GO2-14-164, Response to NRC Request for Additional Information Re License Amendment Request for Adoption of TSTF-493, Revision 4, Option a

Response to NRC Request for Additional Information Re License Amendment Request for Adoption of TSTF-493, Revision 4, Option a

ML14335A320
Person / Time
Site:	Columbia
Issue date:	11/17/2014
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-14-164, TSTF-493, Rev. 4
Download: ML14335A320 (7)

Text

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MOM Alex L Javorik Columbia Geeaffing Station P.O. Box 968, PE04 Richan WA 99352-08 Ph. 509.3778.5 I F. 509.377.2354 November 17, 2014 G02-14-164 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 60497 RESPONSE TO NRC REQUEST FOR ADDIT1OtAL. INFORMATION RELATED TO LICENSE AMENDOMENT REQUEST FOR ADOPTION OF TSTF-49, REVISION 4, OPTION A

References:

1)

Letter dated October 2, 2013, AL Javorik (Energy Northwest) to NRC, "Ucense 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)"

3)

Letter dated June 19, 2014, AL Javorlk (Energy Northwest) to NRC, "Proposed Revision To License Amendment Request To Adopt TSTF-493, Revision 4, Option A, And Response To Request For Additional Information"

4)

E-mail dated October 9, 2014, AE George (NRC) to LL Williams (Energy Northwest), "FW: TSTF-493 request"

Dear Sir or Madam:

By Reference 1, Energy Northwest submitted a License Amendment Request (LAR) to adopt TSTF-493, Revision 4, Option A. By Reference 3, Energy Northwest provided additional information to support its initial LAR at the request of the NRC. By email dated October 9, 2014 (Reference 4), the Nuclear Regulatory Commission (NRC) requested additional information needed for the staff to complete its review of the LAR.

Transmitted herewith in Attachment 1 is the Information requested.

No new regulatory commitments are being made in this submittal.

& oA

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO UCENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-46, REVISION 4, OPTION A Page 2 of 2 Should you have any questions or require additional Information regarding this matter, please contact Ms. L.L. Williams,'Licensing Supervisor, at (509)377-8148.

I declare under penalty of perJuy that the foregoing Is true and correct.

Executed on thisll dayof,

2014 Respectfully,

Ž/A.L. Javonk Vice President, Engineering Attachment as stated cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector - 988C MA Jones-1PA/I 399 (email)

WA Horin - Winston & Strawn (email)

RR Cowley - WOOH (email)

JO Luce - EFSEC (emall)

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF49G, REVISION 4o OPTION A Page 1 of 5 I19s~onae to RBMues for Addftinnl InIMfomtf to the model LAR for TSTF-493 requires 'Summary calculations are provided for. the revised setpolnts."

The licensee provided an example In the LAR forFunction 7,. 'Scram Discharge Volume Water Level - High". This example is acceptable once -they respond to the PRA sent on 9/24/2014. However, this example only illustrates a summary calculation for functions that do not have Analytical Limits. Therefore, the licensee should provide a summary calculation illustrating how they performed the setpolnt calculation for a function that includes Analytical Limits.

[ 17. 77 771 k177 i 777 711 ;17 1 1,

', 17 17 -) I The following summary is provided for level switches MS-LIS-31 A thru D. These safety-related level switches provide the TS 3.3.5.1 Function 3a (High Pressure Core Spray (HPCS) System - Reactor Vessel Water Level - Low, Low, Level 2) by monitoring reactor water level and provide an initiation signal that starts HPCS if water level is below the setpoint.

Setwoint Mthdoo erMnee. TS 3.3.1.1. Emeonc Core Coon m (ECC actuation instrument-Function 3.a Setpoint calculations for MS-LIS-31A thru D, TS 3.3.5.1, ECCS actuation instrumentation Function 3.a instruments were performed in accordance with Columbia's setpoint procedure. The basic methodology is summarized as follows:

" Define the loop to be analyzed

" Determine analytical limit for the instrument loop in question

" Determine normal and accident environmental conditions and associated effects on the accuracy of each instrument in the loop

" Determine normal drift effects for each instrument in the loop

" Combine the effect terms and determine the setting range

" Determine as-found and as-left tolerances.

