ML14195A262
| ML14195A262 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/09/2014 |
| From: | Linda Williams Energy Northwest |
| To: | Andrea George, Lyon F Division of Operating Reactor Licensing |
| References | |
| MF2863, MF3673 | |
| Download: ML14195A262 (40) | |
Text
1 NRR-PMDAPEm Resource From:
Williams, Lisa L. [llwilliams@energy-northwest.com]
Sent:
Wednesday, July 09, 2014 2:40 PM To:
George, Andrea; Lyon, Fred
Subject:
RE: TSTF-493 RAI and link to LAR on scram discharge volume instruments Attachments:
GO2-14-076.pdf; Go2-14-103.pdf Submittals are attached From: Williams, Lisa L.
Sent: Wednesday, July 09, 2014 11:39 AM To: George, Andrea; Lyon, Fred
Subject:
TSTF-493 RAI and link to LAR on scram discharge volume instruments
- Annie, I have been thinking about the NRC comment regarding our RAI response to TSTF-493. In that RAI, the NRC requested the following:
Also, please provide a description of the methodology for calculating the LTSPs, As-Left Tolerance, and As-Found Tolerance based on the analytical limits This request is very similar to the RSI for the scram discharge volume (SDV) instruments:
provide a description of the methodology used to calculate the As-Left Tolerance (ALT), and As-Found Tolerance (AFT).
In our RAI response (made after the RSI response) we state:
Energy Northwest provided supplemental information regarding application of TSTF-493 Option A Surveillance notes to TS Table 3.3.1.1-1, Function 7, Scram Discharge Volume Water Level - High, in letter GO2-14-076 Pages 7 through 13 of the enclosure to that letter provided a description of the methodology used to determine the AFT, ALT, and LTSP for a proposed change to the instrumentation that fulfils Function 7.b in Table 3.3.1.1-1. The basic methodology described in that enclosure exemplifies the methodology used for calculating the AFTs, ALTs, and LTSPs for all the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2.
So, we are not linking the two submittals. We are merely referring the NRC staff to a previously submitted letter in which the methodology is described. We did this to avoid duplication of information which creates error-likely situations. Both of these questions deal with TSTF-493 and related methodology. The methodology is the same for calculating the as-found and as-left tolerances in both submittals. When submittals are linked it means that one submittal is relying on approval of another submittal currently under review (LIC-109). This is not the case for these two submittals. NRC staff reviewing TSTF-493 can state that a description of the methodology was provided under letter dated May 8, 2014. The methodology was reviewed and found to be xxx.
When responding to the RAI, Energy Northwest carefully considered whether to resubmit the methodology and decided that we would rather refer to the NRC to a previously submitted letter. This is still the case. So, I would ask that the NRC reconsider the request to resubmit the methodology as a separate response to the RAI. Thanks, Lisa Lisa L. Williams Licensing Supervisor
2 Energy Northwest Columbia Generating Station 509.377.8148
Hearing Identifier:
NRR_PMDA Email Number:
1425 Mail Envelope Properties (1A9664F6E486074BA0CCA69CF22E5900B0D962)
Subject:
RE: TSTF-493 RAI and link to LAR on scram discharge volume instruments Sent Date:
7/9/2014 2:40:25 PM Received Date:
7/9/2014 5:35:17 PM From:
Williams, Lisa L.
