ML14098A400

Columbia Generating Station - License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level-High

ML14098A400
Person / Time
Site:	Columbia
Issue date:	03/24/2014
From:	Javorik A L Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-14-043
Download: ML14098A400 (24)

Text

ANw L. Javm*kP.O. Sax W&, PEo4Ridhtand, WA 99352M066 P. 509.377.65 I F. 5093774A15 March 24, 2014G02-14-043 10 CFR 50.90U.S. Nuclear Regulatory Coommission ATTN: Document Control DeskWashington, DC 20555-0001 Suwect C "IA GENERATING

STATION, DOCKET NO. 01-LICENSE AMWNOMENT REQU.EST FOR CHANGING TECHNALSPECIFICATION TAKLE 3.3.1.114 FUNCTION 7, "SCRAM DICHARGEVOLUME WATER LEVEL -NOIGW

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Energy Northwest hereby requests a license amendment torevise the Columbia Generating Station Technical Specification Table 3.3.1.1-1 to makethe following changes:1. In Function 7.a, change the term "Transmitter/Trip Unt to "Transmitter/Level Indicating Switch."2. In Function 7.b, change the term "Float Switch' to "Transmitter/Level Switch."3. In Function 7.a, add SR 3.3.1.1.1 to require performance of a Channel Checkevery 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4. Pursuant to TSTF-493 Option A, add footnotes (d) and (e) to SR 3.3.1.1.10 forthe new scram discharge instrumentation in TS Table 3.3.1.1-1 Function 7.b.The respective rationale for the aforementioned changes is as follows:1. The change more accurately describes the existing instrument's Indication capability in the Control Room.2. The change reflects the planned replacement of existing Magnetrol Level FloatSwitches with the comparably reliable and more accurate level transmitters andassociated trip units.3. The change corrects the inadvertent omission of the SR during theimplementation of Improved Technical Specifications.

4. The change adds the Surveillance Notes to the channel calibration for thisFunction which will no longer meet the exclusion criteria.

The Enclosure contains an evaluation of the proposed changes.

Attachments to theEnclosure include the following:

1. Proposed Columbia Technical Specification Changes (Mark-Up)

2. Proposed Columbia Technical Specification Bases Changes (Mark-Up)

3. Proposed Columbia Technical Specification Changes (Re-Typed)

.4 co)

UCENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 33.1..1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Page 2 of 2This letter and its enclosure contain no regulatory commitments.

Approval of the proposed amendment Is requested within one year of the date of thesubmittal.

The requested approval date will allow the instrument upgrades to becompleted during Columbia's Spring 2015 refueling outage (R-22). Once approved, theamendment shll be Implemented prior to restarting from R-22.In accordance with 10 CFR 50.91, Energy Northwest is notifying the State ofWashington of this amendment request by transmitti a copy of this letter andenclosure to the designated State Official.

If there a any questions or if additiotal information is needed, please contact Ms. L. L.Williams, Licensing Supervisor, at 509-377-8148.

I declare under penart of peoury that the foregoing Is true and correct.

Executed onthis_ /dayof .,, __.Respectfully, A.L1.Vice President, Engineering

Enclosures:

As statedcc: NRC RIV Regional Administrator NRC NRR Project ManagerNRC Senior Resident Inspector/988C MA Jones -BPA/1399 (email)JO Luce -ESFECRR Cowley -WDOH (emall)

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 1 of 14EVALUATION OF PROPOSED CHANGES1. SUMMARY DESCRIPTION In accordance with 10 CFR 50.90, Energy Northwest requests changes to the Technical Specifications (TS) for Columbia Generating Station (Columbia).

Specifically, EnergyNorthwest proposes to revise the specified function description and Surveillance Requirements (SRs) in Table 3.3.1.1-1, "Reactor Protection System Instrumentation,"

Function 7, "Scram Discharge Volume Water Level -High." These proposed changessupport a planned upgrade to the Columbia Reactor Protection System (RPS) ScramDischarge Volume (SDV) Water Level -High instrumentation.

The instrument replacements are part of a larger plant modification that will reduce future crudaccumulation and recurring radiation dose exposure to plant personnel.

Theinstrumentation modification was reviewed under 10 CFR 50.59(c)(1) and determined tonot meet any of the criteria in 10 CFR 50.59(c)(2).

The instrumentation upgradereplaces the existing TS Table 3.3.1.1-1 Function 7.b SDV water level float switcheswith electronic analog transmitters and trip units to interface with the existing RPS logic.Consequently, the description of the Function 7.b instrumentation requires revision toreflect the upgraded instrumentation.

In addition, Energy Northwest proposes to add an additional SR to the existing SDVwater level transmitters/trip units specified in Function 7.a of Table 3.3.1.1-1 to correctan inadvertent omission from TS. The existing instrumentation associated with Function7.a provides level indication.

However, the existing level indication allows performance of a channel check which was not included in the TS. Consequently, Energy Northwest proposes to add a SR to perform a channel check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to verify Function 7.a.This SR is currently performed at Columbia for the subject equipment and should bespecified in the TS. The description of the Function 7.a instrumentation will also berevised from "Transmitter/Trip Unit" to "Transmitter/Level Indicating Switch" to moreaccurately describe the instrumentation configuration.

