ML062790322

Issuance of Amendment Technical Specification Change Request for TS 3.10.1 Scram Time Testing Activities

ML062790322
Person / Time
Site:	Cooper
Issue date:	10/23/2006
From:	Brian Benney NRC/NRR/ADRO/DORL/LPLIV
To:	Edington R Nebraska Public Power District (NPPD)
Benney B, NRR/DORL, 415-3764
Shared Package
ML062790319	List: ML062790322 ML062960294
References
TAC MD2418
Download: ML062790322 (11)

Text

October 23, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE:

TECHNICAL SPECIFICATION CHANGE REQUEST FOR TS 3.10.1, SCRAM TIME TESTING ACTIVITIES (TAC NO. MD2418)

Dear Mr. Edington:

The U. S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 225 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station.

The amendment consists of changes to the Technical Specifications in response to your application of June 16, 2006.

The amendment revises limiting condition for operation (LCO) 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 "F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 225 to DPR-46

2. Safety Evaluation cc w/encls: See next page

October 23, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE:

TECHNICAL SPECIFICATION CHANGE REQUEST FOR TS 3.10.1, SCRAM TIME TESTING ACTIVITIES (TAC NO. MD2418)

Dear Mr. Edington:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 225 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station.

The amendment consists of changes to the Technical Specifications in response to your application of June 16, 2006.

The amendment revises limiting condition for operation (LCO) 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 "F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 225 to DPR-46

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC RidsNrrPMBBenney RidsRgn4MailCenter (KKennedy)

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NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 225 License No. DPR-46

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nebraska Public Power District (the licensee),

dated June 16, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Facility Operating License No. DPR-46 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, are hereby incorporated in the license. The Nebraska Public Power District shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: October 23, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 225 FACILITY OPERATING LICENSE NO. DPR-46 DOCKET NO. 50-298 Replace the following page of the Appendix A Technical Specifications with the enclosed revised page. The revised page is identified by an amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3.10-1 3.10-1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 225 TO FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated June 16, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061710087), Nebraska Public Power District (the licensee) requested changes to the Technical Specifications (TSs) for the Cooper Nuclear Station.

The proposed changes would revise limiting condition for operation (LCO) 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 "F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4.

2.0 REGULATORY EVALUATION

2.1 Inservice Leak and Hydrostatic Testing The Reactor Coolant System (RCS) serves as a pressure boundary and also serves to provide a flow path for the circulation of coolant past the fuel. In order to maintain RCS integrity,Section XI of the American Society of Mechanical Engineers (ASME) Pressure Vessel Code (Code) requires periodic hydrostatic and leakage testing. Hydrostatic tests are required to be performed once every 10 years and leakage tests are required to be performed each refueling outage. Appendix G to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR) states that pressure tests and leak tests of the reactor vessel that are required by Section XI of the ASME Code must be completed before the core is critical.

NUREG-1433, General Electric Plants, BWR/4, Revision 3, Standard Technical Specifications (STS), and NUREG-1434, General Electric Plants, BWR/6, Revision 3, STS both currently contain LCO 3.10.1, "Inservice Leak and Hydrostatic Testing Operation." LCO 3.10.1 was created to allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 "F provided certain secondary containment LCOs are met.

Technical Specification Task Force Traveler, (TSTF)-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," modifies LCO 3.10.1 to allow a licensee to implement LCO 3.10.1, while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 "F during testing. This modification does not alter current requirements for hydrostatic and leakage testing as required by Appendix G to 10 CFR Part 50.

2.2 Control Rod Scram Time Testing Control rods function to control reactor power level and to provide adequate excess negative reactivity to shut down the reactor from any normal operating or accident condition at any time during core life. The control rods are scrammed by using hydraulic pressure exerted by the control rod drive (CRD) system. Criterion 10 of Appendix A to 10 CFR Part 50 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in design-basis accidents and transient analyses is based on an assumed control rod scram time.