Summary calculation A brief summary of uncertainty, calibration, drift and other factors associated with the derivation of calculated allowable value, as found tolerance and the as left tolerance is provided below. A number of normal factors which did not affect the instrument loop uncertainty and device calibration and drift were considered but not listed in this summary. These include humidity (HE), insulation resistance (IR), Process/Primary Element Effect (PPE), Power Supply Effect (PSE), Pressure Effect (PE), seismic (SE),

4 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO UCENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-493, REVISION 4, OPTION A Attachment I Page 2 of 5 and temperature effect (TE) effects. Humidity and Temperature Effect are included in the Combined Accident Effect (CAE).

The summary of the calculation is provided in the following pages. Supporting design Input data Is provided in Table 1 for level indicating switches. Finally, a graphical summary of the calculation is presented.

Table I - Instrument Uncertainties and Calibratlon and Drift Design Inputs for MS-LI.31A thru D.

TS Calibration Frequency 18 Moth Tab" 3.3.5.1-1 Function 3.a. The calibration period Is 18 months.

C acorr 1.0 Correctlon for end device when so point Is from a single side. C a 1.0 CS=

calibted span 160.2 inw Low = 216.8 nwg (-50 reactr water level) and High =

_S_=____.__dspn_

• _1" 66.6 inwo (+60 reactor water WMvel)

The maximum seismic Woaing for the device installation Seismic RRS (S) (9) 6.65 g location is sffiLdmately 6.5 a Period of operation during and I day Actuation of HPCS Is while water level Is low in the RPV after LO C A..

RA = Reference Accuracy 0.2% of CS Vendor Data She-Accuracy of Calibrated Span (CS)

MT&E = Maintenance and test iTest Instrument accuracy 0.1%. Test instrument span 280 inwg, equipment unertaintyof CS and Calibration uncertainty of 0.26 or less than device under equpmetncetaitytest

per_,

calibration standards. Calibrated pcan 150.2 Inwa The Input device has a minor graduation of 0.6 inwg. The SA = Setting Accuracy 0.167% of CS reading accuracy is % of the minor graduation. 0.5 + 2+150.2

_x 100% W 0.17% of CS.

CAL a Calibration Effect 0.287%, of CS Plant Setpoint Methodology Standards EES-4, [M&TE 2+SA1j" CAE-'Combined Accident 1.72% of CS Qualification test report 2.4% of FS. Span a150.2/210 = 0.716 Effect...

x 2.4 a 1.72%

DR=Drift W 1.0% of CS Vendor Test Data DR_____D

,._ DR' 1.03% of CS RE a Radiation Effect 1.001% of CS Vendor TestO Data Vendor info 0.25% per loCops overrange. Over range a 1250 SP = Static Pressure Effect 0.435% of CS

- (210 inwg / 27.71 inwg per psig) = 1250 - 7.6 8 1242.4.

0.25% x 1242.4/1000 = 0.311%FS Full Scale is 210 Inwa. 0.311% x 210 /150.2 0.435% CS Level Indgcatina Switch Uncertainty and Drift [refer to Table 1 aboveA UD.R = Uncertainty of instrument (drift, random) =

C x [RA2 + CAL2 + PSE2+ SE2]"/2= 0.35% of CS UD.B* = Uncertainty of instrument (drift, bias in positive direction) =

SCAE+DR +HE++IR +PE +PPE +RE +SP++TE = 4.156% of CS UD." = Uncertainty of instrument (drift, bias in negative direction) =

CAE'+DR'+HE'+IR'+PE'+PPE'+RE'+SP'+TE" = 4.186% of CS

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-40% REVISION 4, OPTION A Page 3 of 5 The total loop uncertaintie are:t UT+

UT,R+ UTT+

=

Uncertainty (total, random+ total, bias in positive direction) =

4.506% of CS = 6.77 inwg UT'= UT.R+ UT," =

Uncertaintiy (total, random + total, bias In negative direction) =

4.538% of CS = 6.81 inwg where UTF, = [U0,RA.n"]

UT.B = ZUo.s.; UT., = EUo.d,.

