GO2-10-116, Supplemental Information in Support of License Amendment Request Regarding Control Rod Operability and Control Rod Scram Accumulators

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Supplemental Information in Support of License Amendment Request Regarding Control Rod Operability and Control Rod Scram Accumulators
ML102360439
Person / Time
Site: Columbia 
Issue date: 08/17/2010
From: Oxenford W
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-10-116
Download: ML102360439 (12)
v • d • e


Text

,

I W. Scott Oxenford Columbia Generating Station ENERGY RiW.

Box 968, Richland, WA 99352-0968 Ph. 509.377.4300 1 F. 509.377.4150 soxenford @ energy-northwest.com August 17, 2010 G02-10-116 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENTAL INFORMATION IN SUPPORT OF LICENSE AMENDMENT REQUEST REGARDING CONTROL ROD OPERABILITY AND CONTROL ROD SCRAM ACCUMULATORS

Reference:

1) Letter G02-10-024 dated February 8, 2010, WS Oxenford (Energy Northwest) to NRC, "License Amendment Request to Change Technical Specifications Relating to Control Rod Operability and Control Rod Scram Accumulators," (ADAMS Accession No. ML100490749)

Dear Sir or Madam:

By Reference 1, Energy Northwest submitted a License Amendment Request (LAR) for changes to the Columbia Generating Station (CGS) Technical Specifications (TS) involving Control Rod Operability and Control Rod Scram Accumulators. Via email, the NRC identified some discrepancies in how the effects of repagination were captured in the retyped TS pages.

This supplement provides the justification and corrections for the retyped TS pages. The enclosure to this letter contains all of the retyped TS (and Operating License) pages in support of the LAR.

Specific changes to the retyped TS pages previously submitted include the following:

With the proposed changes to LCO 3.1.3, the information that previously was contained on TS pages 3.1.3-1 through 3.1.3-4, is now reflected on proposed TS pages 3.1.3-1 through 3.1.3-3. Consistent with this repagination, current TS page 3.1.3-5 will be renumbered to TS page 3.1.3-4, and TS page 3.1.3-5 will be removed from the TS.

SUPPLEMENTAL INFORMATION IN SUPPORT OF LICENSE AMENDMENT REQUEST REGARDING CONTROL ROD OPERABILITY AND CONTROL ROD SCRAM ACCUMULATORS Page 2

" Proposed TS page 3.1.3-3 contains changes due to repagination, as indicated by a change bar at the bottom right hand corner of the page, vice the top of the page as previously submitted in Reference 1. The amendment 212 listing is also removed from this page, as the information listed on this page was not changed by that amendment.

Amendment No. 205 is indicated as crossed out on the bottom of TS page 3.1.5-2.

" Proposed TS page 3.1.5-3 contains changes due to repagination, as indicated by a change bar at the bottom right hand corner of the page, vice the top of the page as previously submitted in Reference 1.

The information contained in this supplement does not impact the original determination of no significant hazards. There are no new commitments contained in this letter.

If you have any questions or require additional information, please contact DW Gregoire at 509-377-8616.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, W-g Oxen Vice Pre ident, Nuc eneration & Chief Nuclear Officer

Enclosure:

Retyped Operating License and Technical Specification Pages cc:

NRC Region IV Administrator NRC Project Manager NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn JO Luce - EFSEC RR Cowley - WDOH

SUPPLEMENTAL INFORMATION IN SUPPORT OF LICENSE AMENDMENT REQUEST REGARDING CONTROL ROD OPERABILITY AND CONTROL ROD SCRAM ACCUMULATORS Enclosure Retyped Operating License and Technical Specification Pages Operating License page 9b Technical Specification pages 3.1.3-2 3.1.3-3 (pagination change only) 3.1.3-4 (pagination change only) 3.1.5-1 3.1.5-2 3.1.5-3 (pagination change only) 3.7.3-3 5.5-13

- 9b -

(b)

The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from November 6, 2003, the date of the most recent successful tracer gas test, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 24 months, plus the 184 days allowed by SR 3.0.2, as measured from March 23, 2006, the date of the most recent successful pressure measurement test, or within 184 days if not performed previously.

Amendment No.

2--ý

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.3 Perform SR 3.1.3.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from for each withdrawn discovery of OPERABLE control rod.

