NLS2019022, Application for Technical Specifications Improvement to Eliminate Requirements for Hydrogen/Oxygen Monitors (TSTF-447, Rev. 1)
| ML19171A268 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/23/2019 |
| From: | Dent J Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2019022 | |
| Download: ML19171A268 (20) | |
Text
H Nebraska Public Power District NLS2019022 May 23, 2019 Always there when you need us Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 50.90
Subject:
Application for Technical Specifications Improvement to Eliminate Requirements for Hydrogen/Oxygen Monitors (TSTF-447, Rev. 1)
Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46
Dear Sir or Madam:
Pursuant to 10 CPR 50.90, Nebraska Public Power District (NPPD) hereby requests *an amendment to the Technical Specifications (TS) for Cooper Nuclear Station (CNS).
The proposed amendment will delete the TS requirements related to hydrogen/oxygen monitors.
The proposed TS changes support implementation of the revisions to 10 CFR50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of Nuclear Regulatory Commission-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003. Post-accident hydrogen recombiners are not installed at CNS; therefore, that portion of the TSTF will not be requested in this proposed amendment. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised, clean TS pages. Attachment 4 contains marked-up TS Bases pages which are provided for information only. Attachment 5 is a summary of regulatory commitments.
NPPD requests approval of the proposed license amendment by May 31, 2020. Once approved, the amendment shall be implemented within 60 days.
In accordance with 10 CPR 50.91(b)(l), "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated State of Nebraska Official.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2019022 Page 2 of2 If you should have any questions regarding this submittal please contact Jim Shaw, Licensing Manager, at ( 402) 825-2788.
I declare under penalty of perjury that the foregoing is true and correct.
Executed On: -----~,___,l....... 'd. J=-i!µ.,,:d=-=0..L..J 9_,___
/nae ent, Jr.
Vice President - Nuclear and Chief Nuclear Officer
/dv Attachments: 1. Description and Assessment
- 2. Proposed Technical Specifications Changes (Mark-up)
- 3. Revised Technical Specifications Pages
- 4. Proposed Technical Specifications Bases Changes (Mark-up) -
Information Only
- 5. Regulatory Commitments cc:
Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/ attachments USNRC-CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/ attachments
NLS2019022 Page 1 of 5 Application for Technical Specifications Improvement to Eliminate Requirements for Hydrogen/Oxygen Monitors (TSTF-447, Rev. 1)
Description and Assessment Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 1.0 Introduction 2.0 Description of Proposed Amendment 3.0
Background
4.0 Regulatory Requirements and Guidance 5.0 Technical Analysis 6.0 Regulatory Analysis 6.1 Verification and Commitments 7.0 No Significant Hazards Consideration 8.0 Environmental Evaluation
- 9. 0 Precedent 10.0 References
NLS2019022 Page 2 of 5
1.0 INTRODUCTION
The proposed license amendment deletes references to the hydrogen and oxygen monitors in Technical Specifications (TS) 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation" and deletes SR 3.3.3.1.2. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.
The changes are consistent with Revision 1 of Nuclear Regulatory Commission (NRC)-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003.
2.0 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 ofTSTF-447, the proposed TS changes include:
SR 3.3.3.1.2 Perform CHANNEL CALIBRATION of the Deleted SR Primary Containment H2 and 02 Analyzers.
SR 3.3.3.1.3 Perform CHANNEL CALIBRATION of each Deleted "except for the required PAM Instrumentation channel, except Primary Containment for the Primary Containment H2 and 02 H2 and 02 Analyzers" Analyzers.
Table 3.3.3.1-1 Function 6, Primary Containment H2 and 02 Deleted function Analyzer As described in NRC-approved Revision 1 ofTSTF-447, the changes to TS requirements results in changes to the TS Bases. Changes to the affected TS Bases pages are provided in Attachment 4 for information only and will be incorporated in accordance with the Cooper Nuclear Station (CNS) TS Bases Control Program.
3.0 BACKGROUND
The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other relat.ed documents.
4.0 REGULATORY REQUIREMENTS AND GUIDANCE
'~
The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003
NLS2019022 Page 3 of 5 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.
5.0 TECHNICAL ANALYSIS
Nebraska Public Power District (NPPD) has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447. NPPD has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to CNS and justify this amendment for the incorporation of the changes to the CNS TS.
6.0 REGULATORY ANALYSIS
A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.