Finally, the TSTF-493 Option A Surveillance Notes that are required to be applied to theSDV instrumentation that are not mechanical components will be added to SR3.3.1.1.10 for the new scram discharge instrumentation in TS Table 3.3.1.1-1 Function7.b.2. DETAILED DESCRIPTION Energy Northwest is submitting the proposed TS change to update TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, Function 7, "Scram Discharge VolumeWater Level -High" to reflect the planned replacement of SDV instrumentation withcurrently available instruments with comparable reliability and greater accuracy and tocorrect an omission of a SR from the existing TS.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Page 2 of 14These proposed changes will ensure that the description of SDV Water Level -Highinstrumentation in TS matches the plant configuration and that the appropriate surveillances and footnotes are applied to this instrumentation.

The following changesare proposed to be made to TS Table 3.3.1.1-1 Function 7, each of which is described in greater detail below:1. In Function 7.a, change the term "Transmitter/Trip Unit" to 'Transmitter/Level Indicating Switch."2. In Function 7.b, change the term "Float Switch" to 'Transmitter/Level Switch."3. In Function 7.a, add SR 3.3.1.1.1 to require performance of a channel checkevery 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4. Pursuant to TSTF-493 Option A, add footnotes (d) and (e) to SR 3.3.1.1.10 forthe new scram discharge instrumentation in TS Table 3.3.1.1-1 Function 7.b.The proposed TS changes are reflected on a marked-up copy of the affected TS pagesin Attachment

1. Revised TS Bases pages affected by the proposed changes are alsoprovided as information in Attachment

2. Following NRC approval of this request,Energy Northwest will revise the TS Bases, in accordance with the TS Bases ControlProgram of TS Section 5.5.10, "Technical Specifications (TS) Bases Control Program,"

to incorporate the changes identified in Attachment

2. Attachment 3 provides revised(clean) TS pages.2.1 Background The SDV instrument replacements are part of a larger plant modification that willcompletely replace the SDV Instrument Volumes and associated piping and instruments in order to reduce future crud accumulation and recurring radiation dose exposure toplant personnel caused by high radiation sources in the SDV Instrument Volumes andassociated piping. The modification is also being driven by equipment obsolescence.

The existing Instrument Volumes are carbon steel which when cycled through wet andvented dry conditions causes internal scaling that becomes a porous surface capturing radioactive particulates.

The Function 7.b instrument sensing lines and liquid levelswitch bodies are carbon steel and are major crud accumulation traps.The existing SDV Instrument

Volumes, level instruments and associated small bore,carbon steel socket welded piping and valves are inherent crud traps that have resultedin chronic, high general area radiation levels. Averaged historical dose exposure fromwork in the area has been significant, resulting in an accumulated dose ofapproximately 10% of the current station annual ALARA goals. As time progresses, thedose rates are expected to increase further as more crud collects in the system.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 3 of 14Flushes of the associated instrument piping have had limited success in reducing doserates due to the inherent material properties of the piping. The current practice ofproviding local shielding has become less practical and contributes to area congestion and increased difficulty performing maintenance and surveillance activities.

SDVInstrument Volume dose rates are presently as high as 6,000 mrem/hr on contact and500 mrem/hr at 30 cm. The dose rates in the area result in an annual averagecollective personnel exposure of at least 2445 mrem, including outage work.The high dose rate coupled with the congestion that exists due to the existingconfiguration of level instruments, piping, and supports on each SDV Instrument Volume continue to impede surveillance testing and maintenance activities and createsa personal safety challenge for plant personnel.

Lastly, the Magnetrol float-type switches are no longer available for safety related applications from the originalmanufacturer.

The new level transmitters and trip units utilize proven technology, arehighly reliable, and are more accurate than the existing float switches.

2.2 Revision of Description of TS Table 3.3.1.1-1 Functions 7.aThe description of the function name in TS Table 3.3.1.1-1 for Function 7.a is beingrevised to more accurately describe the existing instrumentation.

The Function 7.ainstruments are better described as Transmitter/Level Indicating Switches versus theexisting Transmitter/Trip Units.2.3 Revision of Description of TS Table 3.3.1.1-1 Functions 7.bEnergy Northwest is upgrading the SDV Water Level -High instrumentation byreplacing the existing Magnetrol float switches associated with TS Table 3.3.1.1-1 Function 7.b with level sensing equipment of a different design yet diverse from theexisting Function 7.a instruments.

Thus a change to the Function 7.b description isrequired to reflect the new instrumentation.

2.4 Added Surveillance for TS Table 3.3.1.1-1 Function 7.aOne SR is proposed to be added to the existing Function 7.a level indicating switches(also referred to as trip units). These units have indication capability in the controlroom. Currently a channel check is performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in accordance withstation procedures.

However, the TS do not contain this SR requirement in Table3.3.1.1-1 for Function 7.a. The proposed change to add the SR 3.3.1.1.1 to TS Table3.3.1.1-1 Function 7.a makes the TS more comprehensive and is thus appropriate.

During Energy Northwest's conversion to the Improved Technical Specifications (ITS)(Reference 1), the SR for performing channel checks was excluded because it wasbelieved that the instrumentation did not provide an indicated value for the parameter LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 4 of 14being measured by the instruments, and therefore did not support the performance of achannel check. While this was true for the Function 7.b instruments, it was not true forthe Function 7.a instruments.

