ML20070M660
| ML20070M660 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/26/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070M663 | List: |
| References | |
| NSD940428, NUDOCS 9405020372 | |
| Download: ML20070M660 (13) | |
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COOPER NUCLEAR ST ATION s
hD P.O. BOX 98. BROWNVILLE. NEBRA$KA 68321 il
( vQj~ Nebraska Public Power District
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NSD940428 April 26,1994 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington. D.C.
20555
Subject:
Proposed Change No.126 to Technical Specifications Intermittent Operation of the liydrogen/ Oxygen Analyzers Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 Gentlemen:
In accordance with the applicable provisions specified in 10 CFR 50, the Nebraska Public Power District (District) requests that the Cooper Nuclear Station (CNS) Technical Specifications be revised as specified in the attaclunent. This proposed change revises Tables 3.2.11 and 3.2.F including the associated notes, to clarify the requirements regarding the intermittent sampling of hydrogen and oxygen concentrations during normal plant operations.
This change would make explicit that intermittent operation of one division of the flydrogen/ Oxygen (11;/0 ) Concentration Analyzer System is all that is required in order to 2
meet the existing Limiting Condition fbr Operations and Surveillance Requirements applicable to hydrogen and oxygen monitoring during normal plant operations. Additional changes related to this proposed change include the consolidation of requirements of the O portion of the 2
11/0 Concentration Analyzer System with the H portion of this system, along with other 2 2 2
minor editorial changes.
The attached contains a description of the proposed change, the attendant 10 CFR 50.92 evaluation, and the CNS applicable revised Technical Specification pages in both final and marked up forms. This proposed change has been reviewed by the necessary Safety Review Committees and incorporates all amendments to the CNS Facility Operating License through Amendment 165 issued July 16, 1993.
Ily copy of this letter and attachment. the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91(b)(1). Copies to the NRC Region IV Office and the CNS Resident inspector are also being sent in accordance with 10 CFR 50.4(b)(2).
If you have any questions or require any additional infbrmation, please contact me.
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V ce P esident - Nuclear GRil/dnm Attachment 9405020372 940426 ink PDR ADOCK 050C0298 g
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e U'd., Nuclear Regulatory Commission
- Pat,e 2 of 3 April 26,1994 cc:
II. R. Borchert Department of Health State of Nebraska NRC Regional Office Region IV Arlington, TX NRC Resi< lent Inspector Cooper Nuclear Station
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.S. Nuclear Regulatory Commission
' Page 3 of 3 April 26,1994 I
STATE OF NEBRASKA)
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NEMAIIA COUNTY
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-G. R. Ilorn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge d belief.
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1 Attachment'to' NSD940428
' Page 2 of 7 primary containment integrity by checking ' oxygen concentrations during normal plant operations. Limiting Condition'for Operation (LCO):3.7sA.S.
' requires oxygen concentrations to be less than 4% by volume in the primary containment duriag normal plant operations, with certain exceptions not pertinent to thio discussion.
This LCO requirement is. verified 'per.
Surveillance Equirement (SR)
No.
4.7.A.5 which, requires' primary-containment oxygen concentration-to be measured and recorded at least twice weekly.
These LCO and SR requirements are further supported by the Bases Section (No.
3.7.A 4.7.A) ' states, in 'part, that oxygen concentration will be determined at least'twice a week.
Intermittent sampling.during normal plant operations is consistent with the verification of the existing LCO requirements through the applicable surveillance requirements. Furthermore, the absence of a continuous O,
indication is a negligible safety issue because the primary containment is pressurized with nitrogen gas, which prohibits the in-leakage'of oxygen.
There are several other more meaningful and immediate indications,.
available to the operator, which would identify a containment breach. All pneumatic components in'the primary containment are supplied by nitrogen when the primary containment is inerted. Periodic oxygen sampling (per SR 4.7.A.5) is sufficient to ensure that oxygen is not present during normal.
1 plant operations. For the above reasons, the District desires to. clarify the notes located in Table 3.2.H to explicitly reflect that intermittent sampling may be allowed.
Surveillances are conducted to monitor'the performance of the Primary.
Containment H /0. Concentration Analyzers.
These surveillances are to -
2 2
assure that sufficient operating life of the analyzer components:always.
exist so that continuous H /0 monitoring is available for.the required 3
2 time following a design basis accident.
As an additional clarification, the District also desires to consolidate the H and O monitoring requirements into a single.LCO and Surveillance 2
a Requirement, located in Table 3.2.H.
The current instrumentation test and calibration frequency requirements for.both the H and O portions of the' 2
2 analyzers are also being consolidated into Table 4.2.H in. order.to-be.
consistent with the proposal to consolidate the H, and '0 requirements into 2
Table 3.2 H.
