ML19238A007
| ML19238A007 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/30/2019 |
| From: | Thomas Wengert Plant Licensing Branch IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Wengert T, NRR/DORL/LPLIV, 415-4037 | |
| References | |
| EPID L-2019-LLA-0050 | |
| Download: ML19238A007 (29) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 30, 2019 Mr. John Dent, Jr.
Vice President and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 263 RE:
ADOPTION OF TSTF-514, REVISION 3, "REVISE BWR OPERABILITY REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION" (EPID L-2019-LLA-0050)
Dear Mr. Dent:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 263 to Renewed Facility Operating License No. DPR-46 for Cooper Nuclear Station (CNS). The amendment consists of changes to the technical specifications (TSs) in response to your application dated February 28, 2019.
The amendment revises the CNS TSs to define a new time limit for restoring inoperable reactor coolant system (RCS) leakage detection instrumentation to operable status and establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable. The request was submitted in accordance with NRG-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-514, Revision 3, "Revise BWR [Boiling-Water Reactor] Operability Requirements and Actions for RCS Leakage Instrumentation," as part of the consolidated line item improvement process.
J. Dent, Jr. A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
-~~t-Thomas J. Wen rt, Senio~roject Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. Amendment No. 263 to DPR-46
- 2. Safety Evaluation cc: Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 263 Renewed License No. DPR-46
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Nebraska Public Power District (the licensee),
dated February 28, 2019, 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 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.
Enclosure 1
- 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 Renewed 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. 263, are hereby incorporated in the license. The licensee 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 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: October 30, 2019
ATTACHMENT TO LICENSE AMENDMENT NO. 263 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 COOPER NUCLEAR STATION DOCKET NO. 50-298 Replace the following pages of the Renewed Facility Operating License No. DPR-46 and Appendix A Technical Specifications with the enclosed revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT ii ii 3.4-11 3.4-11 3.4-12 3.4-12 3.4-13 3.4-13 3.4-14 3.4-14 3.4-15 3.4-15 3.4-16 3.4-16 3.4-17 3.4-17 3.4-18 3.4-18 3.4-19 3.4-19 3.4-20 3.4-20 3.4-21 3.4-21 3.4-22 3.4-22.
3.4-23 3.4-23 3.4-24
(5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
( 1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 263, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p ). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Cooper Nuclear Station Safeguards Plan," submitted by letter dated May 17, 2006.
NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.
(4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if Amendment No. 263
TABLE OF CONTENTS (continued) 3.4 REACTOR COOLANT SYSTEM (RCS) ....................................................... 3.4-1 3.4.1 Recirculation Loops Operating ............................................................... 3.4-1 3.4.2 Jet Pumps .............................................................................................. 3.4-4 3.4.3 Safety/Relief Valves (SRVs) and Safety Valves (SVs) ........................... 3.4-6 3.4.4 RCS Operational LEAKAGE .................................................................. 3.4-8 3.4.5 RCS Leakage Detection Instrumentation ............................................... 3.4-10 3.4.6 RCS Specific Activity .............................................................................. 3.4-13 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown .................................................................... 3.4-15 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown .................................................................. 3.4-18 3.4.9 RCS Pressure and Temperature (PIT) Limits ......................................... 3.4-20 3.4.10 Reactor Steam Dome Pressure ............................................................. 3.4-24 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ......................................................................... 3.5-1 3.5.1 ECCS - Operating .................................................................................. 3.5-1 3.5.2 RPV Water Inventory Control ................................................................. 3.5-7 3.5.3 RCIC System ......................................................................................... 3.5-12 3.6 CONTAINMENT SYSTEMS ......................................................................... 3.6-1 3.6.1.1 Primary Containment ............................................................................. 3.6-1 3.6.1.2 Primary Containment Air Lock ................................................................ 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs) ...................................... 3.6-8 3.6.1.4 Drywell Pressure .................................................................................... 3.6-16 3.6.1.5 Drywell Air Temperature ........................................................................ 3.6-17 3.6.1.6 Low-Low Set (LLS) Valves ..................................................................... 3.6-18 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers ............... 3.6-20 3.6.1.8 Suppression-Chamber-to-Drywell Vacuum Breakers ............................. 