Created By:
llwilliams@energy-northwest.com Recipients:
"George, Andrea" <Andrea.George@nrc.gov>
Tracking Status: None "Lyon, Fred" <Fred.Lyon@nrc.gov>
Tracking Status: None Post Office:
SERVER153.domain1.energy-northwest.com Files Size Date & Time MESSAGE 2736 7/9/2014 5:35:17 PM GO2-14-076.pdf 1679793 Go2-14-103.pdf 2189640 Options Priority:
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Recipients Received:
Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.4150 aljavorik@energy-northwest.com GO2-14-103 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
Reference:
- 1. Letter, GO2-13-138, dated October 2, 2013, A. L. Javorik (Energy Northwest) to NRC, License Amendment Request for Adoption of TSTF-493, Revision 4, Option A
- 2. Letter, dated April 30, 2014, C. F. Lyon (NRC) to ME Reddemann (Energy Northwest), Columbia Generating Station - Request for Additional Information related to License Amendment Request to Adopt TSTF-493, Revision 4, Option A (TAC No. MF2863)
Dear Sir or Madam:
By Reference 1, Energy Northwest requested approval of a license amendment request to revise the Technical Specifications (TS) by adding requirements to assess channel performance during testing that verifies instrument channel setting values established by the plant-specific setpoint methodologies. Attachment 1 to this letter documents a proposed change to the instrument Functions to be annotated with the TSTF-493 Surveillance Notes. The proposed change will remove the Surveillance Notes from TS Table 3.3.5.1-1 Functions 1.c, 1.d, 2.c, and 2.d and add the Surveillance Notes to TS Table 3.3.6.2-1 Function 1. Revised pages of the TS and TS Bases markups are provided in Attachments 2 and 3, respectively. Revised pages of TS (clean pages) are provided in Attachment 4.
Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information. Attachment 5 provides the response to the requested information.
This letter and its enclosures contain no regulatory commitments. If there are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.
June 19, 2014
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 3 PROPOSED CHANGE TO THE INSTRUMENT FUNCTIONS TO BE ANNOTATED WITH THE TSTF-493 SURVEILLANCE NOTES In Reference 1, Energy Northwest requested approval of a license amendment request to revise the Technical Specification (TS) by adding requirements to assess channel performance during testing that verifies instrument channel setting values established by the plant-specific setpoint methodologies. The proposed amendment incorporates Technical Specification Task Force (TSTF) Traveler TSTF-493-A (Reference 2)
Option A. Attachment 2 to Reference 1 provided the plant-specific evaluation identifying the list of instrument Functions to be annotated with the TSTF-493 Surveillance Notes.
Energy Northwest proposed to add Surveillance Notes to the following functions in Columbia Generating Station (Columbia) TS table for Emergency Core Cooling System instrumentation, Table 3.3.5.1-1:
1.c LPCS [Low Pressure Core Spray] Pump Start - LOCA [Loss of Coolant Accident] Time Delay Relay
1.d LPCI [Low Pressure Coolant Injection] Pump A Start - LOCA Time Delay Relay
2.c LPCI Pump B Start - LOCA Time Delay Relay
2.d LPCI Pump C Start - LOCA Time Delay Relay These Functions correspond to the following functions in NUREG-1434 Table 3.3.5.1-1:
1.c LPCI Pump A Start - Time Delay Relay
2.c LPCI Pump B Start - Time Delay Relay Each LOCA time delay relay channel for TS Table 3.3.5.1-1 Functions 1.c, 1.d, 2.c, and 2.d consists of Drywell Pressure - High, and Reactor Vessel Water Level - Low Low, Level 2 sensors, auxiliary relay logic, and circuit breaker position switches to initiate the LOCA time delay relay when on normal off site power. The Drywell Pressure - High sensor is the same sensor that provides input to the Reactor Protection System and, in accordance with Reference 1, will have Surveillance Notes applied to TS 3.3.1.1-1 Function 6. Thus, it meets the exclusion criteria provided in TSTF-493 which states that Surveillance Notes do not have to be applied to those permissives or interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function.
However, the Reactor Vessel Water Level - Low Low, Level 2 sensor that provides input to the LOCA time delay relays did not have Surveillance Notes applied in Reference 1. In order to meet the exclusion criteria provided in TSTF-493, Energy Northwest proposes to add Surveillance Notes to the Reactor Vessel Water Level - Low Low, Level 2 sensor that provides input to the LOCA time delay relays. These sensors are the same sensors that provide input to the Secondary Containment Isolation Instrumentation in TS Table 3.3.6.2-1 Function 1. Thus, Surveillance Notes will be
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 2 of 3 applied to TS Table 3.3.6.2-1 Function 1, similar to the Drywell Pressure - High sensor.
The TSTF-493 criteria for excluding Surveillance Notes for the LOCA time delay relays will therefore be met. Adding the Surveillance Notes to the actual sensors clarifies which portion of the relay channel the As Found Tolerance and As Left Tolerance should be applied to. This is consistent with the application of TSTF-493 Surveillance Notes to other TS functions.