NUREG-1433, General Electric Plants, BWR/4, Revision 3, STS and NUREG-1434, General Electric Plants, BWR/6, Revision 3, STS, both currently contain surveillance requirements (SRs) to conduct scram time testing when certain conditions are met in order to ensure that Criterion 10 of Appendix A to 10 CFR Part 50 is satisfied. SR 3.1.4.1 requires scram time testing to be conducted following a shutdown greater than 120 days while SR 3.1.4.4 requires scram time testing to be conducted following work on the CRD system or following fuel movement within the affected core cell. Both SRs must be performed at reactor steam dome pressure greater than or equal to 800 pounds per square inch gauge (psig) and prior to exceeding 40 percent rated thermal power (RTP).

TSTF-484, Revision 0, would modify LCO 3.10.1 to allow SR 3.1.4.1 and SR 3.1.4.4 to be conducted in Mode 4 with average reactor coolant temperature greater than 212 "F. Scram time testing would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown." This modification to LCO 3.10.1 does not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR Part 50.

3.0 TECHNICAL EVALUATION

The existing provisions of LCO 3.10.1 allow for hydrostatic and leakage testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 "F, while imposing Mode 3 secondary containment requirements. Under the existing provision, LCO 3.10.1 would have to be implemented prior to hydrostatic and leakage testing. As a result, if LCO 3.10.1 was not implemented prior to hydrostatic and leakage testing, hydrostatic and leakage testing would have to be terminated if average reactor coolant temperature exceeded 212 "F during the conduct of the hydrostatic and leakage test. TSTF-484 modifies LCO 3.10.1 to allow a licensee to implement LCO 3.10.1 while hydrostatic and leakage testing is being conducted should average reactor coolant temperature exceed 212 "F during testing. The modification will allow completion of testing without the potential for interrupting the test in order to reduce reactor vessel pressure, cool the RCS, and restart the test below 212 "F. Since the current LCO 3.10.1 allows testing to be conducted while in Mode 4 with average reactor coolant temperature

greater than 212 "F, the proposed change does not introduce any new operational conditions beyond those currently allowed.

SR 3.1.4.1 and SR 3.1.4.4 require that control rod scram time be tested at reactor steam dome pressure greater than or equal to 800 psig and before exceeding 40 percent RTP.

Performance of control rod scram time testing is typically scheduled concurrent with inservice leak or hydrostatic testing while the RCS is pressurized. Because of the number of control rods that must be tested, it is possible for the inservice leak or hydrostatic test to be completed prior to completing the scram time test. Under existing provisions, if scram time testing cannot be completed during the LCO 3.10.1 inservice leak or hydrostatic test, scram time testing must be suspended. Additionally, if LCO 3.10.1 is not implemented and average reactor coolant temperature exceeds 212 "F while performing the scram time test, scram time testing must also be suspended. In both situations, scram time testing is resumed during startup and is completed prior to exceeding 40 percent RTP. TSTF-484, Revision 0, Use of TS3.10.1 for Scram Time Testing Activities, modifies LCO 3.10.1 to allow a licensee to complete scram time testing initiated during inservice leak or hydrostatic testing. As stated earlier, since the current LCO 3.10.1 allows testing to be conducted while in Mode 4 with average reactor coolant temperature greater than 212 "F, the proposed change does not introduce any new operational conditions beyond those currently allowed. Completion of scram time testing prior to reactor criticality and power operations results in a more conservative operating philosophy with attendant potential safety benefits.

It is acceptable to perform other testing concurrent with the inservice leak or hydrostatic test provided that this testing can be performed safely and does not interfere with the leak or hydrostatic test. However, it is not permissible to remain in TS 3.10.1 solely to complete such testing following the completion of inservice leak or hydrostatic testing and scram time testing.

Since the tests are performed with the reactor pressure vessel (RPV) nearly water solid, at low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurred. In addition, two low-pressure emergency core cooling systems (ECCS) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, "ECCS-Shutdown." In the event of a large RCS leak, the RPV would rapidly depressurize and allow operation of the low-pressure ECCS. The capability of the low-pressure ECCS would be adequate to maintain the fuel covered under the low-decay heat conditions during these tests.