When Energy Northwest discovered that the Function 7.ainstruments did, in fact, provide indication and therefore should not have been excludedfrom the TS channel check requirement, plant procedures were changed and thechannel check performed in accordance with Administrative Letter (AL) 98-10(Reference 2). The proposed changes complete the actions required by AL 98-10 byincluding the channel check SR in the TS.2.5 Addition of TSTF-493 footnotes to TS 3.3.1.1 Function 7.bEnergy Northwest proposes to add TSTF-493, Revision 4, Option A TS Surveillance Notes to Columbia instrumentation Function 7.b. Due to a previously submitted licenseamendment

request, this submittal only adds Surveillance Notes for instrumentation Function 7.b. In letter G02-13-138 dated October 2, 2013 (Reference 3), EnergyNorthwest proposed changes to the TS to incorporate TSTF-493-A, Revision 4, "ClarifyApplication of Setpoint Methodology for LSSS Functions,"

Option A (Reference 4). Thatamendment

request, G02-13-138, proposed changes to the TS to add requirements toassess channel performance during surveillance testing that verifies instrument channelsetting values established by the plant-specific setpoint methodology.

In G02-13-138, instrumentation Functions not meeting the exclusion criteria of TSTF-493 wereannotated with the two Surveillance Notes. The instrumentation associated withFunction 7.a did not meet the exclusion criteria; thus, Surveillance Notes were proposedto be added to the channel calibration for this Function.

However, the existing floatswitch instrumentation in Function 7.b met the exclusion criteria in TSTF-493 as being amechanical device excluded from Surveillance Notes. As such, G02-13-138 did notpropose the addition of Surveillance Notes to the Function 7.b channel calibration.

Thenew instrumentation that will replace the existing float switch does not meet theexclusion criteria; thus, it is appropriate to add the Surveillance Notes to the channelcalibration for Function 7.b.The Surveillance Notes proposed in this license amendment request are identical to thenotes proposed in G02-13-138 Attachment 1 section 4.2 and are consistent with TSTF-493 Option A:Surveillance Note (d) states:If the as-found channel setpoint is outside its predefined as-found tolerance, then thechannel shall be evaluated to verify that it is functioning as required before returning the channel to service.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Page 5 of 14Surveillance Note (e) states:The instrument channel setpoint shall be reset to a value that is within the as-lefttolerance around the Limiting Trip Setpoint (LTSP) at the completion of thesurveillance; otherwise, the channel shall be declared inoperable.

Setpoints moreconservative than the LTSP are acceptable provided that the as-found and as-lefttolerances apply to the actual setpoint implemented in the surveillance procedures (Nominal Trip Setpoint) to confirm channel performance.

The LTSP and themethodologies used to determine the as-found and as-left tolerances are specified inthe Licensee Controlled Specifications.

3. TECHNICAL EVALUATION 3.1 System Description and Current Licensing BasisThe SDV system is described in Final Safety Analysis Report (FSAR) Sections4.6.1.1.2.4.2.5, 4.6.2.2, and 7.2.1.1.7 (Reference 5). Water displaced by the ControlRod Drive (CRD) pistons during a scram goes to the SDV. If the SDV fills with water sothat insufficient capacity remains for the water displaced during a scram, control rodmovement would be hindered during a scram. To prevent this situation, the reactor isscrammed when the water level in the discharge volume is high enough to verify thatthe volume is filling up, yet low enough to ensure that the remaining capacity in thedischarge volume can accommodate a scram. The SDV Water Level -Highinstrumentation inputs to the four RPS channels.

A scram is automatically initiated when sufficient capacity still remains in the discharge volume to accommodate a scram.The Applicable Safety Analyses section of TS Bases 3.3.1.1 for the SDV Water Level -High Function states that Functions 7.a and 7.b are an input to the RPS logic; however,no credit is taken for a scram initiated from these functions for any of the design basisaccidents or transients analyzed in Chapter 15 of the FSAR. The SDV scram functions are retained in the TS to ensure that the RPS remains operable.

The critical function ofthe SDV system is to ensure sufficient volume exists to absorb the CRD discharge inventory when a reactor scram occurs.Water level in the SDV is measured by two diverse methods.

The outputs of the levelinstruments are arranged so that there is a signal from both diverse methods (i.e.Function 7.a and 7.b instruments) to each RPS logic channel.

The level instrumentation is designed consistent with the BWR Scram Discharge System Safety Evaluation transmitted via Generic Letter (GL)80-107 (Reference

6) and GL 81-18 "BWR ScramDischarge System; Clarification of Diverse Instrumentation Requirements" (Reference 7). Four channels of each type of SDV Water Level -High Function, with two channelsof each type in each trip system, are required to be operable to ensure that no singleinstrument failure will preclude a scram from these Functions on a valid signal.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 6 of 14Section 7.2.2.5 of NUREG-0892 (Reference

8) documents NRC review of the ScramDischarge Level Monitoring System as part of plant licensing for operation.

Theinstrumentation associated with the Scram Discharge Volume Water Level -HighFunction was accepted on the following basis:" Diverse means of level sensing were provided,

" Each of the diverse methods provides alarms in the control room as well as theappropriate signals to the RPS for scram, and,* Each diverse sensing system independently satisfies the single-failure criterion.

Based on these attributes of the system, the NRC concluded the applicable criteria ofTable 7.1 of the Standard Review Plan (SRP) (Reference 9a) were met.3.2 Safety Analysis of the Proposed Changes 1 & 2 (changes to Function 7.a &7.b names)The change to the description of Function 7.a and 7.b instrumentation are required toproperly reflect the existing and new SDV instrumentation, respectively.

These changesto accurately describe the functions are administrative in nature and do not impact thedesign or operation of the SDV system.Diversity and redundancy between the instruments supporting the 7.a and 7.b functions is required and ensures that no single event can prevent a scram caused by SDV highwater level. The diversity and redundancy requirement currently is met by use ofdifferent instrument sets measuring level and differential pressure.