Note that TS Table 3.3.5.1-1 also contains Functions for the LOCA/LOOP time delay relays. The LOCA/LOOP time delay relay channels consist of Reactor Vessel Water Level - Low Low Low, Level 1, Drywell Pressure - High sensors, auxiliary relay logic, circuit breaker position switches and power available relays. The Reactor Vessel Water Level - Low Low Low, Level 1 sensors and Drywell Pressure - High sensors for these relays are the same sensors to which Surveillance Notes have been applied in TS 3.3.5.1-1 Functions 1.a, 1.b, 2.a, and 2.b. The LOCA/LOOP time delay relays therefore meet the exclusion criteria provided in TSTF-493 and Surveillance Notes were not applied to these relays.
Applicability of Reference 1 Evaluation of Proposed Changes to Reference 1 provided an Evaluation of Proposed Changes for the original amendment request. Energy Northwest has reviewed the specific topics discussed in that attachment for applicability to the change proposed in this letter.
Energy Northwests review determined the following.
In Reference 1 Attachment 1, Energy Northwest stated that it was not proposing variations or deviations from the TS changes described in TSTF-493, Revision 4 or the model SE. The discussion in Reference 1 Attachment 1 referenced Attachment 2 to that letter as providing a list of instrument Functions to be annotated with the TSTF-493 Surveillance Notes. Energy Northwest has determined that the discussion in Reference 1 Attachment 1 is also applicable to the changes proposed in this letter, with the following explanations:
The changes proposed in this letter include the addition of the two TSTF-493 Surveillance Notes to SR 3.3.6.2.3 for TS Table 3.3.6.2-1, Secondary Containment Isolation Instrumentation, Function 1, Reactor Vessel Water Level - Low Low, Level 2. Neither TSTF-493 Attachment A, Identification of Functions to be Annotated with the TSTF-493 Footnotes, nor the TSTF-493 Option A TS page markups include the addition of the two Surveillance Notes to the corresponding NUREG-1434 or NUREG-1433 TS. This variation or deviation from the TS changes described in TSTF-493 is acceptable because it is consistent with the Exclusion No. 1 on page 9 in Section 4.0, Technical Analysis of TSTF-493, which states:
In addition, the two Notes do not apply to those permissives and interlocks that derive input from a sensor or adjustable device that is tested as part of another TS function.
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 3 of 3 In conjunction with the addition of the two Surveillance Notes to SR 3.3.6.2.3 for TS Table 3.3.6.2-1 Function 1, application of this exclusion criteria permits deletion of the two Surveillance Notes from SR 3.3.5.1.5 for the LOCA time delay relays in TS Table 3.3.5.1-1 Functions 1.c, 1.d, 2.c, and 2.d.
Attachment 2 to Reference 1 will therefore no longer apply with respect to SR 3.3.5.1.5 for Functions 1.c, 1.d, 2.c, and 2.d in TS Table 3.3.5.1-1, or SR 3.3.6.2.3 for Function 1 in TS Table 3.3.6.2-1.
Additionally, Energy Northwests review has determined that all other aspects of the Evaluation of Proposed Changes in Reference 1 Attachment 1, including the sections titled No Significant Hazards Consideration Determination, Applicable Regulatory Requirements/Criteria and Environmental Considerations, remain valid and applicable to the changes proposed in this letter, References for this Attachment
- 1. Letter, GO2-13-138, dated October 2, 2013, AL Javorik (Energy Northwest) to NRC, License Amendment Request for Adoption of TSTF-493, Revision 4, Option A
- 2. Technical Specification Task Force (TSTF) Traveler TSTF-493-A, Revision 4, Clarify Application of Setpoint Methodology for LSSS Functions
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 1 Columbia Generating Station Revision to the Technical Specification Markup Pages Proposed in GO2-13-138
ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-6 Amendment No. 169,172 225 Table 3.3.5.1-1 (page 1 of 65)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- 1. Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)
Subsystems
- a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3, 4(a), 5(a) 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
-142.3 inches
- b.
Drywell Pressure --
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
1.88 psig
- c.
LPCS Pump Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
8.53 seconds and
10.64 seconds
- d.
LPCI Pump A Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
17.24 seconds and 21.53 seconds
- e.