3.6-23 3.6.1.9 Residual Heat Removal (RHR) Containment Spray ............................... 3.6-25 3.6.2.1 Suppression Pool Average Temperature ................................................ 3.6-27 3.6.2.2 Suppression Pool Water Level ............................................................... 3.6-30 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling ..................... 3.6-31 3.6.3.1 Primary Containment Oxygen Concentration ......................................... 3.6-33 3.6.4.1 Secondary Containment.. ....................................................................... 3.6-34 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) .................................. 3.6-36 3.6.4.3 Standby Gas Treatment (SGT) System .................................................. 3.6-40 3.7 PLANT SYSTEMS ....................................................................................... 3. 7-1 3.7.1 Residual Heat Removal Service Water Booster (RHRSWB) System ..... 3.7-1 3.7.2 Service Water (SW) System and Ultimate Heat Sink (UHS) ................... 3.7-3 3.7.3 Reactor Equipment Cooling (REC) System ............................................ 3.7-6 3.7.4 Control Room Emergency Filter (CREF) System ................................... 3.7-8 3.7.5 Air Ejector Offgas ................................................................................... 3.7-11 3.7.6 Spent Fuel Storage Pool Water Level .................................................... 3.7-13 3.7.7 The Main Turbine Bypass System .......................................................... 3.7-14 (continued)
Cooper ii Amendment No. 263
RCS Leakage Detection Instrumentation 3.4.5 ACTIONS ( continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE--------------- C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Only applicable when the the primary containment drywell atmospheric atmosphere.
gaseous radiation monitor is the only OPERABLE AND monitor.
C.2 Monitor RCS LEAKAGE Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by administrative means.
Drywell floor drain sump flow monitoring system AND inoperable.
C.3 Restore drywell floor drain 7 days sump flow monitoring system to OPERABLE status.
D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, B, or C not AND met.
D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. All required leakage E.1 Enter LCO 3.0.3. Immediately detection systems inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Perform a CHANNEL CHECK of required drywell In accordance with atmospheric monitoring channel. the Surveillance Frequency Control Program
( continued)
Cooper 3.4-11 Amendment No. 263
RCS Leakage Detection Instrumentation 3.4.5 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.5.2 Perform a CHANNEL FUNCTIONAL TEST of In accordance with required leakage detection instrumentation. the Surveillance Frequency Control Program SR 3.4.5.3 Perform a CHANNEL CALIBRATION of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program Cooper 3.4-12 Amendment No. 263
RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity s 0.2 µCi/gm.
APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant specific ---------------------NOTE-------------------
activity > 0.2 µCi/gm and s LCO 3.0.4.c is applicable.
4.0 µCi/gm DOSE ------------------------------------------------
EQUIVALENT 1-131.
A.1 Determine DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> EQUIVALENT 1-131.
AND A.2 Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT 1-131 to within limits.
B. Required Action and B.1 Determine DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion Time EQUIVALENT 1-131.
of Condition A not met.
AND OR '
B.2.1 Isolate all main steam 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Reactor Coolant specific lines.
activity > 4.0 µCi/gm DOSE EQUIVALENT 1-131. OR (continued)
Cooper 3.4-13 Amendment No. 263
RCS Specific Activity 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2.2.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B.2.2.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 -------------------------------NOTE--------------------------------
Only required to be performed in MODE 1.
Verify reactor coolant DOSE EQUIVALENT 1-131 In accordance with specific activity is :S 0.2 µCi/gm. the Surveillance Frequency Control Program Cooper 3.4-14 Amendment No. 263
RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
NOTES-------------------------------------------
- 1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
- 2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillances.
APPLICABILITY: MODE 3, with reactor steam dome pressure less than the shutdown cooling permissive pressure.
ACTIONS
NOTE------------------------------------------------------------
Separate Condition entry is allowed for each RHR shutdown cooling subsystem.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Initiate action to restore Immediately cooling subsystems RHR shutdown cooling inoperable. subsystem(s) to OPERABLE status.
(continued)
Cooper 3.4-15 Amendment No. 263
RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.
AND A.3 Be in MODE 4. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B. No RHR shutdown cooling 8.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one AND recirculation pump to operation.
No recirculation pump in operation. AND B.2 Verify reactor coolant 1 hourfrom circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND 8.3 Monitor reactor coolant Once per hour temperature and pressure.
Cooper 3.4-16 Amendment No. 263
RHR Shutdown. Cooling System - Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 -------------------------------N()TE--------------------------------
Not required to be met until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after reactor steam dome pressure is less than the shutdown cooling permissive pressure.
Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program Cooper 3.4-17 Amendment No. 263
RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.
NOTES-------------------------------------------
- 1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
- 2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillances.
APPLICABILITY: MODE 4.
ACTIONS
NOTE-----------------------------------------------------------
Separate Condition entry is allowed for each shutdown cooling subsystem.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> cooling subsystems of decay heat removal is inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter (continued)
Cooper 3.4-18 Amendment No. 263
RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown cooling B.1 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from subsystem in operation. circulating by an alternate discovery of no method. reactor AND coolant circulation No recirculation pump in AND operation.
Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.2 Monitor reactor coolant Once per hour temperature.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program Cooper 3.4-19 Amendment No. 263
RCS PIT Limits 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 RCS Pressure and Temperature (PIT) Limits LCO 3.4.9 RCS pressure, RCS temperature, RCS heatup and cooldown rates, and the recirculation pump starting temperature requirements shall be maintained within the limits specified in the PTLR.
APPLICABILITY: At all times.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ---------------NOTE-------------- A.1 Restore parameter(s) to 30 minutes Required Action A.2 shall be within limits.
completed if this Condition is entered. AND A.2 Determine RCS is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Requirements of the LCO acceptable for continued not met in MODE 1, 2, or 3. operation.
B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)
Cooper 3.4-20 Amendment No. 263
RCS PIT Limits 3.4.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. ---------------NOTE-------------- C. 1 Initiate action to restore Immediately Required Action C.2 shall parameter(s) to within be completed if this limits.
Condition is entered.
AND Requirements of the LCO C.2 Determine RCS is Prior to entering not met in other than acceptable for operation. MODE 2 or 3.
MODES 1, 2, and 3.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------------------NOTE--------------------------------
Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing.
Verify: In accordance with the Surveillance
- a. RCS pressure and RCS temperature are Frequency Control within the applicable limits specified in the Program curves in the PTLR; and
(continued)
Cooper 3.4-21 Amendment No. 263
RCS PIT Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.9.2 Verify RCS pressure and RCS temperature are within Once within the criticality limits specified in the PTLR. 15 minutes prior to control rod withdrawal for the purpose of achieving criticality SR 3.4.9.3 --------------------------------N()TE-------------------------------
Only required to be met in MODES 1, 2, 3, and 4 during recirculation pump startup.
Verify the difference between the bottom head Once within coolant temperature and the reactor pressure vessel 15 minutes prior to (RPV) coolant temperature is within the limits each startup of a specified in the PTLR. recirculation pump SR 3.4.9.4 ---------------------------------NOTE------------------------------
Only required to be met in MODES 1, 2, 3, and 4 during recirculation pump startup.
Verify the difference between the reactor coolant Once within temperature in the recirculation loop to be started and 15 minutes prior to the RPV coolant temperature is within the limits each startup of a specified in the PTLR. recirculation pump (continued)
Cooper 3.4-22 Amendment No. 263
RCS PIT Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.9.5 -------------------------------N()TE--------------------------------
()nly required to be performed when tensioning the reactor vessel head bolting studs.
Verify reactor vessel flange and head flange In accordance with temperatures are within the limits specified in the the Surveillance PTLR. Frequency Control Program SR 3.4.9.6 -------------------------------N()TE--------------------------------
Not required to be performed until 30 minutes after RCS temperature s 80°F in M()DE 4.
Verify reactor vessel flange and head flange In accordance with temperatures are within the limits specified in the the Surveillance PTLR. Frequency Control Program SR 3.4.9.7 -------------------------------N()TE--------------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after RCS temperature s 90°F in M()DE 4.
Verify reactor vessel flange and head flange In accordance with temperatures are within the limits specified in the the Surveillance PTLR. Frequency Control Program Cooper 3.4-23 Amendment No. 263
Reactor Steam Dome Pressure 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Reactor Steam Dome Pressure LCO 3.4.1 O The reactor steam dome pressure shall be s 1020 psig.
APPLICABILITY: MODES 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes pressure not within limit. dome pressure to within limit.
B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify reactor steam dome pressure is s 1020 psig. In accordance with the Surveillance Frequency Control Program Cooper 3.4-24 Amendment No. 263
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 263 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By application dated February 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19071A111 ), Nebraska Public Power District (NPPD, the licensee) requested changes to the technical specifications (TSs) for Cooper Nuclear Station.
