ML14086A389

Columbia - License Amendment Request to Revise Technical Specifications to Adopt TSTF-535, Revision 0

ML14086A389
Person / Time
Site:	Columbia
Issue date:	03/18/2014
From:	Javorik A L Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G02-14-040
Download: ML14086A389 (9)

Text

Alex L. JavorikVice President, Engineering N RP.O. Box 968, Mail Drop PE04Richland, WA 99352-0968 NORTHW E ST Ph. 509-377-8555 F. 509-377-2354 aljavorik@

energy-northwest.com March 18, 2014 10 CFR 50.90G02-14-040 U.S. Nuclear Regulatory Commission

,ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

COLUMBIA GENERATING

STATION, DOCKET NO. 50-397LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-535 REVISION 0

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 modifies the TS definition of "Shutdown Margin" (SDM) torequire calculation of the SDM at a reactor moderator temperature of 680F or a highertemperature that represents the most reactive state throughout the operating cycle.This change is needed to address new Boiling Water Reactor (BWR) fuel designs whichmay be more reactive at shutdown temperatures above 68°F." Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant specification verifications.

" Attachment 2 provides the existing TS pages marked up to show the proposedchange." Attachment 3 provides revised (clean) TS pages.Energy Northwest requests approval of the proposed License Amendment within one yearof the date of this letter with the amendment being implemented within 60 days thereafter.

There are no new regulatory commitments contained in this request.In accordance with 10 CFR 50.91, a copy of this application, with attachments, is beingprovided to the designated Washington State Official.

If you should have any questions regarding this submittal, please contact Ms. L. L.Williams, Licensing Supervisor, at 509-377-8148.

ADD(

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Page 2 of 2I declare under penalty of perjury that the foregoing is true and correct.

Executedon the date of this letter.Respectfully, A. L. JavorikVice President, Engineering Attachment 1: Description and Assessment Attachment 2: Proposed Technical Specification ChangesAttachment 3: Revised (clean) Technical Specification Pagescc: NRC Region IV Administrator NRC NRR Project ManagerNRC Sr. Resident Inspector

-988CMA Jones -BPA/1 399 (email)WA Horin -Winston & Strawn (email)RR Cowley -WDOH (email)JO Luce -EFSEC (email)

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Attachment 1Page 1 of 3DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment modifies the Technical Specifications (TS) definition of"Shutdown Margin" (SDM) to require calculation of the SDM at a reactor moderator temperature of 680F or a higher temperature that represents the most reactive statethroughout the operating cycle. This change is needed to address new Boiling WaterReactor (BWR) fuel designs which may be more reactive at shutdown temperatures above 68°F.2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Energy Northwest has reviewed the model safety evaluation dated February 26, 2013,as part of the Federal Register Notice of Availability.

This review included a review ofthe NRC staff's evaluation, as well as the information provided in TSTF-535 Revision 0,"Revise Shutdown Margin Definition to Address Advanced Fuel Designs."

EnergyNorthwest has concluded that the justifications presented in the TSTF-535 proposal andthe model safety evaluation prepared by the NRC staff are applicable to ColumbiaGenerating Station (Columbia) and justify this amendment for the incorporation of thechanges to the Columbia TS.2.2 Optional Changes and Variations Energy Northwest is not proposing any variations or deviations from the TS changesdescribed in TSTF-535, Revision 0, or the applicable parts of the NRC staff's modelsafety evaluation dated February 26, 2013.3.0 REGULATORY ANALYSIS3.1 No Significant Hazards Consideration Determination Energy Northwest requests adoption of TSTF-535 Revision 0, which is an approvedchange to the standard technical specifications (STS), into the Columbia TS. Theproposed amendment modifies the TS definition of SDM to require calculation of theSDM at a reactor moderator temperature of 68°F or a higher temperature thatrepresents the most reactive state throughout the operating cycle.Energy Northwest has evaluated whether or not a significant hazards consideration isinvolved with the proposed amendment(s) by focusing on the three standards set forthin 10 CFR 50.92, "Issuance of amendment,"

as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Attachment 1Page 2 of 3The proposed change revises the definition of SDM. SDM is not an initiator to anyaccident previously evaluated.

Accordingly, the proposed change to the definition ofSDM has no effect on the probability of any accident previously evaluated.

SDM isan assumption in the analysis of some previously evaluated accidents andinadequate SDM could lead to an increase in consequences for those accidents.

However, the proposed change revises the SDM definition to ensure that the correctSDM is determined for all fuel types at all times during the fuel cycle. As a result,the proposed change does not adversely affect the consequences of any accidentpreviously evaluated.