LPCI Pump A Start -
LOCA/LOOP Time Delay Relay 1, 2, 3, 4(a), 5(a) 1 C
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6
3.04 seconds and
6.00 seconds
- f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
448 psig and
492 psig 4(a), 5(a) 1 per valve B
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
448 psig and
492 psig (a)
When associated subsystem(s) are required to be OPERABLE.
(b)
Also required to initiate the associated diesel generator (DG).
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1 and LCO 3.8.2.
(f)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(g)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
proposed footnotes (f) and (g) deleted
ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-7 Amendment No. 169,172 225 Table 3.3.5.1-1 (page 2 of 65)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- g.
LPCS Pump Discharge Flow -
Low (Minimum Flow) 1, 2, 3, 4(a), 5(a) 1 E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
668 gpm and
1067 gpm
- h.
LPCI Pump A Discharge Flow -
Low (Minimum Flow) 1, 2, 3, 4(a), 5(a) 1 E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
605 gpm and
984 gpm
- i.
Manual Initiation 1, 2, 3, 4(a), 5(a) 2 C
SR 3.3.5.1.6 NA
- a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3, 4(a), 5(a) 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
-142.3 inches
- b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
1.88 psig
- c.
LPCI Pump B Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
17.24 seconds and
21.53 seconds
- d.
LPCI Pump C Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
8.53 seconds and
10.64 seconds (a)
When associated subsystem(s) are required to be OPERABLE.
(b)
Also required to initiate the associated DG.
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1 and LCO 3.8.2.
(f)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(g)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
proposed footnotes (f) and (g) deleted
Secondary Containment Isolation Instrumentation 3.3.6.2 Columbia Generating Station 3.3.6.2-3 Amendment No. 172,199 225 Table 3.3.6.2-1 (page 1 of 1)
Secondary Containment Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- 1. Reactor Vessel Water Level - Low Low, Level 2 1, 2, 3, (a) 2(c)
SR 3.3.6.2.2 SR 3.3.6.2.3(d)(e)
-58 inches
- 2. Drywell Pressure - High 1, 2, 3 2(c)
SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4
1.88 psig
- 3. Reactor Building Vent Exhaust Plenum Radiation - High 1, 2, 3, (a) 2 SR 3.3.6.2.1 SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4
16.0 mR/hr
- 4. Manual Initiation 1, 2, 3, (a) 4 SR 3.3.6.2.4 NA (a)
During operations with a potential for draining the reactor vessel.
(b)
Deleted (c)
Also required to initiate the associated LOCA Time Delay Relay Function pursuant to LCO 3.3.5.1.
(d)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(e)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 1 Columbia Generating Station Revision to the Technical Specification Bases Markup Pages Proposed in GO2-13-138 (for reference only)
ECCS Instrumentation B 3.3.5.1 Columbia Generating Station B 3.3.5.1-35 Revision BASES SURVEILLANCE REQUIREMENTS (continued)
The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.
SR 3.3.5.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Frequency of 92 days is based on the reliability analyses of Reference 5.
SR 3.3.5.1.3, SR 3.3.5.1.4, and SR 3.3.5.1.5 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequencies are based upon the assumption of a 92 day, 18 month, or 24 month calibration interval, as applicable, in the determination of the magnitude of equipment drift in the setpoint analysis. For SR 3.3.5.1.3 and SR 3.3.5.1.5 there is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
SR 3.3.5.1.4 for designated functions is modified by two Notes as identified in Table 3.3.5.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective added
Secondary Containment Isolation Instrumentation B 3.3.6.2 Columbia Generating Station B 3.3.6.2-4 Revision 73 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
The Reactor Water Level-Low Low Level Function is also used to initiate the LOCA Time Delay Relays of LCO 3.3.5.1. A Note (c) is provided to Table 3.3.6.2-1 that identifies Function 1 channels provide one set of initiation signals to the LCO 3.3.5.1 LOCA Time Delay Relay function.
Since this Function is also used to initiate the LOCA Time Delay Relays of LCO 3.3.5.1, TSTF-493 footnotes have been applied to this Function in lieu of applying the footnotes to the LOCA Time Delay Relays themselves.