Following themodification, diversity and redundancy will be ensured by utilizing two different instrument sets which measure differential pressure using different sensing methods.The Function 7.a instrument set employs a strain gage sensor that converts amechanical force (pressure) to an electrical signal. The sensing mechanism is isolatedfrom the process fluid by an isolating diaphragm and silicone fill fluid.The Function 7.b instrument set will utilize direct electronic sensing with a completely sealed coplanar capacitance sensing element.

The design uses an oil-filled cavity witha capacitance plate as the pressure-sensing element.

Process pressure is transmitted through an isolating diaphragm and silicone oil fill fluid to a sensing diaphragm in thecenter of the sensor cell. Process or reference pressure is transmitted in a like mannerto the other side of the center sensing diaphragm.

The capacitor plates on both sides ofthe sensing diaphragm detect the position of the sensing diaphragm.

Differential pressure changes result in a corresponding differential capacitance change in thesensing element (sensor).

This signal is then decoded, amplified, and linearized by ananalog circuit, converting the pressure change into a proportional 4-20 mA electrical current output signal. These capacitance type pressure transmitters have demonstrated high performance levels for accuracy, stability, and reliability in both industrial and LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Page 7 of 14nuclear applications.

The new Function 7.b instruments conform to the existinglicensing and design basis as described in Section 3.1 above.The setpoint calculations, which incorporate the TSTF-493 Rev. 4 requirement forcalculating As-Found Tolerance (AFT) and As-Left Tolerance (ALT) into the settingtolerance, did not result in any changes to the TS Allowable Values for Table 3.3.1.1-1 Functions 7.a and 7.b.The new instrument design preserves diversity and redundancy by use of level sensorsprovided by different manufacturers that utilize different operating principles for levelmeasurement as stated above. The associated level switches are also from different manufacturers.

As such, the requirements for diversity and redundancy of the SDVsystem and the associated level instrumentation continue to be met and plant safety isnot impacted by these proposed changes.3.3 Safety Analysis of the Proposed Change 3 (add SR to Function 7.a)The added SR to perform a channel check for the Function 7.a instrumentation every 12hours does not impact plant safety. The actual performance of the channel check at a12 hour frequency does not have adverse impacts on the overall system design oroperation.

Channel checks on the existing instrumentation are currently beingperformed.

The addition of the channel check to station procedures represented anincrease in plant safety by increasing the likelihood of detecting precursors to a moreserious plant event. In accordance with AL 98-10, the proposed changes seek toformally establish the checks as a required TS SR.In general, a channel check provides opportunity to detect significant deviations between instrument channels which may be indicative of larger equipment problems.

Since the channel calibration on these instruments is at an 18 month frequency, twicedaily channel checks, which are already performed, result in enhanced monitoring ofthese instruments.

3.4 Safety Analysis of the Proposed Change 4 (add TSTF-493 footnotes toFunction 7.b)Setpoint calculations establish an LTSP based on the analytical limit (AL) of the safetyanalysis to ensure that trips or protective actions will occur prior to exceeding theprocess parameter value assumed by the safety analysis calculations.

These setpointcalculations also calculate an allowed limit of expected change (i.e., the AFT) betweenperformances of the surveillance test for assessing the value of the setpoint setting.The least conservative as-found instrument setting value that a channel can have duringcalibration without requiring performing a TS remedial action is the setpoint allowable value (AV). Discovering an instrument setting to be less conservative than the AV LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Page 8 of 14indicates that there may not be sufficient margin between the setting and the AL. TSchannel calibrations are performed to verify channels are operating within theassumptions of the setpoint methodology calculated LTSP and that channel settingshave not exceeded the specified AVs. When the measured as-found setpoint is non-conservative with respect to the AV, the channel is inoperable and the actions identified in the TS must be taken.The first Surveillance Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its AFT but conservative with respect to the AV. Evaluation of channel performance will verify that the channelwill continue to perform in accordance with safety analysis assumptions and the channelperformance assumptions in the setpoint methodology.

The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel toservice.Verifying that a trip setting is conservative with respect to the AV when a surveillance test is performed does not by itself verify the instrument channel will operate properly inthe future. Although the channel was operable during the previous surveillance

interval, if it is discovered that channel performance is outside the performance predicted by theplant setpoint calculations for the test interval, then the design basis for the channelmay not be met, and proper operation of the channel for a future demand cannot beassured.

Surveillance Note (d) formalizes the establishment of the appropriate AFT foreach channel.

This AFT is applied about the LTSP or about any other moreconservative setpoint.

The AFT ensures that channel operation is consistent with theassumptions or design inputs used in the setpoint calculations and establishes a highconfidence of acceptable channel performance in the future. Because the AFT allowsfor both conservative and non-conservative deviation from the LTSP, changes inchannel performance that are conservative with respect to the LTSP will also bedetected and evaluated for possible effects on expected performance.

To implement Surveillance Note (e), the ALT for some instrumentation channels isestablished to ensure that realistic values are used that do not mask instrument performance.

Setpoint calculations assume that the instrument setpoint is left at theLTSP within a specific ALT (e.g., 25 psig +/- 2 psig). A tolerance band is necessary because it is not possible to read and adjust a setting to an absolute value due to thereadability and/or accuracy of the test instruments or the ability to adjust potentiometers.

The ALT is normally as small as possible considering the tools and the objective tomeet an as low as reasonably achievable calibration setting of the instruments.

TheALT is considered in the setpoint calculation.

