View source for GO2-20-108, License Amendment Request to Adopt TSTF-439, Elinate Second Completion Times Limitng Time from Discovery of Failure to Meet an LCO

{{Adams
| number = ML20337A141
| issue date = 12/02/2020
| title = License Amendment Request to Adopt TSTF-439, Elinate Second Completion Times Limitng Time from Discovery of Failure to Meet an LCO
| author name = Schuetz R
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000397
| license number = 
| contact person = 
| case reference number = GO2-20-108
| document type = Letter type:GO, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 37
| project = 
| stage = Request
}}

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ENERGY Robert E. Schuetz Site Vice President P.O. Box 968, Mail Drop PE23 NORTHWEST                                                           Richland, WA 99352-0968 Ph. 509-377-2425 F. 509-377-4674 reschuetz@energy-northwest.com December 2, 2020 GO2-20-108 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 LICENSE AMENDMENT REQUEST TO ADOPT TSTF-439, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO

==Dear Sir or Madam:==

Pursuant to 10 CFR 50.90, Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia).
The proposed amendment is consistent with previously NRC-approved Technical Specifications Task Force Traveler 439 (TSTF-439), Eliminate Second Completion Times Limiting Time from Discovery of Failure to meet an LCO, Revision 2.
Enclosure 1 provides a description and assessment of the proposed changes.
Enclosure 2 provides the existing TS pages marked up to show the proposed changes.
Enclosure 3 provides, for information only, existing TS Bases pages marked to show the proposed changes.
Enclosure 4 provides revised (clean) TS pages.
This letter and its enclosures contain no regulatory commitments.
Approval of the proposed amendment is requested within one year of the date of the submittal. Once approved, the amendment shall be implemented within 90 days.
In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.

 
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GO-20-108 Page 2 If there are any questions, or if additional information is needed, please contact Mr.
R.M. Garcia, Licensing Supervisor, at 509-377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
                                                   
Executed this ______         day of ___________, 2020.
Respectfully, R.E. Schuetz Site Vice President

==Enclosures:==
As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH

 
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GO-20-108 Enclosure 1 Page 1 of 9 DESCRIPTION AND ASSESSMENT 1.0       

==SUMMARY==
DESCRIPTION Energy Northwest requests adoption of Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2 (Reference 1),
into the Columbia Generating Station (Columbia) Technical Specifications (TS).
The proposed change deletes the second Completion Times (CT) from Columbia TS 3.8.1 and 3.8.7 Required Actions. It also revises Example 1.3-3 to remove the second CT and to revise the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the Limiting Condition of Operation (LCO) is inconsistent with the basis of the CT and is inappropriate.
2.0       ASSESSMENT 2.1       Proposed Change Consistent with TSTF-439, Revision 2 (Reference 1), the proposed change: (1) modifies CT Example 1.3-3 to eliminate the second CT contained within and revises the discussion in the Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the bases of the CT, and (2) removes second CT contained in the TS.
Specifically, for Columbia TS 3.8.1, Required Actions A.3 and B.4.1.1 and 4.2.2; and, TS 3.8.7 Required Actions A.1 and B.1.
The Bases associated with these Required Actions are also being revised to delete the discussion of the second CT.
Energy-Northwest has reviewed the information provided in TSTF-439, Revision 2 (Reference 1) and concluded that the justifications presented in TSTF-439, as accepted by the NRC letter to the TSTF (Reference 3), are applicable to Columbia, and justify this amendment request for the incorporation of the changes to the Columbia TS.
2.2       Variations Energy-Northwest is proposing the following variations from the TS changes described in TSTF-439. These variations do not affect the applicability of TSTF-439 to the proposed license amendment requested for Columbia.