A clarification has been'made to the once/ day instrument check requirement of the 0, portion of the analyzers to make obvious that this requirement is applicable to the inservice analyzer only.
Other enhancements to improve readability and consistency are also being made in this proposed change. First, a footnote has been added to Tables 3.2.F and 4.2.F to inform the reader that the applicable requirements-of-the oxygen portion of the H /0 Concontration Analyzer System' are relocated [
a 3
2 into Tables 2.2.H and 4.2.H.
Second, terms which are defined in the CNS Technical Specifications. are being capitalized.
This practice, which' highlights terms with special meaning, has been followed in other sections of the CNS Technical Specifications, and is also the practice followed in=
Standard Technical Specifications.
'In some specifications where the intent was clearly used to define a term but different wording was used,-
the wording is revised to use the defined term.
Other administrative corrections include the addition of obviously ' missing words, and - the.
deletion of an LCO that is no longer in force.
These enhancements have-been reviewed to ensure that they are editorial in nature and do;not change the intent of any specification.
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s Attachment to
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.NSD940428 l]
Page.3 of 7
.i II.
DESCRIPTION OF CHANGES The changes to the CNS Technical Specifications consist ofi 1) Revising'
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Note. 2 (applicable ' to the H,/0 analyzers) of Table 3.2.H,-" Post-Accident 3
Monitoring Instrumentation Requirements" to clarify' intermittent operation of the H /0 analyzers may also be included as = a normal condition.
A' 3
3 corresponding paragraph is also proposed in the~ corresponding BASES section; 2)-
Moving the information concerning the Oxygen Concentration portion (including Note 3) of the Ha/0 analyzers 'from Table 3.2.F, 2
" Primary Containment Surveillance Instrumentation", and consolidating.it with the Hydrogen Concentration portion located in Table 3.2.H.
For consistency, the of instrumentation test and calibration frequency 1 requirements. contained in Table 4.2.F will be located in 4.2.H;- and 3)
Other editorial changes, such as the capitalization of-defined terms, equipment' nomenclature changes, and a new footnote for Tables 3.2.F and 4.2.F.
1 Please note that, in making the specific changes associated with 2) above, the oxygen concentration portion of the H,/0 Concentration Analyzer 3
System, with two inoperable channels, would require an action of restoring at least one channel to operable status within.7 days or be.in at least hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, as opposed to the present requirement of having to initiate an orderly shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The specific changes proposed to the CNS Technical Specifications are detailed in Appendix A.
A mark-up of the. af fected CNS Technical Specification pages are provided in Appendix B, and the new affected CNS Technical Specification pages are provided in Appendix C.
To provide sufficient time for licensed operator training and the revision of station procedures, the District requests the amendment implementing-these changes become effective thirty days after-its issuance.
As an administrative note, Page 87a is subject to revision by Proposed Technical Specification change No. 91.
t
'h III.
SIGNIFICANT HAZARDS DETERMINATION 10 CFR 50. 91(a) (1) requires that licensee requests cor operating license.
amendments be accompanied by an evaluation of significant hazards posed by ~
the issuance of the amendment.
This evaluatica is to be performed with respect to the criteria given in 10 CFR 50.92(2). The following analysis-meets these requirements.
I r
Evaluation of this Amendment with Respect to 10 CFR 50.92 The enclosed Technical' specifications ~ change is judged to involve no significant hazards based on the following:
-1.
Does ' the proposed ch'ange involve a significant. increase in. the i
probability or consequences of an accident previously evaluated?.
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'NSD940428 Page 4 of 7-Evaluation j
l The' first. part. of this license amendment request, involves the revision of Table 3.2.H,
" Post-A aent Monitoring Instrumentation Requirements", and the associateo Bases section, to clarify that as needed (intermittent) ' operation 'of the Hydrogen / Oxygen (H /0 )
2 2
Concentration Analyzer System during ' normal plant _ operations is permitted.
This system serves two safety functions: containment' integrity monitoring and post-accident monitoring..Because this system's function is strictly related to monitoring, there?is'no potential for this system to cause a design basis. accident.
For normal plant operations, intermittent sampling of H,/Of.
concentrations is consistent with existing Surveillance Requirement 4.7. A.5, which ensures the primary containment oxygen concentration limits are maintained.
Intermittent sampling during normal plant operations will reduce service-related wear on the system equipment.
The requirement to continuously monitor H /0 concentrations during a
2 the applicable post-accident time frame is not affected by this part of the proposed change.