Condition A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND A.4 Perform SR 3.1.1.1.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.

Two or more withdrawn 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 /> control rods stuck.

C.

One or more control C.1

NOTE--------

rods inoperable for RWM may be bypassed reasons other than as allowed by Condition A or B.

LCO 3.3.2.1, if required, to allow insertion of inoperable control rod and continued operation.

Fully insert 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> inoperable control rod.

AND C.2 Disarm the associated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CRD.

(continued)

Columbia Generating Station 3.1.3-2 Amendment No. 149,169,2121

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. ----------

NOTE ----------

D.1 Restore compliance 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Not applicable when with BPWS.

THERMAL POWER

> 10% RTP.

OR D.2 Restore control rod 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Two or more inoperable to OPERABLE status.

control rods not in compliance with banked position withdrawal sequence (BPWS) and not separated by two or more OPERABLE control rods.

E.

NOTE---------

E.1 Restore the control 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Not applicable when rod to OPERABLE THERMAL POWER status.

> 10% RTP.

One or more groups with four or more inoperable control rods.

F.

Required Action and F.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, C, D, or E not met.

OR Nine or more control rods inoperable.

Columbia Generating Station 3.1.3-3 Amendment No. 149,169 1

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.1.3.2 NOTE--------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least 31 days one notch.

SR 3.1.3.3 Verify each control rod scram time from In accordance fully withdrawn to notch position 5 is with

< 7 seconds.

SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR 3.1.3.4 Verify each control rod does not go to the Each time the withdrawn overtravel position.

control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling Columbia Generating Station 3.1.3-4 Amendment No.

149,1CD,212E I

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

Separate Condition entry is allowed for each control rod scram accumulator.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One control rod scram A.1

NOTE--------

accumulator inoperable Only applicable ifý with reactor steam the associated dome pressure control rod scram

> 900 psig.

time was within the limits of Table 3.1.4-1 during the last scram time Surveillance.

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 scram time "slow."

OR 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.

(continued)

Columbia Generating Station 3.1.5-1 Amendment No. 149,169,29S,

Control Rod Scram Accumulators 3.1.5 ACTIONS CONDITION IREQUIRED ACTION COMPLETION TIME B.

Two or more control rod scram accumulators inoperable with reactor steam dome pressure > 900 psig.

B.1 Restore charging water header pressure to > 940 psig.

AND B.2.1 NOTE--------

Only applicable if the associated control rod scram time was within the limits of Table 3.1.4-1 during the last scram time Surveillance.

Declare the associated control rod scram time "sl ow."

OR B.2.2 Declare the associated control rod inoperable.

20 minutes from discovery of Condition B concurrent with charging water header pressure

< 940 psig 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 hour (continued)

Columbia Generating Station 3.1.5-2 Amendment No. 149,169,285,

Control Rod Scram Accumulators 3.1.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more control C.1 Verify the associated Immediately upon rod scram accumulators control rod is fully discovery of inoperable with

inserted, charging water reactor steam dome header pressure pressure < 900 psig.

< 940 psig AND C.2 Declare the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> associated control rod inoperable.

D.

Required Action B.1 or D.1

NOTE--------

C.1 and associated Not applicable if all Completion Time not inoperable control met.

rod scram accumulators are associated with fully inserted control rods.

Place the reactor Immediately mode switch in the shutdown position.

Columbia Generating Station 3.1.5-3 Amendment No. 149,169 1

CREF System 3.7.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

Two CREF subsystems F.1 Initiate action to Immediately inoperable during suspend OPDRVs.

OPDRVs.

OR One or more CREF subsystems inoperable due to inoperable CRE boundary during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREF subsystem for > 10 31 days continuous hours with the heaters operating.

SR 3.7.3.2 Perform required CREF filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

(continued)

Columbia Generating Station 3.7.3-3 Amendment No.

149, 1691.,

199,27

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Battery Monitoring and Maintenance Program (continued)

b.

Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates; and

c.

Actions to verify that the remaining cells are > 2.07 V when a cell or cells have been found to be < 2.13 V.

5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE)

Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE, Control Room Emergency Filtration (CREF)

System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.

The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a.

The definition of the CRE and the CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

(continued)

I Columbia Generating Station 5.5-13 Amendment No. 294,29ý

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