 
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GO-20-108 Enclosure 1 Page 2 of 9 Columbia            TSTF-439               Columbia Variation                 Comment Affected Sections TS 3.1.7,             No changes made.                 The CT for the equivalent Standby Liquid                                         Columbia TS does not 3.1.7          Control System,                                        include a Second Required Actions                                       Completion Time.
A.1 and B.1 second CT deleted.
TS 3.8.1 AC           TS 3.8.1, Required Action A.3 The justification for Sources -             contains two second CT that removal of Required Action 3.8.1          Operating,            will be removed. The first is 6 A.3 two second CT in Required Action       days from discovery of failure TSTF-439 remains the A.3 second CT         to meet LCO when not             same for the plant-specific deleted.              associated with Required         CT. Therefore, this change Action B.4.2.2 and then 17 does not impact the days from discovery of failure applicability of TSTF-to meet LCO.                    439.
This plant-specific change is the result of license amendment 197 issued on April 14, 2006, Extension of Diesel Generator Completion Time, (ML061000672).

 
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GO-20-108 Enclosure 1 Page 3 of 9 Columbia            TSTF-439               Columbia Variation                 Comment Affected Sections TS 3.8.1 AC           TS 3.8.1, Condition B,          The justification for Sources -             contains two Required Actions   removal of the Required 3.8.1          Operating,            to Restore required DG to       Action B.4 second CT in Required Action       OPERABLE status instead of      TSTF-439 remains the B.4, Restore          one. Required Actions B.4.1     same for the plant-specific required DG to        and B.4.2.2, Restore required   completion times.
OPERABLE              DG to OPERABLE status are       Therefore, this change status, second        separated by the Logical        does not impact the CT deleted.           Connector OR and each         applicability of TSTF-have a second CT.               439.
Required Action B.4.1 Restore required DG to OPERABLE status second Completion Time of 6 days from discovery of failure to meet LCO is being removed.
Required Action B.4.2.2 Restore required DG to OPERABLE status second Completion Time of 17 days instead of 6 days from discovery of failure to meet LCO is also being removed.
This plant-specific change is the result of license amendment 197 issued on April 14, 2006, Extension of Diesel Generator Completion Time, (ML061000672).
3.8.7          TS 3.8.9,             TS 3.8.7, Distribution Systems Numbering difference only.
Distribution          - Operating Systems -
Operating,

 
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GO-20-108 Enclosure 1 Page 4 of 9 Columbia            TSTF-439              Columbia Variation                   Comment Affected Sections 3.8.7          TS 3.8.9,              TS 3.8.9, Distribution          This is a plant specific Distribution           Systems - Operating,            variation which does not Systems -              Condition B is not included in impact the applicability of Operating,             Columbia TS. Columbia TS TSTF-439.
removes                3.8.7 contains Condition A.1 Required Action        and a Condition B.1, which is A.1, B.1 and C.1       the Condition C.1 of TS 3.8.9 second CT.             in TSTF-439.
3.8.7          TS 3.8.9,             TS 3.8.7, Distribution Systems These are plant specific Distribution          - Operating, Condition A         variations with set Systems -             contains two NOTES allowing expiration dates. The Operating,            an additional CT, not to be      notes are being deleted in removes               applied simultaneously, for the this LAR. The applicability Required Action       replacement of E-TR-8A/1 or date for NOTE 1 has A.1, B.1 and C.1      the replacement of WMA expired. The applicability second C T            8F1E or its failed starter coil. date for NOTE 2 will expire NOTE 1 is applicable until       before this LAR is October 1, 2020. NOTE 2 is approved. The existence applicable until June 30, 2021. and the removal of these notes do not impact the NOTE 1 is result of a Change applicability of TSTF-439.
to Technical Specification Limiting Condition for Operation 3.8.7 (Exigent Circumstances), issued September 4, 2020 (ML20242A002).
NOTE 2 is result of Changes to Technical Specification Limiting Conditions for Operation 3.8.4 and 3.8.7 (Exigent Circumstances),
issued May 12, 2020 (ML20125A080).

 
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GO2-20-108 Enclosure 1 Page 5 of 9 2.3        Technical Evaluation As discussed in TSTF-439, Revision 2, the adoption of a second CT was based on a NRC concern that a plant could continue to operate indefinitely with a LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the TS. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.
Maintenance Rule The Maintenance Rule, 10 CFR 50.65(a)(1), requires each licensee to monitor the performance or condition of structures, systems, and components (SSCs) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensees maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the actions of the TS and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).
Under the TS, the CT for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the CT for one system based on the condition of another system, if the two systems were required by the same LCO.
However, 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.
Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3 dated May 2012. Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4A, dated April 2011."
These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or