6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, NPPD is making the following verifications and regulatory commitments:
- 1.
NPPD has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at CNS and is making a regulatory commitment to maintain that capability. The hydrogen monitor will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 60 days from the date of approval of this license amendment request.
- 2.
NPPD has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed at CNS and is making a regulatory commitment to maintain that capability. The oxygen monitor will be included in the TRM. This regulatory commitment will be implemented within 60 days from the date of approval of this license amendment request.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Nebraska Public Power District has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416). NPPD has concluded that the proposed determination presented in the notice is applicable to Cooper Nuclear Station and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
NLS2019022 Page 4 of 5 8.0 ENVIRONMENTAL EVALUATION NPPD has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416). NPPD has concluded that the staffs findings presented in the evaluation are applicable to CNS and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the NRC-approved TSTF. Due to differences between the CNS TS and the model TS in NUREG-1433, "Standard Technical Specifications, General Electric Plants BWR/4," Revision 2, which was in effect at the time, certain variances from the TSTF mark-up changes are necessary. These variances are discussed below and do not affect the no significant hazards consideration determination and environmental evaluation included in the SE, or the adoption and application of TSTF-447, Revision 1. These variations are similar to variations described in the license amendment request for Brunswick Steam Electric Plant dated July 26, 2004 (ML042180205).
- 1.
Post-accident hydrogen recombiners are not installed at CNS; therefore, that portion of the TSTF will not be requested in this proposed amendment.
- 2.
TSTF-447, Revision 1, modifies the Standard Technical Specifications (STS) 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," by deleting a Note to Condition C, eliminating Condition D, and re-lettering the subsequent Conditions.
The CNS TS do not have the Note in condition C nor is there a need to delete the existing Condition D. Therefore, these changes are not needed to adopt the TSTF.
- 3.
The CNS TS have a specific surveillance requirement (SR) (i.e., SR 3.3.3.1.2) which requires channel calibration of the Primary Containment H2 and 02 Analyzers. A similar SR, specific to the Primary Containment H2 and 0 2 Analyzers does not exist in NUREG-1433, Revision 2 and, as such, is not reflected in the TSTF-447, Revision 1, markups. Consistent with the intent of removing the H2 and 02 Analyzers from the TS, the requirements of CNS SR 3.3.3.1.2 are deleted and replaced with the designation "Deleted."
Associated with the change to CNS SR 3.3.3.1.2, CNS SR 3.3.3.1.3 currently requires channel calibration of the PAM instrumentation, except for the Primary Containment H2 and 0 2 Analyzers. Reference to the Primary Containment H2 and 0 2 Analyzers is deleted from the CNS SR 3.3.3.1.3.
- 4.
TSTF-447, Revision 1, modifies STS Table 3.3.3.1-1, "Post Accident Monitoring Instrumentation," by deleting Functions 10 and 11, for the Drywell and Containment H2 and 0 2 Analyzers, respectively. In the CNS TS, these functions exist as a single entry (Function 6, Primary Containment H2 and 02 Analyzers).
NLS2019022 Page 5 of5 Accordingly, this single function is deleted and replaced with the designation "Deleted."
- 5.
TSTF-447, Revision 1, modifies STS 5.6.7, "Post Accident Monitoring Report," to reflect the changes discussed in Item 2, above. Since the CNS TS do not require the changes discussed in Item 2, changes to the equivalent CNS TS 5.6.6 are not required.
10.0 REFERENCES
- 1.
Federal Register Notice, "Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process," published September 25, 2003 (68 FR 55416).
- 2.
Technical Specification Task Force Improved Standard Technical Specifications Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1.
NLS2019022 Page 1 of 3 Proposed Technical Specifications Changes (Mark-up)
Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 3.3-24 3.3-25
SURVEILLANCE REQUIREMENTS SR 3.3.3.1.1 SURVEILLANCE Perform CHANNEL CHECK on each required PAM Instrumentation channel.
PAM Instrumentation 3.3.3.1 FREQUENCY In accordance with the Surveillance Frequency Control Program
,'[DELETED] 'F"""'~------
........._~
~3.1.2~ Pel'ferffl GMANNel CALIBRATION of the Pr=imary IR aeeeRfaAee *:lith
~
Containment I b artd 0 2 Analyzers.
fi:te-81:1FVeillaAee SR 3.3.3.1.3 Cooper Perform CHANNEL CALIBRATION of each required PAM Instrumentation channel B'K6Elpt f.8r tf:le Primary Co11lah 11,,ent I 12 and ~
Analyzers.