The device Calibration and Drift c for MS-UB41 A thru 31D are:

CD+o= CAL + DR+ = 1.287% of CS =1.93 inwg CD =CAL + DR'= 1.317% of CS =1.98 mg Setpolnt Detemination ALuW,2 Analytical Limit, Upper, Level 2:159.6 inwg Pb Process Limit, Lower, Level 2:104.2 inwg Mgximum.Setting:

MxS 2 = A[-uw U" = 152.79 lnwg Minimum, Sttina:

MnS 2 = P"-.wer.2 + UD+ (including reactor vessel level notching bias of 2.11 in wg) =

113.07 inwg Note: This setpoint determination and allowable value reflect a reversal in usage of the positive and negative drift terms to ensure conservatism in the calculation; this Is the usage developed in the original calculation. The higher term Is used to provide a more conservative upper Allowable Max Setting'based on the Technical Specification Allowable Value and the lower term is used to provide an earlier HPCS tum-off.

Allowable Value AVumw,2 Allowable Value, Upper, Level 2 = MxS 2 +CD* = 154.77 inwg AVkwer.2 Allowable Value, Lower, Level 2 = MnS 2 - CD÷ = 111.14 inwg

-I RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR, ADOPTION OF TSTF-483, REVISION 4, OPTION.A Page 4 of 5 As-Found Tolerance (AFT) and As-Left Tolerance (ALT)

For those instruments subject to the requirements of TSTF-493, Setting Tolerance has two parts. As-Found Tolerance (AFT) and As-Left Tolerance (ALT).

AFT is defined as the bounds, within which the setpoint is expected to be found at the end of surveillance, and ALT is defined as the bounds within which the setpoint must be adjusted at the end of surveillance.

The following calculations are for instrument loop MS-LIS-31A.

Given Data:

k 1*

CAL = CAL" 0.287% of CS RA+ = RA 0.20% of CS DRR:

0.0%(of CS DR.

1.0% of CS DR'a 1.03% of CS

• Note: k=W for a normal distribution Calculated Values:

As Found Tolerances (AFT) are oalculated as follows:

AFT+ = k x [(ICAL+)2 + (ERA*)2 + (TDRFq) 21] 2 + ZDR+e = 1.35% of CS = 2.03 inwg AFT = k x [(ZCAL) 2 + ('RA') + ("DRR)4i" 2 + IDR'e = 1.38% of CS = 2.07 inwg As Left Tolerances (ALT) are calculated as follows:

ALT _ AFT'- IDR6+ = 0.53 inwg ALT =AFT- -!DRs" = 0.52 inwg The translation between Vessel level (Hm) and differential pressure at the instrument (APinm) is described in the following equation:

AP~t = 216.8 inwg + [Hvea - (.150in)] (216.8inwg - 66.6 inwg) / (-150in - 60 in)

Note that the TS Allowable Value remains conservative to the calculated AV.

%OF RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-4M3, REVISION 4, OPTION A Page 5 of 5 Summery diagram fg in RX U

.0 -70 LWM~aly"ca LW UP TrImav 2 J*

0,.

161 1

-f Tech Specs AVý,

AFT*

~154.77 152.79 2.0 ALTJ 0.$

2*1

-113.07 M.1.4 As*Fam TdKMe A"4fTO*tUWc 1T40

-&U. A~wcomsemftoi AFTI NwrkgdSoodt To 1LOWs 2 Lsoydvmwsum U.

9.87" 1042 7.5 Lower FMCM UrM bb~s~ead, L

0w Z~~gS.

W ft W.E~ X W56 (U 1g.lAuLa Ltl.