 
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GO2-20-108 Enclosure 1 Page 6 of 9 compensatory measures), and determination that the proposed maintenance is acceptable. This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the TS.
Reactor Oversight Process NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by Regulatory Issue Summary 2001-11, "Voluntary Submission of Performance Indicator Data." NEI 99-02, Section 2.2, describes the mitigating systems cornerstone. NEI 99-02 specifically addresses emergency AC sources, which encompasses the AC Sources and distribution system LCOs and the Auxiliary feedwater system. Extended unavailability of these systems due to multiple entries into the actions would affect the NRC's evaluation of the licensees performance under the ROP.
Administrative Control In addition to these programs, a requirement is added to Section 1.3 of the TS to require licensees to have administrative controls to limit the maximum time allowed for any combination of conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls consider plant risk and limit the maximum contiguous time of failing to meet the LCO. This TS requirement, when considered with the regulatory processes discussed herein, provide an equivalent or superior level of plant safety without the unnecessary complication of the TS by second Completion Times on some TS.
Furthermore, as part of the implementation process for this TS change Columbia plans to revise PPM 1.3.1, Operating Policies, Programs and Practices, Section 4.1, Operating within Technical Specifications/Licensee Controlled Specification/ODCM Limits, to implement the requirement contained in TSTF-439, Revision 2. Specifically:
Alternating between LCO Conditions, in order to allow indefinite continued operation while not meeting the LCO, is not allowed. Doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

==3.0         REGULATORY ANALYSIS==

3.1         Applicable Regulatory Requirements/Criteria The following NRC requirements are applicable to the proposed change:

 
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GO2-20-108 Enclosure 1 Page 7 of 9 The requirements of 10 CFR 50.36, "Technical specifications," establish the requirements related to the content of the TS. Section 50.36(c)(2) states:
When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," establish a performance-based rule to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.
The proposed change continues to meet the requirements of these regulations.
3.2        No Significant Hazards Consideration Determination Analysis Energy-Northwest requests adoption of Technical Specification Task Force (TSTF)
Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Columbia Generating Station Technical Specifications (TS). The proposed change eliminates the second Completion Times limiting time from discovery of failure to meet a limiting condition for operation (LCO). These changes are consistent with Nuclear Regulatory Commission (NRC) approved TSTF-439, Revision 2.
Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1.         Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change eliminates second Completion Times from the TS.
Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed changes do not increase the types

 
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GO2-20-108 Enclosure 1 Page 8 of 9 or amounts of radioactive effluent that may be released offsite nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2.         Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does not alter any assumptions made in the safety analysis.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from an accident previously evaluated.
: 3.         Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change to delete the second Completion Times does not alter the way safety limits, limiting safety system settings, or limiting conditions for operations are determined. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside of the design basis.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Energy Northwest concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),
and, accordingly, a finding of "no significant hazards consideration" is justified.

==4.0        ENVIRONMENTAL CONSIDERATION==

Energy-Northwest has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

 
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GO2-20-108 Enclosure 1 Page 9 of 9 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 change.

==5.0 REFERENCES==
: 1.       Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO,"
Revision 2, dated June 20, 2005 (ADAMS Accession No. ML051860296).
: 2.       NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Rev. 4, dated April 2012.
: 3.       Letter from Thomas H. Boyce, Technical Specifications Branch Chief (U.S Nuclear Regulatory Commission) to the Technical Specifications Task Force, "Status of TSTF 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," dated January 11, 2006 (ADAMS Accession No. ML060120272).

 
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GO2-20-108 Enclosure 2 Technical Specifications Markup Pages