3.3-24 Freqtteney Gel"ltrel PFegFaffi In accordance with the Surveillance Frequency Control Program Amendment No. 58-
Table ~.3.3.1*1 (page 1 of 1)
Post Accident Monitoring Jnstrunentation REQUIRED FUNCTION CHANNELS
- 1. Reactor Pressure 2
- a. Fuel Zone 2
- b. llide Range 2
- c. Steam Nozzle 1
- 3. Suppression Pool Level (Uide Range) 2
- 4. Primary Contail'Vl\\l!nt Cross Radiation Monitors 2
- 5. PCIV Position 2 per penetrat(yin
'fli,11 path(B) )
PAM Instrumentation 3.3.3.l COMDITIONS REFERENCED FRCl'i REQUIRED ACTION D.1 E
E E
F E
F E
-E-
- 6.
PrllllBPY 6eRtS1N!leRt II, & S,,":.11Slynr
~rimary Contairvnent Pressure a, Drywell Narrow Range
- 2 E
u
)
- b. Drywell Uide Range 2
E
- c. Suppression Chamber Vide Range 2
E
- 8. Suppression Pool Uater Tllfll>erature z<c>
E (a) Not required for isolation volves whose associated penetration flow path is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with floH through the valve secured.
(b) Only one position Indication channel is required for penetration flow paths with only one installed control room indication charuiel.
(c) A channel requires a minimt111 of four resistance t~rature detectors (RTDs) to be OPERABLE with no two adjacent RTDs inoperable.
Cooper 3.3-25 Amendment No. ~
NLS2019022 Page 1 of 3 Revised Technical Specifications Pages Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 3.3-24 3.3-25
PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SR 3.3.3.1.1 SR 3.3.3.1.2 SR 3.3.3.1.3 Cooper SURVEILLANCE FREQUENCY Perform CHANNEL CHECK on each required PAM In accordance with Instrumentation channel.
the Surveillance Frequency Control Program
[DELETED]
[DELETED]
Perform CHANNEL CALIBRATION of each required In accordance with PAM Instrumentation channel.
the Surveillance Frequency Control Program 3.3-24 Amendment No.
FUNCTION
- 1.
Reactor Pressure
- 2.
- a.
Fuel Zone
- b.
Wide Range
- c.
Steam Nozzle
- 3.
Suppression Pool Level (Wide Range)
Table 3.3.3.1-1 (page 1 of 1)
Post Accident Monitoring Instrumentation REQUIRED CHANNELS 2
2 2
2
- 4.
Primary Containment Gross Radiation Monitors 2
- 5.
PCIV Position
- 6.
[DELETED]
- 7.
Primary Containment Pressure
- a.
Drywell Narrow Range
- b.
Drywell Wide Range C.
Suppression Chamber Wide Range
- 8.
Suppression Pool Water Temperature 2 per penetration flow path(aXbl 2
2 2
z(c)
PAM Instrumentation 3.3.3.1 CONDITIONS REFERENCED FROM REQUIRED ACTION D.1 E
E E
F E
F E
E E
E E
(a) Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.
(c) A channel requires a minimum of four resistance temperature detectors (RTDs) to be OPERABLE with no two adjacent RTDs inoperable.
Cooper 3.3-25 Amendment No.
NLS2019022 Page 1 of 5 Proposed Technical Specifications Bases Changes (Mark-up) -
Information Only Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages B 3.3-65 B 3.3-66 i3 3.3-99 B 3.3-70
B,!\\SES LCO (continued)
PAM lnsJrumentatiori B3.3.;3.1 flow path With _two acffye valves. for containment r:ienetraitioris with only oneactfv~ PCIV having control room indicati9n, Note (b) requires a single channel of. valve position indication to be OPERABLE. This is sufficient to tedun~antly verify the _i$olation status of each isolable penetration via indicated status oflhe active valve, a_s applicelb!e; and prior knowledge of passive valve or system boundary. status. lf a penetration flow path is isolated, position indication for the PCIV(s} in the associated penetration flow path 1s*.not nee.dad to determine.status. Thi;irefore, the positiQn indication for valves in an isolated penetration flow patll is nQt requJi"ed to be bPERABLE.