- 2. Drywell Pressure - High High drywell pressure can indicate a break in the reactor coolant pressure boundary (RCPB). An isolation of the secondary containment and actuation of the SGT System are initiated in order to minimize the potential of an offsite dose release. The isolation on high drywell pressure supports actions to ensure that any offsite releases are within the limits calculated in the safety analysis. However, the Drywell Pressure - High Function associated with isolation is not assumed in any FSAR accident or transient analysis. It is retained for the overall redundancy and diversity of the secondary containment isolation instrumentation as required by the NRC approved licensing basis. High drywell pressure signals are initiated from pressure switches that sense the pressure in the drywell. Four channels of Drywell - 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 was chosen to be the same as the RPS Drywell Pressure - High Function Allowable Value (LCO 3.3.1.1) since this is indicative of a loss of coolant accident.
The Drywell Pressure - High Function is required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists in the RCS; thus, there is a probability of pipe breaks resulting in significant releases of radioactive steam and gas. This Function is not required in MODES 4 and 5 because the probability and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES.
- 3. Reactor Building Vent Exhaust Plenum Radiation - High High secondary containment exhaust radiation is an indication of possible gross failure of the fuel cladding. The release may have originated from the primary containment due to a break in the RCPB or the refueling floor due to a fuel handling accident. When Reactor Building Vent Exhaust Plenum Radiation - High is detected, secondary containment isolation and actuation of the SGT System are initiated to limit the release of fission products (Ref. 1).
added
Secondary Containment Isolation Instrumentation B 3.3.6.2 Columbia Generating Station B 3.3.6.2-9 Revision 73 BASES SURVEILLANCE REQUIREMENTS (continued)
Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.
SR 3.3.6.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Frequency of 92 days is based upon the reliability analysis of References 4 and 5.
SR 3.3.6.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations, consistent with the plant specific setpoint methodology.
The Frequency is based upon the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.
Secondary Containment Isolation Instrumentation B 3.3.6.2 Columbia Generating Station B 3.3.6.2-10 Revision 73 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.3.6.2.3 for designated functions is modified by two Notes as identified in Table 3.3.6.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be within the as-left tolerance of the LTSP. Where a setpoint more conservative than the LTSP is used in the plant surveillance procedures (i.e., nominal trip setpoint, or NTSP), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the LTSP, then the channel shall be declared inoperable.
The second Note also requires that LTSP and the methodologies for calculating the as-left and the as-found tolerances be in the Licensee Controlled Specifications.
SR 3.3.6.2.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing, performed on SCIVs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
added
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 1 Columbia Generating Station Revision to the Revised (Clean) Technical Specification Pages Proposed in GO2-13-138
ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-6 Amendment No. 169,172 225 Table 3.3.5.1-1 (page 1 of 6)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- 1. Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)
Subsystems
- a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3, 4(a), 5(a) 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
-142.3 inches
- b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
1.88 psig
- c.
LPCS Pump Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
8.53 seconds and
10.64 seconds
- d.
LPCI Pump A Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
17.24 seconds and 21.53 seconds
- e.
LPCI Pump A Start -
LOCA/LOOP Time Delay Relay 1, 2, 3, 4(a), 5(a) 1 C
SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.6
3.04 seconds and
6.00 seconds
- f.
Reactor Vessel Pressure - Low (Injection Permissive) 1, 2, 3 1 per valve C
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
448 psig and
492 psig 4(a), 5(a) 1 per valve B
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
448 psig and
492 psig (a)
When associated subsystem(s) are required to be OPERABLE.
(b)
Also required to initiate the associated diesel generator (DG).
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1 and LCO 3.8.2.
(f)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(g)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
ECCS Instrumentation 3.3.5.1 Columbia Generating Station 3.3.5.1-7 Amendment No. 169,172 225 Table 3.3.5.1-1 (page 2 of 6)
Emergency Core Cooling System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- g.
LPCS Pump Discharge Flow -
Low (Minimum Flow) 1, 2, 3, 4(a), 5(a) 1 E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
668 gpm and
1067 gpm
- h.
LPCI Pump A Discharge Flow -
Low (Minimum Flow) 1, 2, 3, 4(a), 5(a) 1 E
SR 3.3.5.1.2 SR 3.3.5.1.4 SR 3.3.5.1.6
605 gpm and
984 gpm
- i.