Failure to set the actual plant trip setpointto the LTSP (or more conservative than the LTSP), and within the ALT, would invalidate the assumptions in the setpoint calculation because any subsequent instrument driftwould not start from the expected as-left setpoint.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 9 of 143.5 Summary Conclusion Plant safety is not impacted by the proposed changes.

The changes do not impact thedesign or operation of the SDV system and hence is consistent with existing safetyanalyses.

The diversity and redundancy of the SDV instrumentation is preserved.

Theaddition of a Channel Check SR to TS Table 3.3.1.1-1 Function 7.a and the addition ofTSTF-493 notes (d) and (e) to SR 3.3.1.1.10 for the new scram discharge instrumentation in TS Table 3.3.1.1-1 Function 7.b are conservative changes that alignthe SRs for proper determination of operability with that of similar instrumentation.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The licensing bases for the scram discharge system are provided in the ColumbiaOperating License Safety Evaluation Report (SER), NUREG-0892 Section 4.6 and 7.2.The SDV Water Level-High instruments are part of the RPS instrumentation described in Section 7.2 of Columbia's FSAR. The RPS is required to meet 10 CFR 50.55a(h) and 10 CFR 50, Appendix A General Design Criteria.

Requirements for Protection Systems in 10 CFR 50.55a(h)(2) stipulate that RPS mustmeet the requirements of IEEE Std. 279, "Criteria for Protection Systems for NuclearPower Generating Stations,"

(Reference

10) or IEEE 603-1991, "Criteria for SafetySystems for Nuclear Power Generating Stations" (Reference 11). Columbia's RPS isdesigned in accordance with IEEE 279-1971.

None of the TS changes impact theoverall design or operation of the RPS system.General Design Criteria (GDC) 21 is most relevant to the proposed changes.

Thechanges to the instrumentation associated with the SDV do not adversely change thesystem design aspects that establish GDC 21 compliance.

Namely, reliability, testability, and operability of the RPS and SDV system instrumentation are preserved.

In addition to the requirements derived from the RPS, the scram discharge system isaddressed in NUREG-0800, Section 4.6 (Reference 9b). Item 111.6 of NUREG-0800, Section 4.6 states that the design of the SDV and its associated systems should bereviewed for conformance with the guidance and criteria in the NRC's BWR ScramDischarge System Safety Evaluation dated December 1, 1980. Columbia's existingscram discharge system was accepted in NUREG-0892 as noted in section 3.1 above.Energy Northwest's plant design control process for the overall SDV modification ensures that the applicable criteria of the BWR Scram Discharge System SafetyEvaluation will continue to be met. Specifically, the critical function of the system is to LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 10 of 14provide sufficient volume to absorb CRD discharge inventory when a credited RPS tripoccurs. The proposed changes do not impede draining the volume or the control logicfor venting or draining the SDV, and conform with the existing design and licensing basis of the SDV instrumentation.

Safety Criterion 3 in Section 4.2.2.3 of the BWR Scram Discharge System SafetyEvaluation is most directly applicable to the proposed TS changes as it deals withinstrument diversity and redundancy.

Specific requirements under Safety Criterion 3include designing the system to meet single failure criterion and addressing commoncause failures.

Included as part of addressing common cause failures is a requirement that the design includes diverse and redundant level sensing instruments using different operating principles.

Additional NRC guidance on this topic was provided in GL 81-18,which is also specifically referenced in NUREG-0800, Section 4.6.The current SDV instruments and the replacement instruments are designed as singlefailure proof. As stated above, the Function 7.a and Function 7.b instrumentation employ diverse operating principles, namely a strain gage sensor and capacitance sensing element, respectively.

Common mode failures resulting from environmental

effects, design and manufacturing issues, and human error have been addressed withthe new instrumentation in a manner comparable to the existing design. EnergyNorthwest has determined that the applicable criteria of the BWR Scram Discharge System Safety Evaluation and the guidance in GL 81-18 continue to be met.4.2 Precedent The proposed changes are similar to TS changes approved for Dresden Nuclear PowerStation, Units 2 and 3 via Amendments 198 and 191, respectively on April 3, 2003(Reference 12). Dresden proposed changes to the TS SDV Water Level -Highinstrumentation function descriptions resulting from replacing the SDV Water Level -High float switches with analog trip units, the associated change to, and addition of a TSSR which was being performed but not required by TS (Reference 13). Dresden's proposed changes were in support of RPS SDV Water Level -High instrumentation upgrades.

The changes accepted for Dresden Units 2 and 3 differ from the proposed changes inthat they also included the addition of plant specific footnotes and the modification ofallowable values. The plant specific notes are not appropriate for Columbia since theyare related to the multiple unit configuration at Dresden.

Energy Northwest reviewedthe allowable values using the established plant setpoint methodology and concluded that no changes are required to the TS Allowable Values for Table 3.3.1.1-1 Functions 7.a and 7.b. As such, neither of the differences from the Dresden precedent aregermane to the acceptability of Energy Northwest's proposed changes.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 11 of 144.3 No Significant Hazards Consideration Determination Energy Northwest has evaluated whether or not a significant hazards consideration isinvolved with the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of amendment,"

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

Response:

No.The proposed changes to change Function 7 names are administrative in natureand ensure that the description of SDV Water Level -High instrumentation in TSmatches the plant configuration.

The addition of a missing channel check SRand TSTF-493 footnotes for the new Function 7.b instruments makes the TSmore comprehensive by ensuring the appropriate surveillances and footnotes areapplied to this instrumentation.

The replacement instruments for Function 7.b meet the high functional reliability standard of GDC 21 and all pertinent requirements of 10 CFR 50.55a(h)(2).