The PCIVposition PAM instrumentation consists of position.s\\'l(itches, associated wiring and control room indicating lamps for active PCIYs (check valves and manual valves are not-required to have position inaic~tion}. Therefqre, the PAM §pe~ffication ~eals_ specifically.witb these
- instrument channels.
~Pfimef\\'
Cm=ite1Ameflt HydroaeA 8fld_ Oxyqefl AAel\\'zers Cooper P1if,1dl1y *..xn1tai111mfot hyd1oge11 a11d oxygen ~maly2.e1s afe Category I iflst~mems pl'O'iided to deteet high t::iydmgeA or mtygeH eeAeef'itratieA sgnditiQns that ~pl"8sBRt a p8tential 'fur s~nta1RM&Rt bF&aGh, Th(s
\\'aFiable is i:tlse iA'l13eftaAt iA *ielifyiRg tt:te adeetuaey ef m1tigat1Rg aetieRs.
The:s)IStern eoHsists oftvto BHslyzers ~~hiGR _are.divisioflally SE;JP8f8Jed.
Eaeh aAafyzer eeHtaiAs a t::iytiregeA ~Ad. afl eeygeA doteeier. \\O/hil~ in se r...*iee. tt::ie oof'ltaii'\\ment air is se m pied. frei'fl oi'te. ef feu r saFHple. streaFAs.
PoiH=t£i 1, 2, efid_~ a.re fre"' tt::i*eef)~ll aAd p~lflt4 is'frem~the su131:)Fess1en ehamber. The.Saffil:)le afr fJ~sses thro_ugh ihe Hyetr=ageA AAalyzer aRd Qfy-gefl ARal)'2er iA pafflllel. - 0Aee the air t::ias 13eeA arial~ed, _it is F0&1i:Red te tAe SYl:)fJFessieri s!=laJT113et air spaee. 1J1;1rit19 AOFFflal 013eFaijOR, the DhfisieR -1 analyze_r is iA stancley and the Division II aRelyz!eF is iA seF\\*iee. The,EIAaly:fPFS ai:e eapaele ef EteieFF.AiFtiAg [;J*)'gee soneehtratioR in the r:ango af Q. to 10% {Di\\'. 1) and O.to @Q% (D1\\.'. 2), ane hydrogeA ~pReentratiefl. ifi the: raRgEI of.0 te 30%: (Di'i'isii3as_ 1 ~Fi~ 2). The t:iydrogen an(;t OJEJ'gen concentration from ea_ch ana_l~f:l~ may be displayed eA,ts assoeiateel eoAtrol r:eoFA Feeefder. Therofero, the PAM
§,r,ef?ifiesti~fl deals sr,eeifieelly V1*itl=I thes~- r,9a=tions ef U'le e.f'ie.!y~r QhilAnels.
1112sn2 I
BASES.
LCO (continued~
Cooper PAM lri;;trum~ntation*
B ~.3.3.1 The aFtal)'2t;;Fifl standby is eensfdered QPEflABLE e*weA thatlfJh a itJeFFA' up peried up to 1 hot1r may be r,eeded t6 pla.ee it iR eperalieR. _Tt=lie,s ooilsistenh-*,itli RC 1.7, Seetion r?-1 (8), tt-lat n9tod ado~tioA ofthe ftiflc.tional r~cjuileme1 its b) licensees ii, lieu of the Pe,st--TMI 30 rnintrle reqt1iremem: FC:;sults_ in ti=ie A~Fe§eR.fflBFlitaFS b_eing funetlonal *tJitAiR QO min biles after tl=to initiation of safety.injostion. Tl=lis ~et:iod af tiFRe iRGl~des equipme.,t.varm up but net ~quipffleftt ealibratieA.
- 7.
Primary Containment Pressure primary contafr1ment pressure is a Category I variable provided -to vei:ify RCS and containment integrity a:nd to Verifylhe effectiveness of ECCS acticms ~en lQ preven{conta_i11mentbr:each.. Two ~rywell narrow range channels monitor ~ -_range of -_5 psig to + 70 psig. TWQ drywell Wide f1il_hge ctiannels monitor a range ofo psig to 250 psig. Two suppression.
~hambefr wide range charinels monitor a range of,.,5 psig to + 70 psig.
Each of the_ six channels ha~ {I separate transmitter:. The six transmitters
_ qispiay their signals on recorders in the control room. The~e transmitters
-ahd recorders are the* primary 1ndicati9h used by the operator during an
-accipent. Therefore, the PAM ?Pecificationdeals specifically With these portions of the instrument channel.