Also, LCO 3.10.1 requires that secondary containment and standby gas treatment system be operable and capable of handling any airborne radioactivity or steam leaks that may occur during performance of testing.

The protection provided by the normally required Mode 4 applicable LCOs, in addition to the secondary containment requirements required to be met by LCO 3.10.1, minimizes potential consequences in the event of any postulated abnormal event during testing. In addition, the requested modification to LCO 3.10.1 does not create any new modes of operation or operating conditions that are not currently allowed. Therefore, the NRC staff finds the proposed change acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding issued on August 1, 2006 (71 FR 43535). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. NUREG-1433, "General Electric Plants, BWR/4, Revision 3, Standard Technical Specifications," August 31, 2003

2. NUREG-1434, "General Electric Plants, BWR/6, Revision 3, Standard Technical Specifications," August 31, 2003

3. Request for Additional Information (RAI) Regarding TSTF-484, April 7, 2006, ADAMS Accession Number ML060970568

4. Response to NRC RAIs Regarding TSTF-484, June 5, 2006, ADAMS Accession Number ML061560523

5. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Times Testing Activities," May 5, 2005, ADAMS Accession Number ML052930102

6. TSTF Response to NRC Notice for Comment, September 20, 2006, ADAMS Accession Number ML062650171 Principal Contributor: Aron Lewin Date: October 23, 2006

Cooper Nuclear Station cc:

Mr. Ronald D. Asche Senior Resident Inspector President and Chief Executive Officer U.S. Nuclear Regulatory Commission Nebraska Public Power District P. O. Box 218 1414 15th Street Brownville, NE 68321 Columbus, NE 68601 Regional Administrator, Region IV Mr. Gene Mace U.S. Nuclear Regulatory Commission Nuclear Asset Manager 611 Ryan Plaza Drive, Suite 400 Nebraska Public Power District Arlington, TX 76011 P.O. Box 98 Brownville, NE 68321 Director, Missouri State Emergency Management Agency Mr. John C. McClure P. O. Box 116 Vice President and General Counsel Jefferson City, MO 65102-0116 Nebraska Public Power District P. O. Box 499 Chief, Radiation and Asbestos Columbus, NE 68602-0499 Control Section Kansas Department of Health Mr. Paul V. Fleming and Environment Licensing Manager Bureau of Air and Radiation Nebraska Public Power District 1000 SW Jackson P.O. Box 98 Suite 310 Brownville, NE 68321 Topeka, KS 66612-1366 Mr. Michael J. Linder, Director Mr. Don Flater Nebraska Department of Environmental Bureau of Radiological Health Quality Iowa Department of Public Health P. O. Box 98922 Lucas State Office Building, 5th Floor Lincoln, NE 68509-8922 321 East 12th Street Des Moines, IA 50319 Chairman Nemaha County Board of Commissioners Mr. Keith G. Henke, Planner Nemaha County Courthouse Division of Community and Public Health 1824 N Street Office of Emergency Coordination Auburn, NE 68305 930 Wildwood P.O. Box 570 Jefferson City, MO 65102 Ms. Julia Schmitt, Manager Radiation Control Program Jerry C. Roberts, Director of Nuclear Nebraska Health & Human Services R & L Safety Assurance Public Health Assurance Nebraska Public Power District 301 Centennial Mall, South P.O. Box 98 P.O. Box 95007 Brownville, NE 68321 Lincoln, NE 68509-5007 Mr. John F. McCann, Director Mr. H. Floyd Gilzow Licensing, Entergy Nuclear Northeast Deputy Director for Policy Entergy Nuclear Operations, Inc.

Missouri Department of Natural Resources 440 Hamilton Avenue P. O. Box 176 White Plains, NY 10601-1813 Jefferson City, MO 65102-0176 October 2006