This part of the proposed change is considered purely as a clarification and does not involve a. change in plant settings that affect plant operation responses, nor does it affect the plant operations. Therefore, this part of_the proposed change does not involve a significant. increase in the probability or consequences of an accident previously evaluated.
The second part of this license amendment request consists of moving the information (including applicable notes) concerning the oxygen concentration portion of the H /O, analyzers from _ Table. 3.2.F, 2
" Primary Containment Surveillance Instrumentation",
and consolidating it with the hydrogen concentration portion'of Table 3.2.H.
Other than making a new action' statement applicable, this; change is editorial in nature by.having a. single-table.contain the-requirements for the H,/O, analyzers..The new LCO action statement, which was previously only applicable 'to the Ha portion. 'of l the ;
analyzers, will be applicable to the 0 portion as'well.
The LCO 2
action statement, requiring hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for-two inoperable channels out of service for more than 7 days,Jis.more restrictive than requiring an orderly shutdown to 'be. initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (currently applicable to 0 portion).
'For 2
consistency, the 0 instrumentation.' calibration and' test frequency 2
requirements are being relocated to Table 4.2.H.
This consolidation does not result in a change in the requirements; There are no.
setpoint
- changes, changes to plant equipment, changesL.in maintenance,'or changes in plant operations. Therefore, _ this part of the proposed change does not involve a significant: increase.in~
the probability or consequences of an accident previously evaluated.
The third - part of this license amendment ' request consists. of c editorial changes not.directly related to the previou' sly described changes. These changes include the capitalization of defined terms,:
equipment nomenclature changes (equipment
' identification designations), replacing informal ~ terms with defined terms,' addition of a new footnote for Tables 3.2.F and 4.2.Fi and the deletion' of t a -
LCO that is no longer applicable.
These' changes.are editorial'in nature and have no impact on plant equipment, plant design, L or-
s Attachment to NSD940428 Page 5 of 7 operations.
These editorial changes do not modify or add any initiating parameters. Therefore, this part of the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed change create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation The first part of this license amendment request involves the revision of Table 3.2.H, and the associated Bases section, to clarify that intermittent operation of the Hydrogen / Oxygen (H /0 )
2 2
Concentration Analyzer System during normal plant operations is permitted.
Because this system's function is strictly related to monitoring, there is no potential for this system to cause a new or different kind of accident. This part of the proposed change does not affect the requirements of this system to operate continuously under post-accident conditions. This part of the proposed change is simply a clarification and does not involve the creation, deletion, or modification of the function of any structure, system, or component, nor does this change introduce or change any mode of plant operation. This part of the proposed change does not create the possibility for a new or different kind of accident from any
'l accident previously evaluated.
The second part of this license amendment request consists of moving the information (including applicable notes) concerning the. oxygen concentration portion of the H /0 analyzers from Tables 3.2.F and 2
2 4.2.F, and consolidating it with the hydrogen concentration portion of Tables 3.2.H and 4.2.H.
Other than applying the H LCO action 2
statement, concerning two inoperable channels, to 0 as well, this 2
part of the proposed change is editorial in nature. The new LCO action statement is more restrictive than the LCO action statement currently applicable to 0 portion of the H /0 Concentration 2
2 2
Analyzer System. This part of the proposed change does not involve the modification, addition, or deletion of any plant equipment, nor does it change or introduce any new mode of plant operation. This part of the proposed change does not create the possibility for a ner or different kind of accident from any accident previously evaluated.
The third part of this license amendment request consists of editorial changes not directly related to the previously described changes. These changes include the capitalization of defined terms, equipment nomenclature changes (equipment number designations), a new footnote for Tables 3.2 F and 4.2.F, replacement of informal terms irith defined terms, and deletion of an non-applicable LCO.
These changes are editorial in nature and do not involve any alteracion to plant design, setpoints, or operating parameters, nor do thr.y introduce or change any mode of plant operation. Therefore, this part of the proposed change does not create the possibility for a new or different kind of accident from any accident previously evaluated.
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i Attia'chment' to NSD940428 Page 6 of 7
'3.
Does the proposed change create a significant reduction in the-margin'of safety?
Evaluation The first part of this license amendment request. involves the revision of Table 3.2.H and the associated Bases section, to clarify that intermittent operation of the H /0 Concentration Analyzer 3
2 system during normal plant operations is permitted.
This; system provides strictly a monitoring function. Intermittent operation will not affect the ability to ensure that primary containment oxygen.
concentrations are being maintained since Surveillance Requirement 4.7.A.5 continues to require that oxygen concentration be measured-twice a week.