Manual Initiation 1, 2, 3, 4(a), 5(a) 2 C
SR 3.3.5.1.6 NA
- a.
Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3, 4(a), 5(a) 2(b)
B SR 3.3.5.1.1 SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
-142.3 inches
- b.
Drywell Pressure -
High 1, 2, 3 2(b)
B SR 3.3.5.1.2 SR 3.3.5.1.4(f)(g)
1.88 psig
- c.
LPCI Pump B Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
17.24 seconds and
21.53 seconds
- d.
LPCI Pump C Start -
LOCA Time Delay Relay 1, 2, 3, 4(a), 5(a) 1(e)
C SR 3.3.5.1.5 SR 3.3.5.1.6
8.53 seconds and
10.64 seconds (a)
When associated subsystem(s) are required to be OPERABLE.
(b)
Also required to initiate the associated DG.
(e)
Also supports OPERABILITY of 230 kV offsite power circuit pursuant to LCO 3.8.1 and LCO 3.8.2.
(f)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(g)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
Secondary Containment Isolation Instrumentation 3.3.6.2 Columbia Generating Station 3.3.6.2-3 Amendment No. 172,199 225 Table 3.3.6.2-1 (page 1 of 1)
Secondary Containment Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
- 1. Reactor Vessel Water Level - Low Low, Level 2 1, 2, 3, (a) 2(c)
SR 3.3.6.2.2 SR 3.3.6.2.3(d)(e)
-58 inches
- 2. Drywell Pressure - High 1, 2, 3 2(c)
SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4
1.88 psig
- 3. Reactor Building Vent Exhaust Plenum Radiation - High 1, 2, 3, (a) 2 SR 3.3.6.2.1 SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4
16.0 mR/hr
- 4. Manual Initiation 1, 2, 3, (a) 4 SR 3.3.6.2.4 NA (a)
During operations with a potential for draining the reactor vessel.
(b)
Deleted (c)
Also required to initiate the associated LOCA Time Delay Relay Function pursuant to LCO 3.3.5.1.
(d)
If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(e)
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Limiting Trip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
Setpoints more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance. The LTSP and the methodologies used to determine the as-found and the as-left tolerances are specified in the Licensee Controlled Specifications.
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 3 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-493, Revision 4, Option A NRC Request:
- 1.
Please provide the Nominal Trip Setpoint and Limiting Trip Setpoint (LTSP) for the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2.
Also, please provide a description of the methodology for calculating the LTSPs, As-Left Tolerance, and As-Found Tolerance based on the analytical limits, where applicable.
Energy Northwest Response:
NTSP and LTSP for Functions that Will Include TSTF-493, Revision 4, Surveillance Notes 1 and 2.
The nominal trip setpoint (NTSP) and LTSP for the instrument Functions that will include the TSTF-493, Revision 4, Surveillance Notes are provided in Table 1 on the following pages. The calculations of the AFT and ALT values are still in progress.
Energy Northwest applies the AFT and ALT around the NTSP. In some cases, the values for the AFT and ALT require changes to the NTSP. For these cases, revisions to the NTSP are still in progress and will be processed using Energy Northwests setpoint change process. These cases are marked by TBD in the NTSP column.
Description of Methodology for Calculating the LTSPs, As-Left Tolerance, and As-Found Tolerance Based on the Analytical Limits Energy Northwest provided supplemental information regarding application of TSTF-493 Option A Surveillance notes to TS Table 3.3.1.1-1, Function 7, Scram Discharge Volume Water Level - High, in letter GO2-14-076, from A. L. Javorik (Energy Northwest) to the Nuclear Regulatory Commission (NRC), dated May 8, 2014. Pages 7 through 13 of the enclosure to that letter provided a description of the methodology used to determine the AFT, ALT, and LTSP for a proposed change to the instrumentation that fulfils Function 7.b in Table 3.3.1.1-1. The basic methodology described in that enclosure exemplifies the methodology used for calculating the AFTs, ALTs, and LTSPs for all the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2. Note that Energy Northwest utilizes the term maximum setting or minimum setting, as appropriate, synonymously with LTSP.
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 2 of 3 Table 1 TS or Table Fun.