Theinstrumentation modification was reviewed under 10 CFR 50.59(c)(1) anddetermined to not meet any of the criteria in 10 CFR 50.59(c)(2).

The addition of a channel check to Function 7.a and addition of TSTF-493 notes(d) and (e) to SR 3.3.1.1.10 for the Function 7.b instrumentation do not changeaccident frequency or consequences.

TS requirements that govern operability orroutine testing of plant instruments are not assumed to be initiators of anyanalyzed event because these instruments are intended to prevent, detect, ormitigate accidents.

Additionally, these proposed changes will not increase theconsequences of an accident previously evaluated because the proposedchanges do not adversely impact structures,

systems, or components.

Theproposed TS changes establish requirements that ensure components areoperable when necessary for the prevention or mitigation of accidents ortransients.

Furthermore, there will be no change in the types or significant increase in the amounts of any effluents released offsite.In summary, the proposed changes do not involve a significant increase in theprobability or consequences of an accident previously evaluated.

LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Page 12 of 142) Does the proposed amendment create the possibility of a new or different kind ofaccident from any accident previously evaluated?

Response:

No.The proposed changes to administratively revise instrument descriptions, incorporate a new SR, and add footnotes to an existing SR do not change theparameters within which Columbia is operated.

The proposed changes do not adversely impact the manner in which the SDVWater Level -High RPS instrumentation will operate under normal and abnormaloperating conditions.

The instrumentation design changes were reviewed under10 CFR 50.59(c)(1) and determined to not meet any of the criteria of 10 CFR50.59(c)(2).

The proposed changes will not alter the functional demands oncredited equipment.

No alteration in the procedures which ensure that Columbiaremains within analyzed limits are proposed and no change is being made toprocedures relied upon to respond to an off-normal event. Therefore, theseproposed changes provide an equivalent level of safety and will not create thepossibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin ofsafety?Response:

No.The proposed changes to the function descriptions in TS Table 3.3.1.1-1 Functions 7.a and 7.b are considered administrative in nature, and do not impactplant safety.Margins of safety are established in the design of components, the configuration of components to meet certain performance parameters, and in theestablishment of setpoints to initiate alarms and actions.

The proposed changessupport a planned upgrade of the SDV instrumentation that preserves thereliability of RPS system. The proposed changes do not adversely affect theprobability of failure or availability of the affected instrumentation.

Theinstrumentation design changes were evaluated under 10 CFR 50.59(c)(1) anddetermined to not meet any of the criteria of 10 CFR 50.59(c)(2).

The addition of a Channel Check SR to TS Table 3.3.1.1-1 Function 7.a and theaddition of TSTF-493 notes (d) and (e) to SR 3.3.1.1.10 for the new scramdischarge instrumentation in TS Table 3.3.1.1-1 Function 7.b are conservative LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 13 of 14changes that align the SRs for proper determination of operability with that ofsimilar instrumentation.

On this basis, is concluded that the proposed changes do not result in areduction in the margin of safety.4.4 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.5. ENVIRONMENTAL CONSIDERATION The proposed amendment does not involve (i) a significant hazards consideration, (ii) asignificant change in the types or significant increase in the amounts of any effluent thatmay be released

offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets theeligibility 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 amendment.

6. REFERENCES

1. Letter G02-95-265, J.V. Parrish (Washington Public Power Supply System) toNRC, WNP-2 Operating License NPF-21 Request For Amendment to Technical Specifications, dated December 8, 19952. N RC Administrative Letter 98-10, Dispositioning of Technical Specifications that areInsufficient to Assure Plant Safety, US NRC, December 29, 19983. Letter G02-13-138, A.L. Javorik (Energy Northwest) to NRC, Columbia Generating

Station, Docket No. 50-397 License Amendment Request For Adoption of TSTF493, Revision 4, Option A, dated October 2, 20134. Owners Group Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-493-A, Revision 4 Clarify Application ofSetpoint Methodology for LSSS Functions

5. "Columbia Generating

Station, Final Safety Analysis Report,"

Amendment 62, April20136. Generic Letter 80-107, BWR Scram Discharge System, December 9,19807. Generic Letter 81-18, BWR Scram Discharge System; Clarification of DiverseInstrumentation Requirement, March 31, 1981 LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH"Enclosure Page 14 of 148. NUREG-0892, Safety evaluation report related to the operation of WPPSS nuclearproject no. 2, docket no. 50-397: Washington Public Power Supply System,December 19809. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports forNuclear Power Plants: LWR Edition,a. Section 7.1 -T, Table 7-1 Regulatory Requirements, Acceptance

Criteria, and Guidelines for Instrumentation and Control Systems Important toSafety, Second Revision 5, March 2007b. Section 4.6, Functional Design of Control Rod Drive System, Revision 2,March 200710. IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations11. IEEE 603-1991, Criteria for Safety Systems for Nuclear Power Generating Stations12. Letter, LW Rossbach (NRC) to JL Skolds (Exelon Nuclear Generation Company,LLC), Dresden Nuclear Power Station, Units 2 and 3 -Issuance of Amendments forScram Discharge Volume Water Level Instruments, dated April 3, 2003[ML030730739]

13. Letter, PR Simpson (Exelon Nuclear Generation

Company, LLC) NRC, Request forTechnical Specifications Changes Related to Reactor Protection SystemInstrumentation (Scram Discharge Volume Water Level -High) Dresden NuclearPower Station, Units 2 and 3 -Issuance of Amendments for Scram Discharge Volume Water Level Instruments, dated August 16, 2002 [ML022400240]