Intermittent operation of the primary containment hydrogen analyzers during normal plant operations conforms to NRC guidance given in the clarifications to NUREG-0737,-Item II.F.1.6, issued October 31, 1980.
The requirement to continuously monitor H /0 concentrations during the applicable post-accident time frame.
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is not effected by this part of the proposed change.
As previously stated, the proposed clarification to allow for intermittent sampling of H and 0 concentrations during normal plant '
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operations.has no impact on the operational margin of' safety, and does not af fect the instruments' ability to be available to perform.
continuous monitoring of the post-accident primary containment atmosphere. This part of the proposed change has no effect on plant safety setpoint settings or overall operation of the station, as it pertains to maintaining plant safety margins. Therefore, - this part of the proposed change does not create a significant reduction in the margin of safety.
The second part of this license amendment request consists of moving the information (including applicable notes) concerning the oxygen concentration portion of the H /0 analyzers from Tables 3.2.F and,
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4,2.F, and consolidating it with the hydrogen concentration portion of Tables 3.2.H and 4.2.H, respectively. The LCO that is proposed (in Table 3.2.H) to be applicable to 0 portion of the analyzer 3
system is more restrictive than the LCO that is currently applicable (Table 3.2.F).
All of the other changes are purely editorial in nature. This portion of the proposed change does not impact the operability determination of installed plant equipment, has ne effect.on plant safety setpoint settings, and does not have any.
effect on plant operations.
Therefore, this.part of the proposed change does not-create a significant reduction in the margin of.-
safety.
The third part of this -license amendment request consists l of editorial changes not directly related to the previously described-changes. These changes include the capitalization'of defined terms, L
use of defined terms-instead of informal
- terms, equipment k
nomenclature changes (equipment number designations), a new footnote for Tables 3.2.F and 4.'2.F, and the deletion of an LCO that ~is no longer applicable.
These individual changes do not involvefany change to plant design, equipment, instrument setpoints,.or operation.
Therefore, this part of the proposed change does:not f
create a significant reduction in the margin of safety.
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' Attachment.to NSD940428.
Page 7 of 7 i
IV.
CONCLUSION The District has evaluated-the individual parts of the. proposed change,
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described above against~.the' criteria! given in 10 CFR 50.92(c) in.
accordance with the requirements of 10 CFR '50. 91 ' (a) (1). This evaluation has determined that this proposed change will not 1). involve a significant
' increase in the probability or consequences of an accident previously.
evaluated, 2) create ' the possibility for a new or dif ferent ' kind of
[
accident.from any accident previously evaluated, or 3) create. a significant reduction in the margin of safety. Therefore, for the' reasons detailed above, the District requests NRC approval of this Proposed Change No. 126.
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Attachment to NSD940428 Page 1 of 3 APPENDIX A PROPOSED CllANGE NO.126 Intermittent Operation of the Hydrogen / Oxygen Analyzers The following is a detailed listing ofindividual changes associated with Proposed Change No.
126.
1)
Intermittent Operation of the H,/0, Analyzers Pace No.
Description of Changes 67b Modify Note 2, at the bottom of the page to read "With two channels OPERABLE, the normal condition may include sampling intermittently." This note previously required one analyzer to be in the standby mode. Table 3.2 H' has been modified so that this note is applicable to both the H and 0 portions 2
2 of the analyzer system.
87a Add a new paragraph to 3.2.H. BASES. Post-Accident Monitorine. to provide a basis for the change on Page 67b.
180 Revise the Bases for 3/4.7 A Oxygen Concentration, by removing the statement that monitoring of oxygen concentration is not required once primary containment is inerted.
2)
Relocation of Information Renardinu Oxyuen Concentration Monitorine fmm Tables 3.2 F and 4,2.F to Tables 3.2.H and 4.4.H. respectively Pace No.
Description of Channes 65 Delete last two lines of Table 3.2.F. Information contained in these two lines is located in the last entry of Table 3.2.11 which was previously only applicable to the H portion of the analyzer system.
2 66 Move Note 3, on the bottom of this page, to the bottom of Page 67b.
Note that Table 3.2.F no longer contains the requirements for Primary Containment Oxygen Monitoring. Therefore Conditions A, B, and C are no longer applicable. Ilowever, rew conditions delineated in Action B, and Notes 1, 2, & 3 are applicable.
These conditions are the same, except HOT SilUTDOWN is required within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when two channels are inoperable.
67a Revise the first column, last entry to read " Primary Containment flydrogen/ Oxygen Analyzer" Revise the third column, last entry to specify the instrument range for both hydrogen and oxygen analyzers. Percentage values, which do not represent new
' Attachment to.
