testing Program (continued)
- b.
The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities;
- c.
The provisions of SR 3.0.3 are applicable to inservice testing activities; and
- d.
Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.
5.5.7 Ventilation Filter Testing Program (VFTP)
The VFTP shall establish the required testing of Engineered Safety Feature (ESF) filter ventilation systems.
Tests described in Specification 5.5.7.a and 5.5.7.b shall be performed once per 24 months; after each complete or partial replacement of the HEPA filter train or charcoal adsorber filter; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.
Tests described in Specification 5.5.7,c shall be performed once per 24 months; after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.
Tests described in Specification 5.5.7.d and 5.5.7.e shall be performed once per 24 months.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flowrate specified below:
(continued)
Columbia Generating Station 5.5-6 Amendment No.