 
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Completion Times 1.3 1.3    Completion Times DESCRIPTION (continued) discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
: a. Must exist concurrent with the first inoperability; and
: b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
: a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours; or
: b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery. . . " Example 1.3-3 illustrates one use of Columbia Generating Station                        1.3-2        Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times DESCRIPTION (continued) this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.
EXAMPLES                  The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION           REQUIRED ACTION           COMPLETION TIME B. Required            B.1 Be in MODE 3.          12 hours Action and associated        AND Completion Time not met. B.2 Be in MODE 4.          36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition B are to be in MODE 3 within 12 hours AND in MODE 4 within 36 hours. A total of 12 hours is allowed for reaching MODE 3 and a total of 36 hours (not 48 hours) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours, the time allowed for reaching MODE 4 is the next 30 hours because the total time allowed for reaching MODE 4 is 36 hours.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours.
Columbia Generating Station                       1.3-3       Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times EXAMPLES (continued)
EXAMPLE 1.3-3 ACTIONS CONDITION            REQUIRED ACTION          COMPLETION TIME A. One                A.1 Restore Function X      7 days Function X             subsystem to subsystem              OPERABLE status.       AND inoperable.
10 days from discovery of failure to meet the LCO B. One                B.1 Restore Function Y      72 hours Function Y             subsystem to subsystem              OPERABLE status.       AND inoperable.
10 days from discovery of failure to meet the LCO C. One                C.1 Restore Function X      72 hours Function X             subsystem to subsystem              OPERABLE status.
inoperable.
OR AND C.2 Restore Function Y      72 hours One                    subsystem to Function Y             OPERABLE status.
subsystem inoperable.
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
Columbia Generating Station                       1.3-6      Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times EXAMPLES (continued)
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).
The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.
However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
EXAMPLE 1.3-4 ACTIONS CONDITION            REQUIRED ACTION          COMPLETION TIME A. One or more         A.1 Restore valve(s) to     4 hours valves                 OPERABLE status.
inoperable.
Columbia Generating Station                        1.3-7       Amendment No. 149,169 225 

 
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AC Sources - Operating 3.8.1 ACTIONS CONDITION                          REQUIRED ACTION               COMPLETION TIME A. (continued)                         A.2    Declare required feature(s)  24 hours from with no offsite power        discovery of no offsite available inoperable when    power to one division the redundant required       concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)
AND A.3    Restore offsite circuit to   72 hours OPERABLE status.
AND 6 days from discovery of failure to meet LCO when not associated with Required Action B.4.2.2 AND 17 days from discovery of failure to meet LCO B. One required DG                     B.1    Perform SR 3.8.1.1 for       1 hour inoperable.                              OPERABLE offsite circuit(s).                  AND Once per 8 hours thereafter AND B.2    Declare required feature(s), 4 hours from supported by the inoperable  discovery of DG, inoperable when the      Condition B redundant required           concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)
AND Columbia Generating Station                        3.8.1-2         Amendment No. 195,197,225

 
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AC Sources - Operating 3.8.1 ACTIONS CONDITION                        REQUIRED ACTION                COMPLETION TIME B. (continued)                      B.3.1   Determine OPERABLE           24 hours DG(s) are not inoperable due to common cause failure.
OR B.3.2   Perform SR 3.8.1.2 for       24 hours if not OPERABLE DG(s).              performed within the past 24 hours AND B.4.1   Restore required DG to       72 hours from OPERABLE status.             discovery of an inoperable DG AND 6 days from discovery of failure to meet LCO OR B.4.2.1 Establish risk management    72 hours actions for the alternate AC sources.
AND B.4.2.2 Restore required DG to       14 days OPERABLE status.
AND 17 days from discovery of failure to meet LCO Columbia Generating Station                       3.8.1-3          Amendment No. 197,205 225

 
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Distribution Systems - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7         Distribution Systems - Operating LCO 3.8.7                 The following AC and DC electrical power distribution subsystems shall be OPERABLE:
: a. Division 1 and Division 2 AC electrical power distribution subsystems;
: b. Division 1 and Division 2 125 V DC electrical power distribution subsystems;
: c. Division 1 250 V DC electrical power distribution subsystem; and
: d. Division 3 AC and DC electrical power distribution subsystems.
APPLICABILITY:            MODES 1, 2, and 3.
Columbia Generating Station                       3.8.7-1 Amendment No. -    149,169,225
                                                                                                 - -- -- -  254
                                                                                                              --258,  261