The proposed changes would define a new time limit for restoring inoperable reactor coolant system (RCS) leakage detection instrumentation to operable status and establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable.
The licensee stated that the license amendment request (LAR) is consistent with U.S. Nuclear Regulatory Commission (NRC or the Commission)-approved Revision 3 to Technical Specifications Task Force (TSTF) Standard Technical Specifications (STSs) Change Traveler TSTF-514, Revision 3, "Revise BWR [Boiling-Water Reactor] Operability Requirements and Actions for RCS Leakage Instrumentation," dated November 24, 2010 (ADAMS Accession No. ML103280389). The availability of this TS improvement was published in the Federal Register on December 17, 2010 (75 FR 79048), as part of the consolidated line item improvement process (CLIIP).
2.0 REGULATORY EVALUATION
2.1 TSTF-514 Applicable Regulatory Requirements/Criteria Under Section 50.92(a) of Title 10 of the Code of Federal Regulations (10 CFR), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be "reasonable assurance" that the activities at issue will not endanger the health and safety of the public.
Enclosure 2
The NRC's regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36. Paragraph (c)(2)(i) of 10 CFR 50.36 states that limiting conditions for operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
The NRC's guidance for the format and content of BWR TSs can be found in NUREG-1433, Revision 4.0. STS 3.4.6, "RCS Leakage Detection Instrumentation," in NUREG-1433, contains the guidance specific to the RCS leakage detection instrumentation for BWRs. Cooper Nuclear Station is a BWR/4 facility.
The Bases for STS 3.4.6 contained in NUREG-1433 provide background information, the applicable safety analyses, a description of the limiting condition for operation (LCO), the applicability for the RCS leakage detection instrumentation TSs, and describe the Actions and surveillance requirements. The TS Bases provide the purpose or reason for the TSs, which are derived from the analyses and evaluation included in the safety analysis report, and for these TSs, the RCS leakage detection instrumentation design assumptions and licensing basis for the plant.
As stated in NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity" (ADAMS Accession No. ML051780073), the reactor coolant activity assumptions for primary containment/drywell atmosphere gaseous radioactivity monitors may be nonconservative. This means that the monitors may not be able to detect a 1 gallon per minute (gpm) leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under all likely operating conditions.
The issue described in IN 2005-24 has raised questions regarding operability requirements for primary containment/drywell atmosphere gaseous radioactivity monitors. TSTF-514, Revision 3, includes a new TS Condition for RCS leakage detection instrumentation to establish Required Actions for operation during conditions of reduced monitoring sensitivity because the gaseous radioactivity instrumentation is the only operable instrument.
The regulation at 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC) 30, "Quality of reactor coolant pressure boundary,"
specifies means for detecting and, to the extent practical, identifying the location of the source of RCS leakage. Regulatory Guide (RG) 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," dated May 1973 (ADAMS Accession No. ML003740113),
describes acceptable methods of implementing GDC 30 with regard to the selection of leakage detection systems for the reactor coolant pressure boundary.
RG 1.45, Revision 0, Regulatory Position C.2, states that, Leakage to the primary reactor containment from unidentified sources should be collected and the flow rate monitored with an accuracy of one gallon per minute (gpm) or better.
RG 1.45, Revision 0, Regulatory Position C.3 states that, At least three separate detection methods should be employed and two of these methods should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may be selected from the following:
- a. monitoring of condensate flow rate from air coolers, [or]
- b. monitoring of airborne gaseous radioactivity.
Humidity, temperature, or pressure monitoring of the containment atmosphere should be considered as alarms or indirect indication of leakage to the containment.
RG 1.45, Revision 0, Regulatory Position C.5 states that, The sensitivity and response time of each leakage detection system in regulatory position 3. above employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour.
RG 1.45, Revision 0, "Detector Response Time," states, in part, that, In analyzing the sensitivity of leak detection systems using airborne particulate or gaseous radioactivity, a realistic primary coolant radioactivity concentration assumption should be used. The expected values used in the plant environmental report would be acceptable.
RG 1.45, Revision 1, "Guidance on Monitoring and Responding to Reactor Coolant System Leakage," was issued in May 2008 (ADAMS Accession No. ML073200271 ). RG 1.45, Revision 1, describes methods for implementing GDC 30 that are different from those in RG 1.45, Revision 0, and was developed and issued to support new reactor licensing.