Type Description Units TS Allowable Value Instruments LTSP NTSP 3.3.1.1-1 1.a RPS Intermediate Range Monitor Neutron Flux -
High divisions LE 122 IRM-EMSQ-601A-H 121.2 120 3.3.1.1-1 3
RPS Reactor Vessel Steam Dome Pressure - High psig LE 1079 MS-PS-23A-D 1063.1 TBD 3.3.1.1-1 4
RPS Reactor Vessel Water Level - Low, Level 3 inches GE 9.5 MS-LIS-24A-D 10.4 13.2 3.3.1.1-1 6
RPS Primary Containment Pressure - High psig LE 1.88 RPS-PS-2A,C,D 1.72 TBD RPS-PS-2B 1.79 TBD 3.3.1.1-1 7.a RPS Scram Discharge Volume Water Level - High n/a LE 529' 9" CRD-LIS-601A-D 529' 7.68" 529' 7"
3.3.1.1-1 9
RPS Turbine Governor Valve Fast Closure, Trip Oil Pressure - Low psig GE 1000 RPS-PS-5A-D 1171 1252 3.3.4.1.2 b
EOC-RPT Turbine Governor Valve Fast Closure, Trip Oil Pressure - Low psig GE 1000 RPS-PS-5A-D 1171 1252 3.3.5.1-1 1.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE
-142.3 MS-LIS-37A,C
-139.2
-127.7 3.3.5.1-1 1.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-48A,C 1.75 1.65 3.3.5.1-1 2.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE
-142.3 MS-LIS-37B,D
-139.2
-127.7 3.3.5.1-1 2.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-48B 1.72 1.65 MS-PS-48D 1.75 1.65 3.3.5.1-1 3.a ECCS Reactor Vessel Water Level - Low Low, Level 2
inches GE
-58 MS-LIS-31A-D
-55.1
-49.5 3.3.5.1-1 3.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-47A-D 1.72 1.65 3.3.5.1-1 3.c ECCS Reactor Vessel Water Level - High, Level 8 inches LE 56 MS-LIS-100A,B 55.1 54.3 3.3.5.1-1 3.f ECCS HPCS System Flow Rate - Low (Minimum Flow) gpm GE 1200 HPCS-FIS-6 1223 1277 gpm LE 1512 1493 1362 3.3.5.1-1 4.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE
-142.3 MS-LIS-37A,C
-139.2
-127.7 3.3.5.1-1 4.c ECCS Reactor Vessel Water Level - Low, Level 3 (Permissive) inches GE 9.5 MS-LIS-38A 10.4 13.2 3.3.5.1-1 4.f ECCS Accumulator Backup Compressed Gas System Pressure - Low psig GE 151.4 CIA-PS-21A 154 160 CIA-PS-22A 154 156 CIA-PS-39A 154 160
PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 3 of 3 TS or Table Fun.
Type Description Units TS Allowable Value Instruments LTSP NTSP 3.3.5.1-1 5.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE
-142.3 MS-LIS-37B,D
-139.2
-127.7 3.3.5.1-1 5.c ECCS Reactor Vessel Water Level - Low, Level 3 (Permissive) inches GE 9.5 MS-LIS-38B 10.4 13.2 3.3.5.1-1 5.e ECCS Accumulator Backup Compressed Gas System Pressure - Low psig GE 151.4 CIA-PS-21B 154 160 CIA-PS-22B 154 156 CIA-PS-39B 154 160 3.3.5.2-1 1
RCIC Reactor Vessel Water Level - Low Low, Level 2
inches GE
-58 MS-LIS-37A-D
-55.1
-49.5 3.3.5.2-1 2
RCIC Reactor Vessel Water Level - High, Level 8 inches LE 56 MS-LIS-24B,D 55.1 54.3 3.3.6.2-1 1
SCII Reactor Vessel Water Level - Low Low, Level 2
inches GE
-58 MS-LS-300A-D
-52.5
-50 ECCS = emergency core cooling system LE = less than or equal to EOC-RPT = end of cycle recirculation pump trip GE = greater than or equal to RCIC = reactor core isolation and cooling TBD = to be determined RPS = reactor protection system SCII = secondary containment isolation instrumentation