 
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Distribution Systems - Operating 3.8.7 ACTIONS CONDITION                      REQUIRED ACTION                  COMPLETION TIME A. Division 1 or 2 AC               A.1  Restore Division 1 and 2       ---------NOTES---------
electrical power                    AC electrical power            These completion distribution subsystem              distribution subsystems        times may not be inoperable.                         to OPERABLE status.            used simultaneously.
: 1. Until October 1, 2020, a Completion Time of 16 hours may be used for replacement of E-TR-8A/1.
: 2. Until June 30, 2021, a Completion Time of 16 hours may be used for replacement of WMA-42-8F1E or its failed starter coil.
8 hours AND 16 hours from discovery of failure to meet LCO 3.8.7.a or b
Columbia Generating Station                      3.8.7-2 Amendment No. 149,169,225 254 258, 261

 
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Distribution Systems - Operating 3.8.7 ACTIONS CONDITION                          REQUIRED ACTION                     COMPLETION TIME B. Division 1 or 2 125 V DC            B.1    Restore Division 1 and 2           ----------NOTE----------
electrical power                         125 V DC electrical power          Until June 30, 2021, a distribution subsystem                   distribution subsystems to         Completion Time of inoperable.                              OPERABLE status.                   16 hours is applicable for replacement of WMA-42-8F1E or its failed starter coil.
2 hours AND 16 hours from discovery of failure to meet LCO 3.8.7.a or b
C. Required Action and                 C.1    ---------------NOTE--------------
associated Completion                    LCO 3.0.4.a is not Time of Condition A or B                 applicable when entering not met.                                 MODE 3.
Be in MODE 3.                      12 hours D. Division 1 250 V DC                 D.1    Declare associated                 Immediately electrical power                         supported feature(s) distribution subsystem                   inoperable.
inoperable.
E. One or more Division 3              E.1    Declare High Pressure              Immediately AC or DC electrical                      Core Spray System power distribution                       inoperable.
subsystems inoperable.
F. Two or more divisions               F.1    Enter LCO 3.0.3.                   Immediately with inoperable electrical power distribution subsystems that result in a loss of function.
Columbia Generating Station                        3.8.7-3                       ------1 Amendment No. 149, 169,225,236 238 258, 261

 
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Distribution Systems - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                     FREQUENCY SR 3.8.7.1              Verify correct breaker alignments and indicated         In accordance power availability to required AC and DC electrical     with the power distribution subsystems.                          Surveillance Frequency Control Program Columbia Generating Station                       3.8.7-4 Amendment No. 261149,
                                                                                        169,225,236 238

 
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GO2-20-108 Enclosure 3 Technical Specification Bases Markup Pages For Information Only

 
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AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)
The Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.
The second Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO when not associated with Required Action B.4.2.2. The reason for this limit and a third Completion Time limit is further explained below.
The third Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for a combination of required AC power sources that are associated with Required Action B.4.2.2 to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DG is inoperable and that DG is subsequently returned OPERABLE, the LCO may already have been not met for up to 14 days. This situation could lead to a total of 17 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 14 days (for a total of 31 days) allowed prior to complete restoration of the LCO. The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the Completion Times means that all Completion Times apply simultaneously, and the more restrictive must be met.
Similar to Required Action A.2, the Completion Time of Required Action A.3 allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition A was entered.
Columbia Generating Station                    B 3.8.1-8                                         Revision

 
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AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)
The second Completion Time for Required Action B.4.1 established a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours.
This situation could lead to a total of 144 hours, since initial failure to meet the LCO, to restore the DG. At this time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours (for a total of 9 days) allowed prior to complete restoration of the LCO. The 6 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO when the required risk management action of B.4.2.1 is not in place. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The "AND" connector between the 72 hour and 6 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.
A second optional set of Actions is provided, that if the risk management actions for establishing the alternate AC sources to division 1 or division 2 (AACS) occurs within the 72 hours Completion Time limit, an extended Completion Time up to 14 days from the DGs initial inoperability is allowed.
To establish the AACS, the DG-3 cross-connection to power selected safe shutdown loads is available and an additional AC source, a 480-volt diesel generator (DG-4), is staged and available. The AACS is considered available when DG-3 cross-connection can be implemented in accordance with the emergency procedures for a loss of offsite power or a station blackout event within 2 hours and DG-4 can be aligned and supplying the battery chargers within 4 hours. Additional risk management actions in accordance with the configuration risk management program required by 10 CFR 50.65a(4) are to be put in place to assure that significant risk configurations are avoided during the extended DG inoperability.
Similar to Action A.3 Completion Time, when the 14-day extended Completion Time is applicable, the 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO.
Similar to Required Action B.2, the Completion Time of Required Actions B.4.1 and B.4.2.2 allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered.
Columbia Generating Station                   B 3.8.1-11                                         Revision