LICENSE AMENDMENT REQUEST CHANGING TECHNICAL SPECWICATION TABLE 3411.1-1 FUNCTION 7, "SCRAM OiSCHARGE VOLUME WATER LEVEL -HIGH"Enclosure Attachment IProposed Columbia Technical Specification Changes (Mak-Up)

RPS Instruwwmen (PNor to /i/en of PRNM Upgrade)3.3.1.1Table 3.3.1.1-1 (page 2 of 3)Reactor Protection System IntKumenUtation APPLICABLE CONOITINS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROMSPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION 0.1 REQUIREMENTS VALUE3. ReactorVesselStemn 1.2 2 0 SR 3.3.1.1.8 s !079pigDome Prowe -Nogh SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

4. Reacor Veel lWateLevrL 1,2 2 G SR 3.3.1.1.1

>9.5Inches

-Low, Level 3 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

5. Main Stnam Isolation Val"e 1 8 F SR 3.3,1.1.8 s 12.5% dosed.Clown SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

8. PflmwyConatnnmt 1,2 2 G SR 3.3.1.1.8 51.88 pigPressure

-High SR 3.3.1.1.10 SR 3.3.1.114

7. Scram ODcharg.

VoakleW Level- Higha. Tranantthr/l 1,2 2 G SR 3111 mI2 nohe asSR 3.3.1.1.8 elevation 3c SR 3.3.1.1.10 SR 3.3,11.1.14 5(s) 2 H SR '3, 1 1 529ft9inches SR 3.3.1.1.8 elevation SR 3.3.1.1.10 SR 3.3.1.1.14

b. 1,2 2 G SR 3.3.1.1.8 s 529 ft 9 inchesSR 3.311.16"'

elevation SR 3.3.1.1.14 So) 2 H SR 3.3.1.1.8 529 ft 9 inchesSR 3.3.1.1.10" elevation SR 3.3.1.1.14 (a) With any control rod wixthdaw from a core cell containing one or nwre fuel aaaoembllee.

T(-) Th nst Iw[ine : hl teý ,,j( J,_ 181, 8T wsa 0h a ltle ranct 514ýýe th1, ~nn XI 0 TSP at the 1 elo ofi the ilei nr' erw. the R00e ,~ e~ noeaColumbia Generating Station3.3.1.1-7 Amendment No. 40 226 226 RPS Instruentation (After fImpietaWton of PRN Upgrade)3.3.1.1Table 3.3.1.1-1 (pogp 3 of 4)Reactor Protection System Instrumentation APPICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROMSPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE3. Reactor VeseleSaem 1,2 2 G SR 33.1.1-8

<1079psig Dome Preese .-High SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

4. ReactorVesselWater 1,2 2 a SR 3.3.1.1.1 9.5 inciesLevel -Low, Leve 3 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

5. Mau 8ton Isolatio Valve 1 8 F SR 3.3.1.1.8

< 12.5% closedClosure SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

6. PmtaryContulnmdnt 1,2 2 0 SR 3.3.1.1.8

!1.88palg Press#, -High SR 33.1.1.10 SR 3.3.1.1.14

7. Scram Dischi VolmeWater Level -Higha. Tram~ 1,2 2 0 !5 529ft9inches tSR 3.3.1.1.8 elevation SR 3,3.1.1.10 SR 3.3.1..14 524) H s 33 529ft9inches SR 3.3.1.1A8 elevation SR 3.3.1.1.10 SR 3.3.1.1.14

b. 1,2 2 G SR 3.3.1.1.8 s 529 ft 9 Inchesm , SR 3.3.1.1.1 elevation SR 3.3.1.1.14

50) 2 H SR 3.3.1.1.8 529 ft 9 InchesSR 3.3.1.1.10""'

elevation 8R 3.3.1.1.14 (a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

d) if the a4-funl nhe is rid, d ne. then ne chapno sha be(e) fhe Insounlet chni~oeI cotot iami to ~a is winb te asl-l tomi a n the Limit"ngT# t LTSP the cxmpet~on f sr nne o , c o ldlnoberable channel perfonance n ThSLTSP nd oc I r riQh ci an thetoierances are in th Li nae oe -d pe:{a~Columbia Generating Station3.3.1.1-17 Amendment No. 226 UCENSE A"lMET REQUEST CHANGING TCHNC SPECIFICATION TABLE 3.3.1-11 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL -mwHEnclosure Afachment 2Proposed Columbi Tedhnic 9- fl clo m sn Chn1 (Mauk.Up)l RPS Instumentaston B 3.3.1.1BASESAPPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

SDV water level is measured by two diveme methods.

The level in eachof the two SOV sis measured by two fl4level switches and two transmitters andThe outputs of these devices am arranged so thatthere is a signal from a level switch and a transmittr aw4iý to each RPS logic channelThe level mesument instrumentation satisfies therecommendatn of Reference 10.The A1llow Value is chosen low enough to ensure that there Issufficient volume in the SOV to accommodate the water from a full scram.Four channels of each type of Scram Discharge Volume Water Level -High Function, with two channels of each type in each trip system, arrequired to be OPERABLE to ensure that no single instrument failur, willpreclude a scram from these Functions on a valid signal. TheseFunctlons we required in MODES I and 2, and in MODE 5 with anycontrol rod withdrawn from a core cel containing one or more fuelassemblies, since these are the MODES and other specified conditions when control rods are withdrawn.

At all other times, this Function may bebypassed.