Revision 1 addresses having two TS leakage detection methods capable of detecting a 1 gpm leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provides adequate leakage detection capability from a safety perspective. It recommends that other potential indicators (including the gaseous radiation monitors) be maintained even though they may not have the same detection capability. These indicators, in effect, provide additional defense-in-depth.
2.2 CNS Regulatory Requirements/Criteria In the LAR dated February 28, 2019, the licensee states, in part:
The following regulatory requirements apply to CNS:
CNS was designed and constructed to meet the principle [principal] design criteria described in the AEC's [Atomic Energy Commission's] proposed rule, "General Design Criteria for Nuclear Power Plant Construction P~rmits,"
published in the Federal Register on July 11, 1967 (32 FR 10213). The degree of conformance to the 1967 proposed GDC is described in Appendix F, "Conformance to AEC Proposed General Design Criteria" to the USAR [Updated
Safety Analysis Report] for CNS. CNS' current licensing basis incorporates the proposed GDC that are equivalent to the 10 CFR Part 50, Appendix A, GDC 30.
Criterion 30, "Quality of reactor coolant pressure boundary," requires that means be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage. The proposed license amendment is consistent with the AEC proposed GDC in that the design requirements for instrumentation, reactor coolant leak detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected.
In the LAR, the licensee states, in part, regarding the RG 1.45, Regulatory Position stated in TSTF-514:
RG 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems,"
May 1973, describes acceptable methods of implementing this requirement with regard to the selection of leakage detection systems for the reactor coolant boundary. The position of RG 1.45 is that at least three different detection methods should be employed. Two of these methods should be: (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may involve either monitoring of condensate flow rate from air coolers or monitoring of gaseous radioactivity. The RG recommends that the sensitivity and r~sponse time of each leakage detection system employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour. CNS conforms to the regulatory position outlined in RG 1.45. However, as discussed in the Technical Analysis
[in the licensee's application], the gaseous portion of the drywall atmospheric radiation monitor does not meet the sensitivity requirements of RG 1.45 nor is CNS specifically committed to RG 1.45. This difference does not alter the conclusion that the proposed change is applicable to CNS.
Section IV-10, "Reactor Coolant System Leakage Rate Limits," of the CNS USAR provides details associated with the containment atmospheric leakage detection systems in use at CNS. TS 3.4.5 establishes LCOs for three of these systems:
(1) the drywall floor drain sump flow monitoring system, (2) the drywall atmospheric particulate monitoring system, and (3) the drywall atmospheric gaseous monitoring system. As discussed in the USAR, drywall equipment sump temperature, suppression pool water level, primary containment pressure, and primary containment temperature also provide a means for detecting leaks within the primary containment.
2.3 Proposed TS Changes In adopting the changes to TSs included in TSTF-514, Revision 3, the licensee proposed to revise the Conditions and Required Actions for TS 3.4.5, "RCS Leakage Detection Instrumentation." The licensee proposed adding new Condition C to TS 3.4.5. New Condition C would be applicable when the drywall atmospheric gaseous monitoring system is the only operable RCS leakage detection system. This new Condition is necessary because improved fuel integrity and the resulting lower primary coolant radioactivity concentration affect the response of a plant's drywall atmospheric gaseous monitoring system to a greater extent than the response of other RCS leakage detection monitors to leakage radioactivity. The proposed Required Actions for new Condition C require the licensee to analyze grab samples of the primary containment atmosphere once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, restore the drywall floor drain sump
flow monitoring system to operable status within 7 days, and monitor RCS leakage by administrative means once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
In addition, in the LAR, the licensee proposed the following administrative measures:
The administrative means of monitoring include diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions.
NPPD will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell equipment sump temperature, suppression pool water level, primary containment pressure, and primary containment temperature.
There are diverse alternative methods for determining that RCS leakage has not increased, from which appropriate indicators may be selected based on plant conditions. NPPD will utilize the following method or methods considering the current plant conditions and historical or expected. sources of unidentified leakage: drywell equipment sump temperature, suppression pool water level, primary containment pressure, and primary containment temperature. Actions to verify that these indications have not increased since the required monitors became inoperable and analyze primary containment atmospheric grab samples are sufficient to alert the operating staff to an unexpected increase in RCS leakage.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the licensee's request as follows. First, the staff compared the plant's license, licensing basis, and design with the baseline assumptions in the model TSTF. Next, the staff considered how the licensee proposed to adopt TSTF-514 in light of CNS's plant-specific design and licensing. The staff then considered if the licensee showed that adopting TSTF-514 would provide reasonable assurance of public health and safety, and compliance with the Commission's regulations.