 
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Distribution Systems - Operating B 3.8.7 BASES ACTIONS                   A.1 With one or more Division 1 or 2 required AC buses, load centers, motor control centers, or distribution panels, in one division inoperable, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours.
The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit and restoring power to the affected division. The 8 hour time limit before requiring a unit shutdown in this Condition is acceptable because of:
: a. The potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.
: b. The low potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP).")
The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 2 hours. This situation could lead to a total duration of 10 hours, since initial failure of the LCO, to restore the AC electrical power distribution system. At this time, a DC bus could again become inoperable, and the AC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.
Columbia Generating Station                    B 3.8.7-4                                        Revision

 
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Distribution Systems - Operating B 3.8.7 BASES ACTIONS (continued)
This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition A was entered. The 16 hour Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.
B.1 With Division 1 or 2 125 VDC buses in one division inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystems could result in the minimum required ESF functions not being supported.
Therefore, the required DC electrical power distribution subsystem must be restored to OPERABLE status within 2 hours by powering the bus from the associated battery or charger.
Condition B represents one division without adequate 125 VDC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning. In this situation, the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.
This 2 hour limit is more conservative than Completion Times allowed for the majority of components that could be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, that would have Required Action Completion Times shorter than 2 hours, is acceptable because of:
: a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue;
: b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; and Columbia Generating Station                   B 3.8.7-5                                         Revision

 
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Distribution Systems - Operating B 3.8.7 BASES ACTIONS (continued)
: c. The potential for an event in conjunction with a single failure of a redundant component.
The 2 hour Completion Time for DC electrical power distribution subsystems is consistent with Regulatory Guide 1.93 (Ref. 4).
The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours. This situation could lead to a total duration of 10 hours, since initial failure of the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and DC electrical power distribution could be restored OPERABLE. This could continue indefinitely.
This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.
C.1 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.
However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the Columbia Generating Station                   B 3.8.7-6                                         Revision

 
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GO2-20-108 Enclosure 4 Technical Specifications Clean Pages

 
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Completion Times 1.3 1.3    Completion Times DESCRIPTION (continued) discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
: a. Must exist concurrent with the first inoperability; and
: b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
: a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours; or
: b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery. . . "
Columbia Generating Station                        1.3-2        Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times EXAMPLES                  The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION           REQUIRED ACTION           COMPLETION TIME B. Required            B.1 Be in MODE 3.          12 hours Action and associated        AND Completion Time not met. B.2 Be in MODE 4.          36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition B are to be in MODE 3 within 12 hours AND in MODE 4 within 36 hours. A total of 12 hours is allowed for reaching MODE 3 and a total of 36 hours (not 48 hours) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours, the time allowed for reaching MODE 4 is the next 30 hours because the total time allowed for reaching MODE 4 is 36 hours.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours.
Columbia Generating Station                       1.3-3       Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times EXAMPLES (continued)
EXAMPLE 1.3-3 ACTIONS CONDITION            REQUIRED ACTION          COMPLETION TIME A. One                A.1 Restore Function X      7 days Function X             subsystem to subsystem              OPERABLE status.
inoperable.
B. One                B.1 Restore Function Y      72 hours Function Y             subsystem to subsystem              OPERABLE status.
inoperable.
C. One                C.1 Restore Function X      72 hours Function X             subsystem to subsystem              OPERABLE status.
inoperable.
OR AND C.2 Restore Function Y      72 hours One                    subsystem to Function Y             OPERABLE status.
subsystem inoperable.
When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).
Columbia Generating Station                       1.3-6      Amendment No. 149,169 225 259