8. Turbine Throttle Valve -ClosureClosure of the TTVs results in the loss of a heat sink that producesreactor pressure, neutron flux, and heat flux transients that must belimited.

Therefore, a reactor scram is initiated at the start of TTV closurein anticipation of the transients that would result from the closure of thesevalves. The Turbine Throttle Valve -Closure Function Is the primaryscram signal for the turbine trip event analyzed in Reference

5. For thisevent, the reactor scram reduces the amount of energy required to beabsorbed and, along with the actions of the End of Cycle Recirculation Pump Trip (EOC-RPT)

System, ensures that the MCPR SL is notexceeded.

Turbine Throttle Valve -Closure signals are initiated by valve stemposition switches at each throttle valve. Two switches are associated with each throttle valve. One of the two provides input to RPS tripsystem A; the other, to RPS trip system B. Thus, each RPS trip systemreceives an input from four Turbine Throttle Valve -Closure channels, each consisting of one valve stem position switch. The logic for theTurbine Throttle Valve -Closure Function is such that three or more TTVsColumbia Generating Station8 3.3.1.1-14 Revision 73 UCENSE AMENDMENT REQUEST CHANGING TECHNICAL SPECIFITION TABLE 3.3.1.14 FUNCTION 71 "SCRAM DISCHARGE VOLUME WATER LEVEL -HIGO"Enclosure Aftachment 3Proposed Columbia Technical Specification Changes (Re-Typed)

RPS Instrumentation (Pror to Implementation of PRNM Upgrade)3.3.1.1Table 3.3.1.1-1 (page 2 of 3)Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROMSPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION 0.1 REQUIREMENTS VALUE3. Reactor Vessel SteamDome Pressure

-High4. Reactor Vessel Water Level-Low, Level 35. Main Steam Isolation Valve-Closure6. Primary Containment Pressure

-Hih7. Scrum Discharge VolumeWater Level- Higha.

Indicating Switch1,222o ' SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15 G SR 3.3.1.1.1 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15 F SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15 O SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14

< 1079 paigz 9.5 inchesIa2< 12.6% dosed1,2:51.88 pslg1,256)2222( SR 3.3.1.1.1 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 H SR 3.3.1.1.1 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 G SR 3.3.1.1.8 SR 3.3.1.1.10'")

SR 3.3.1.1.14 H SR 3.3.1.1.8 SR 3.3.1.1,10(d"e)SR 3.3.1.1.14

< 529 It 9 incheselevation

! 529 ft 9 incheselevation

< 529 It 9 Incheselevation

< 529 It 9 Incheselevation

b. TransmltterYLevel Switch1,25(01(a) With any control rod withdrawn.from

a. core cell containing one or more fuel assemblies.

.(d) If the as-found channel setpolnt Is outside its predefined as-found tolerance, then the channel shall beevaluated-to verify that it Is functioning asrequired before returning the channel to service.(a) The Instrument channel setpolnt shall be reset to a value that is within the as-left tolerance around the LimitingTrip Setpoint (LTSP) at the completion of the surveillance; othenrise, the channel shall be declared Inoperable.

Setpolnts more conservative than the LTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpolnt Implemented In the surveillance procedures (Nominal Trip Setpoint) to confirmchannel performance.

The LTSP and the methodologies used to determine the as-found and the as-lefttolerances are specified In the Ucensee Controlled Specifications.

Columbia Generating Station3.3.1.1-7 Amendment No. 46g 226 226 1RPS Instrumentation (After Implementation of PRNM Upgrade)3.3.1.1Table 3.3.1.1-1 (page 3 of 4)Reactor Protection System Instrumentation APPLICASLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROMSPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE3. Reactor Vessel Stam 1,2 2 a SR 3.3.1.1.8

<1079psig Dome Pressure-High SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

4. ReactorVesoelWater 1,2 2 G SR 3.3.1.1.1

>9.6 InchesLevel- Low. Level 3 SR 3.3.1.1.8 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

5. Main Steam Isolation Valve I 8 F SR 3.3.1.1.8

< 12.5% cosed-Closure SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15

6. PrlmaryContainment 1,2 2 0 SR 3.3.1.1.8 51.88pslg Pressure-High SR 3.3.1.1.10 SR 3.3.1.1.14

7. Scram Discharge VolumeWater Level -Higha. Transmitter/Level 1,2 2 G SR 3.3.1.1.1

<529ft9Inches Indicating Switch SR 3.3.1.1.8 elevation SR 3.3.1.1.10 SR 3.3.1.1.14 5(al 2 H SR 3.3.1.1.1

ý5 529 ft 9 InchesSR 3.3.1A1.8 elevation SR 3.3.1.1.10 SR 3.3.1.1.14

b. TransmitterdLevel 1,2 2 G SR 3.3.1.1.8

529ft9 InchesSwitch SR 3.3.1.1.10"e) elevation SR 3.3.1.1.14 5(.) 2 H SR 3.3.1.1.8

529ft 9 InchesSR 3.3.1.1.10(dle) eleaonSR 3.3.1.1.14 (a) With any control rod withdrawn from a core cell containing one or more fuel assemblies.

(d) If the as-found channel setpolnt Is outside Its predefined as-found tolerance, then the channel shall beevaluated 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 LimitingTrip Setpoint (LTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

Selpoints 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 confirmchannel performance.

The LTSP and the methodologies used to determine the as-found and the as-lefttolerances are specified In the Licensee Controlled Specifications.

Columbia Generating Station3.3.1.1-17 Amendment No. 226