NSD940428 Page 2 of 3 requirements, of 0-10% and 0-30% for oxygen concentration have been specified to replace the term "various". Oxygen concentration ~ ranges were previously controlled by Table 3.2.F.
Revise the fourth column, last entry, to acknowledge the relocated Note 3, associated with the oxygen analyzer.
67b Move Note 3 from bottom of Page 66 and place at the bottom of this page.
80 Move all of the information concerning the Primary Containment Oxygen Concentration Analyzer and relocate this information in Table 4.2.H, Page 82a.
82a Revise the first column, last entry to read " Primary Containment--
Ilydrogen/ Oxygen Concentration Analyzer". Add corresponding footnote to require that instrument check is required for the oxygen portion of the inservice analyzer once/ day. This requirement was taken from Table 4.2.F and does not represent a modified requirement; simply a clarification of existing requirements.
Revise the third column, last entries to require function test frequency once/ month for both H /0 analyzers.
Add the once/ quarter calibration 2 2 frequency requirement for PC-AN-II /011. These changes are purely editorial 2 2 and do not represent a change in requirements.
180 Add a statement in the Bases for 3/4.7.A, Oxygen Concentration, referencing Table 3.2.11 for oxygen monitoring instrumentation requirements.
3)
Other Editorial Channes Pace No.
Description of Channes 65 Place an asterisk (*) next to the IIcading " PRIMARY CONTAINMENT.
SURVEILLANCE INSTRUMENTATION". Put a footnote at the bottom of the -
page which reads, " Notes:
- Other Primary Containment Surveillance Instrumentation is locr ad in Table 3.2.11
- Primary Containment liydrogen/ Oxygen Analyzer" In the instrument range column, spell out the terms " inches and feet", replace the dashes with the word "to" in order to be consistent, and remove unnecessary parenthesis.
In the line item for Drywell Temperature, the instrument identification number is expanded to indicate that five separate drywell temperature indicator channels are installed. These channels were installed at the time of the issuance of the Operating License, but the instrument identification number on line items on this -
instrument table did not indicate that five separate channel designators were installed. This change will clarify the operability requirements fbr the Drywell Temperature instrumentation.
66 For consistency with other specifications and with the definitions,'the phrase
" continued operation" in the action statements of notes 1.A.1.B, and 2.A is
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being replaced with " continued REACTOR POWER OPERATION",
67a Move asterisk (*) to the other side of the colon (:) and change the term " Note" to " Notes" to be consistent with other editorial changes being made to footnotes on other tables.
67b Add the term bxygen analyzer" to the moved Note 3, at the bottom of the page.
80 Place an asterisk (*) next to the ficading " PRIMARY CONTAINMENT l
SURVEILLANCE INSTRUMENTATION". Put a footnote at the bottom of the page which reads, " Notes:
Other Primary Containment Surveillance Instrumentation calibration requirements are located in Table 4.2.11 - Primary Containment Ilydrogen/ Oxygen Analyzer" The instrument identification number in the line item for Drywell Temperature is being expanded to indicate that five separate drywell temperature indicator' channels are installed.
These channels were ' installed when the Operating License fbr CNS was issued, but the channel designators were not listed on this instrument table.
82a Move asterisk (*) to the other side of the colon (:) and change the term " Note" to " Notes" to be consistent with other editorial changes being made to footnotes on other tables. Move the footnote for channel calibration up to where the other footnotes are located.
For the Primary Containment Gross Radiation Monitor RMA-RM-4013, identify the function test frequency as once/ month and calibration test frequency is once/ cycle. This is not a new requirement and is simply a change in the format the existing requirements are presented.
164 LCO 3.7.A.S.e is being deleted since the exemption it provided from LCOs 3.7.A.S a through 5.d were applicable only in 1982 (
Reference:
II. L. Siegel to J. M. Pilant, May 10, 1982, Amendment No. 79 to CNS. Technical Specifications). Correct the wording (including the logical connector) in LCO 3.7.A.5 d to account for the removal of LCO 3.7.A.5.e and to retain original intent. There is no change to this specification's requirements.
Spell the word " inch" in LCO 3.7.A.4.c and add a missing comma in LCO 3.7.AA.d.
180 Modify defined terms for correct usage and make all defined terms capitalized.
Correct the abbreviations fbr the safety relief valve and main steam isolation valves to use standard abbreviations used in other portions 'of the Technical-J Specifications. Specify as " Group 6" the containment isolation that initiates the.
start of the Standby Gas Treatment fims. Move the first two paragraphs 'of llases 3/4.7.C, Standby Gas Treatment System 'and Secondary Containment, to Page 181.
All Pages -
Capitalize (All CAPS) the defined terms.
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