 
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Completion Times 1.3 1.3    Completion Times EXAMPLES (continued)
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
EXAMPLE 1.3-4 ACTIONS CONDITION              REQUIRED ACTION            COMPLETION TIME A. One or more           A.1 Restore valve(s) to       4 hours valves                    OPERABLE status.
inoperable.
B. Required              B.1 Be in MODE 3.             12 hours Action and associated          AND Completion Time not met.       B.2 Be in MODE 4.             36 hours A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.
Columbia Generating Station                          1.3-7       Amendment No. 149,169 225 259

 
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AC Sources - Operating 3.8.1 ACTIONS CONDITION                          REQUIRED ACTION               COMPLETION TIME A. (continued)                         A.2    Declare required feature(s)  24 hours from with no offsite power        discovery of no offsite available inoperable when    power to one division the redundant required       concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)
AND A.3    Restore offsite circuit to   72 hours OPERABLE status.
B. One required DG                     B.1    Perform SR 3.8.1.1 for       1 hour inoperable.                              OPERABLE offsite circuit(s).                  AND Once per 8 hours thereafter AND B.2    Declare required feature(s), 4 hours from supported by the inoperable  discovery of DG, inoperable when the      Condition B redundant required           concurrent with feature(s) are inoperable. inoperability of redundant required feature(s)
AND Columbia Generating Station                        3.8.1-2         Amendment No. 195,197,225

 
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AC Sources - Operating 3.8.1 ACTIONS CONDITION                        REQUIRED ACTION                COMPLETION TIME B. (continued)                      B.3.1   Determine OPERABLE           24 hours DG(s) are not inoperable due to common cause failure.
OR B.3.2   Perform SR 3.8.1.2 for       24 hours if not OPERABLE DG(s).              performed within the past 24 hours AND B.4.1   Restore required DG to       72 hours from OPERABLE status.             discovery of an inoperable DG OR B.4.2.1 Establish risk management    72 hours actions for the alternate AC sources.
AND B.4.2.2 Restore required DG to       14 days OPERABLE status.
Columbia Generating Station                       3.8.1-3          Amendment No. 197,205 225

 
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Distribution Systems - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7          Distribution Systems - Operating LCO 3.8.7                  The following AC and DC electrical power distribution subsystems shall be OPERABLE:
: a. Division 1 and Division 2 AC electrical power distribution subsystems;
: b. Division 1 and Division 2 125 V DC electrical power distribution subsystems;
: c. Division 1 250 V DC electrical power distribution subsystem; and
: d. Division 3 AC and DC electrical power distribution subsystems.
APPLICABILITY:             MODES 1, 2, and 3.
ACTIONS CONDITION                          REQUIRED ACTION                  COMPLETION TIME A. Division 1 or 2 AC               A.1      Restore Division 1 and 2        8 hours electrical power                        AC electrical power distribution subsystem                  distribution subsystems to inoperable.                             OPERABLE status.
B. Division 1 or 2 125 V            B.1      Restore Division 1 and 2        2 hours DC electrical power                     125 V DC electrical power distribution subsystem                  distribution subsystems to inoperable.                             OPERABLE status.
C. Required Action and              C.1      ---------------NOTE-----------
associated Completion                   ---LCO 3.0.4.a is not Time of Condition A                     applicable when entering or B not met.                           MODE 3.
Be in MODE 3.                   12 hours Columbia Generating Station                           3.8.7-1 Amendment No. 149,169,225 254 258, 261 XXX

 
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Distribution Systems - Operating 3.8.7 ACTIONS CONDITION                          REQUIRED ACTION                 COMPLETION TIME D. Division 1 250 V DC                 D.1    Declare associated             Immediately electrical power                         supported feature(s) distribution subsystem                   inoperable.
inoperable.
E. One or more Division 3              E.1    Declare High Pressure          Immediately AC or DC electrical                      Core Spray System power distribution                       inoperable.
subsystems inoperable.
F. Two or more divisions               F.1    Enter LCO 3.0.3.               Immediately with inoperable electrical power distribution subsystems that result in a loss of function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                     FREQUENCY SR 3.8.7.1              Verify correct breaker alignments and indicated         In accordance power availability to required AC and DC electrical     with the power distribution subsystems.                          Surveillance Frequency Control Program Columbia Generating Station                       3.8.7-2    Amendment No. 149, 169,225 254 258, 261 XXX}}