Therefore, the proposed change does not involve a significant increase in theprobability or consequences of an accident previously evaluated.

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

Response:

No.The proposed change revises the definition of SDM. The change does not involve aphysical alteration of the plant (i.e., no new or different type of equipment will beinstalled) or a change in the methods governing normal plant operations.

Thechange does not alter assumptions made in the safety analysis regarding SDM.Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change revises the definition of SDM. The proposed change does notalter the manner in which safety limits, limiting safety system settings or limitingconditions for operation are determined.

The proposed change ensures that theSDM assumed in determining safety limits, limiting safety system settings or limitingconditions for operation is correct for all BWR fuel types at all times during the fuelcycle.Therefore, the proposed change does not involve a significant reduction in a marginof safety.Based on the above, Energy Northwest concludes that the proposed change presentsno 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.

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Attachment 1Page 3 of 33.2 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation inthe proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimical tothe common defense and security or to the health and safety of the public.4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use ofa facility component located within the restricted area, as defined in 10 CFR 20, orwould change an inspection or surveillance requirement.

However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant changein the types or significant increase in the amounts of any effluents that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

noenvironmental impact statement or environmental assessment need be prepared inconnection with the proposed change.

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Attachment 2PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UPS)

Definitions 1.11.1 Definitions PHYSICS TESTS (continued)

RATED THERMAL POWER(RTP)REACTOR PROTECTION SYSTEM (RPS) RESPONSETIMESHUTDOWN MARGIN (SDM)c. Otherwise approved by the Nuclear Regulatory Commission.

RTP shall be a total reactor core heat transfer rate to thereactor coolant of 3486 MWt.The RPS RESPONSE TIME shall be that time interval fromwhen the monitored parameter exceeds its RPS trip setpoint atthe channel sensor until de-energization of the scram pilotvalve solenoids.

The response time may be measured bymeans of any series of sequential, overlapping, or total stepsso that the entire response time is measured.

SDM shall be the amount of reactivity by which the reactor issubcritical or would be subcritical throughout the operating cycle assuming that:a. The reactor is xenon free;b. The moderator temperature is a 680F, corresponding tothe most reactive state; andc. All control rods are fully inserted except for the singlecontrol rod of highest reactivity worth, which is assumedto be fully withdrawn.

With control rods not capable ofbeing fully inserted, the reactivity worth of these controlrods must be accounted for in the determination of SDM.A STAGGERED TEST BASIS shall consist of the testing ofone of the systems, subsystems,

channels, or otherdesignated components during the interval specified by theSurveillance Frequency, so that all systems, subsystems,

channels, or other designated components are tested during nSurveillance Frequency intervals, where n is the total numberof systems, subsystems,

channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor core heattransfer rate to the reactor coolant.ISTAGGERED TEST BASISTHERMAL POWERColumbia Generating Station 1.1-5 Amendment No. 449 22~Columbia Generating Station1.1-5Amendment No. 44M 226 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TOADOPT TSTF-535 REVISION 0Attachment 3PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN)

Definitions 1.11.1 Definitions PHYSICS TESTS (continued)

RATED THERMAL POWER(RTP)REACTOR PROTECTION SYSTEM (RPS) RESPONSETIMESHUTDOWN MARGIN (SDM)c. Otherwise approved by the Nuclear Regulatory Commission.

RTP shall be a total reactor core heat transfer rate to thereactor coolant of 3486 MWt.The RPS RESPONSE TIME shall be that time interval fromwhen the monitored parameter exceeds its RPS trip setpoint atthe channel sensor until de-energization of the scram pilotvalve solenoids.

The response time may be measured bymeans of any series of sequential, overlapping, or total stepsso that the entire response time is measured.

SDM shall be the amount of reactivity by which the reactor issubcritical or would be subcritical throughout the operating cycle assuming that:a. The reactor is xenon free;b. The moderator temperature is > 680F, corresponding tothe most reactive state; andc. All control rods are fully inserted except for the singlecontrol rod of highest reactivity worth, which is assumedto be fully withdrawn.

With control rods not capable ofbeing fully inserted, the reactivity worth of these controlrods must be accounted for in the determination of SDM.A STAGGERED TEST BASIS shall consist of the testing ofone of the systems, subsystems,

channels, or otherdesignated components during the interval specified by theSurveillance Frequency, so that all systems, subsystems,

channels, or other designated components are tested during nSurveillance Frequency intervals, where n is the total numberof systems, subsystems,

channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor core heattransfer rate to the reactor coolant.STAGGERED TEST BASISTHERMAL POWERColumbia Generating Station 1.1-5 Amendment No. 4~Q 22~Columbia Generating Station1.1-5Amendment No. 469 2-26