- 8.
Suppression Pool Water Temperature Suppres*sion pool water temperature-is c1 Category I variable provided to detect a con_dition that could potential_ly l~ad to conta,inment breaqh ari"ci to verify the effectiveness ofECCS actions taken to prev.1;1nt qo.ntainment breach*. The suppret1sion pooi water temperature instrumentation allows operators to detect trends in s_uppres$ion pool water tem~ri,iture*.
- suppression chamber water temperature is-monitored* by two* redundant channel$. Each f::hannel consists of a multipoint recorder with inputs from 8 resistance temperature deiectors {RTOs), that mottit9rtefrip~rature:,.over a range o{0°F to 250°E The RTDs are mounted in. thetmoWells-insmlied in.. the suppression chamtler shE!ll b.eJciY!' the minimllm water le.val. A GhanneUs com,;idered Of>"~MBLI= with up to 4 RT[)s inoperable, provided no 2 adjacentRIDs are inoperable. This minimum requirement rhaint~i9st~mperatur:e mtjn_itpriog in each quadrant of the suppression chc1mber. This i~ acceptable based on engin¢ering j1,idgeme1rit considering the temperature response profile of the suppression cham~er w~ter volume for previ9usly ~11alyzed events* an~ the i'nost sliallenged RTDs inoperable.
B 3:3.,.66 11/25,'t2 J
BASES PAM Instrumentation B 3.3.3.1 ACTIONS (continued)
For the majority of Functions in Table 3.3.3.1-1, if any Required Action and associated Completion Time of Condition C is not met, the plant must be brought to a MODE in which the LCO not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
Since alternate means of monitoring primary containment area radiation have been developed and tested, the Required Action is not to shut down the plant, but rather to follow the directions of Spe~ification 5.6.6. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.
SURVEILLANCE REQUIREMENTS SR 3.3.3.1.1 Cooper Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel agc!inst a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
The high radiation instrumentation should be compared to similar plant instruments located throughout the plant. n,e CHANNEL Cl IECI< dees ngt apply tQ th& primary sgntainm8nt ~l and o~ analy:z&r that is in a normal standby senfig~ratien.
- Agreement criteria are determined by the plant staff, based on a combinatipn of the channel instrume11t uncertainties, including isolation, B 3.3-69 05/17/17
BASES PAM Instrumentation B 3.3.3.1 SURVEILLANCE REQUIREMENTS (continued) indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
!SR 3.3.3.1.2 [DELETED] ~
This SR requires REFERENCES Cooper SR 3.3.3.1.2 BF1e SR 3.3.3.1.3 These SRs Fequirn a CHANNEL CALIBRATION to be performed.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy. There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology. For the Primary Containment Gross Radiation Monitors, the CHANNEL CALIBRATION consists of an electronic calibration of the channel, excluding the detector, for range decades ~ 1 O R/hour and a one point calibration check of the detector with an installed or portable gamma source for range decades
< 10 R/hour. For the PCIV Position Function, the CHANNEL CALIBRATION consists of verifying the remote indication conforms to actual value position.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
- 1.
Regulatory Guide 1.97, "Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2," December 1980.
- 2.
Letter from G. A. Trevors (NPPD) to U.S. NRC dated April 12, 1990, "NUREG-0737, Supplement 1-:-Regulatory Guide 1.97 Response, Revision IX."
B 3.3-70 0§/29/18
NLS2019022 Page 1 of2 Regulatory Commitments Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46
NLS2019022 Page 2 of2 This table identifies actions discussed in this letter which Nebraska Public Power District commits to perform. Any other actions discussed in this submittal are described for the Nuclear Regulatory Commission's information and are not regulatory commitments.
TYPE (check one)
ONE-CONTINUING SCHEDULED TIME COMPLETION COMMITMENT/COMMITMENT NO.
ACTION COMPLIANCE DATE NLS2019022-01 NPPD has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis Implementation accidents is installed at CNS and is making a X
ofTS regulatory commitment to maintain that capability.
Amendment The hydrogen monitor will be included in the Technical Requirements Manual (TRM).
NLS2019022-02 NPPD has verified that an oxygen monitoring system capable of verifying the status of the Implementation inerted containment is installed at CNS and is X
ofTS making a regulatory commitment to maintain that Amendment capability. The oxygen monitor will be included in the Technical Requirements Manual (TRM).