3.1 NRC Staff Evaluation The licensee proposed adding new Condition C to TS 3.4.5. New Condition C Required Actions require monitoring RCS leakage by obtaining and analyzing grab samples of the primary containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; and taking action to restore monitoring capability using another monitor within 7 days. Condition C would be applicable when the drywell atmospheric gaseous monitoring system is the only operable RCS leakage detection system.
The associated proposed Actions and Completion Times are adequate because monitoring the RCS by administrative means, coupled with primary containment atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified leakage. The grab samples provide a method of detecting particulate and gaseous radioactive material in the primary containment atmosphere. However, taking frequent grab samples will ensure there is no significant loss of monitoring capability during the Required Action Completion Time. The 12-hour interval is reasonable given the availability of the drywell atmospheric gaseous monitoring system. Allowing 7 days to restore another RCS leakage monitor to operable status is reasonable given the diverse methods employed in the Required Actions to detect an RCS leak and the low probability of a large RCS leak during this period. Proposed Condition C is
conservative relative to the STS, sufficiently alerts the operating staff, provides a comparable ability to detect RCS leakage, and provides time intervals that are reasonable. Therefore, the NRC staff determined that proposed Condition C provides reasonable assurance of safety.
The TSTF-514 Traveler and SE discuss the applicable regulatory requirements and guidance, including GDC 30 of 10 CFR Part 50, Appendix A. TSTF-514 states, in part, "Many plants pre-date the issuance of RG 1.45 and their plant-specific licensing basis is described in their UFSAR. In either case, the appropriate sensitivity of the atmospheric radiation monitors is dependent on the design assumptions and the plant licensing basis of each licensee."
The CNS USAR, Revision XXIX,Section IV.10.3.2, states, in part:
In addition to the existing leak detection system within the drywell during normal operation, a two channel (particulate and gas) radiation monitor is used to draw an air sample from containment. This monitor, the Drywell Atmospheric Monitoring System, has indication and annunciation in the Main Control Room. If the Drywell Atmospheric Monitoring System is inoperable, grab samples of the drywell atmosphere are taken in accordance with the Technical Specifications.
In the LAR, the licensee stated that the design calculations determined that the gaseous portion of the drywell atmospheric radioactivity monitor could detect a leakage rate of less than the leakage rate limits as defined by CNS Technical Specifications, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The licensee further stated that this information was then included in the design basis calculations for the gaseous portion of the drywell atmospheric radioactivity monitor. This difference does not alter the conclusion that the proposed change is applicable to CNS. Therefore, based on the above, the NRC staff concludes that the licensee's explanation supports the applicability of the TSTF-514 changes to the CNS TSs.
The licensee also proposed minor changes to ensure continuity of the TS format. These changes re-letter current Condition C, which applies when the Required Action and the associated Completion Time are not satisfied, to Condition D, and current Condition D, which applies when all required leakage detection systems are inoperable, to Condition E. Similar changes were made to the associated Required Actions. The licensee also made changes to the TS Table of Contents consistent with the associated TS page numbers, and is reissuing several TS pages due to repagination. The NRC staff determined that these changes are editorial, and therefore acceptable.
The NRC staff evaluated the licensee's proposed changes against the applicable regulatory requirements listed in Section 2 of this SE. The NRC staff also compared the proposed changes to the changes made to STS by TSTF-514, Revision 3. The NRC staff determined that all the proposed changes afford reasonable assurance of safety. Therefore, the NRC staff finds the proposed changes acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment on September 20, 2019. 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 published in the Federal Register on June 4, 2019 (84 FR 25838), and there has been no public comment on such finding. 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) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Grover, NRR Da~: October 30, 2019
J. Dent, Jr.
SUBJECT:
COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 263 RE:
ADOPTION OF TSTF-514, REVISION 3, "REVISE BWR OPERABILITY REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION" (EPID L-2019-LLA-0050) DATED OCTOBER 30, 2019 DISTRIBUTION:
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